WASHINGTON-Today, as part of Operation Economic Outcast, the U.S. Department of the Treasury took unprecedented action against the A7 Network, a shadow banking network with ties to Russia used by the Iranian regime to evade sanctions.
- Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule that would prohibit transmittals of funds regarding transactions involving the A7 Network’s Sub-Agents.
- Additionally, FinCEN issued an Alert to help financial institutions detect and report suspicious activity related to the A7 Network.
- Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the A7 Network as a significant transnational criminal organization.
“Treasury is dismantling the financial infrastructure that allows Iran and other adversaries to evade sanctions, move illicit funds, and undermine the integrity of the global financial system,” said Secretary of the Treasury Scott Bessent. “Today’s action targeting A7 continues Treasury’s unprecedented efforts to isolate Iran and its financial enablers and sends a clear message that if you facilitate illicit finance for America’s adversaries, you will lose access to the U.S. financial system.”
The A7 Network was created and backed by U.S.-sanctioned persons in order to evade sanctions. It has developed a global web of Sub-Agents, companies that are purpose-built to disguise payments linked to sanctioned sectors and persons as ordinary commercial activity. The A7 Network has been leveraged by Iran, including Iran’s Islamic Revolutionary Guard Corps. Today’s actions build on the August 14, 2025 designation of several A7 Network entities, such as A7 LLC and Old Vector LLC, by exposing the broader network itself to U.S. sanctions.
THE A7 NETWORK’S FACILITATION OF RUSSIAN ILLICIT FINANCE: CREATING A PARALLEL FINANCIAL SYSTEM
As set out in the notice of proposed rulemaking, the A7 Network’s Sub-Agents are a constellation of companies based in third-country jurisdictions designed to receive and remit payments to facilitate transactions for the A7 Network. These Sub-Agents form a core layer of the A7 Network’s operational architecture as a purpose-built sanctions evasion and money laundering mechanism connected to Russian illicit finance and exploited by other illicit finance threat actors, including Iran. The public comment period will close 30 days after the NPRM is published in the Federal Register.
The A7 Network exploits the international financial system by leveraging Sub-Agents, falsified trade documents, falsified import-export records, and misleading goods descriptions to make sanctioned or illicit payments appear to be ordinary commercial activity. By its own account, as of January 2026, the A7 Network claimed to process more than 2,000 transactions a day with a total transaction volume of more than 7.5 trillion rubles, the U.S. dollar equivalent of $91.5 billion or approximately 13 percent of the Russian Federation’s 2025 foreign trade transactions.
Today’s notice of proposed rulemaking, issued pursuant to section 9714(a) of the Combating Russian Money Laundering Act, is not limited to Russian sanctions evasion. The same A7 Network Sub-Agents that enable Russian illicit finance created pathways for other actors, including the Central Bank of Iran, the IRGC, and Iran-backed terrorist organizations, to move funds through the international financial system. Beyond state actors, A7 Network Sub-Agents also catered to cybercriminals, including ransomware and procurement actors seeking to obtain restricted goods, to move funds through the international financial system. FinCEN’s investigation identified that the A7 Network’s Sub-Agents processed more than $17 billion between January 2025 and June 2026, aggregated globally.
In addition, A7 Network Sub-Agents have been used to facilitate Iranian oil sales and weapons procurement efforts. For example, one A7 Network Sub-Agent directly transacted with entities involved in Iran’s “shadow fleet”-the network of tankers, shipping companies, and front companies used to transport and sell Iranian oil in contravention of U.S. and international sanctions; that same A7 Network Sub-Agent and its sister company received nearly $140 million from entities involved in Iranian sanctions evasion. A separate A7 Network Sub-Agent transferred approximately $1.6 million to a company linked to Iranian sanctions evasion and weapons procurement efforts.
FINCEN ISSUING KEY INDICATORS OF A7 NETWORK ACTIVITY
FinCEN’s Alert will assist financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity and specifies a list of red flags to assist in identifying activity involving the A7 Network. The Alert describes the A7 Network’s use of foreign companies to facilitate its access to international payment systems.
FinCEN’s Notice of Proposed Rulemaking can be found here.
FinCEN’s Alert can be found here.
Today’s action follows the United Kingdom’s National Crime Agency’s August 31, 2026 Alert on A7 which describes the use of the A7 Network to facilitate sanctions evasion and illicit financial activity involving Russia and Iran.