The National Crime Agency and the UK government published their first national alert on the A7 network on Monday 31 August 2026. Referenced 0808-NECC, it comes from the National Economic Crime Centre and was written with the Office of Financial Sanctions Implementation (OFSI). The same day, Chancellor of the Exchequer John Healey announced that OFSI's civil penalty cap would double.
What A7 sells its clients
A7 is a commercial enterprise set up in 2024, backed by Promsvyazbank, a sanctioned Russian state-owned bank, and by VEB.RF, a state development corporation. The alert attributes its creation to Ilan Shor, a Russian-Moldovan oligarch and convicted fraudster, and places its structures between Kyrgyzstan and Russia. Promsvyazbank pitches it as a way to settle trade under sanctions. The network is sanctioned by the UK, the United States and the European Union.
How the money travels, as the alert sets it out
A7 builds pools of liquidity outside Russia and draws on them to settle client transactions. Those pools entered the international financial system from Kyrgyzstan, mainly through the Trading Company of the Republic of Kyrgyzstan, liquidated in February 2026. The liquidity then carries no trace of its Russian origin. It presents as belonging to shell companies, which the alert calls sub-agents.
- the sub-agents are run from inside Russia, though incorporated abroad;
- A7 builds them websites and email addresses, and virtual private networks place its staff in the target country;
- transfers between sub-agent accounts pay the suppliers of Russian or sanctioned clients;
- false invoices provide cover for those transactions, following standard trade-based money laundering practice.
The network's credit instrument is the veksel, a promissory note under Russian law. The client buys it in Russia and its value covers the transactions executed abroad, so no correspondent transfer ever leaves Russia. A shell company performs a seemingly separate transaction elsewhere. The alert flags a move into payment service providers, including Pilot Finance Limited in Nigeria, a firm with British connectivity that the UK has since sanctioned. OFSI says it has identified transactions between A7 shell companies and UK-incorporated beneficiaries, routed through banks in several intermediary jurisdictions.
The indicators the alert flags
- companies with a short history handling large volumes with entities from an unrelated industry;
- invoices for goods that sit outside the supplier's usual product range;
- limited information on owners, directors or beneficiaries;
- banking access over a virtual private network, from an exit point matching the target jurisdiction but not the customer profile.
OFSI's penalty, and what the doubling moves
The penalty rests on section 146 of the Policing and Crime Act 2017. The Treasury may impose it once satisfied, on the balance of probabilities, that a person has breached financial sanctions legislation. The Economic Crime (Transparency and Enforcement) Act 2022 removed any knowledge or suspicion requirement from that test with effect from 15 June 2022. Civil liability is therefore strict.
The cap has two limbs. Where the value of the funds involved can be estimated, it is the greater of £1 million and 50% of that value, otherwise it is £1 million. The percentage limb therefore bites only above £2 million, and the announced move to 100% would drop that crossover to £1 million.
| Value of the breach | Cap today | Cap as announced |
|---|---|---|
| £500,000 | £1 million | £1 million |
| £2 million | £1 million | £2 million |
| £10 million | £5 million | £10 million |
The cap does not set the amount. OFSI fixes a baseline penalty inside the statutory maximum, at or above 75% of that maximum for seriousness level 4, then applies discounts that stack, up to 30% for prompt voluntary disclosure and co-operation.
OFSI published twenty enforcement outcomes between January 2019 and 31 August 2026. The largest went to Standard Chartered Bank, at £20.47 million in February 2020. The four penalties issued in 2026 before the alert run from £160,000 for Bank of Scotland to £1,000,920.59 for Sabre Global Technologies. Payment firms have been in that series since 2019, with Travelex, Clear Junction and TransferGo.