{"id":8301,"date":"2026-10-01T12:00:00","date_gmt":"2026-10-01T09:00:00","guid":{"rendered":"https:\/\/legalbit.top\/en\/us-treasury-a7-network-sanctions-fincen-proposal\/"},"modified":"2026-10-26T01:18:26","modified_gmt":"2026-10-25T22:18:26","slug":"us-treasury-a7-network-sanctions-fincen-proposal","status":"publish","type":"post","link":"https:\/\/legalbit.top\/en\/us-treasury-a7-network-sanctions-fincen-proposal\/","title":{"rendered":"US Treasury Sanctions the A7 Network and FinCEN Proposes a Ban on Transfers Involving Its Sub-Agents"},"content":{"rendered":"\n\n
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On 1 October 2026 the US Treasury’s Office of Foreign Assets Control (OFAC) designated the A7 Network as a significant transnational criminal organization, and FinCEN proposed to ban transfers of funds involving its sub-agents. This news item covers what happened, what exactly would be prohibited and the timeline.<\/p>

Checked 25 October 2026.<\/p><\/div><\/section>

What happened<\/h4>

OFAC sanctioned the A7 Network, led by Ilan Shor, as part of Operation Economic Outcast. The network uses “sub-agents”, meaning companies in third countries that receive and pass on payments to hide sanctioned transactions. Treasury links the network to the ruble-backed token A7A5, issued by Old Vector LLC, and to Iran, including the crypto exchange Nobitex, which OFAC designated on 2 June 2026.<\/p>

Treasury gives figures. By the network’s own account, its volume exceeded 7.5 trillion rubles, about USD 91.5 billion, as of January 2026. According to FinCEN’s investigation, sub-agents processed more than USD 17 billion between January 2025 and June 2026.<\/p><\/div><\/div>

What FinCEN proposes<\/h4>

The proposal (docket FINCEN-2026-0265) relies on section 9714(a) of the Combating Russian Money Laundering Act. It would bar covered financial institutions from engaging in transmittals of funds involving any A7 sub-agent, meaning funds sent to or from a sub-agent or to or from accounts or crypto addresses it administers. Institutions could reject some crypto transfers. They would have to notify affected counterparties and apply risk-based due diligence and screening, and FinCEN would share the list of sub-agents through a secure portal.<\/p>

The draft names six companies, including Galadriel Trading FZCO, Gimli Trade LLC-FZ and Sigizmund FZCO. FinCEN also issued an alert with red flags of suspicious activity.<\/p><\/div><\/div>

What happens next<\/h4>

This is a proposal, not a final rule. Comments are due 30 days after publication in the Federal Register, which means around early November 2026. Please check the exact date in the published version.<\/p><\/div><\/div>

What businesses should do<\/h4>

Property of the A7 Network in the US or under the control of US persons is blocked, as are companies owned 50 percent or more by blocked persons. Persons outside the US risk sanctions if they provide funds or services to blocked persons. Payment and crypto companies that handle ruble settlements, intermediaries in third countries or the A7A5 token should check counterparties and payment chains. We covered AML risks of accepting crypto payments in our article on crypto payments for business<\/a>.<\/p><\/div><\/div>

Primary sources<\/h4>