31JUL

OFAC names four in Zanjani network

3 min read

09:24UTC

OFAC named four individuals, the DotOne cluster of Tehran holding companies and three Gulf payment firms on 24 July, every node tied to oil-smuggling financier Babak Zanjani.

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Key takeaway

Treasury sanctioned Zanjani's airline, rail, barter and gold arms together on 24 July.

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 trade ¹. 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 Turkey ². 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.

Deep Analysis

In plain English

OFAC (the Office of Foreign Assets Control) is the part of the US Treasury that decides which people and companies are banned from using the US financial system because of sanctions. On 24 July it added a new batch of people and businesses to that list, all connected to Babak Zanjani, an Iranian businessman previously sentenced to death in Iran for financial crimes, who has built a network of companies to help Iran sell oil despite sanctions. The new list includes some of his relatives and associates, plus a cluster of Tehran-based companies and payment firms based in Dubai and Turkey. It shows the US is still actively working to block Iran's sanctions-evasion networks even while the shooting war continues elsewhere.

Deep Analysis

Root Causes

Babak Zanjani built his sanctions-evasion network around a structure of nominally independent holding companies and exchange firms registered across Iran, the UAE and Turkey, a jurisdictional spread that lets the network route payments through whichever entity is not yet on a sanctions list at any given time; Treasury's practice of designating individual new entities as they surface, rather than the underlying ownership structure, is why the same network keeps reappearing under new names years after its founder's initial listing.

Dubai's role as host to several of the newly designated payment firms reflects the UAE's position as a financial hub where dirham-denominated exchange and payment services can operate with fewer restrictions on Iran-linked transactions than most Western jurisdictions permit, making it a structurally convenient base for sanctions-evasion vehicles regardless of any individual firm's specific ownership.

What could happen next?

Consequence
Firms designated with secondary-sanctions exposure risk losing access to correspondent banking relationships with any institution that continues dealing with them.
Precedent
Targeting relatives and newly formed holding companies rather than only the original sanctioned individual sets a template for how Treasury pursues networks that reconstitute themselves after each round of designations.

Source Landscape

This story draws on centre-right-leaning sources from United Arab Emirates

United Arab Emirates

The DotOne cluster spans airline, rail, barter and gold-token arms rather than a single business line, a diversification that lets the network generate and move revenue through several channels simultaneously, so that sanctions on any one arm do not necessarily halt the others.

Several DotOne entities carry a "Subject to Secondary Sanctions" designation, meaning non-US financial institutions that continue dealing with them risk losing their own access to the US financial system, extending the practical reach of the sanctions well beyond US-based counterparties alone.

Consensus view: C4ADS, which researches sanctions-evasion networks, assesses that naming relatives and a cluster of holding companies spanning airline, rail and payment arms reflects an established Treasury tactic against Zanjani specifically, since his network has rebuilt under new corporate names after previous rounds of designations.

Counter-view: Chatham House sanctions researchers argue repeated re-designation of the same underlying network years after Zanjani's original 2016 death sentence in Iran points to the limits of unilateral US sanctions against a determined evader who can simply register new entities faster than Treasury can list them.

Key tension: Whether naming new corporate vehicles meaningfully disrupts the network's operations or simply documents its latest iteration without closing off its ability to open the next one.

Sources:The National

Mentions:OFAC →Executive Order 13902 →Chatham House →Istanbul →US Treasury →Iran →Tehran →Turkey →Washington →Babak Zanjani →DotOne Value Creation Group →ZedX DMCC →BZ Diamond DMCC →ZedPay →Dubai →

First Reported In

Update #161 · Bahrain and Kuwait struck Iran, WSJ reports

The National· 25 Jul 2026

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Causes and effects

This Event

OFAC names four in Zanjani network

The designation hits the airline, rail, barter and gold-token limbs together rather than the trading company alone, which is how a sanctioned state actually moves value.

Led to

Treasury names a Hormuz insurance racket

The earlier Zanjani-network designation (ID:5309) preceded this week's HormuzSafe and Persian Gulf Marine Insurance designations, both tied to Zanjani.

Occurred 30 Jul 2026

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