FinCEN proposes cutting A7's Sub-Agents off from US finance, with the full list going only to the institutions that must enforce it

On 1 October 2026 OFAC added 'A7 NETWORK' to the SDN List as a transnational criminal organization under E.O. 13581; the entry gives Russia, Kyrgyzstan, Nigeria and Zimbabwe as locations and no addresses. Treasury announced a parallel FinCEN action the same day, published on 5 October as a notice of proposed rulemaking at 91 FR 63208 (RIN 1506-AB77, docket FINCEN-2026-0265). Under section 9714(a) of the Combating Russian Money Laundering Act, as amended by section 6106(b) of the FY2022 NDAA, FinCEN finds that transactions involving any company operating outside the United States that is controlled by the A7 Network, which it calls a 'Sub-Agent', are a class of transactions of primary money laundering concern in connection with Russian illicit finance. It proposes to prohibit covered financial institutions from any transmittal of funds involving a Sub-Agent, including to or from any account or CVC address administered by or on behalf of one, and treats the ruble-backed A7A5 stablecoin as CVC for that purpose. The designation is in force; the prohibition is a proposal, with comments due by 4 November.

The class is defined by control; the obligation is defined by a list the public will not see. The proposed rule defines Sub-Agents as 'including, but not limited to' six named entities (Power Sphere LLC-FZ, Hydrofusion Resources FZ-LLC, Gimli Trade LLC-FZ, Galadriel Trading FZCO, Sigizmund FZCO and Pearl Bridge, all described as UAE-based) and 'any other entity identified by FinCEN'. Covered institutions would have to refuse only the entities on a list FinCEN would send them through its FI-Portal once a final rule issues, updated as Sub-Agents are added or removed. FinCEN's stated reason for not publishing it: broader distribution would let the network get round the measure by setting up new Sub-Agents. The NPRM puts the network at hundreds of Sub-Agents, formed, acquired or partnered in jurisdictions such as Hong Kong, Indonesia, the Kyrgyz Republic, the Seychelles, Türkiye and the UAE, with accounts at about 435 financial institutions in at least 83 countries as of June 2026. It notes a UK designation of Gimli Trade on 18 December 2025; none of the six appears among the entries OFAC added on 1 October.

Two consequences follow from the text. A bank, exchange or payment firm outside the United States has no public list to screen against beyond those six names. And a listed company would learn of its status from the payment chain rather than from FinCEN: a US institution that stops a prohibited transfer must notify the affected persons with which it has a direct commercial relationship, and is not barred from saying the reason is FinCEN's list. A company identified as a Sub-Agent may petition FinCEN in the first instance, arguing insufficient grounds or changed circumstances; FinCEN would decide in writing and update the list. For crypto, the rule provides for rejecting incoming CVC from Sub-Agent addresses, while FinCEN concedes there are few, if any, readily available ways to reject such transfers before they arrive.

'Covered financial institution' takes the Bank Secrecy Act meaning in 31 CFR 1010.100(t), and FinCEN's impact table counts casinos or card clubs among the 347,926 institutions the rule would reach, putting that category at 1,304 on the basis of an industry count of commercial casinos. FinCEN expects about 35,000 institutions to bear more than a de minimis burden. Its figures for the network: Sub-Agents processed more than 17 billion in USD-denominated transactions between January 2025 and June 2026; more than 180 entities processed A7A5 transactions worth at least USD 179.1 billion between February 2025 and June 2026; and one Sub-Agent and a sister company received nearly USD 140 million from entities involved in Iranian sanctions evasion between July 2023 and October 2025. The definition-based reach recalls the successor clause in the Huione action (Signal 011), with one difference: there the class was a fallback for rebrands, here it is the target from day one. A7 joins the settlement network designated under the same executive order in Signal 022, and its Türkiye formations bear on the corridor logged in Signals 021 and 024.