U.S. Treasury Says A7 Network Agents Processed More Than $17 Billion
Key Facts
The U.S. Treasury Department said A7 network subagents processed more than $17 billion between January 2025 and June 2026, as part of Washington’s action against the network over its role in moving money through multiple financial and commercial channels. On October 1, 2026, the Office of Foreign Assets Control sanctioned A7, which Treasury described as a transnational criminal organization. On the same day, the U.S. Financial Crimes Enforcement Network proposed a rule prohibiting certain transfers involving the network’s subagents. The proposed measures place responsibility for managing the network’s risks at the center of oversight by the financial institutions through which payments pass. The steps follow an expansion in the agents’ activity and the reach of their accounts into institutions in many countries.
According to FinCEN estimates published in the Federal Register, the network created or acquired hundreds of subagents, who held accounts at about 435 financial institutions in at least 83 countries as of June 2026. This reach reflects the scale of the infrastructure used to make payments outside Russia through multiple institutions rather than relying on a single visible route. The notice described the agents’ transactions as a form of trade-based money laundering that relies on forged trade documents, inaccurate import and export records, and misleading descriptions of goods. FinCEN said these methods conceal the identity of the network and the sanctioned customer in the paperwork associated with the deals. The spread of accounts across different countries and institutions makes identifying links between parties a central part of the compliance challenge.
FinCEN says the network’s clients purchased more than 3,200 promissory notes with an equivalent value exceeding $25 billion between September 30, 2024, and July 22, 2025. The notes recorded the value within the A7 system, reducing the need for direct international bank transfers. After the balance was recorded, the network assigned a foreign subagent to appear as a contracting party or payer on invoices, sales agreements and payment instructions. The agency said this enabled payments through bank accounts outside Russia and SWIFT channels. The mechanism connects notes within the system with payments made through foreign banks, while presenting the agent as the visible party in the documents.
Treasury said the network claimed it was processing more than 2,000 transactions a day, with a total volume exceeding 7.5 trillion rubles in January 2026, equivalent to $91.5 billion by the department’s estimate. Treasury estimated that this stated volume equaled about 13% of Russia’s foreign trade transactions in 2025. These figures were attributed by the department to the network’s claims about its activity, while FinCEN said subagents processed more than $17 billion between January 2025 and June 2026. The British government also said A7 claimed to have settled transactions exceeding $86 billion during its first year of operation. The figures cover different periods and scopes, spanning a volume claimed by the network and official estimates of agent flows.
Regarding links to Iran, Treasury said subagent routes enabled money to be transferred to entities including the Central Bank of Iran, the Islamic Revolutionary Guard Corps and Iran-backed terrorist organizations. It said one agent dealt directly with entities linked to Iran’s shadow fleet, and that the company itself and a sister company received about $140 million from entities involved in evading Iranian sanctions. In a separate case, a Treasury statement said another subagent transferred about $1.6 million to a company linked to evasion of Iranian sanctions and weapons procurement efforts. Treasury did not specify the period for the payments totaling about $140 million or the transfer of about $1.6 million. As set out in the department’s statement, these cases illustrate the network’s use in routes linked to sanctioned parties or weapons procurement efforts.
Britain imposed sanctions on May 26, 2026, targeting the A7 network and individuals linked to it, and said the network exploited Kyrgyzstan’s financial systems to channel money into Russia’s war economy. On August 31, the National Crime Agency and the British government issued the first national alert on A7, aimed at helping the private sector counter sanctions evasion. FinCEN identified potential indicators of agent activity, including unusually high transaction volumes soon after a company’s formation, descriptions of goods inconsistent with a supplier’s business, and unusual payment routes. The indicators also included invoices forged or altered using artificial intelligence. The deadline for comments on FinCEN’s proposal was November 4, 2026, after the agency requested feedback on the proposed rule.