Treasury sanctions the company that built BitBank's exchange software

OFAC's listing gives names, corporate roles and two domains, bitbank.com and bitbank3.com, and identifies BitBank as an Iran-based financial and insurance business established in 2024 ^[11]. Treasury's release and the SDN entry do not include wallet addresses, transaction hashes or a precise total ^[15]. That difference decides how a foreign venue finds its own exposure. An address goes into a blockchain analytics feed and screens automatically; a name and a domain have to be matched against onboarding files, ownership records and a compliance officer's judgement. U.S. persons are obliged to block designated property, and for non-U.S. parties certain dealings can create secondary sanctions exposure ^[8].

The corporate side is where the reach sits. Pishtaz Simorgh, which Treasury says built BitBank's software, is a subsidiary of Dot One Value Creation Group, sanctioned in July ^[7]. Its chief executive, Mohammad Mahdi Zaker Hossein, was designated with it, alongside Seyed Adel Heidari, vice chairman of Dot One's board ^[2]. TRM Labs said it started with about $1 billion in IRGC-linked activity around Zedcex and Zedxion, the two exchanges sanctioned with Zanjani in January, then broadened into the companies and payment systems surrounding them ^[16]. TRM said BitBank and Pishtaz Simorgh sit inside that same network, with the MyDot social platform, the DOTO digital asset and Dot One Smart Chain ^[17].

Scott Bessent, the Treasury secretary, said "efforts to finance the Iranian regime using cryptocurrencies are not beyond OFAC's reach" ^[5]. The venue count behind that sentence: Nobitex, Wallex, Bitpin and Ramzinex in June, Shelbit and Aban Tether in August, BitBank on Sept. 17 ^[12][1]. Seven Iranian exchanges in four months, nine counting Zedcex and Zedxion from January ^[18][19].

Treasury put the Bitcoin figure at hundreds of millions of dollars and stopped there ^[4]. Read that at its floor, $200m across June and July, and the two-month pace annualises to $1.2bn, which is above the roughly $1 billion TRM described at the two January exchanges ^[23]. The crypto.news account said no independent on-chain evidence it reviewed confirms the full amount, and these are administrative designations, not criminal convictions ^[21][20].

The weaker version of the case is that none of this changes a dollar of settlement, because an Iranian exchange serving Iranian users was never inside U.S. clearing to begin with, and the designation is a statement of intent priced at the cost of a press release. The stronger objection is continuity: BitBank was established in 2024, Zanjani had promoted it publicly since at least 2024, several companies in his network listed it as a partner, and it came through the January and July rounds undesignated ^[11][14]. Software written once can be deployed under a new brand, and a designation then buys months. If OFAC adds digital currency addresses to the BitBank entry, screening automates and the question narrows to which counterparties kept transacting after Sept. 17 ^[15][1].