The US Treasury has put a label on a network it says moves money for America’s enemies. The A7 Network, launched in September 2024 by the fugitive Moldovan oligarch Ilan Shor and Promsvyazbank, Russia’s state-owned defense bank, has been designated a significant transnational criminal organization. The move targets both fiat payments and a ruble-backed token that has moved billions.
The OFAC Designation and FinCEN Proposal
On Thursday, OFAC made its designation. FinCEN then put forward a proposal to bar transfers tied to the network’s Sub-Agents, the firms it employs to dress up sanctioned payments as routine commerce. The proposed rule would apply to convertible virtual currency as well as fiat.
Token Transactions
Between February 2025 and June 2026, more than 180 addresses moved at least $179.1 billion in A7’s ruble-backed A7A5 token. FinCEN has said these transactions historically passed almost entirely through the sanctioned exchanges Garantex and Grinex. The token, A7A5, is backed by the ruble and comes from Old Vector, a Kyrgyz registration, running on both Tron and Ethereum networks with deposits kept at Promsvyazbank.
The Sub-Agent Network
A7 has built up a network of hundreds of Sub-Agents with accounts at roughly 435 financial institutions across at least 83 countries. The accounts handled more than $17 billion between January 2025 and June 2026. Workers manage these accounts from Moscow through custom virtual private networks that disguise the activity as coming from Dubai, Hong Kong or Bishkek.
“You will lose access to the U.S. financial system” if you facilitate illicit finance for America’s adversaries.
Sanctioned Connections
A Sub-Agent handled dealings with entities connected to Iran’s hidden fleet of tankers, taking in nearly $140 million from companies caught up in Iranian sanctions evasion. A separate Sub-Agent forwarded roughly $1.6 million to an enterprise tied to weapons purchases. The network is tied to Nobitex, the Iranian exchange marked by Treasury in June, and to the laundering of funds from North Korean exchange break-ins.
The Network’s Scale
Launched in September 2024, the network now says it processes over 2,000 transactions daily, backed by a stated historical total of 7.5 trillion rubles, which works out to about $91.5 billion. That figure amounts to roughly an eighth of Russia’s foreign trade from the previous year.
The Rule’s Reach
The transmittal-of-funds prohibition is the sixth measure chosen by FinCEN under section 9714 of the Combating Russian Money Laundering Act. TRM Labs points out that the fifth measure, which restricts correspondent accounts, would have failed to cover A7A5 transactions, since they move outside correspondent banking entirely.
This rule proposal would apply to around 348,000 institutions, including crypto exchanges. Comments must be submitted within 30 days of the rule’s publication in the Federal Register.
Recent Developments
Since a reported hack at Grinex in April, FinCEN says supply has consolidated into unhosted wallets, which the agency reads as a possible move away from sanctioned venues.
The UK’s National Crime Agency issued an alert in August, while the EU has previously sanctioned parts of the network.
The Warning
Treasury Secretary Scott Bessent said the warning was aimed directly at anyone caught handling money for America’s adversaries. “You will lose access to the U.S. financial system” if you facilitate illicit finance for America’s adversaries, he said.
This move touches both fiat and crypto, and its reach extends across more than 83 countries. The network’s design depends on making sanctioned payments look like ordinary trade, and FinCEN’s suggested rule is designed to shut that door.
The combined effort of the designation and the proposed rule is designed to halt that machine.
Where the paper stands
The paper backs neither the Treasury’s crackdown nor the A7 Network’s operations, but it supports keeping open the channels for diplomacy and trade even while sanctions are applied. The move targets both fiat payments and a ruble-backed token that has moved billions, and it reaches across hundreds of financial institutions across more than 83 countries. The paper’s position is clear: focus at home, and keep the channels open for trade, diplomacy and compromise.
FinCEN’s proposed rule would apply to convertible virtual currency as well as fiat, and it would affect roughly 348,000 institutions, including crypto exchanges. The rule is designed to bar transfers tied to the network’s Sub-Agents, the firms it employs to dress up sanctioned payments as routine commerce. Comments must be submitted within 30 days of the rule’s publication in the Federal Register.
The paper would want Treasury and FinCEN to proceed with care, mindful of the scale of the network and the reach of the rule. The reader should watch for how the sanctions play out in practice, and whether the channels for trade and diplomacy remain open despite the crackdown.
Source material: “US Designates Russia's A7 Network as Transnational Criminal Organization,” Decrypt.
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