Treasury Moves Against Tehran’s Recycled Sanctions Evader

July 28, 2026 | Policy Brief Treasury Moves Against Tehran’s Recycled Sanctions Evader July 28, 2026 | Policy Brief Treasury Moves Against Tehran’s Recycled Sanctions Evader As U.S. bombs struck Iran’s military, Treasury targeted the financier who helped keep it funded. The U.S. Treasury Department on July 24 sanctioned four individuals and nine entities sustaining the network of Iranian illicit financier Babak Zanjani, extending its penalties beyond his previously designated cryptocurrency exchanges to the offshore companies and facilitators supporting them. Zanjani built the multibillion-dollar machinery Tehran used to sell oil and move funds for the Islamic Revolutionary Guard Corps (IRGC). He then rebuilt it around digital assets and state-linked companies. Although Tehran sentenced Zanjani to death in 2016 for withholding $2.7 billion in illicit oil revenues, it later commuted his sentence after claiming to have recovered $2.1 billion in assets, as he remained too valuable for the regime to discard. By 2025, he was back financing state projects and building new payment networks, showing that Tehran again needed the skills of the same operator who had previously moved billions for it. Zanjani Keeps the Islamic Republic Afloat The U.S. Treasury Department first sanctioned Zanjani in 2013 under counterproliferation authorities for having created and used illicit banking and shipping networks spanning Malaysia, the United Arab Emirates, Turkey, and Tajikistan. Through these operations, he sold tens of millions of barrels of Iranian oil and moved billions for the National Iranian Oil Company (NIOC), itself a sanctioned entity. Individual transactions included a nearly $600 million deal through a Hong Kong front, a separate oil contract worth more than $200 million, a concealed €300 million transfer, and tens of millions of dollars involving the IRGC-controlled Iran Marine Industrial Company. Treasury removed Zanjani from its sanctions lists in January 2016 pursuant to the 2015 Iran nuclear deal. In January 2026, Treasury redesignated him under Executive Order 13902, which contained expanded economic measures against Iran, in an action that also marked its first-ever designation of an IRGC-linked digital-asset exchange. It also sanctioned his United Kingdom-registered Zedcex and Zedxion exchanges under that executive order and counterterrorism authorities due to its support of the IRGC, itself a Foreign Terrorist Organization (FTO). Zedcex had processed more than $94 billion in transactions since August 2022. Crypto Fuels Iran’s Military and Proxy Networks The latest sanctions target six companies in Zanjani’s Dot One conglomerate, including its rail, aviation, ride-sharing, barter, and gold subsidiaries, as well as three Turkish and Emirati firms supporting his crypto operations and four facilitators, including his sister. The designations cover DotOne Gold, which supports the allegedly gold-backed Tala Token traded through Zedcex, as well as DotOne Rail, which secured an $800 million contract with Iran’s state railway in April 2025. Treasury also sanctioned DotOne Barter, DotOne Airlines, and DotOne Trip for operating under the conglomerate controlled and financed by Zanjani. The new designations build upon September 2025 sanctions targeting a network that facilitated more than $100 million in cryptocurrency purchases tied to Iranian oil sales from 2023 to 2025. These transactions benefited the IRGC’s Quds Force and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), which fund proxies and develop ballistic missiles and drones. Similarly, earlier actions in 2024 and 2025 targeted Hezbollah-linked digital accounts receiving proceeds from the Quds Force’s commodity sales, Hamas-affiliated exchanges transferring funds, and Houthi wallets tied to a Russian weapons-procurement network. In September 2025, the U.S. Justice Department also sought forfeiture of cryptocurrency linked to an Iranian supplier of navigation systems for the IRGC Aerospace Force’s drones and missiles. Keep Maximum Pressure, War or No War Sanctions remain Washington’s most important source of economic leverage denying the Islamic Republic revenue to fund its military, missile, nuclear, and terror programs. Trading them away for any short-term diplomatic agreement or a lull in fighting surrenders that advantage while giving Tehran both access to its finances and time to recover. Regardless of the status of U.S. military operations against Iran, Washington should escalate and enforce penalties pursuant to its stated policy of maximum pressure against a broad web of actors and front companies, such as those against Zanjani’s evolving networks, that are keen to help Tehran access revenue and the formal financial system. Janatan Sayeh is a research analyst at the Foundation for Defense of Democracies (FDD). Behnam Ben Taleblu is senior director of the Iran Program and a senior fellow at FDD. For more analysis from the authors and FDD, please subscribe HERE. Follow FDD on X @FDD and @FDD_Iran. Follow Janatan and Behnam on X @JanatanSayeh and @therealBehnamBT. FDD is a Washington, DC-based, nonpartisan research institute focusing on national security and foreign policy.