What Did OFAC Sanction BitBank For?
A Tehran-based exchange most global traders had never heard of is now the centerpiece of Washington's crypto pressure campaign against Iran — and the designation carries secondary sanctions exposure that reaches far beyond Iran's borders.
On September 17, 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) designated BitBank, an Iran-based digital asset exchange, for allegedly moving hundreds of millions of dollars' worth of bitcoin to Iran's Islamic Revolutionary Guard Corps (IRGC) between June and July 2026 . Treasury alleges the platform was controlled by previously sanctioned Iranian financier Babak Morteza Zanjani, who has advertised BitBank's services on his social media accounts since at least 2024 . The designation was issued under Executive Order 13902, which authorizes action against persons operating in designated sectors of the Iranian economy — here, the digital asset sector.
Quick Answer: OFAC sanctioned BitBank on September 17, 2026 for allegedly routing hundreds of millions of dollars in bitcoin to Iran's IRGC between June and July 2026. Treasury says the Tehran exchange was controlled by financier Babak Zanjani. The action falls under E.O. 13902 and carries secondary sanctions risk for non-U.S. firms.
The action is one strand of Operation Economic Outcast, a whole-of-government pressure campaign announced by Treasury Secretary Scott Bessent and launched on August 24, 2026 as an "Economic D-Day" . The campaign targets five Iranian economic "lifelines": digital assets, technology, gold, aviation, and shipping . OFAC also alleges that since June 2026 the already-designated Hormuz Safe Marine Services Authority — a maritime scheme charging vessels transiting the Strait of Hormuz — has used BitBank to route payments back to the Iranian regime, making the exchange a downstream payments rail for a state-linked revenue stream rather than merely a retail venue, per Treasury's September 17 release.
"Today's designations of Iranian digital asset infrastructure make perfectly clear that efforts to finance the Iranian regime using cryptocurrencies are not beyond OFAC's reach. If you support the Iranian regime, the Department of the Treasury will sanction you," — Scott Bessent, Secretary of the Treasury (source: U.S. Department of the Treasury, 2026-09).
One detail matters for anyone running screening infrastructure: OFAC published no digital currency addresses with the BitBank entries on the SDN list . That is a meaningful contrast with OFAC's 2018 Iran cyber action, the first time the agency ever listed bitcoin addresses on the SDN list . Without on-chain identifiers, address-based blocklists will not catch this exposure automatically — screening has to work from entity names, the Tehran address, and counterparty relationships instead.
A final disambiguation before going further: "BitBank" here is not bitbank, inc., the licensed Japanese exchange, which is not implicated in this action. The designated entity is the Tehran platform also known as BITBANK3, operating at bitbank3.com and registered in 2024 .
Inside the September 17 SDN Listing: BitBank, Pishtaz Simorgh, and Three Executives
The September 17 SDN listing names five parties, not one: the BitBank exchange, its named software developer Pishtaz Simorgh Electronic Trade Company, and three individuals tied to Babak Morteza Zanjani's Dot One conglomerate . That structure matters for screening: blocking BitBank alone would leave the developer entity and the executives free to rebuild the same rail under a new brand. OFAC's published identifiers give compliance teams the concrete strings to match against.
BitBank's SDN entry lists it at No. 2, 35th Street, Alvand Street, Argentina Square, Tehran, Iran, with an establishment date of 2024, websites www.bitbank3.com and www.bitbank.com, an organization type of "Financial and Insurance Activities," a note that it is subject to secondary sanctions, and the program tag IRAN-EO13902 . Pishtaz Simorgh shares that same Tehran address and carries Iranian national ID 14012169913, registration number 611800, website www.pishtazsimorgh.com, a 2024 establishment date, and the same "Financial and Insurance Activities" classification . Treasury describes Pishtaz Simorgh as a subsidiary of the previously designated Dot One Value Creation Group . A shared street address between an exchange and its developer is the kind of detail that turns two separate corporate records into one operational unit.
The three designated individuals are described by Treasury as executives within the Dot One network and "key lieutenants" in Zanjani's digital-asset sanctions-evasion structure . Their SDN entries carry the following identifiers :
- Hossein Ali Zaker Hossein — DOB 23 May 1957, Kish Island address, passport B61766700, linked directly to Babak Morteza Zanjani.
- Mohammad Mahdi Zaker Hossein — DOB 9 Sep 1981, Tehran, passport K61893781, identified as CEO of Pishtaz Simorgh.
- Seyed Adel Heidari — DOB 22 Nov 1974, Iranian national ID 4621551825, identified as vice chairman of Dot One Value Creation Group's board of directors.
One structural fact in the listing changes how the exchange should be classified. OFAC states that since June 2026, the already-designated Hormuz Safe Marine Services Authority has used BitBank to route payments it received back to the Iranian regime . Hormuz Safe was designated on July 29, 2026 over an alleged maritime-insurance or extortion scheme charging vessels for Strait of Hormuz transits, a platform Treasury said was developed by Iran's Ministry of Economy and accepted payment in bitcoin and other digital assets . BitBank, on that account, is not merely a retail venue that happened to onboard bad actors — it is described as the settlement layer for a state-linked revenue stream .
Worth noting for anyone building automated controls: OFAC published no digital currency addresses alongside these entries . There is nothing here to load into an on-chain screening list. The enforceable identifiers are names, passports, national IDs, registration numbers, domains, and one Tehran address — which pushes the burden onto KYC records and counterparty diligence rather than blockchain analytics.
Who Is Babak Zanjani, and How Does BitBank Fit His Network?
Babak Morteza Zanjani is an Iranian financier who was sentenced to death in Iran in 2016 for embezzling from the National Iranian Oil Company, had that sentence commuted in 2024, and by 2025 had re-emerged publicly as a backer of regime-linked economic projects while assembling a network of digital asset companies that OFAC says was used in part to launder funds for the Islamic Revolutionary Guard Corps . BitBank is not a standalone platform in that story. Treasury describes it as a "priority digital asset venture" under Zanjani's control, advertised on his own social media accounts since at least 2024 and listed as a partner by multiple companies in his network .
The designation history shows a network mapped in stages rather than a single strike. On January 30, 2026, OFAC designated Zanjani together with his two largest digital asset projects, Zedcex Exchange Ltd. and Zedxion Exchange Ltd. — an action Treasury characterized as its first designation of a digital asset exchange for operating in Iran's financial sector. Treasury said Zedcex had processed more than $94 billion in transactions since its August 2022 registration, and that addresses attributed to Zedcex and Zedxion had processed funds for IRGC-linked wallets .
Six months later, on July 24, 2026, OFAC widened the perimeter to the conglomerate itself, designating four individuals and nine entities across the Dot One network — a group spanning logistics, telecommunications, aviation, transportation, and digital assets, run from a Tehran tower with Zanjani as chief executive. That action included Dot One Value Creation Group, the conglomerate's primary holding company .
That sequencing is what makes the September 17 listing legible. Pishtaz Simorgh Electronic Trade Company, designated the same day as BitBank, is described as BitBank's software developer and a subsidiary of the already-designated Dot One Value Creation Group, and the three individuals named alongside it are characterized as executives within the Dot One conglomerate and "key lieutenants" in Zanjani's digital-asset evasion network . The alleged conduct is specific and recent: between June and July 2026, Treasury says, Zanjani used BitBank to move hundreds of millions of dollars' worth of bitcoin to the IRGC .
"If you support the Iranian regime, the Department of the Treasury will sanction you," — Scott Bessent, Secretary of the Treasury (source: U.S. Department of the Treasury, 2026-09).
The practical takeaway for diligence work is that Zanjani, not any single exchange brand, is the node to screen against. Zedcex and Zedxion were designated in January; Dot One and nine affiliates in July; BitBank, its developer, and three executives in September. A counterparty that clears a name check against BitBank alone may still sit one corporate layer away from a blocked person — and under OFAC's 50 percent rule, that layer is not a safe distance .
2026 Iran Crypto Sanctions Timeline: Six Actions Compared
Treasury's 2026 campaign against Iranian digital assets ran through six discrete OFAC actions between January 30 and September 17, escalating from a single exchange operator to domestic market infrastructure, then to a maritime revenue scheme and its payments rail . The sequence matters for screening because each action added corporate layers rather than replacing earlier ones: the January designations named Zanjani and two exchanges, while the September action named his developer and his lieutenants. Read as one arc, it shows OFAC moving from named platforms toward the ownership structures behind them.
January 30, 2026 — Zanjani, Zedcex, Zedxion. OFAC designated Babak Morteza Zanjani together with his two largest digital asset projects, Zedcex Exchange Ltd. and Zedxion Exchange Ltd., in what Treasury described as its first designation of a digital asset exchange for operating in Iran's financial sector. Treasury said Zedcex had processed more than $94 billion in transactions since registering in August 2022, and that addresses attributed to Zedcex and Zedxion had processed funds for IRGC-linked wallets .
June 2, 2026 — the four domestic exchanges. OFAC designated Nobitex, Wallex, Bitpin, and Ramzinex under Executive Orders 13224 and 13902. Treasury stated that Nobitex processed more than 50 percent of all Iranian digital asset inflows in 2025, with Wallex at 12 percent and Bitpin at 10 percent, and that Ramzinex had processed over $2.45 billion in cumulative transactions. Nobitex leadership, including chairman Amir Hossein Rad, was designated alongside the platforms .
July 24 and July 29, 2026 — the network and the revenue stream. On July 24, OFAC designated four individuals and nine entities across the Dot One network, spanning logistics, telecommunications, aviation, transportation, and digital assets, operated from a Tehran tower with Zanjani as CEO, including holding company Dot One Value Creation Group . Five days later, OFAC designated Persian Gulf Marine Insurance Company and HormuzSafe Marine Services Authority over an alleged maritime-insurance or extortion scheme for vessels transiting the Strait of Hormuz. Treasury said Hormuz Safe was developed by Iran's Ministry of Economy, accepted bitcoin and other digital assets, and generated IRGC revenue; Iranian officials reportedly targeted more than $10 billion from the scheme .
August 7 and September 17, 2026 — offshore rails, then BitBank. The August action named Shelbit Exchange, Aban Tether, and Iranian-born Siavash Kayvanpour (a citizen of Dominica and Afghanistan), plus UAE-, Poland-, and Georgia-registered entities including Shelbit General Trading LLC, Shelbit Technologies Ltd, Crypto Home DMCC, and NFT Home DMCC. Treasury said Shelbit processed over $1 million in digital assets from IRGC-controlled addresses and more than $2 million to them, while Aban Tether handled millions of dollars' worth of transactions; the release also cited a State Department Rewards for Justice offer of up to $15 million . September 17 closed the loop, designating BitBank, Pishtaz Simorgh, and three executives over hundreds of millions of dollars in bitcoin allegedly routed to the IRGC between June and July 2026 .
| Date (2026) | Primary targets | Authority cited | Headline figure disclosed |
|---|---|---|---|
| Jan 30 | Babak Zanjani, Zedcex Exchange Ltd., Zedxion Exchange Ltd. | Iran financial sector (first exchange designation) | $94B+ processed by Zedcex since Aug 2022 |
| Jun 2 | Nobitex, Wallex, Bitpin, Ramzinex; Nobitex chairman Amir Hossein Rad | E.O. 13224 and E.O. 13902 | Nobitex 50%+ of 2025 Iranian inflows; Ramzinex $2.45B cumulative |
| Jul 24 | Dot One Value Creation Group and affiliates — 4 individuals, 9 entities | Iran-related designations | Network spans logistics, telecom, aviation, transport, digital assets |
| Jul 29 | Persian Gulf Marine Insurance Co., HormuzSafe Marine Services Authority | Iran-related designations | Reported $10B+ revenue target for the Hormuz scheme |
| Aug 7 | Shelbit Exchange, Aban Tether, Siavash Kayvanpour, UAE/Poland/Georgia entities | Iran-related designations | $1M+ in from IRGC addresses, $2M+ out; $15M Rewards for Justice offer |
| Sep 17 | BitBank (BITBANK3), Pishtaz Simorgh Electronic Trade Co., 3 executives | E.O. 13902 (IRAN-EO13902) | Hundreds of millions in bitcoin to the IRGC, Jun–Jul 2026 |
Two patterns stand out for anyone building a screening policy. First, the disclosed figures shrink as the targets move offshore — $94 billion for Zedcex, $2.45 billion for Ramzinex, then single-digit millions for Shelbit — which suggests OFAC is designating smaller offshore rails on qualitative network evidence rather than volume thresholds . Second, on-chain identifiers are inconsistent: Zedcex and Zedxion designations referenced attributed addresses, but the September 17 SDN entries published none, leaving name- and jurisdiction-based screening as the only practical control for BitBank .
Are You Exposed? A Decision Framework for Traders, Exchanges, and Compliance Teams
Exposure to the BitBank designation depends on what you touch, not where you sit. Any U.S. person holding property or interests in property of BitBank, Pishtaz Simorgh Electronic Trade Company, or the three designated individuals must block and report those interests to OFAC, and non-U.S. institutions that knowingly facilitate significant transactions for them face secondary sanctions exposure . Because OFAC published no wallet addresses with the September 17 action , screening has to run on names, jurisdictions, and ownership chains rather than on-chain identifiers. The four steps below map that work in order of legal urgency.
Step 1 — Screen names, aliases, and network adjacency. Run counterparty lists, corporate customers, OTC desk relationships, and any attributable wallet clusters against the new SDN entries: BitBank (a.k.a. BITBANK3, websites www.bitbank3.com and www.bitbank.com), Pishtaz Simorgh Electronic Trade Company (Iranian national ID 14012169913, registration number 611800), Hossein Ali Zaker Hossein (passport B61766700), Mohammad Mahdi Zaker Hossein (passport K61893781), and Seyed Adel Heidari (Iranian national ID 4621551825) . Widen the query to the broader Zanjani perimeter already designated during 2026 — Dot One Value Creation Group and the nine entities named on July 24, plus Zedcex and Zedxion from the January 30 action . One practical filter: BitBank and Pishtaz Simorgh share a single Tehran address at No. 2, 35th Street, Alvand Street, Argentina Square, so address matching catches records that name matching misses .
Step 2 — Test the 50 Percent Rule. Entities owned 50 percent or more, directly or indirectly, by one or more blocked persons are themselves blocked even though they never appear on the SDN list . This is the highest-probability failure point in the BitBank case, because Pishtaz Simorgh was itself described as a subsidiary of the already-designated Dot One Value Creation Group . Conglomerate structures spanning logistics, telecommunications, aviation, and digital assets produce unlisted subsidiaries that a plain list-match will clear.
Step 3 — U.S. persons: block first, ask later. If a match survives review, freeze the property and report it to OFAC; U.S. persons are generally prohibited from transacting with blocked parties absent authorization, so processing a withdrawal "to close out the relationship" is itself a prohibited transaction . OFAC FAQ 1250 states that Iranian digital-asset exchanges meet the definition of Iranian financial institutions, with property interests in U.S. jurisdiction blocked under the Iranian Transactions and Sanctions Regulations — a category-level rule, not a case-by-case one.
Step 4 — Non-U.S. firms: price the secondary-sanctions risk before the flow. FAQ 1257 warns that foreign financial institutions and non-U.S. persons transacting with E.O. 13902-designated Iranian digital-asset exchanges may face secondary sanctions, including restrictions on correspondent or payable-through accounts . The BitBank entry is explicitly flagged as subject to secondary sanctions . Treasury Secretary Scott Bessent framed the reach plainly: "If you support the Iranian regime, the Department of the Treasury will sanction you," adding that "efforts to finance the Iranian regime using cryptocurrencies are not beyond OFAC's reach" (source: U.S. Department of the Treasury, 2026-09).
Exposure is not uniform, and the correct response scales with your role:
- Retail trader — low direct exposure, monitor only. If you trade on a licensed non-Iranian venue, you have no plausible path to BitBank, which was established in 2024 and served an Iran-domestic user base . The one real trap is name confusion: bitbank, inc., the licensed Japanese exchange, is unrelated to this action and is not designated . Verify the domain — bitbank3.com is the sanctioned platform — before reacting to a headline.
- Exchange or VASP — active screening required. Update SDN lists same-day, re-screen historical counterparties back to at least June 2026, when Treasury alleges the Hormuz Safe payment routing began , and apply ownership analysis to corporate accounts rather than list-matching alone. Pay attention to offshore incorporation as a red flag: the August 7 action reached UAE-, Poland-, and Georgia-registered entities including Shelbit General Trading LLC and Crypto Home DMCC .
- Bank or payment firm — highest priority. Correspondent and payable-through account restrictions are the specific penalty named in FAQ 1257 , and Operation Economic Outcast has already reached alleged Iran-linked financial institutions in Russia, the UAE, and Turkey . Shipping, marine-insurance, and trade-finance corridors touching the Strait of Hormuz warrant enhanced review given the Hormuz Safe linkage .
The decision rule in one line: retail traders verify the domain and move on; VASPs re-screen and re-baseline ownership data; institutions with dollar-clearing relationships treat this as a correspondent-banking review, not a crypto-desk memo. Full designation detail is published in the OFAC Recent Actions entry for September 17, 2026 and the accompanying Treasury press release.
Secondary Sanctions Exposure: What Counts as 'Material Support'?
Material support, in OFAC's usage, means knowingly providing goods, services, technology, or financial facilitation that benefits a blocked person — and for non-U.S. firms it is the trigger for secondary sanctions, not a U.S.-jurisdiction question. Two OFAC FAQs set the perimeter here. FAQ 1250 states that Iranian digital-asset exchanges meet the definition of Iranian financial institutions, so their property interests within U.S. jurisdiction are blocked under the Iranian Transactions and Sanctions Regulations . FAQ 1257 extends the point outward: foreign financial institutions and non-U.S. persons that conduct significant transactions with exchanges designated under E.O. 13902 may face secondary sanctions, including restrictions on U.S. correspondent or payable-through accounts .
That combination is what makes the September 17, 2026 designation of BitBank consequential for firms with no Iranian customer base at all . Correspondent-account loss is a dollar-clearing problem, and it lands on the bank rather than the crypto desk. The exposure chain runs through intermediaries: an OTC desk filling an order sourced from a blocked wallet, a payment processor settling invoices for Pishtaz Simorgh Electronic Trade Company, a shipping agent handling premiums tied to Hormuz Safe Marine Services Authority — which OFAC says has routed payments received back to the Iranian regime through BitBank since June 2026 .
Ownership is the second trap. Entities owned 50 percent or more, directly or indirectly, by one or more blocked persons are themselves blocked, whether or not OFAC has named them . With Babak Morteza Zanjani's Dot One conglomerate spanning logistics, telecommunications, aviation, transportation, and digital assets, the named list is a floor, not a ceiling.
| Actor | Jurisdiction basis | Primary risk | Governing reference |
|---|---|---|---|
| U.S. person or U.S.-incorporated VASP | Primary — ITSR blocking | Blocked property; mandatory report to OFAC; general prohibition on transacting | FAQ 1250 |
| Foreign financial institution | Secondary — E.O. 13902 | Correspondent / payable-through account restriction or prohibition | FAQ 1257 |
| Non-U.S. exchange, OTC desk, payment processor | Secondary — material support | Designation risk for knowingly facilitating significant transactions | Treasury release, 2026-09-17 |
| Subsidiary ≥50% owned by a blocked person | Derivative blocking | Blocked automatically, even if unnamed on the SDN list | 50 Percent Rule |
There is also an incentive layer. Treasury's August 7, 2026 action referenced a State Department Rewards for Justice offer of up to $15 million for information that disrupts the IRGC's financial mechanisms . For compliance teams, that raises the realistic probability that counterparty conduct surfaces through insiders rather than through blockchain analytics — particularly relevant because OFAC published no digital currency addresses alongside the BitBank entries . Screening cannot rely on address lists that do not exist; the practical controls are entity-name and ownership screening, domain checks against bitbank3.com, and documented evidence that a transaction was not knowingly facilitated. The State Department release accompanying the action framed international exchanges as a gateway to the financial system for Iranian institutions, including the Central Bank of Iran — a signal that the material-support standard is being read broadly, not narrowly.
What Comes Next in Treasury's Crypto Pressure on Iran?
Treasury's crypto pressure on Iran is likely to widen rather than pause, because Operation Economic Outcast is structured as a five-lifeline campaign — digital assets, technology, gold, aviation, and shipping — announced by Treasury Secretary Scott Bessent and launched on August 24, 2026 . Digital assets is only one of five columns, and within that column OFAC has issued at least five distinct designation rounds in 2026 alone. Traders should plan for further exchange-level listings, not treat the September 17 BitBank action as a closing chapter (source: U.S. Treasury, 2026-09).
The escalation pattern is the most useful forward indicator. OFAC moved from a single operator and his two largest projects — Zedcex Exchange Ltd. and Zedxion Exchange Ltd., designated January 30, 2026 — to Iran's four largest domestic venues on June 2, 2026 , to a conglomerate-wide sweep of four individuals and nine entities across the Dot One network on July 24, 2026 , to offshore intermediaries in the UAE, Poland, and Georgia on August 7, 2026 , and finally to a downstream payments rail: BitBank routing Hormuz Safe receipts back to the regime. Each step moves one layer further from the named operator and one layer closer to the counterparties that touch him. The reasonable expectation is that the next layer is foreign service providers — banking, OTC, and software vendors — rather than another Tehran-based exchange.
One technical detail is worth tracking on its own. OFAC published no digital currency addresses alongside the BitBank, Pishtaz Simorgh, or individual entries , despite having listed bitcoin addresses on the SDN list as far back as its 2018 Iran cyber action. Whether that reflects an ongoing investigation, an evidentiary gap, or a deliberate shift in disclosure practice is not stated publicly. For screening teams it matters operationally: without addresses, blocking depends on name, ownership, and domain matching rather than on-chain lists. Watch the next two or three actions to see whether address publication returns.
For traders, the practical read is narrow and worth holding onto. These designations target named Iranian infrastructure and the people behind it — not bitcoin as an asset, and not self-custody. Treasury did not disclose a dollar figure, transaction count, wallet addresses, or any asset seizure in the September 17 action, so claims of a direct market impact are unsupported by the public record. What is rising is compliance friction: OFAC FAQ 1257 puts foreign financial institutions on notice of correspondent-account restrictions for dealing with E.O. 13902-designated exchanges , and that cost lands on global venues, not on the protocol. Concretely: screen counterparties against the September 17 SDN entries, treat bitbank3.com as blocked, and do not confuse the Tehran platform with the unrelated licensed Japanese exchange bitbank, inc.
Last updated: 2026-09-18. Reviewed against OFAC's September 17, 2026 recent-actions listing and the accompanying Treasury and State Department releases.
Frequently asked questions
What exactly did OFAC accuse BitBank of doing?
OFAC alleges that BitBank, a Tehran-based digital asset exchange controlled by sanctioned Iranian financier Babak Morteza Zanjani, was used to move hundreds of millions of dollars' worth of bitcoin to Iran's Islamic Revolutionary Guard Corps between June and July 2026 . The designation landed on September 17, 2026 under Executive Order 13902, which covers persons operating in designated sectors of the Iranian economy — here, the digital asset sector . Treasury separately states that since June 2026 the already-designated Hormuz Safe Marine Services Authority used BitBank to route payments it collected back to the Iranian regime, tying the exchange to a maritime revenue stream as well as to general-purpose trading . Treasury did not publish a precise dollar figure, transaction counts, or hashes.
Who is Babak Zanjani and why does he keep appearing in OFAC actions?
Babak Morteza Zanjani is an Iranian financier who was sentenced to death in Iran in 2016 for embezzling from the National Iranian Oil Company; his sentence was commuted in 2024, and by 2025 he had re-emerged publicly as a backer of regime-linked economic projects . He recurs in OFAC filings because Treasury says he rebuilt his influence through a digital-asset conglomerate, Dot One Value Creation Group, used in part to launder funds for the IRGC. Four separate 2026 actions touch that network: the January 30 designation of Zanjani with Zedcex Exchange Ltd. and Zedxion Exchange Ltd. — Treasury's first designation of a digital asset exchange for operating in Iran's financial sector, with Zedcex said to have processed more than $94 billion in transactions since its August 2022 registration ; the July 24 designation of four individuals and nine Dot One entities ; the July 29 maritime-insurance action; and the September 17 BitBank designation.
Did OFAC list any BitBank bitcoin wallet addresses?
No. The September 17, 2026 SDN entries for BitBank and Pishtaz Simorgh Electronic Trade Company contain no associated digital currency addresses . That is a meaningful contrast with OFAC's 2018 Iran cyber action, the first time the agency published bitcoin addresses on the SDN list. The practical consequence for compliance teams is that address-based blocklist screening will not catch this designation on its own; matching has to run on names, aliases (including BITBANK3), the Tehran address at No. 2, 35th Street, Alvand Street, Argentina Square, the websites www.bitbank3.com and www.bitbank.com, and the identifying data for the three designated individuals . Any on-chain attribution has to come from your own analytics vendor rather than from the SDN file.
What happens if a U.S. person or exchange has dealt with BitBank?
All property and interests in property of the designated parties located in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC, and U.S. persons are generally prohibited from transacting with them absent authorization . The 50 percent rule extends the block automatically: entities owned 50 percent or more, directly or indirectly, by one or more blocked persons are themselves blocked even if they never appear on the SDN list by name. OFAC FAQ 1250 adds that Iranian digital-asset exchanges meet the definition of Iranian financial institutions, so their property interests in U.S. jurisdiction are blocked under the Iranian Transactions and Sanctions Regulations . A U.S. platform that finds historical exposure should freeze the relevant assets, file the required report, and take licensing questions to counsel rather than resolving them internally.
Are non-U.S. exchanges at risk even without U.S. persons involved?
Yes. OFAC FAQ 1257 states that foreign financial institutions and other non-U.S. persons transacting with digital-asset exchanges designated under E.O. 13902 may face secondary sanctions, including restrictions on U.S. correspondent or payable-through accounts . BitBank's own SDN entry carries an explicit note that it is subject to secondary sanctions . That exposure reaches offshore exchanges, brokers, OTC desks, payment firms, banks, and shipping intermediaries that knowingly facilitate significant transactions for BitBank, Pishtaz Simorgh, Hormuz Safe, or associated blocked persons — no U.S. nexus required . For a non-U.S. venue, losing correspondent banking access is usually the more severe outcome than the designation itself.
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