The U.S. Financial Crimes Enforcement Network proposed prohibiting covered financial institutions from sending or receiving funds, including convertible virtual currency, in transactions involving identified A7 Network Sub-Agents. FinCEN found such transactions to be a class of transactions of primary money laundering concern linked to Russian illicit finance and also issued an alert to help financial institutions detect and report related suspicious activity. The action targets a shadow banking network that obscures payments for sanctioned Russian and Iranian actors and other illicit clients through third-country companies, trade-based money laundering and digital assets. The proposed prohibition would cover transfers to or from an identified Sub-Agent or any account or convertible virtual currency address administered on its behalf. Covered financial institutions would have to apply risk-based screening, notify affected parties with which they have a direct commercial relationship when a transfer is prohibited or blocked, and document that notification. FinCEN plans to provide and periodically update a secure list of known Sub-Agents. The proposal also provides a route to reject and return certain incoming digital asset transfers where blocking is not otherwise required, while existing Office of Foreign Assets Control blocking and reporting obligations would take precedence. FinCEN identified hundreds of Sub-Agents with accounts at about 435 financial institutions in at least 83 countries and assessed that they processed more than USD 17 billion between January 2025 and June 2026. The accompanying alert highlights indicators involving shell companies, layered payment routes, falsified or artificial intelligence-altered trade documents, A7-linked digital infrastructure and exposure to the ruble-backed A7A5 token or related wrapped tokens. FinCEN found that more than 180 entities processed at least USD 179.1 billion in A7A5 transactions between February 2025 and June 2026.

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