FinCEN proposes barring US banks from A7 Network Sub-Agent transfers

The Financial Crimes Enforcement Network (FinCEN) proposed on Monday to prohibit U.S. financial institutions from processing any transmittal of funds involving the Sub-Agents of the A7 Network, a Russia- and Kyrgyzstan-based sanctions evasion and money laundering service it has found to be a class of transactions of primary money laundering concern. The notice of proposed rulemaking was published in the Federal Register of 5 October 2026 (Vol. 91, No. 191, Proposed Rules, p. 63208) under RIN 1506–AB77, docket FINCEN–2026–0265, amending 31 CFR Part 1010.

FinCEN acts under section 9714(a) of the Combating Russian Money Laundering Act (Pub. L. 116–283), as amended by section 6106(b) of the National Defense Authorization Act for Fiscal Year 2022 (Pub. L. 117–81), which allows the Treasury Secretary to prohibit certain transmittals of funds involving a class of transactions found to be of primary money laundering concern in connection with Russian illicit finance. The A7 Network is an OFAC-sanctioned transnational criminal organization that FinCEN describes as a global wholesale sanctions evasion and money laundering service with ties to Russia, leveraged by a wide range of illicit actors including Iran and its terrorist proxies; it was formally launched in September 2024 as a purpose-built mechanism to evade Western sanctions.

The finding covers any company operating outside the United States that is controlled by the A7 Network — the Sub-Agents — which FinCEN says obfuscate the Russian or otherwise sanctioned party in the payment chain, commonly causing financial institutions to become unwitting accomplices. The proposed rule would define the Sub-Agents as including, but not limited to, Galadriel Trading FZCO, Gimli Trade LLC–FZ, Hydrofusion Resources FZ–LLC, Pearl Bridge, Power Sphere LLC–FZ and Sigizmund FZCO, plus any other entity FinCEN identifies.

A network built on Sub-Agents

• As of June 2026, the A7 Network had created or acquired hundreds of Sub-Agents with bank accounts at approximately 435 financial institutions in at least 83 countries.
• As of January 2026, it claimed to process more than 2,000 transactions per day, with a historical total volume of more than 7.5 trillion rubles, the equivalent of USD 91.5 billion — nearly 13 percent of Russia’s 2025 foreign trade.
• Between 30 September 2024 and 22 July 2025, its clients purchased more than 3,200 bills of exchange worth more than USD 25 billion.
• The first Sub-Agents were established in the Kyrgyz Republic, followed by expansion across Central and East Asia, Africa, Europe and the Middle East, with offices opened in Nigeria and Zimbabwe.

Named Sub-Agents and illicit flows

FinCEN’s analysis of public and non-public information quantified activity at several identified Sub-Agents:

• Galadriel Trading FZCO, a Dubai-based agricultural trader, processed more than USD 946,000 between May and July 2025.
• Hydrofusion Resources FZ–LLC processed USD 3.6 million between May and June 2025 in funds tied to Russian trade-based money laundering.
• Gimli Trade LLC–FZ, sanctioned by the United Kingdom on 18 December 2025, processed USD 1.5 million between May and June 2025.
• Sigizmund FZCO processed USD 41,000 tied to Russian sanctions evasion, including the acquisition of dual-use goods.
• One Sub-Agent received nearly USD 140 million from entities involved in Iranian sanctions evasion; another transferred approximately USD 1.6 million between January 2024 and September 2025 to a company linked to Iranian sanctions evasion and weapons procurement.

The network also runs the A7A5 ruble-backed stablecoin on the Tron and Ethereum blockchains, issued by Kyrgyzstan-based Old Vector LLC, with each coin backed by ruble deposits held at PSB.

What the prohibition would require

Proposed section 1010.668(b)(1) would bar covered financial institutions from engaging in a transmittal of funds involving any A7 Network Sub-Agent, including from or to any account or convertible virtual currency address administered by or on behalf of one. Institutions could reject CVC originating at such addresses, would have to notify affected persons with which they maintain a direct commercial relationship, apply risk-based due diligence, and block and report to OFAC any blocked accounts or transactions. FinCEN would share the list of known Sub-Agents only with covered institutions through its secure “FI-Portal,” updated periodically, and entities could petition for removal via Globalinvestigations@fincen.gov.

Comment period and estimated cost

FinCEN is requesting comments for 30 days after publication; comments must be received by 4 November 2026. The agency estimates a total annual burden of approximately 139,700 hours and a total annual cost of approximately USD 17,740,000, against 347,926 potentially affected covered financial institutions and about 34,793 expected respondents. FinCEN consulted the Department of Justice, the Department of State, the Federal Reserve, the FDIC, the SEC, the CFTC, the OCC and the NCUA; none objected.

The proposal matters beyond correspondent banking: because it reaches any transmittal involving a Sub-Agent, it would also cover digital-asset and payment flows, forcing banks, crypto exchanges and payment firms to screen against a confidential FinCEN list and to reject or block transfers rather than merely report them.

Source: Federal Register, Vol. 91, No. 191, 5 October 2026, Proposed Rules, p. 63208 (official reference: 2026–20371).