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nid 95508
Oct 01, 2026
pdonofrio@vixio.com
US Track 2
U.S. Department of the Treasury
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2017 charsUS Department of the Treasury Takes Action Against A7 Network Sanctions Evasion Scheme
On October 1, 2026, the U.S. Department of the Treasury announced unprecedented action against the A7 Network, a shadow banking network with ties to Russia used by Iran to evade sanctions. The Financial Crimes Enforcement Network (FinCEN) proposed a rule prohibiting fund transmittals involving the A7 Network's Sub-Agents and issued an alert to help financial institutions detect suspicious activity. The Office of Foreign Assets Control (OFAC) designated the A7 Network as a significant transnational criminal organization.
The A7 Network operates as a parallel financial system designed to disguise sanctioned or illicit payments as ordinary commercial activity. According to the Treasury, the network processes more than 2,000 transactions daily, with transaction volumes exceeding 7.5 trillion rubles (approximately $91.5 billion), representing roughly 13 percent of Russia's 2025 foreign trade transactions. FinCEN identified that A7 Network Sub-Agents processed more than $17 billion between January 2025 and June 2026. The network facilitates transactions for Iran's Islamic Revolutionary Guard Corps, Iranian proxies including Hamas, and other illicit actors. Specific examples include transactions involving Iran's shadow fleet and weapons procurement efforts, with one Sub-Agent receiving nearly $140 million from Iranian sanctions evasion entities.
The network, led by sanctioned criminal Ilan Mironovich Shor, uses falsified trade documents and misleading goods descriptions to obscure illicit transactions. OFAC's designation blocks all A7 Network property and interests in the United States and prohibits U.S. persons from engaging in transactions involving the network or its Sub-Agents. The notice of proposed rulemaking, issued under the Combating Russian Money Laundering Act, opens a 30-day public comment period following Federal Register publication. FinCEN's alert provides red flags for identifying A7 Network activity, and financial institutions must report suspicious transactions to OFAC.
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1561 charsUS Department of the Treasury Takes Action Against A7 Network Sanctions Evasion
On October 1, 2026, the US Department of the Treasury announced a series of financial crime- and sanctions-oriented actions taken against the "A7 Network," a shadow banking network with ties to Russia and used by Iran to evade sanctions. The actions were taken by two sub-agencies of the Treasury: the US Financial Crimes Enforcement Network (FinCEN) and US Office of Foreign Assets Control (OFAC).
According to the Treasury, the A7 Network processes more than 2,000 transactions daily, with transaction volumes exceeding US$91.5bn, representing roughly 13 percent of Russia's 2025 foreign trade transactions. Furthermore, it identified that A7 Network sub-agents processed more than US$17bn in transactions between January 2025 and June 2026.
FinCEN issued a proposed rule prohibiting fund transmittals involving the A7 Network's sub-agents, as well as issuing an alert to assist financial institutions in detecting suspicious activity linked to the network. Interested parties my submit comments on the proposed rule up to 30 days after its publication in the Federal Register at this link .
Concurrently, OFAC designated the A7 Network as a transnational criminal organization (TCO) due to its operation as a parallel financial system designed to disguise sanctioned or illicit payments as ordinary commercial activity. As a result of the new designation, all US-based property and interests of the A7 Network are blocked, and US individuals and entities are generally prohibited from engaging in transactions with it, unless expressly authorized by OFAC.