U.S. Treasury Targets A7 Shadow Banking Network With FinCEN Rule and OFAC Sanctions
The U.S. Department of the Treasury has launched a coordinated action against the A7 Network, a Russia-linked shadow banking network that Treasury says has been used by Iran and other illicit-finance actors to evade sanctions and move funds through the international financial system.
On October 1, 2026, the Financial Crimes Enforcement Network proposed a rule that would prohibit transmittals of funds involving A7 Network Sub-Agents. FinCEN also issued an Alert to help financial institutions identify and report suspicious activity associated with the network. Separately, the Office of Foreign Assets Control sanctioned the A7 Network as a significant transnational criminal organization.
Treasury describes the Sub-Agents as companies in third-country jurisdictions used to receive and remit payments while disguising sanctioned or illicit transactions as ordinary commercial activity. The network allegedly uses falsified trade documents, import-export records and misleading descriptions of goods to obscure the nature of payments.
FinCEN identified more than US$17 billion processed by A7 Network Sub-Agents between January 2025 and June 2026, aggregated globally. Treasury also said the A7 Network claimed that by January 2026 it was processing more than 2,000 transactions per day with total transaction volume exceeding 7.5 trillion rubles, equivalent to approximately US$91.5 billion.
According to Treasury, the same payment infrastructure created channels used by actors including the Central Bank of Iran and the Islamic Revolutionary Guard Corps, as well as cybercriminal and procurement networks. Treasury also cited transactions connected to Iranian oil sales, weapons procurement and North Korean cryptocurrency theft.
The proposed FinCEN rule was issued under section 9714(a) of the Combating Russian Money Laundering Act. The public comment period will close 30 days after publication of the proposal in the Federal Register.
OFAC’s designation blocks property and interests in property of the A7 Network within U.S. jurisdiction and applies U.S. sanctions restrictions to transactions involving the designated network, subject to applicable authorizations and exemptions.
For financial institutions, the FinCEN Alert is particularly relevant to transaction monitoring and sanctions controls because it provides indicators intended to help identify activity involving A7 Network Sub-Agents and their use of foreign companies and international payment systems.
Source
U.S. Department of the Treasury, “Operation Economic Outcast Takes Unprecedented Action Against Sanctions Evasion Network Used by Iran,” October 1, 2026.
