FinCEN has published a proposed rule that would designate transactions involving companies controlled by the A7 Network’s sub-agents as a class of primary money-laundering concern tied to Russian illicit finance and prohibit certain related fund transfers by covered financial institutions. The notice, published in the Federal Register on Oct. 5, is a proposal rather than an effective prohibition.
The action puts the focus on the network’s sub-agent layer, which U.S. authorities say has been used to move payments through companies outside Russia while concealing their sanctioned or illicit origins.
Proposed transfer prohibition
Under the notice of proposed rulemaking, FinCEN found that transactions involving companies controlled by A7 Network sub-agents constitute a class of primary money-laundering concern. It proposed a special measure that would bar covered financial institutions from carrying out certain fund transfers involving those companies.
The published notice does not mean the restriction is already in force. Its immediate effect is to open the rulemaking process around the proposed measure and FinCEN’s underlying finding.
Third-country payment routes
The Treasury Department said the targeted sub-agents allegedly disguise sanctioned or otherwise illicit payments through third-country companies, falsified trade documents and misleading descriptions of goods. That structure, according to Treasury, is intended to obscure the nature of the transactions and the parties involved.
Public comments on the proposal are due 30 days after its Federal Register publication. The consultation will determine the formal record before FinCEN decides whether to finalize, alter or withdraw the proposed restriction.
Transaction scale and Iran links
FinCEN assessed that A7 Network sub-agents processed more than $17 billion in aggregate U.S.-dollar-denominated transactions from January 2025 through June 2026. The agency said the activity facilitated transactions involving sanctioned Russian persons, Iranian sanctions evasion and other illicit actors.
Treasury cited specific Iran-related transfers in outlining its case. One A7 sub-agent transferred about $1.6 million to a company linked to Iranian sanctions evasion and weapons procurement, it said. Another sub-agent and a sister company received nearly $140 million from entities involved in Iranian sanctions evasion.
The proposed rule therefore reaches beyond named A7 Network entities to companies under the control of its sub-agents, reflecting FinCEN’s assessment that those intermediaries are central to the alleged payment flows.
