FinCEN and OFAC target the A7 Network and key Iranian industries 

On October 1, 2026, the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) announced a number of actions targeting the A7 Network, an alleged “wholesale sanctions evasion and money laundering service” based in Russia that operates through a network of third-country entities to move funds for sanctioned actors.[1] FinCEN issued a proposed rule that would prohibit transmittals of funds involving any non-U.S. company that is controlled by the A7 Network (the Proposed Rule)[2] and published an alert to provide guidance on detecting and reporting suspicious activity related to the A7 Network (the FinCEN Alert).[3] OFAC concurrently sanctioned the A7 Network as a transnational criminal organization (TCO), building on previous designations of several key A7 Network entities last year. 

Treasury characterized the actions targeting the A7 Network as part of the administration’s ongoing “Operation Economic Outcast” directed at the Iranian regime (described in our client update). According to Treasury, A7 has used its network of companies and agents to support Iranian oil sales and weapons procurement efforts and to facilitate billions of dollars in transactions on behalf of sanctioned persons in Russia, Iran, North Korea, and other jurisdictions. 

As the war with Iran enters its eighth month, Treasury continues to pile sanctions on top of sanctions to pressure the Iranian regime and cut off Iran’s access to funding and the global financial system. The same day as the designation of the A7 Network, OFAC issued two sectoral sanctions determinations pursuant to Executive Order (E.O.) 13902 targeting Iran’s automotive and rail sectors, which provide additional authority to sanction individuals or entities operating in those sectors (the Determinations).[4] While the Determinations generally expanded on OFAC’s existing authorities (and global financial institutions have broadly de-risked from Iran), the actions targeting the A7 Network may present more meaningful compliance challenges for financial institutions given A7’s sprawling global reach. 

Actions targeting the A7 Network

The A7 Network was established in Russia to serve as a sanctions-resistant payment service. The backbone of the network consists of three Russia-based companies (sanctioned by OFAC, the European Union, and the United Kingdom in 2025), which control or partner with hundreds of shell companies and other “sub-agents” in third countries to move funds across the global financial system. FinCEN found that the A7 Network’s sub-agents processed more than $17 billion between January 2025 and June 2026, aggregated globally, including through fiat currency, a ruble-backed stablecoin issued by the network (the A7A5 token), and sophisticated trade-based money laundering schemes. The network’s client base is alleged to include state actors such as North Korea, Iran, and Russia, as well as TCOs, ransomware actors, and terrorist groups. FinCEN stated that the A7 Network operates through hundreds of entities “that have established bank accounts at approximately 435 financial institutions in at least 83 countries.” 

FinCEN’s and OFAC’s actions targeting the A7 Network included:

• The Proposed Rule. FinCEN issued the Proposed Rule pursuant to its authority under the Combating Russian Money Laundering Act, which authorizes Treasury to impose one or more “special measures” – including restrictions on transmittals of funds – on any class of transaction that FinCEN identifies as being of “primary money laundering concern in connection with Russian illicit finance.” The Proposed Rule would identify transactions involving any A7 Network “Sub-Agent” (defined as any company operating outside of the United States that is controlled by the A7 Network) as a class of transaction of “primary money laundering concern” and would prohibit domestic financial institutions subject to the Bank Secrecy Act from engaging in any “transmittal of funds” involving any A7 Network Sub-Agent.[5] The “A7 Network” would be defined to include specified entities involved in the operation of the network. The definition of “Sub-Agents” would be broader and include entities publicly identified by FinCEN, as well as entities on a non-public list that would be shared with financial institutions upon request through FinCEN’s secure “FI-Portal.” Financial institutions would be expected to take a risk-based approach to determine what, if any, other due diligence measures they should adopt to guard against prohibited transactions. As described below, transactions for the benefit of the A7 Network and persons acting on the network’s behalf are separately prohibited following OFAC’s designation of the group.
• The FinCEN Alert. The Alert describes the operations of the A7 Network and provides guidance for financial institutions to identify and report suspicious activity relating to the network. According to FinCEN, the A7 Network uses a wide range of techniques and typologies to evade sanctions and anti-money laundering controls, including “falsified trade documents, falsified import-export records, and misleading goods descriptions to make sanctioned or illicit payments appear to be ordinary commercial activity.” The FinCEN Alert provides a list of potential red flags relating to the network’s activities and instructs financial institutions to reference the alert in suspicious activity reports submitted to the agency. 
• OFAC’s designation of the A7 Network as a TCO. While OFAC previously designated three of the key Russia-based operators of the A7 Network and other core actors, as well as the Kyrgyz Republic-based issuer of A7’s stablecoin, OFAC has now designated the A7 Network as a sanctioned TCO, which blocks all property and interests in property of the A7 Network, including transactions involving persons acting on the group’s behalf (e.g., Sub-Agents of the network). OFAC identified and designated certain specific A7 Network Sub-Agents but, unlike FinCEN, has not indicated that it will share a full list (meaning standard sanctions-related due diligence expectations would continue to apply to identify prohibited transactions). 

Other actions targeting Iran

The actions taken against the A7 Network reflect Treasury’s broader actions to target Iran’s “shadow banking networks” and access to the global financial system. As part of these efforts, OFAC continues to emphasize the risk of secondary sanctions for any foreign financial institutions that engage in significant transactions for the benefit of the government of Iran or sanctioned Iranian persons. The agency issued a further reminder of this for foreign financial institutions through an alert published on October 5.[6]

Separately, on October 1, OFAC issued the Determinations pursuant to its authority under E.O. 13092, which authorizes OFAC, in consultation with the State Department, to impose sanctions on any person determined to operate in designated sectors of the Iranian economy. The Determinations add the “rail and automotive” sectors of Iran’s economy to the list of designated sectors, which already include Iran’s construction sector, mining sector, manufacturing sector, textiles sector, and financial sector. Sanctions imposed under the Determinations do not attach automatically and would be imposed on an individualized basis.