Three Enforcement Layers in Five Months: OFAC Designates Iran's Domestic Crypto Exchanges

Key takeaways

• OFAC designated four Iranian domestic crypto exchanges on June 2, 2026 — Nobitex, Bit Pin, Wallex, and Ramzinex — under E.O. 13224 and E.O. 13902, the third distinct enforcement action targeting Iran's crypto infrastructure in five months
• The four exchanges accounted for roughly USD 7.7 billion — 78% of Iran's USD 9.9 billion in attributed 2025 crypto volume
• Designations extends compliance obligations beyond US persons: under E.O. 13902, foreign financial institutions conducting significant transactions with these exchanges face correspondent account restrictions and secondary designation exposure
• Iran's attributed crypto volumes have held at roughly USD 10 billion annually despite sustained enforcement; additional exchange infrastructure with significant Iran-linked address exposure remains undesignated

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Three enforcement layers in five months

Iran recorded USD 9.9 billion in attributed crypto volume in 2025, despite a decade of comprehensive sanctions. OFAC has taken three enforcement actions this year, each aimed at a different layer of that infrastructure.

In January, OFAC designated Zedcex and Zedxion, exchange-branded stablecoin infrastructure with direct IRGC exposure and roughly USD 1 billion routed through the platform.

In April, OFAC designated two wallets as property of Iran's Central Bank — with IRGC-Qods Force and Hezbollah linkages — and Tether coordinated with US law enforcement to freeze USD 344 million in USDT. 

Yesterday’s action targets Nobitex, Bit Pin, Wallex, and Ramzinex, the domestic exchanges through which Iranians access dollar-denominated assets. The four exchanges accounted for roughly USD 7.7 billion — 78% of Iran's attributed crypto volume in 2025. Nobitex alone processed more than 50% of Iran's digital asset inflows that year.

How the exchange layer works

Not all crypto infrastructure in Iran serves the same function. The Central Bank wallets designated in April were sovereign reserve storage: institutional, accumulating, dormant until moved. Zedcex and Zedxion were IRGC-adjacent exchange infrastructure, built around regime-specific flows.

Nobitex, Bit Pin, Wallex, and Ramzinex are the platforms that give Iranians access to dollar-denominated assets and cross-border transfers — serving both civilian users and regime-linked actors. Sanctioning them targets the rails, rather than a specific account.According to TRM, Nobitex processed USD 4.7 billion in 2025 volume. Wallex, USD 1.45 billion. Bitpin, USD 821 million. Ramzinex, USD 739 million. All four are attributed in TRM across millions of addresses on Bitcoin, Ethereum, and TRON.

The sanctions extend compliance risk globally — any institution with indirect exposure to these platforms faces immediate screening and remediation obligations.In an FAQ released alongside yesterday's action, OFAC confirmed that non-US persons — including foreign financial institutions — conducting significant transactions with any of the four exchanges face correspondent account restrictions and secondary designation exposure under E.O. 13902.

Mandatory statutory sanctions under the National Defense Authorization Act of Fiscal Year 2012 also apply to significant transactions with designated Iranian financial institutions. The sanctions targeting Iran’s exchange ecosystem create compliance obligations for foreign institutions that a standard wallet-level SDN entry does not.

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Nobitex leadership and their operational role

In July 2025, TRM identified Seyed Mohammad Aghamir as Nobitex's blockchain lead with ties to the Iranian regime. A Reuters investigation published in May 2026 corroborated the Aghamir brothers' connection to the Kharrazi family — a dynasty related by marriage to all three supreme leaders of the Islamic Republic.

The source code leaked in the June 2025 Predatory Sparrow hack corroborates his operational role. Aghamir is the named author and maintainer of Nobitex's address-validation software — the component that verifies every deposit and withdrawal address across the exchange's supported blockchains — and updated it 17 times between 2022 and 2024. His commits were signed with his Nobitex company email, a personal Gmail address, and a Sharif University of Technology account. Several API keys in Nobitex's production configuration files are registered to his personal accounts, meaning the exchange's live transaction monitoring ran on infrastructure he personally owned.

Yesterday’s OFAC designation names both Aghamir brothers alongside current CEO Seyed Ali Khoee and Chairman Amir Hossein Rad, and identifies Nobitex's corporate alias, Rahkar Fanavari Nooyan.

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Frequently asked questions (FAQs)

1. What exchanges did OFAC designate on June 2, 2026?

OFAC designated Nobitex, Bit Pin, Wallex, and Ramzinex — four Iranian domestic crypto exchanges — under E.O. 13224 and E.O. 13902.

2. What is the three-layer enforcement pattern?

OFAC has taken three enforcement actions targeting structurally distinct layers of Iran's crypto economy in 2026: the Central Bank of Iran's sovereign reserves (USD 344 million USDT freeze, April), IRGC-linked exchange infrastructure (Zedcex and Zedxion, January), and the domestic exchange layer (yesterday's action).

3. Are non-US institutions affected by yesterday's designation?

Yes. Under E.O. 13902, foreign financial institutions that conduct significant transactions with Nobitex, Bit Pin, Wallex, or Ramzinex face correspondent account restrictions and secondary designation exposure. Mandatory statutory sanctions under the NDAA FY2012 also apply.

4. Does this change TRM's attribution for these exchanges?

No. All four exchanges were already attributed in TRM's entity graph under Iran jurisdictional sanctions. Yesterday's action adds explicit OFAC SDN designation on top of existing coverage.

5. Who is Seyed Mohammad Aghamir?

Aghamir served as Nobitex's blockchain lead and authored the exchange's core address-validation software, updating it 17 times between 2022 and 2024. He and his brother are members of the Kharrazi family, a dynasty related by marriage to all three supreme leaders of the Islamic Republic. OFAC's June 2, 2026 designation names both brothers alongside CEO Seyed Ali Khoee and Chairman Amir Hossein Rad.

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Volume data is derived from TRM's entity attribution database using an adjusted volume methodology. Iran total reflects all entities attributed to Iran by country; per-exchange figures reflect individual entity attribution for the four exchanges designated on June 2, 2026. Data covers January 1–December 31, 2025.