US Designates Russia's A7 Network as Transnational Criminal Organization

In brief

• OFAC has designated the A7 Network a transnational criminal organization, and FinCEN has proposed barring U.S. institutions from any transfer involving its front companies.
• The proposed rule covers convertible virtual currency, not just fiat.
• FinCEN says more than 180 entities moved at least $179.1 billion in A7's ruble-backed A7A5 token between February 2025 and June 2026.

The U.S. Treasury has moved against the A7 Network, a Russian shadow banking operation it says Iran and the Islamic Revolutionary Guard Corps have used to evade sanctions, with a proposed rule that would cut its front companies off from American finance, including in crypto.

The Office of Foreign Assets Control designated the network a significant transnational criminal organization on Thursday, listing it with addresses in Russia, Kyrgyzstan, Nigeria and Zimbabwe. The Financial Crimes Enforcement Network separately proposed prohibiting transfers involving what it calls the network's Sub-Agents, the companies it uses to make sanctioned payments look like ordinary trade.

FinCEN is acting under section 9714 of the Combating Russian Money Laundering Act, which offers six special measures, and picked the sixth, a transmittal-of-funds prohibition. The fifth, which restricts correspondent accounts, would have left a hole, blockchain intelligence firm TRM Labs noted, based on its research into the network: A7A5 transactions move outside correspondent banking entirely, and FinCEN considers them integral to the business model. The sixth measure reaches fiat and crypto alike, and the proposed rule would bind roughly 348,000 institutions, crypto exchanges among them.