Sanctions Evasion

The Ghost CEO and the $94 Billion Laundromat

The Ghost CEO and the $94 Billion Laundromat

Image: The Ghost CEO and the $94 Billion Laundromat

A stock-footage model fronted two UK-registered crypto exchanges that moved $94 billion for Iran's Islamic Revolutionary Guard Corps. Behind the fiction: a pardoned financier once sentenced to death, and a British corporate system that never once checked who it was dealing with.

BLACKWIRE INVESTIGATIONS — 4 March 2026

Her name was Elizabeth Newman. She was listed as director and "person with significant control" of two cryptocurrency exchanges registered in the United Kingdom. She had a Caribbean address, a Covent Garden correspondence office, and a suite in a 68-story Dubai tower.

She also did not exist.

The woman in the company's promotional video was a Shutterstock stock footage model. Her clip was titled "Pretty black woman talking to camera." The supposed finance administrator and team leader shown alongside her were also stock footage. OCCRP's months-long search across global corporate registries, social media platforms, and official Dominican Republic immigration records found no evidence of any real person named Elizabeth Newman matching the profile filed with UK authorities.

Behind the fiction was a different kind of executive entirely: Babak Zanjani, an Iranian financier with a long history of sanctions evasion, a 2016 Iranian death sentence for embezzling state oil funds, and a fresh pardon from the same Islamic Republic that had condemned him. The U.S. Treasury sanctioned Zanjani and both exchanges on January 30 of this year.

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Dormant on Paper, Functional in the Field

Both Zedcex and Zedxion were registered in the UK and classified as "dormant" in official filings. Under UK company law, a dormant company is one that conducts no significant accounting transactions. These two firms reported exactly that: nothing.

Zedcex processed over $94 billion in that same period.

The discrepancy is not a clerical anomaly. It is the architecture. UK corporate registration has long operated, in the words of anti-money-laundering expert Graham Barrow, "along the lines of an honesty box." No legal mandate to verify submitted information. No requirement to check whether the director filing paperwork was a real person. No cross-referencing of identities against international sanctions lists at the point of registration.

The UK's Economic Crime and Corporate Transparency Act 2023 was meant to fix this. Directors and persons with significant control would now need to verify their identities with Companies House. Existing directors like "Elizabeth Newman" were granted a grace period of up to a year. The deadline for the two exchanges fell on May 19, 2025.

By then, the IRGC had already been paid.

"Treasury will continue to target Iranian networks and corrupt elites that enrich themselves at the expense of the Iranian people" - U.S. Treasury Secretary Scott Bessent, January 30, 2026
The Ghost CEO and the $94 Billion Laundromat - analysis

From a Death Sentence to a Sanctions Network

Babak Zanjani's career trajectory tracks the Islamic Republic's willingness to weaponize financial crime when politically convenient.

He made his name helping Iran circumvent Western sanctions on its oil sector - moving money through front companies, manipulating foreign exchange flows, exploiting regulatory gaps in smaller jurisdictions. By the early 2010s he was one of Iran's wealthiest men. By 2016, Iran had sentenced him to death for embezzling roughly $2.8 billion in oil revenues owed to the government. The sentence was never carried out.

In 2024, Iran's courts commuted his sentence. In 2025, he was formally released. The US Treasury describes his freedom as a transaction: he was freed, it alleges, specifically to operate the financial infrastructure that would help the IRGC bypass the global sanctions architecture.

Zanjani pushed back on X, calling the US accusations "merely a pretext for seizing 660 million Tether." He did not directly deny involvement with Zedcex or Zedxion. He did not respond to OCCRP's detailed questions.

The Ghost CEO and the $94 Billion Laundromat - section

IRGC Payroll and the Red Sea

TRM Labs, a blockchain analytics firm that published its own analysis of the network in January, found something beyond routine sanctions evasion in the transaction data.

The Zedcex and Zedxion network had processed over $10 million in transfers to Sa'id Ahmad Muhammad al-Jamal, a Yemeni national the US Treasury has designated as a senior Houthi financial official - specifically one linked to the IRGC's support for Houthi attacks on commercial shipping in the Red Sea.

Those attacks have disrupted global freight lanes, driven up insurance premiums, and forced dozens of major shipping operators to reroute around the Cape of Good Hope. The financial pipeline sustaining them, according to TRM's analysis, ran partly through two companies registered in the United Kingdom that reported doing no business at all.

Parliament Asked. The UK Sanctioned the Man, Not the Firms

On January 19, British MP Alex Sobel raised the matter in Parliament: "We know that the IRGC has used two registered cryptocurrency exchanges to move approximately $1 billion since 2023, evading international sanctions."

Two weeks later, the UK sanctioned Zanjani himself. It did not sanction Zedcex or Zedxion.

The gap matters. Sanctioning the man without sanctioning the corporate instruments leaves the infrastructure formally intact. New "Elizabeth Newmans" can be filed. New companies can be registered. The honesty box accepts whatever it is handed.

Iran's most recent wave of protests, which killed at least 20,000 people according to the Center for Human Rights in Iran, were partly funded through this same network. The IRGC used it to pay for the suppression of its own citizens. It used it to move money to militia fighters attacking global shipping. And it registered the whole operation at Companies House using a woman whose only documented existence is a stock footage clip.

The UK identity verification deadline passes in May. The companies remain registered.

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