Treasury Expands Sanctions Against Babak Zanjani’s Network, Targeting the Commercial Ecosystem Behind Zedcex

Key takeaways

• OFAC's July 24 action expands sanctions on Babak Zanjani's network beyond Zedcex/Zedxion into gold, payments, and transportation.
• Newly named entities (ZEDX DMCC, ZedPay, BZ Diamond, Dot One companies) all appeared in TRM's earlier Zedxion investigation.
• CEO Mehdi Rezazadeh was individually sanctioned, showing Treasury is targeting personnel, not just companies.
• The network relied on shared leadership, corporate rotation, and persistent digital infrastructure to survive entity changes.
• Diversification across nine-plus industries let the network spread risk across sectors and jurisdictions.
• Lesson for compliance teams: illicit finance networks span far more than exchanges — full investigations need blockchain plus corporate/domain research.

On July 24, 2026, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) significantly expanded its Iran sanctions program, designating individuals and entities associated with Iranian businessman Babak Zanjani and the Dot One commercial network.

While previous Treasury actions targeted cryptocurrency exchanges Zedcex Exchange Ltd (Zedcex) and Zedxion Exchange Ltd (Zedxion), today's designation spanned gold production, digital assets, and transportation — alongside a set of Turkey- and UAE-based companies that provided material, technological, and financial support to Zedcex and Zedxion.

The action reflects an increasingly sophisticated understanding of how sanctions-evasion networks operate. Rather than relying on a single exchange or financial institution, modern illicit financial ecosystems distribute operational risk across numerous seemingly independent companies, each responsible for a different stage of commercial activity, financial settlement, or value transfer.

Earlier this year, TRM Labs investigated the Zedcex ecosystem following OFAC's designation of Zedcex Exchange Ltd and Zedxion Exchange Ltd—the first digital asset exchanges sanctioned for supporting the Islamic Revolutionary Guard Corps (IRGC).

Blockchain analysis demonstrated that the exchanges processed tens of billions of dollars in cryptocurrency transactions while serving as key financial infrastructure within Iran's digital asset ecosystem.

Our subsequent investigation expanded beyond blockchain activity to examine the broader commercial network surrounding the exchanges, identifying payment providers, corporate entities, logistics businesses, and key personnel that appeared to support the ecosystem's operations.

Today's designations substantially broaden Treasury's enforcement focus beyond cryptocurrency exchanges alone, reaching the wider commercial ecosystem that surrounds them. Many of the newly designated entities—including ZEDX DMCC, ZedPay, BZ Diamond, and multiple Dot One companies—featured prominently in TRM Labs' earlier investigation into the corporate and operational architecture supporting the Zedxion ecosystem.

Rather than examining each designation in isolation, today's action is best understood as targeting a vertically integrated commercial network spanning digital assets, payment services, commodity trading, logistics, transportation, and international commerce.

While each company presented itself as an independent business operating within a particular sector, our investigation found recurring governance patterns, shared branding, persistent digital infrastructure, and overlapping personnel that suggested a far more integrated ecosystem than public corporate records alone would indicate.

This blog examines several of the newly sanctioned entities and individuals identified in Treasury's action, providing additional context from TRM Labs' prior investigation into how these organizations fit within the broader Zedxion and Dot One ecosystem. By combining blockchain intelligence with corporate records, digital infrastructure, and open-source research, a more complete picture emerges of the commercial architecture surrounding one of Iran's most significant sanctions-evasion networks.

The commercial ecosystem behind the exchanges

While OFAC's July 24 action designated entities associated with Babak Zanjani and the Dot One network, many of these organizations had already appeared in TRM Labs' earlier investigation into the commercial ecosystem surrounding Zedcex and Zedxion. Rather than functioning as isolated businesses, the companies appeared to occupy complementary roles across payments, trade, logistics, and digital assets.

ZEDX DMCC

Among the newly sanctioned entities is ZEDX DMCC, a Dubai-based company that represents the network's continued shift toward the United Arab Emirates.

TRM Labs' investigation found that, over time, operational activity increasingly migrated away from short-lived UK corporate structures toward UAE-based commercial entities. This transition coincided with greater emphasis on Dubai as the network's commercial center, with UAE companies appearing to provide more durable operational infrastructure while UK entities frequently cycled through incorporation, dormancy, and governance changes.

The designation of ZEDX DMCC reinforces Treasury's focus on the UAE-based businesses supporting the broader ecosystem, rather than limiting enforcement to the cryptocurrency exchanges themselves.

ZedPay

Treasury also designated ZedPay, the payment platform operating alongside the Zedxion ecosystem.

TRM Labs previously identified ZedPay as a distinct financial services business closely associated with the exchange infrastructure. Rather than functioning solely as a cryptocurrency platform, the ecosystem incorporated dedicated payment services alongside digital asset businesses, reflecting a broader commercial strategy spanning multiple financial products.

Corporate records, branding, and publicly available material consistently positioned ZedPay alongside Zedxion and related entities, suggesting that payment processing represented an integral component of the ecosystem rather than a standalone business.

The inclusion of ZedPay in Treasury's latest action illustrates how enforcement has expanded beyond cryptocurrency exchanges to encompass the supporting financial infrastructure surrounding them.

Mehdi Rezazadeh

Treasury also designated Mehdi Rezazadeh, Chief Executive Officer of ZedPay.

Prior to the designation, TRM Labs identified Rezazadeh as one of the senior executives associated with the broader Zedxion ecosystem. Beyond his role leading ZedPay, publicly available reporting showed Rezazadeh participating in international commercial forums discussing mining investment and cooperation between Africa, Russia, China, and Iran, reflecting involvement extending beyond digital assets alone. Earlier UK corporate records also connected him to companies associated with the network during its formative years.

His designation reflects Treasury's decision to target not only corporate entities but also senior personnel responsible for managing components of the broader commercial ecosystem.

BZ Diamond DMCC

Another notable addition is BZ Diamond DMCC, a Dubai-based precious metals company.

TRM Labs' investigation previously identified BZ Diamond as part of the wider BZ commercial ecosystem operating from the UAE. Public records associated the company with Bahareh Zanjani, while technical infrastructure connected to the business was administered by recurring figures identified elsewhere in the investigation. Although operating within the precious metals sector rather than digital assets, BZ Diamond illustrated the diversification of commercial activity surrounding the network.

Its designation demonstrates Treasury's willingness to target commercial businesses outside the cryptocurrency sector when they form part of the broader sanctions-evasion ecosystem.

Beyond cryptocurrency

The newly sanctioned entities span industries including aviation, rail transportation, commodity trading, travel services, precious metals, payment processing, and digital assets.

Viewed individually, each company appears to serve a distinct commercial purpose.

Viewed collectively, they reveal a diversified business ecosystem capable of supporting multiple forms of international commerce while reducing reliance on any single company or jurisdiction.

That broader architecture is what Treasury's latest action ultimately targets.

More than a collection of companies

One of the strongest themes emerging from TRM Labs' earlier investigation was that the Zedxion ecosystem could not be understood by examining any single company in isolation.

Instead, the investigation documented recurring patterns that appeared consistently across the corporate network.

Shared leadership

Many of the same individuals repeatedly surfaced across different companies over several years.

Directors, shareholders, technical administrators, and executives frequently appeared in multiple businesses spanning cryptocurrency exchanges, payment companies, financial services, and commercial enterprises. While each organization maintained its own corporate identity, the recurrence of the same personnel suggested an unusually interconnected governance structure rather than unrelated businesses operating independently.

Corporate rotation

The investigation also documented repeated cycles of incorporation, governance changes, dormancy, and successor entities.

Several UK companies appeared briefly before entering dormant status or undergoing leadership changes, while newer entities emerged under related branding or ownership structures. Rather than indicating business discontinuity, these transitions often preserved the same branding, operational relationships, or digital infrastructure despite changes in legal entities.

This pattern reduced dependence on any individual company while allowing commercial operations to continue under new corporate vehicles.

Persistent digital infrastructure

Although legal entities changed over time, digital infrastructure frequently remained remarkably consistent.

TRM Labs observed recurring domain registrations, email addresses, technical administrators, and branding that persisted across multiple corporate transitions. These enduring digital assets provided continuity even as companies were dissolved, reorganized, or replaced.

From an investigative perspective, this highlights the importance of combining blockchain intelligence with domain intelligence, corporate records, and open-source research to identify operational continuity beyond formal company registrations.

Diversification as Resilience

Perhaps the most significant finding was the breadth of commercial activity represented within the ecosystem.

Rather than concentrating operations within cryptocurrency alone, the network incorporated businesses involved in:

• Digital asset exchanges
• Payment processing
• Commodity trading
• Precious metals
• Logistics
• Aviation
• Rail transportation
• Travel services
• International commercial operations

This diversification distributed operational risk while creating multiple pathways for commercial activity across sectors and jurisdictions.

Treasury's July 24 sanctions reflect this broader understanding. Rather than focusing solely on cryptocurrency businesses, the action targets the commercial ecosystem surrounding them—a recognition that sanctions-evasion networks increasingly rely on interconnected corporate structures extending well beyond digital assets.

Treasury's July 24 designations represent more than an expansion of sanctions against Babak Zanjani—they illustrate the continued evolution of sanctions enforcement against sophisticated financial networks.

Earlier actions focused primarily on cryptocurrency exchanges operating within Iran's financial sector. Today's designations extend well beyond digital assets, targeting payment companies, commercial enterprises, logistics providers, transportation businesses, and senior executives operating across multiple jurisdictions. Taken together, the action reflects a recognition that sanctions-evasion networks increasingly rely on interconnected commercial ecosystems rather than isolated financial institutions.

TRM Labs' earlier investigation reached a similar conclusion. While blockchain analysis identified the movement of billions of dollars in digital assets through Zedcex and Zedxion, examining the surrounding corporate infrastructure revealed a far broader network of companies and individuals supporting those operations. Payment platforms, commodity businesses, logistics firms, and commercial entities appeared to occupy complementary roles within a diversified ecosystem capable of moving value through multiple channels while reducing reliance on any single company or jurisdiction.

For investigators and compliance teams, the implications extend beyond this particular network. Cryptocurrency rarely operates in isolation. Exchanges require payment providers, corporate service companies, logistics networks, banking relationships, technology infrastructure, and trusted personnel to function at scale. Understanding how these components interact is increasingly critical to identifying the full scope of illicit financial activity.

The Zedcex ecosystem also demonstrates the value of combining blockchain intelligence with corporate records, domain infrastructure, and open-source research. While on-chain analysis reveals how value moves, off-chain information provides the organizational context needed to understand who controls that activity, how companies relate to one another, and how commercial networks evolve over time.

As sanctions-evasion networks continue to diversify across industries and jurisdictions, investigations must similarly move beyond individual wallets and exchanges. Identifying the broader commercial architecture that enables illicit finance will remain essential to understanding—and ultimately disrupting—the financial infrastructure supporting sanctioned actors.

Frequently asked questions (FAQs)

1. Why did the US sanction Babak Zanjani in July 2026?

OFAC designated Zanjani and entities tied to his Dot One commercial network for supporting Iran's sanctions-evasion infrastructure, expanding a crypto-focused case into gold production, payments, and transportation businesses that funded or supported it.

2. What is Zedcex and why was it sanctioned?

Zedcex Exchange Ltd is an Iranian cryptocurrency exchange that OFAC designated earlier in 2026 as the first digital asset exchange sanctioned for supporting the IRGC. TRM Labs found it processed tens of billions of dollars in crypto transactions as key financial infrastructure inside Iran.

3. What companies were newly sanctioned in the July 24, 2026 OFAC action?

The action named ZEDX DMCC, ZedPay, BZ Diamond DMCC, several Dot One entities, and additional Turkey- and UAE-based companies spanning gold, payments, transportation, and commodity trading.

4. Who is Mehdi Rezazadeh?

Mehdi Rezazadeh is the CEO of ZedPay, a payment platform tied to the Zedxion ecosystem. He was individually sanctioned by OFAC and had previously surfaced in TRM Labs' research linked to UK corporate structures and international mining-investment forums involving Iran, Russia, China, and Africa.

5. Is Babak Zanjani connected to the IRGC?

TRM Labs' research and OFAC's designations link Zanjani's commercial network to companies (including Zedcex and Zedxion) that provided financial infrastructure supporting Iran's IRGC, though Zanjani himself is a businessman rather than a government official.

6. Why does a sanctions case involve so many unrelated industries like aviation and rail?

Because the network diversified across sectors — crypto, payments, commodities, logistics, aviation, rail, travel — to spread operational risk and avoid dependence on any single company or jurisdiction, a pattern Treasury's action was designed to disrupt.