The US Treasury Department’s Office of Foreign Assets Control has designated Iranian digital-asset exchange BitBank and its software developer, alleging that infrastructure linked to financier Babak Zanjani helped transfer hundreds of millions of dollars in Bitcoin to Iran’s Islamic Revolutionary Guard Corps.
The September 17 action adds BitBank and developer Pishtaz Simorgh Electronic Trade Company to OFAC’s sanctions regime under Executive Order 13902. Treasury also designated three associates of Zanjani: Hossein Ali Zaker Hossein, Mohammad Mahdi Zaker Hossein and Seyed Adel Heidari.
The designations are a consequential compliance event for crypto exchanges, custodians, payment processors and blockchain analytics providers. They place named digital-asset infrastructure and its operators within the scope of US blocking sanctions, creating obligations for US persons and potential exposure for non-US firms whose activity touches sanctioned parties or the US financial system.
Treasury links BitBank to maritime payment flows
Treasury said the already-designated Hormuz Safe Marine Services Authority has used BitBank since June to transfer payments it received to the Iranian regime. The department further alleged that Zanjani’s network used BitBank between June and July to facilitate transfers of hundreds of millions of dollars’ worth of Bitcoin to the IRGC.
Those claims are allegations by the US government accompanying an administrative sanctions action, not findings from a criminal trial. Treasury described BitBank as an Iranian digital-asset exchange promoted by Zanjani since at least 2024 and said Pishtaz Simorgh developed its software. It designated both entities for operating in Iran’s digital-asset sector.
The action forms part of Treasury’s Operation Economic Outcast, an enforcement campaign announced in August. OFAC said the broader effort is intended to disrupt financial channels used by Iran to evade sanctions. The agency had previously designated Zanjani and other entities connected to his digital-asset network.
What the designation changes for payment companies
Under OFAC’s notice, property and interests in property belonging to designated or blocked persons that are in the United States or held by US persons must be blocked and reported. Entities owned 50% or more, directly or indirectly and individually or in aggregate, by one or more blocked persons are also blocked even if they are not separately named.
Unless authorized or exempt, US persons generally may not process transactions involving blocked property or designated parties. OFAC also warned that financial institutions and other businesses can face sanctions exposure for certain dealings with blocked persons, while non-US parties may not cause US persons to violate sanctions or engage in evasion.
For crypto payment companies, the operational issue extends beyond screening a beneficiary name at onboarding. Wallet addresses, exchange deposit routes, software operators, corporate ownership and intermediary services can all connect a payment to a blocked network. A name-only check may also miss newly identified wallets or entities captured by OFAC’s 50 Percent Rule.
The case highlights why sanctions controls for digital-asset payments need to combine customer and counterparty screening with wallet-risk monitoring, ownership analysis and transaction review. Firms should also preserve the evidence behind a decision to block or reject a transfer and have escalation procedures for ambiguous matches, especially where an exchange brand may be confused with an unrelated business.
Enforcement targets infrastructure, not only wallets
OFAC’s inclusion of BitBank’s software developer is notable for payment infrastructure providers. The action shows that US sanctions policy may target the organizations that build or operate transaction systems alongside the exchange or financial actor accused of moving funds.
That does not mean software development for a sanctioned jurisdiction is automatically prohibited in every circumstance. The legal analysis depends on the parties, services, ownership, jurisdiction and applicable authorizations. But providers serving exchanges and payment businesses should treat technical and operational relationships as part of sanctions due diligence rather than limiting reviews to direct fund flows.
Treasury’s release did not identify all transaction hashes, wallets, intermediaries or counterparties behind the alleged transfers. That limits independent assessment of the complete payment chain. The designation itself, however, is effective compliance information: firms subject to US sanctions rules must act on the listed parties and associated blocked property, while other businesses need to evaluate their own legal exposure.