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US blacklists A7 network and moves to cut off its sub-agents

Treasury designated A7, a Russia-linked payment network it says Iran used to evade sanctions, as a transnational criminal organization. FinCEN proposed barring US institutions from any transfer involving its sub-agents, which it says processed more than $17 billion in 18 months.

The US Treasury on Thursday, October 1, 2026, designated the A7 Network, a Russia-linked payment network that it says Iran used to evade sanctions, as a significant transnational criminal organization. A7 is led by Ilan Shor, a fugitive Moldovan oligarch already under US sanctions. Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed the same day to bar US financial institutions from sending or receiving funds, crypto included, in any transaction involving A7’s “Sub-Agents.” These are the companies A7 controls in third countries to receive and send its payments. FinCEN also issued an alert with red flags.

Treasury filed the move under Operation Economic Outcast, the banner it also used that day for new Iran-related designations. “Treasury is dismantling the financial infrastructure that allows Iran and other adversaries to evade sanctions, move illicit funds, and undermine the integrity of the global financial system,” Treasury Secretary Scott Bessent said. Treasury says the action follows the UK National Crime Agency’s August 31, 2026 alert on A7.

$17B+
in dollar-denominated transactions processed by A7 sub-agents, January 2025 to June 2026
FinCEN
≈435
financial institutions in at least 83 countries hold sub-agent accounts (June 2026)
FinCEN alert
$179.1B
at least, in A7A5 token transactions processed by more than 180 entities, February 2025 to June 2026
FinCEN alert
RUB 7.5T+
cumulative volume A7 claimed as of January 2026 ($91.5 billion), about 13% of Russia’s 2025 foreign trade
US Treasury

A ban on any transfer that touches a listed sub-agent

FinCEN used section 9714(a) of the Combating Russian Money Laundering Act, which lets Treasury act against a class of transactions of “primary money laundering concern in connection with Russian illicit finance.” Beyond the five special measures of section 311 of the USA PATRIOT Act, it allows a sixth: prohibiting or conditioning certain transmittals of funds. FinCEN chose that one, arguing that a curb on correspondent accounts would miss A7A5, the network’s ruble-backed token, whose transactions do not rely on correspondent banking.

The proposed 31 CFR 1010.668 would bar banks, broker-dealers, money services businesses, and other covered financial institutions from any transmittal of funds “from or to an A7 Network Sub-Agent, or from or to any account or CVC address administered by or on behalf of” one. An institution that knows or has reason to believe a transfer is prohibited would have to notify the affected parties with which it has a direct commercial relationship. Each institution would also take a risk-based approach to deciding what further due diligence, if any, it needs to avoid processing prohibited transfers; FinCEN says the screening software already used for sanctions compliance could serve. FinCEN counts 347,926 potentially affected institutions, about 35,000 of them likely to bear more than a minimal burden, and puts their recordkeeping and disclosure costs at up to about $18 million a year in total.

🔑
A list only financial institutions will see
The proposal names six sub-agents, all based in the United Arab Emirates. FinCEN would share the rest of its list only with covered institutions, through its secure FI-Portal, and update it over time; the ban would apply only to listed entities. FinCEN says publishing the list would let A7 get around the measure with new sub-agents. A listed company could petition FinCEN for removal.
Sub-agentBaseAmountPeriod
Power Sphere LLC-FZDubai$61MSept. 2023 to July 2025
Hydrofusion Resources FZ-LLCUAE$3.6MMay to June 2025
Gimli Trade LLC-FZDubai$1.5MMay to June 2025
Galadriel Trading FZCODubaiMore than $946,000May to July 2025
Sigizmund FZCODubai$41,000July to Sept. 2025
Pearl BridgeDubaiAbout $30,000April 2025
Sub-agents named in FinCEN’s proposal and the illicit funds it says each processed

Comments are due 30 days after the proposal appears in the Federal Register, under docket FINCEN-2026-0265. FinCEN says that window balances public notice against the national security risk of letting illicit transfers continue.

Shell companies, false invoices, and VPNs run from Moscow

In a typical A7 transaction, the customer settles inside the network, using instruments such as veksels, the Russian term for bills of exchange or promissory notes, while a sub-agent appears as the payer on the invoice and sends the money through correspondent banks and SWIFT. By June 2026, A7 had created or acquired hundreds of sub-agents, in places such as Hong Kong, Indonesia, the Kyrgyz Republic, the Seychelles, Türkiye, and the UAE. Moscow-based staff run their accounts over VPNs that make them appear to be abroad, FinCEN says.

Skyscrapers at dusk above a highway interchange
All six sub-agents named in FinCEN’s proposal are based in the United Arab Emirates, five of them in Dubai.

FinCEN ties some sub-agents to Iran. One dealt directly with entities in Iran’s oil-smuggling “shadow fleet” and, with a sister company, received nearly $140 million from entities involved in Iranian sanctions evasion between July 2023 and October 2025. Another sent about $1.6 million to a company linked to Iranian weapons procurement. Treasury also cites financial support for Iran’s Islamic Revolutionary Guard Corps and Hamas, and links A7 to Nobitex, Iran’s largest digital asset exchange, sanctioned on June 2, 2026.

OFAC blocks the network, and its ruble token with it

The designation by Treasury’s Office of Foreign Assets Control (OFAC) blocks all property and interests in property of the A7 Network in the US or held by US persons, including transactions involving sub-agents acting on its behalf. It extends the August 14, 2025 designations of A7 LLC and Old Vector LLC, the Kyrgyz issuer of A7A5; OFAC treats the token itself as blocked property. Each A7A5 is advertised as backed by ruble deposits at Promsvyazbank (PSB), the sanctioned Russian state defense bank that set up A7 with Shor. FinCEN says the token serves mostly as a bridge into more widely accepted digital assets, such as Tether’s USDT.

The alert, FIN-2026-Alert007, asks institutions to cite the key term “FIN-2026-A7NETWORK” in suspicious activity reports. Its red flags include:

  • A recently formed company suddenly running unusually high volumes of large transactions
  • Account access from IP addresses tied to A7’s VPN infrastructure, such as the domains muzpan[.]com and sodkamus[.]com
  • Invoices with out-of-place Cyrillic characters, an analog company stamp on an otherwise digital document, or signs of AI alteration
  • Direct or indirect exposure to A7A5 or to “wrapped” tokens based on it

A7 categorically rejected any accusation that it had worked with Iran or terrorist organizations, Reuters reported on October 2. The company said it serves legitimate import and export operations in consumer goods and raw materials.

October 2022
OFAC designates Ilan Shor
Over Russian malign influence operations in Moldova.
September 2024
A7 launches
Shor and PSB are behind it, FinCEN says.
August 14, 2025
First A7 designations
OFAC sanctions A7 LLC, Old Vector LLC, and other entities.
August 31, 2026
UK alert
The National Crime Agency issues an alert on A7.
October 1, 2026
Designation and proposed ban
OFAC designates the A7 Network; FinCEN publishes its proposal and alert.

Provenance

Published October 1, 2026

7 sources, 6 distinct domains

↗ US Treasury, Operation Economic Outcast Takes Unprecedented Action Against Sanctions Evasion Network Used by Iran, October 1, 2026 · home.treasury.gov↗ FinCEN, Operation Economic Outcast takes unprecedented action against sanctions evasion network used by Iran · fincen.gov↗ Federal Register, FinCEN proposed rule: Special Measure Prohibiting the Transmittal of Funds Regarding Transactions Involving the A7 Network’s Sub-Agents (2026-20371) · federalregister.gov↗ FinCEN, FIN-2026-Alert007: FinCEN Alert on the A7 Network, October 1, 2026 · fincen.gov↗ OFAC, Recent Actions, October 1, 2026: Transnational Criminal Organizations Designation · ofac.treasury.gov↗ TRM Labs, FinCEN Moves to Cut the A7 Network’s Sub-Agents Off From the US Financial System · trmlabs.com↗ Zonebourse (Reuters), Russian payment platform A7 denies any link with Iran after US sanctions · ch.zonebourse.com
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