OFAC Designates A7 Network as a Transnational Criminal Organization as FinCEN Proposes Special Measure and Issues Alert

OFAC imposed blocking sanctions on 1 entity, the A7 Network (listed in Russia, Kyrgyzstan, Nigeria and Zimbabwe), under its Transnational Criminal Organizations program, tagged [TCO], for operating a Russia-linked shadow banking network used to evade sanctions. All property of the network, including transactions involving Sub-Agents acting for it, is now blocked. The network moves payments for Russian and other sanctioned customers through "Sub-Agent" companies in third countries that appear as the paying party on trade documents, and Iran (including its central bank and the IRGC) has used it. FinCEN issued a finding and proposed rule under section 9714(a) of the Combating Russian Money Laundering Act, treating transactions involving any foreign company controlled by the network as a class of primary money laundering concern. The proposal would prohibit transmittals of funds involving the Sub-Agents. FinCEN also issued Alert FIN-2026-Alert007, which: asks institutions to cite the key term "FIN-2026-A7NETWORK" in SARs reports that, as of June 2026, the network ran hundreds of Sub-Agents with accounts at about 435 institutions in at least 83 countries reports that more than 180 entities processed at least $179.1 billion in A7A5 ruble-backed stablecoin transactions between February 2025 and June 2026 lists red flags covering Sub-Agent use, invoice falsification and digital asset abuse