OFAC (Office of Foreign Assets Control) is the U.S. Treasury bureau that administers and enforces U.S. economic and trade sanctions. It acts under statutory authorities (notably the International Emergency Economic Powers Act (IEEPA) and, where applicable, the Trading with the Enemy Act) and executive orders to block property and prohibit transactions with targeted foreign governments, individuals, and entities.
The SDN (Specially Designated Nationals and Blocked Persons) List is OFAC's list of individuals and entities whose property is blocked; U.S. persons are generally prohibited from dealing with SDNs and must block any assets they control that belong to them. Being listed typically freezes access to assets in U.S. jurisdiction and bars most transactions with U.S. persons, with potential civil and criminal penalties for violations.
Eskandar Momeni Kalagari is Iran’s Minister of Interior (named in the Treasury release) and, as interior minister, oversees Iran's Law Enforcement Forces (LEF). The LEF (also called NAJA) is Iran’s national police force responsible for public order, security, and enforcement of internal laws.
Babak Morteza Zanjani is an Iranian businessman previously accused and convicted by Iranian authorities of embezzling oil revenues; the Treasury accuses him of sanctions evasion and laundering funds for Tehran. He has been a high-profile figure in Iran’s oil-money cases (his death sentence was commuted; he remains a significant actor in sanctions-related enforcement actions).
Zedcex Exchange, Ltd. and Zedxion Exchange, Ltd. are UK-registered digital-asset (cryptocurrency) exchanges the Treasury says are linked to Zanjani and IRGC-associated wallets; OFAC says they operated in Iran’s financial sector. Digital asset exchanges can facilitate sanctions evasion by converting cryptocurrencies to fiat, moving funds across borders quickly, and linking sanctioned wallets to on-ramps/off-ramps — especially when controls, know-your-customer checks, or jurisdictional oversight are weak.
Executive Order 13553 authorizes blocking property of persons involved in serious human rights abuses; EO 13224 targets persons who commit, or provide support for, acts of terrorism (blocking and prohibiting transactions); EO 13902 targets persons supporting Iran’s malign activities in the financial/petroleum sectors. Practically, these EOs permit the U.S. government to add people/entities to sanctions lists, block their U.S.-located assets, and prohibit transactions by U.S. persons without a license.
GL D-2 (31 CFR § 560.540) is an OFAC general license that authorizes certain services that enable internet-based communications and information dissemination to, from, or within Iran (including VPNs and access to online platforms) so long as they meet license terms; it is intended to help Iranians maintain internet access during government-imposed blackouts by permitting U.S. persons to provide covered services without a specific OFAC license.
Banks, companies, or individuals who knowingly engage in prohibited transactions with OFAC-designated/blocked persons face blocked assets, civil monetary penalties, regulatory enforcement, loss of access to U.S. financial markets, and potential criminal charges for willful violations; U.S. persons must generally reject or block transactions and file reports as required.