The Office of Foreign Assets Control (OFAC), the US Treasury bureau that administers sanctions, designated a fresh network on 24 July under Executive Order 13902, the order aimed at Iran's petroleum, petrochemical and metals trade1. Every node is tied to Babak Zanjani, the oil-smuggling financier Washington sanctioned years ago and whom an Iranian court sentenced to death in 2016 over embezzlement. Designation freezes any US-reachable assets and bars Americans from dealing with those named.
The listing names Bahareh Morteza Zanjani, Solmaz Bani, Sukhrob Oimakhmadov and Mehdi Rezazadeh, a cluster of Tehran holding companies trading as DotOne across airline, rail, barter, gold and travel arms, and the payment and exchange firms ZedX DMCC and BZ Diamond DMCC, both registered at the Dubai Multi Commodities Centre, alongside ZedPay in the UAE and Turkey2. Several DotOne entities carry a secondary-sanctions flag, meaning a bank in Istanbul or Dubai risks its own dollar clearing by processing their payments.
Read as a diagram, the list shows what evasion looks like once a state loses its banks. An airline moves people and cargo, a railway moves freight overland, a barter arm swaps goods for goods with no money changing hands, and a gold-backed token settles whatever balance remains. Designating all four limbs on one day, rather than the trading company alone, closes the substitution routes the network would otherwise use to reconstitute itself under new paperwork within weeks.
This is the second Iran action of the quarter and it runs on a different legal track from the last. OFAC designated twelve individuals and entities on 15 May under Executive Order 13224, Washington's counter-terrorism sanctions authority. Executive Order 13902 reaches commercial sectors rather than the terrorism-financing conduct 13224 targets, so the two actions cover different conduct and different people, and the choice of authority signals which part of the Iranian economy Treasury is working on at any given moment.
