Proposal Of Special Measure Prohibiting The Transmittal Of Funds Regarding Transactions Involving

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Financial Crimes Enforcement Network (FinCEN), Treasury.

Notice of proposed rulemaking.

FinCEN is issuing a finding and notice of proposed rulemaking, pursuant to section 9714(a) of the Combating Russian Money Laundering Act ( Public Law 116-283 ), as amended by section 6106(b) of the National Defense Authorization Act for Fiscal Year 2022 ( Public Law 117-81 ), finding transactions involving any company operating outside of the United States that is controlled by the A7 Network, a sanctions evasion and money laundering service with ties to Russia, leveraged by a wide range of illicit actors, including Iran and its terrorist proxies, to be a class of transactions of primary money laundering concern in connection with Russian illicit finance and proposing the imposition of a prohibition on certain transmittals of funds, by any covered financial institution, involving that class of transactions.

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I. Summary of Notice of Proposed Rulemaking

This notice of proposed rulemaking (NPRM) (1) sets forth FinCEN's finding that transactions involving any company operating outside of the United States that is controlled by the A7 Network [ 1 ] (a “Sub-Agent” and, collectively, the “Sub-Agents”), are a class of transactions of primary money laundering concern in connection with Russian illicit finance; and (2) proposes prohibiting certain transmittals of funds involving that class of transactions by any covered financial institution. As set out in this NPRM, transactions involving any Sub-Agent fall within a class of transactions of primary money laundering concern in connection with Russian illicit finance, as such transactions present a material risk of facilitating funds transfers designed to evade sanctions by illicit actors, including Russian and Iranian persons that have been designated by Treasury's Office of Foreign Assets Control (OFAC), such as the Islamic Revolutionary Guard Corps (IRGC), and intended to support illicit activities, including sanctions evasion involving or benefitting Russian and Iranian clients.

A. Statutory Provisions

Section 9714(a) of the Combating Russian Money Laundering Act ( Pub. L. 116-283 ), as amended by section 6106(b) of the National Defense Authorization Act for Fiscal Year 2022 ( Pub. L. 117-81 ) (section 9714), [ 2 ] provides, in relevant part, that, if the Secretary of the Treasury (Secretary) “determines that reasonable grounds exist for concluding that . . . one or more classes of transactions within, or involving, a jurisdiction outside the United States . . . is of primary money laundering concern in connection with Russian illicit finance,” the Secretary may, “by order, regulation, or otherwise as permitted by law”: (1) require domestic financial institutions and domestic financial agencies to take 1 or more of the special measures described in 31 U.S.C. 5318A(b) ; [ 3 ] or (2) prohibit, or impose conditions upon, certain transmittals of funds (as defined by the Secretary) by any domestic financial institution or domestic financial agency, if such transmittal of funds involves any such class of transaction. The authority of the Secretary to administer both section 9714 and the Bank Secrecy Act (BSA) has been delegated to FinCEN. [ 4 ]

Pursuant to section 9714, the Secretary may impose one or more of six special measures. First, the Secretary may impose any of the five special measures provided for in 31 U.S.C. 5318A(b) , commonly known as section 311 of the USA PATRIOT Act. [ 5 ] Through special measures one through four, the Secretary may impose additional recordkeeping, information collection, and reporting requirements on covered financial institutions. [ 6 ] Through special measure five, the Secretary, in consultation with the Secretary of State, the Attorney General, and the Chairman of the Board of Governors of the Federal Reserve System, may “prohibit, or impose conditions upon, the opening or maintaining in the United States of a correspondent account or payable-through account” for or on behalf of a foreign banking institution, if such correspondent account or payable-through account involves the class of transactions found to be of primary money laundering concern. [ 7 ] In addition to the special measures set out in 31 U.S.C. 5318A , section 9714 also provides that the Secretary may impose a special measure prohibiting, or imposing conditions upon, certain transmittals of funds. [ 8 ]

B. A7 Network and its Sub-Agents

The OFAC-sanctioned transnational criminal organization (TCO), A7 Network, is a global wholesale sanctions evasion and money laundering service with ties to Russia, leveraged by a wide range of illicit actors, including Iran and its terrorist proxies. Approximately 80 percent of Russian banks have been sanctioned by the United States, United Kingdom, and European Union since 2022, and numerous key Russian banks have lost their access to the Society of Worldwide Interbank Financial Telecommunication (SWIFT). [ 9 ] U.S., European Union (EU), and/or United Kingdom (UK) sanctions and the resulting “de-SWIFTing” of Russian banks have significantly curtailed Russia's connectivity to the international financial system, leaving a void for the A7 Network to fill. Against that backdrop and although the A7 Network markets itself as merely an alternative payment system, the A7 Network was formally launched in September 2024 as a purpose-built mechanism to evade Western sanctions imposed in response to Russia's further ( printed page 63210) invasion of Ukraine in 2022. [ 10 ] However, as a self-described sanctions-resistant payment service provider, the A7 Network has evolved into a conduit for illicit activity associated with a wide range of threat actors, including North Korea (DPRK);Iran-backed terrorist organizations; cybercriminals and ransomware actors; and the IRGC. [ 11 ]

The A7 Network's creation was driven by two U.S.-, EU- and UK-designated parties: fugitive Moldovan oligarch Ilan Shor [ 12 ] and Russia's state-owned defense bank Promsvyazbank Public Joint Stock Company (PSB). [ 13 ] The core of the A7 Network is formed by three Russia-based companies—A7 Liability Company (A7 LLC), and its subsidiaries, A71 Limited Liability Company (A71 LLC) and A7 Agent Limited Liability Company (A7 Agent LLC)—which are jointly owned by Ilan Shor and PSB and subject to sanctions imposed by the United States, EU, and UK. [ 14 ] These entities administer the network with and through several Russia- and Kyrgyz Republic-based persons, including businesses and digital asset exchanges subject to sanctions imposed by OFAC and the UK (as well as, in most cases, the EU), including Old Vector LLC, Garantex, Grinex, Independent Decentralized Finance Smartbank and Ecosystem (InDeFi Bank), ExVed, and Garantex co-founder Sergey Mendeleev (Mendeleev). [ 15 ] Collectively, these entities leverage companies transacting in both fiat currency and digital assets in complex trade-based money laundering schemes to enable illicit actors to access the international financial system. [ 16 ]

Significantly (and as noted above), OFAC has designated the founders and these core components and enablers, as well as sanctioning the A7 Network as a significant TCO. [ 17 ] As a result, all property and interests in property of these persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC's regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. In addition, financial institutions and other persons that engage in certain transactions or activities with these sanctioned entities and individuals may expose themselves to sanctions, including making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person, or be subject to an enforcement action.

Building on these actions, FinCEN assesses that the A7 Network has created, and continues to operate, a financial network to further and enable widespread sanctions evasion and the laundering of billions of dollars tied to illicit activity. When A7 LLC was founded in 2024, PSB issued a press release touting the new service as a way to “support Russian foreign trade participants and their trading partners amid anti-Russian sanctions pressure,” indicating that sanctions evasion is part of the business model. [ 18 ] Speaking at the Russia-China Mutually Beneficial Cooperation forum (ROSTKI) in August 2025, A7 LLC's Vice President Mikhail Tolkunov described A7's core capabilities:

“The company `A7' was created by PSB Bank [in 2025] and operates in the field of cross border transfers . . . the service allows you to create a personal account remotely and transfer funds within one day with minimal fees. Document management is carried out electronically . . . The platform was created for transfers in any currency, including dollars, yuan, dirhams, and euros. Transfers are completely secure, as our entire financial infrastructure is built on an independent architecture and is not tied to international payment systems. This means ( printed page 63211) we are not threatened by any unilateral restrictions.” [ 19 ]

As of January 2026, the A7 Network claimed to process more than 2,000 transactions per day with a historical total transaction volume of more than 7.5 trillion rubles (RUB), the equivalent of USD 91.5 billion. This would amount to nearly 13 percent of the Russian Federation's 2025 foreign trade transactions, meaning that nearly one in eight dollars of Russia's foreign trade allegedly flows through A7's Network. [ 20 ]

There are indications that the Russian government perceives the A7 Network to be a strategically important enterprise. In September 2025 Russian President Vladimir Putin attended the virtual ribbon cutting for the opening of an A7 Network office in Vladivostok, Russia. [ 21 ] Several oligarchs with close ties to the Kremlin have reportedly used the A7 Network to make international payments, including UK-sanctioned Roman Abramovich, OFAC-sanctioned former Federal Security Service Director Nikolai Patrushev, OFAC-sanctioned Arkady Rotenberg, and businesses linked to UK-sanctioned Leonid Mikkelson. [ 22 ] Moreover, two OFAC-sanctioned Russian financial institutions maintain an interest in the A7 Network, PSB and VEB.RF (VEB), Russia's state-owned development bank. [ 23 ] Additionally, a Kyrgyzstan-based company reportedly used the A7 Network to obfuscate transactions related to the purchase of Russian gas supplies for Türkiye following the imposition of sanctions on Russian bank Gazprombank, which typically handles energy transactions. [ 24 ]

The scope of the A7 Network's activities is only possible through its global network of Sub-Agents. Shortly after its establishment, the A7 Network began aggressively expanding into new jurisdictions and forming companies—“Sub-Agents”—controlled by the A7 Network and designed to receive and remit payments to facilitate transactions for the A7 Network. The first Sub-Agents were established in the Kyrgyz Republic, and the A7 Network has since established Sub-Agents across Central and East Asia, Africa, Europe, and the Middle East. [ 25 ]

The A7 Network has indicated it plans to expand its global footprint, potentially enhancing its reach and ability to move funds outside of the formal financial system into currently untapped regions, including Latin America. [ 26 ] Until recently, the A7 Network only had a physical presence in Russia, but in the fall of 2025 the company announced the opening of its first overseas offices in Nigeria and Zimbabwe and signaled aspirations to further expand in Africa. [ 27 ] In June 2026, Shor stated that “A7 plans to operate everywhere.” [ 28 ]

III. Finding That Transactions Involving any Sub-Agent of the A7 Network Are a Class of Transactions of Primary Money Laundering Concern in Connection With Russian Illicit Finance

Based on public and non-public information available to FinCEN, FinCEN finds that reasonable grounds exist for concluding that transactions involving any Sub-Agent of the A7 Network are a class of transactions of primary money laundering concern in connection with Russian illicit finance, as such transactions present a material risk of facilitating funds transfers designed to evade sanctions by illicit actors, including Russian and Iranian persons that have been designated by OFAC, and intended to support illicit activities, including sanctions evasion involving or benefitting Russian and Iranian clients. In making this finding, FinCEN has considered the relevant evidence in light of factors identified in 31 U.S.C. 5318A(c)(2)(B) , taking into account the specific circumstances of money laundering activities in connection with Russian illicit finance and the protection of U.S. national security and the U.S. financial system. While FinCEN is under no obligation pursuant to section 9714 to consider any particular factor or set of factors when making a finding that a financial institution operating outside of the United States is of primary money laundering concern in connection with Russian illicit finance, it nonetheless finds these factors instructive in guiding the analysis set forth below. [ 29 ]

A. The Extent to Which Transactions Involving any Sub-Agent of the A7 Network Are a Class of Transactions of Primary Money Laundering Concern in Connection With Russian Illicit Finance

As indicated above, the A7 Network provides a financial services infrastructure for clients in Russia and other heavily sanctioned jurisdictions, such as Iran, that enables those clients to make cross-border payments in both fiat currency and digital assets while obscuring the sanctions nexus from U.S. and foreign financial institutions. Importantly, a crucial feature of the A7 Network's financial services infrastructure is, and remains, its use of, and reliance on, its Sub-Agents, offering the A7 Network and its clients a means of obfuscating the involvement of Russian or other sanctioned actors in payments that appear to financial institutions as ordinary commercial activity.

1. The A7 Network's Sub-Agents

Although the core operations of the A7 Network are directed by A7 LLC and its subsidiaries, working with and through several Russia- and Kyrgyz Republic-based businesses and digital asset exchanges, the A7 Network's Sub-Agents are a critical element within the Network's financial services infrastructure, allowing the Network to obfuscate the source and parties to transactions, to access foreign currencies, to make payments appear as ordinary commercial activity, and to circumvent applicable sanctions and other restrictions.

As noted above, shortly after its establishment, the A7 Network began aggressively expanding into new jurisdictions and forming Sub-Agents, with the first Sub-Agents established in Kyrgyz Republic, followed by expansion across Central and East Asia, Africa, Europe, and the Middle East. [ 30 ] As of June 2026, the A7 Network has created or acquired hundreds of Sub-Agents, with bank accounts at approximately 435 financial institutions in at least 83 countries.

To establish the Sub-Agents, the A7 Network forms, acquires, or partners with companies in third countries—such as Hong Kong, Indonesia, the Kyrgyz Republic, the Seychelles, Türkiye, and the United Arab Emirates (UAE). Although on paper, these companies are typically represented to be owned or managed by non-Russian third-country nationals, they are ultimately controlled by with the A7 Network. [ 31 ] Once established, Sub-Agents provide the A7 Network with access to correspondent banking relationships and foreign-currency liquidity, enabling the A7 Network to transmit value through the international financial system without a Russian or other sanctioned customer appearing in the payment chain and commonly causing financial institutions to be unwitting accomplices.

In a typical A7 Network transaction, the A7 Network customer satisfies its payment obligation through the A7 Network's internal settlement system, while a Sub-Agent located outside of Russia appears as the contracting or paying party on invoices, sales agreements, and payment instructions to the ultimate supplier of a good. In essence, this is a form of trade-based money laundering that leverages Sub-Agents, falsified trade documents, false import-export records, and misleading goods descriptions. In many cases, funds may be transferred between multiple Sub-Agents to create additional layers of obfuscation before arriving at the final destination. [ 32 ] Through this process, the Sub-Agents provide the A7 Network with access to correspondent banking relationships, access to the SWIFT network, and foreign-currency liquidity, enabling it to transmit value through the international financial system without a Russian customer appearing in the payment chain. [ 33 ]

While funds are typically moved between companies by Moscow-based A7 Network personnel, the A7 Network leverages Virtual Private Networks (VPNs) to create the illusion that these individuals are located outside of Russia and obscuring the connection between Russia and the Sub-Agents. [ 34 ] These VPNs typically depend on infrastructure provided by IT companies controlled by Ilan Shor and have operated on the domains muzpan.com and sodkamus.com and often appear to have IP addresses in Dubai, Hong Kong, or the Kyrgyz Republic, thereby disguising the connection to Russia. [ 35 ] Thus, there is often no clear indication of a connection between a Sub-Agent and the A7 Network's clients, including, in particular, clients in the heavily sanctioned jurisdiction, on whose behalf the Sub-Agent is transacting. Sub-Agent transactions, however, are likely to exhibit typical money laundering indicators, including transactions in unusually high volumes shortly after the company is formed, inconsistencies between goods descriptions and supplier business profiles, unusual payment routing through A7 Network-controlled companies, and falsified or AI-altered invoices. [ 36 ]

FinCEN assesses that the layer of obfuscation provided by Sub-Agents has enabled the A7 Network to circumvent U.S. sanctions and anti-money laundering and countering the financing of terrorism (AML/CFT) controls, tainting the global financial system with billions in illicit funds stemming from, among other activities, Russian and Iranian sanctions evasion.

2. The A7 Network's Use of Financial Instruments Facilitates Illicit Cross-Border Trade

In a typical fiat transaction, the A7 Network facilitates international trade through extensive use of financial instruments, including bills of exchange or promissory notes (referred to as veksels in Russian), that record value inside the Network. Specifically, an A7 Network customer provides the A7 Network with information necessary to execute the transaction, which may include supplier information and trade documentation. The A7 Network then satisfies its customer's payment obligation through A7 Network-controlled settlement mechanisms that record value inside the Network. [ 37 ] Between September 30, 2024 and July ( printed page 63213) 22, 2025, the A7 Network's clients purchased more than 3,200 bills of exchange worth the equivalent of more than USD 25 billion, indicating that there is robust demand for A7 Network's services. [ 38 ] These bills of exchange are purchased by companies and traders—becoming the customer's credit within the system—and each purchase gets them on the A7 Network's ledger, reducing the need to do direct international bank transfers and helping to avoid scrutiny by banks. The A7 Network then assigns a foreign Sub-Agent to appear as the contracting or paying party on invoices, sales agreements, and payment instructions. This enables the payment to be executed from non-Russian bank accounts through correspondent banking and SWIFT channels. [ 39 ]

In particular, the A7 Network has honed its process for executing international payments through complex financial arrangements and its constellation of enabling Sub-Agents. The typical process requires a customer to provide the A7 Network with documentation outlining the foreign counterparty requiring payment and attendant bank details, description of the goods being bought, and price. The A7 Network then matches the intended transaction with a relevant Sub-Agent in its global network, many of which are industry-specific to provide plausible cover for transactions. [ 40 ] These Sub-Agents do not have any Russians on the board of directors or as shareholders and their bank accounts are managed by A7 Network staff in Russia via VPNs, all to appear as if the companies are being operated from within the country of registration. [ 41 ] The A7 Network then uses software that generates fake invoices and trade documents to make the transactions seem legitimate—including by stripping any reference to Russia. [ 42 ]

The A7 Network also reportedly maintains reserves of currency in foreign bank accounts, to pay individuals and entities outside of Russia without the need for cross-border transactions. The A7 Network keeps records of the money it receives from its clients in Russia, and the money it sends to external parties to maintain adequate funding on both sides of the border and balance the books, enabling the Russian clients of the A7 Network to evade sanctions and avoid disruption. [ 43 ] FinCEN assesses transactions involving the A7 Network's Sub-Agents enable its clients to send or receive money to nearly any country and in nearly any currency—including, U.S. dollars, yuan, dirhams, and euros—by using banks that have correspondent relationships with larger financial institutions that, but for obfuscation by the A7 Network, would not engage in these transactions, permitting illicit actors access to a money laundering platform and decreasing the risk of this activity being identified by investigating authorities. [ 44 ]

Using these settlement mechanisms, the A7 Network's clients have reportedly been able to transact with counterparties in Africa, Asia, Europe, North America, and South America despite the restrictive sanctions on Russian banks. [ 45 ]

3. The A7 Network's Creation and Use of the A7A5 Stablecoin

In parallel with its fiat settlement mechanism, the A7 Network may use digital assets, including A7A5, a ruble-backed stablecoin that operates on the Tron and Ethereum blockchains, [ 46 47 ] to transfer value across A7 Network-linked actors where banking channels are restricted or less dependable. [ 48 ] Kyrgyz Republic-registered, OFAC-sanctioned digital assets firm Old Vector LLC worked with digital assets exchange Garantex, Garantex's successor exchange Grinex, and others in the creation, issuance, and trading of the A7A5 token. [ 49 ] A7 Network created the A7A5 stablecoin for Russian clients of OFAC-designated A7 LLC, a firm that provides cross-border settlement platforms frequently used for sanctions evasion. [ 50 ] Although A7A5 is issued by Kyrgyzstan-based Old Vector, each coin is backed by ruble deposits held at PSB, meaning for every A7A5 transaction, there is a corresponding nexus to a sanctioned Russian bank. [ 51 ]

The A7A5 tokens are used to conduct transactions outside of the formal financial system. The token serves as an internal accounting method for the network, moving across internal addresses to maintain a balanced ledger, effectively acting as part of a broader mirror system, [ 52 ] to the international ( printed page 63214) payments that the network makes. [ 53 ] This broader mirror system also involves the use of the aforementioned bills of exchange, known as “veksels”. According to public and nonpublic information, the tokens are used for transfers within Russia that represent foreign payments and are made through nested digital asset wallets and financial accounts held in the name of A7 Network Sub-Agents. On the other side of the mirror trading system, the A7 Network employs its Sub-Agents to conduct fiat transactions—including U.S. dollars, yuan, dirhams, and euros—through the international financial system. FinCEN, through analysis of available financial data, found that more than 180 entities processed A7A5 transactions worth at least USD 179.1 billion, between February 2025 and June 2026. Historically, almost all of these transactions were processed through U.S.-, EU-, and/or UK-sanctioned entities, including Garantex and Grinex, and likely involved touchpoints with Russian banks; [ 54 ] however following an alleged hack of Grinex in April 2026, [ 55 ] A7A5 has been consolidated into unhosted wallets, suggesting the A7 Network may be moving away from using sanctioned exchanges. [ 56 ]

The A7 Network has most often used the A7A5 tokens as a non-freezable, bridging asset to convert into other, more widely accepted digital assets, such as the stablecoin Tether (USDT), and which may then be converted to the fiat currency of the customers choosing as another means of settling payments internationally. [ 57 ] In order to maintain the necessary liquidity to operate, the A7 Network uses its Sub-Agents or other trusted intermediary entities, such as digital asset exchanges. This includes over-the-counter digital asset brokers (OTCs) [ 58 ] outside of Russia operating in jurisdictions of concern for A7 Network activity—especially firms that are newly created or dramatically expanding their stablecoin trading operations—which could serve as A7 Network liquidity providers. [ 59 ] In addition, FinCEN analysis indicates that U.S. financial institutions may encounter use of derivative or “wrapped” tokens distinct from but “pegged” to the A7A5 token that serve as a representation of the A7A5 token on a blockchain to which A7A5 is not native; [ 60 ] wrapped tokens are often accessed through decentralized finance applications. [ 61 ]

The A7 Network's well-established and far-reaching digital asset channels are an appealing tool for a wide range of threat actors. Analysis of public and nonpublic information reveals that Iranian actors are leveraging the A7 Network, including the Central Bank of Iran and the IRGC. Other illicit actors known to have used this network include North Korea (DPRK); Iran-backed terrorist organizations; cybercriminals and ransomware actors. [ 62 ]

4. The A7 Network's Sub-Agents Are Used in Furtherance of International Money Laundering and Sanctions Evasion in Connection With Russian Illicit Finance

As demonstrated above, the A7 Network's Sub-Agents play a key role in enabling, and facilitating, the A7 Network's activities. Based on analysis of public and nonpublic information, FinCEN assesses that, in the aggregate, the A7 Network's Sub-Agents have processed more than 17 billion in USD-denominated transactions between January 2025 and June 2026. Moreover, FinCEN has identified and assessed hundreds of Sub-Agents of the A7 Network, finding that, based on public and nonpublic information, these Sub-Agents have (1) extensively facilitated transactions on behalf of, and for the benefit of, sanctioned Russian persons; (2) supported Russia's military operations in Africa; (3) enabled Iranian sanctions evasion, including transactions involving entities involved in the “shadow fleet” that Iran uses to illicitly sell oil; and (4) assisted at least one company involved in procurement for Iran's weapons programs.

For instance, publicly identified [ 63 ] Sub-Agents that FinCEN assesses engaged in illicit activity include:

Power Sphere LLC-FZ. Power Sphere LLC-FZ is a Dubai, UAE-based electronics supplier that purportedly trades in energy products, agricultural products, consumer goods, and food and beverages. [ 64 ] However, FinCEN's ( printed page 63215) analysis of public and non-public information identified that between September 2023 and July 2025, Power Sphere LLC-FZ processed USD 61 million in illicit funds tied to Russian trade-based money laundering and procurement activities in the energy sector.

Hydrofusion Resources FZ-LLC. Hydrofusion Resources FZ-LLC is a UAE-based energy commodities trader that also purportedly trades in various other products, such as food and beverages, electronics, and heavy machinery. [ 65 ] FinCEN's analysis of public and non-public information determined that between May and June 2025, Hydrofusion Resource FZ-LLC processed USD 3.6 million in illicit funds tied to Russian trade-based money laundering activity.

Gimli Trade LLC-FZ. Gimli Trade LLC-FZ is a Dubai, UAE-based trading firm that purportedly trades in food and beverages, household goods, cosmetic products, machinery, oil trading, and general trading. [ 66 ] The company maintained an account at PSB in Russia, which was used to make ruble-denominated transactions. [ 67 ] Gimli Trade LLC-FZ was sanctioned by the United Kingdom on December 18, 2025, for its involvement in providing financial support to the Russian government. [ 68 ] FinCEN's analysis of public and non-public information determined that between May and June 2025, Gimli Trade LLC-FZ processed USD 1.5 million in illicit funds tied to Russian sanctions evasion.

Galadriel Trading FZCO. Galadriel Trading FZCO is a Dubai, UAE-based agricultural trading firm that purportedly trades commodities such as wheat, corn, barley, chickpeas, and vegetable oils. [ 69 ] FinCEN's analysis of public and non-public information determined that between May and July 2025, Galadriel Trading FZCO processed more than USD 946,000 in illicit funds tied to Russian export control evasion.

Sigizmund FZCO. Sigizmund FZCO is a Dubai, UAE-based marketing management, research, and support consultancy firm. [ 70 ] FinCEN's analysis of public and non-public information determined that between July and September 2025, Sigizmund FZCO processed USD 41,000 in illicit funds tied to Russian sanctions evasion, including the acquisition of dual-use goods.

Pearl Bridge. Pearl Bridge is a Dubai, UAE-based trading firm that purportedly specializes in precious metals, commodities, and other general trade. [ 71 ] FinCEN's analysis of public and non-public information determined that in April 2025, Pearl Bridge processed approximately USD 30,000 in illicit funds tied to suspected Russian sanctions evasion activity.

Additionally, based on analysis of public and nonpublic information, there are indications that certain Sub-Agents have facilitated Iranian sanctions evasion efforts. One Sub-Agent engaged in direct transactions with other Sub-Agents and entities associated with Iran's shadow fleet—a network of oil tankers, shipping companies, and front companies used to transport and sell Iranian oil—indicating that Iranian actors have used the A7 Network and its infrastructure, including its Sub-Agents, in connection with sanctions-evasion activity. Between July 2023 and October 2025, the same A7 Sub-Agent and one of its sister companies received nearly USD 140 million from entities involved in Iranian sanctions evasion. In a separate instance, based on public and nonpublic information, FinCEN assess that another A7 Network Sub-Agent transferred approximately USD 1.6 million, between January 2024 and September 2025, to a company linked to Iranian sanctions evasion and weapons procurement efforts.

Across fiat and digital asset-based settlement mechanisms, the A7 Network's well-established and far-reaching constellation of Sub-Agents have provided a tool for threat actors to engage in a wide array of illicit activity, including sanctions evasion.

B. The Extent to Which Transactions Involving any Sub-Agent of the A7 Network Involve Legitimate Business Activity

In reaching its finding, FinCEN has considered the extent to which transactions involving any Sub-Agent are used for legitimate business purposes. [ 72 ] As discussed above, the A7 Network's Sub-Agents are used to facilitate illicit activities by illicit actors. Although some components of the A7 Network, including its known Sub-Agents, may offer services that could potentially be used by licit actors, the A7 Network's own creators, acknowledge its services are expressly designed to circumvent U.S. and international sanctions placed on the operators, owners, and enablers of the A7 Network [ 73 ] and licit actors would have access to other, more established channels through which they might direct financial activity. Accordingly, given the extensive flow of illegitimate funds through the A7 Network, FinCEN assesses that the need to protect U.S. financial institutions from the money laundering risks presented by the A7 Network outweighs any potential legitimate utility its services may provide.

C. The Extent to Which This Proposed Action Would Guard Against the Risks Posed by Transactions Involving any Sub-Agent of the A7 Network

A finding that transactions involving any Sub-Agent of the A7 Network are a class of transactions of primary money laundering concern in connection with Russian illicit finance establishes—and emphasizes—the significant illicit finance risks posed by the A7 Network and its Sub-Agents. This finding will place U.S. and foreign financial institutions and regulators on notice to guard against those risks. [ 74 ] Moreover, as Sub-Agents of the A7 Network are, by design, challenging to readily identify, such a finding—in combination with a prohibition on certain transmittals of funds by covered financial institutions—will safeguard the U.S. financial system, by assisting financial institutions in identifying Sub-Agent and severing access.

IV. Proposed Special Measure

Having found that transactions involving any Sub-Agent of the A7 ( printed page 63216) Network are a class of transactions of primary money laundering concern in connection with Russian illicit finance, FinCEN proposes imposing a prohibition on certain transmittals of funds involving any of the A7 Network's Sub-Agents. [ 75 ] In making this determination and assessing which special measures may be appropriate, FinCEN has considered the relevant evidence in light of factors identified in 31 U.S.C. 5318A(a)(4)(B) . While FinCEN is under no obligation pursuant to section 9714(a) to consider any particular factor or set of factors in selecting one or more special measures, it nonetheless finds these factors instructive in guiding the analysis set forth below. [ 76 ]

As noted above, OFAC has not only designated the A7 Network as a significant TCO, but also designated, and imposed restrictions upon, certain core actors and components of the A7 Network—namely, A7 LLC, A71 LLC, A7 Agent LLC, Old Vector LLC, Garantex, Grinex, InDeFi Bank, ExVed, Mendeleev, Ilan Shor, and PSB, as well as certain other persons whose property and interests in property have been blocked, by designation, order, or by operation of law. The proposed imposition of a special measure would reinforce those existing restrictions, and importantly, the purposes served by this proposed action differ from the purposes of the existing economic sanctions. Apart from the rationale and purposes of the existing sanctions, this action is specifically designed to address a significant money laundering threat to the U.S. and international financial systems premised on the Secretary's determination that transactions involving any Sub-Agent of the A7 Network poses an unacceptable risk of money laundering and other financial crimes.

Further, this action is intended to encourage other jurisdictions—as well as financial institutions throughout the world—to take similar steps to sever the A7 Network and its Sub-Agents from the international financial system.

Notwithstanding the differing purposes of the existing sanctions and the special measure proposed in this NPRM, the proposed special measure is intended to apply in concert, not conflict with the existing sanctions. Covered financial institutions should block and report to OFAC any accounts or transactions that are blocked pursuant to any applicable OFAC sanctions authority, and to the extent required or necessary, continue to maintain any blocked accounts in accordance with the Reporting Procedures and Penalties Regulations, 31 CFR part 501 . And, for avoidance of doubt, if there is an apparent conflict between an obligation to block property or interests in property under existing OFAC sanctions and the requirements of this proposed special measure, covered financial institutions should comply with the obligation to block and, in doing so, would be deemed to comply with the requirements of this proposed special measure.

A. Whether the Proposed Special Measure Would Address the Money Laundering Concern in a Manner Consistent With U.S. National Security and Foreign Policy Interests

FinCEN has considered the effect this proposed special measure will have on U.S. national security and foreign policy, as well as the extent to which multilateral groups or other nations have taken similar action. [ 77 ] Given that the A7 Network's Sub-Agents' association with sanctioned persons and other actors involved in illicit activity, for the purpose of furthering sanctions evasion, FinCEN assesses that imposing a prohibition on certain transmittals of funds involving the A7 Network's Sub-Agents is necessary to safeguard U.S. national security and the U.S. financial system, as well as serve key U.S. national security objectives. Specifically, prohibiting certain transmittals of funds involving any of the A7 Network's Sub-Agents would insulate the U.S. financial system from international money laundering and other financial crimes, further ongoing U.S. efforts to curtail suspected sanctions evasion and related illicit activity tied to Russian and Iranian illicit finance, and sever a significant pathway that facilitates circumvention of U.S. and other sanctions, supporting the efficacy of U.S. sanctions and complementing actions taken by the U.S. government.

B. Whether the Proposed Special Measure Would Create Undue Burdens on Any Legitimate Activity of the A7 Network's Sub-Agents or Third Parties

FinCEN has considered whether the proposed prohibition on certain transmittals of funds would create a significant competitive disadvantage, including any undue cost or burden associated with compliance, for financial institutions organized or licensed in the United States as affected third parties, as well as the extent to which the action could have a significant adverse systemic impact on legitimate business activities involving the A7 Network's Sub-Agents. As noted above, FinCEN assesses that to the extent the A7 Network Sub-Agents are engaged in licit activity, such activity is relatively minimal compared to the sanctions evasion and illicit financial activity that flows through these Sub-Agents. Moreover, these Sub-Agents operate companies in a variety of industries and the disperse nature of these businesses underscores that any overall impacts from any decrease in legitimate commercial or financial activity by these Sub-Agents is likely de minimis.

When considering the anticipated burden on covered financial institutions, FinCEN assesses that the proposed prohibition is unlikely to impose a significant competitive disadvantage on any one particular financial institution organized or licensed in the United States as a consequence of business forgone due to the proposed prohibition given that the A7 Network's Sub-Agents uses of hundreds of Sub-Agents across a wide number of financial institutions, globally. Further, compliance with the proposed prohibition on certain transmittals of funds set out in this NPRM should not require tools or competencies other than those already employed by domestic financial institutions to maintain their current AML/CFT compliance programs and/or sanctions compliance programs. To ensure that minimal additional burden would attach to compliance with the proposed rule, FinCEN has elected to ( printed page 63217) provide for the rejection of certain transmittals of funds that are received from or originate with A7 Network Sub-Agents and outline the steps a covered financial institution should take in such circumstances to satisfy the proposed requirements. Further, upon issuance of a Final Rule, FinCEN is prepared to aid covered financial institutions in compliance with this NPRM, by providing additional information regarding known Sub-Agents, as appropriate, through a secure communications channel and proposes to limit the obligation on covered financial institutions to prohibit certain transmittals to only those entities on the provisioned list(s), which may be updated over time, as FinCEN, for instance, identifies additional Sub-Agents.

C. Whether Any Other Reasonable Alternatives or Special Measures Would Adequately Address the Money Laundering Concern

In assessing the appropriate special measure to impose, FinCEN considered alternatives to a prohibition on certain transmittal of funds, including the imposition of one or more of the first five special measures. Having considered these alternatives, FinCEN assesses, for the reasons set out below, that a special measure prohibiting certain transmittals of funds involving the A7 Network's Sub-Agents is the most appropriate means to adequately address the illicit finance risks posed by the A7 Network's Sub-Agents and the need to prevent it from accessing the U.S. financial system. None of the special measures set out in 31 U.S.C. 5318A —special measures one through five—would effectively address the illicit finance threat posed by the A7 Network's Sub-Agents. [ 78 ] Any additional recordkeeping, information collection, or reporting requirements, as described in 31 U.S.C 5318A(b)(1)-(4) , would be insufficient to guard against the risks posed by covered financial institutions processing transmittals of funds involving the A7 Network's Sub-Agents. Those special measures would allow such transfers to continue to benefit illicit actors connected to Russian illicit finance and Iranian sanctions evasion. Further, prohibiting or placing conditions upon the opening or maintaining in the United States of correspondent accounts or payable-through accounts for or on behalf of the A7 Network's Sub-Agents, as described in 31 U.S.C 5318A(b)(5) would be similarly inadequate. Neither prohibiting nor imposing conditions on such accounts would safeguard the U.S. financial system to the same degree as prohibiting transmittals of funds, as such a special measure would not address the movement of funds outside of a strict correspondent or payable-through relationship, for example, through the movement of funds outside the traditional banking relationship, including because the types of CVC transactions, namely A7A5-related transactions (which are an integral part of the A7 Network's business model), do not rely on the correspondent banking system. FinCEN therefore assesses that such a prohibition is the most appropriate special measure to protect the U.S. financial system.

D. Whether the Proposed Prohibition Should Be Imposed by Order or Regulation

Pursuant to section 9714, the Secretary may impose specified special measures, including a prohibition on certain transmittals of funds, “by order, regulation or otherwise as permitted by law.” In determining the appropriate approach in this instance, FinCEN considered imposing special measures by order or regulation, taking into account the nature of the underlying threat, and determined that proceeding by an NPRM is the most appropriate course of action, as that approach appropriately balances the risks posed by the A7 Network, with the interest in ensuring that covered financial institutions have an opportunity to on the proposed mechanisms through which FinCEN will identify Sub-Agents (as discussed below).

A copy of this NPRM will be published in the Federal Register . To the extent the A7 Network's Sub-Agents or parties have information relevant to this NPRM, they may submit it to FinCEN at .

V. Section-by-Section Analysis

The goal of this proposed rule is to combat and deter illicit activity, including Russian and Iranian sanctions evasion through the A7 Network's Sub-Agents, and to prevent the A7 Network's Sub-Agents from using the U.S. financial system to enable illicit financial activity. The subsections below the respective portions of the proposed rule, which is separately presented in Section IX. Importantly, nothing in this NPRM should be construed to modify, impair, or otherwise affect any requirements or obligations to which a covered financial institution is subject pursuant to the BSA, including, but not limited to, the filing of Suspicious Activity Reports, or other applicable laws or regulations, such as the sanctions administered and enforced by OFAC.

The term “A7 Network” means the core grouping of entities and persons involved in the operation of a Russian-Kyrgyzstan based sanctions evasion and money laundering network including: A7 LLC, A71 LLC, A7 Agent LLC, Old Vector LLC, Garantex, Grinex, InDeFi Bank, Mendeleev, Ilan Shor, and PSB, and any other persons whose property and interests in property have been blocked, by designation, order, or by operation of law, in light of their connection to the A7 Network. [ 79 ]

2. A7 Network Sub-Agents

The proposed rule would define the A7 Network Sub-Agents as including, but not limited to, the following: Galadriel Trading FZCO, Gimli Trade LLC-FZ, Hydrofusion Resources FZ-LLC, Pearl Bridge, Power Sphere LLC-FZ, and Sigizmund FZCO, and any other entity identified by FinCEN as a Sub-Agent of the A7 Network.

As suggested in this definition, to facilitate identifying entities that are ( printed page 63218) deemed Sub-Agents of the A7 Network, FinCEN would be prepared to provide—through secure means—covered financial institutions with additional information regarding known A7 Sub-Agents, as appropriate, and proposes limiting the obligation on covered financial institutions to prohibit certain transmittals only as to those entities identified on that list. Specifically, FinCEN would that list with covered financial institutions through FinCEN's “FI-Portal,” a secure messaging system that FinCEN and covered financial institutions utilize to securely exchange information, as appropriate. That list will be updated periodically, both to add additional Sub-Agents as well as to remove Sub-Agents. Given the nature of the A7 Network and its operations (as discussed above), FinCEN is opting to securely provide this list only to covered financial institutions, as FinCEN has assessed that a broader public distribution of the list would undermine the purposes of the proposed rule—allowing the A7 Network to circumvent the proposed special measure through additional and new Sub-Agents.

Importantly, as proposed in this NPRM, that list would identify known Sub-Agents, for the purposes of compliance with the proposed special measure, and covered financial institutions would only be prohibited from engaging in certain transmittals of funds involving those Sub-Agents. Covered financial institutions would not, however, be prohibited from disclosing that, in the context of any particular transaction, they have declined to proceed with the transaction because of party has been identified on FinCEN's list. Rather, as discussed below covered financial institutions would be required to affected persons associated with the transmittal of funds with which the covered financial institution maintains a direct commercial relationship.

And, as discussed below, should an entity seek to challenge being identified as a Sub-Agent, FinCEN has set out a process by which the aggrieved party may petition for reconsideration of their inclusion on the list. Should an aggrieved identified Sub-Agent successfully challenge the determination, FinCEN would update the list accordingly.

3. Convertible Virtual Currency (CVC)

The term “convertible virtual currency (CVC)” means a medium of exchange that either has an equivalent value as currency, or acts as a substitute for currency, but lacks legal tender status. Despite having legal tender status in at least one jurisdiction, for the purpose of this NPRM, the A7A5 stablecoin is included as a type of CVC.

4. Covered Financial Institution

The term “covered financial institution” has the same meaning as “financial institution” in 31 CFR 1010.100(t) .

5. Trans...