OFAC targets the A7 network: what the A7A5 token means for onchain screening

What happened

On 1 October 2026 the US Treasury took three linked actions against the A7 network, which it calls "a shadow banking network with ties to Russia used by the Iranian regime to evade sanctions".1

• OFAC designated the A7 network as a significant transnational criminal organisation, naming its leader, Ilan Shor, a sanctioned and convicted fraudster.1
• FinCEN proposed a special measure that would prohibit funds transfers involving A7's "sub-agents": third-country companies that receive and send payments for the network.1, 2
• FinCEN issued an alert giving banks and other firms red flags for spotting A7 activity.3

The numbers are large. FinCEN found that A7's sub-agents processed more than $17 billion between January 2025 and June 2026.1 By its own account, as of January 2026 A7 processed more than 2,000 transactions a day, with a total volume of more than 7.5 trillion roubles (about $91.5 billion), roughly 13% of Russia's 2025 foreign trade.1

Treasury also links the network to Nobitex, the Iranian virtual asset exchange OFAC designated on 2 June 2026, and to North Korean hacks of virtual asset firms.1

The rules behind it

Two separate regimes apply, and virtual asset firms need to treat them differently.

OFAC sanctions apply now. Once a person is designated, any of their property in the US or under the control of a US person is blocked and must be reported to OFAC. The same applies to entities owned 50% or more by blocked persons.1 This builds on OFAC's 14 August 2025 designation of A7 LLC and Old Vector LLC, the issuer of A7A5.1, 4

The FinCEN measure is only a proposal. FinCEN is using section 9714(a) of the Combating Russian Money Laundering Act, which lets Treasury impose section 311-style special measures over Russian illicit finance, or ban certain funds transfers outright.2 As drafted, the rule would:

• prohibit "covered financial institutions" from any transmittal of funds to or from an A7 sub-agent, including to or from virtual asset addresses held for one2
• treat the A7A5 stablecoin as convertible virtual currency, and define "transmittals of funds" to include virtual assets2
• require a risk-based approach to due diligence, including screening for sub-agents as originators, beneficiaries or references2

Covered financial institutions take the Bank Secrecy Act definition, which includes money services businesses, so US-registered virtual asset exchanges and kiosk operators fall within scope.2 The proposal names six UAE-based sub-agents, listed in the FAQs below. Once the rule is final, FinCEN says it is prepared to share more information on known sub-agents with covered institutions through a secure channel.2

Who it affects

The common thread is that A7A5 exposure, direct or indirect, is now a red flag in the US, a banned asset in the EU and a sanctions concern in the UK.

Timeline

1. 5 April 2022

   OFAC designates the Russian virtual asset exchange Garantex.4

2. 14 August 2025

   OFAC re-designates Garantex and designates its successor Grinex, A7 LLC, A71 LLC, A7 Agent LLC and Old Vector, the Kyrgyz issuer of A7A5.4

3. 23 October 2025

   The EU adopts its 19th sanctions package. Its ban on transactions in A7A5 applies from 25 November 2025.5

4. 2 June 2026

   OFAC designates Nobitex, the Iranian virtual asset exchange Treasury now links to A7.1

5. 31 August 2026

   HM Treasury and the National Crime Agency issue the UK's first nationwide alert on A7.6

6. 1 October 2026

   OFAC designates the A7 network as a transnational criminal organisation. FinCEN issues its alert and proposes the sub-agent transmittal ban.1, 2, 3

7. 4 November 2026Upcoming

   Comments on FinCEN's proposal close. It was published on 5 October 2026.2

After that, FinCEN can issue a final rule. Its date is not yet known.

What compliance teams should do now

KYT and screening

• Confirm your blockchain analytics provider flags A7A5 and tokens wrapped from it.3 We also recommend checking for addresses tied to Garantex, Grinex and Old Vector. Then look back for past exposure, direct and indirect.
• Add the six named sub-agents to your counterparty and name screening now. Screen them as originator, beneficiary and in payment references, as the proposal requires.2

KYC and customer risk

• Re-review customers whose profiles involve trade with Russia, Iran, the UAE, the Kyrgyz Republic or other Central Asian hubs.
• Treat large stablecoin payments for commodities such as oil, dual-use goods or military items as a red flag.3
• For OTC desks and payment firms you onboard, check for sudden volume growth, thin online presence and short operating history.3

Investigations

• Add FinCEN's document red flags to your case checklist: non-standard invoices, vague goods descriptions, implausible prices, AI-altered documents and stray Cyrillic text.3
• Check logins against the IP ranges and email domains listed in FinCEN's alert.3

Reporting

• In the US, use the key term FIN-2026-A7NETWORK in SAR field 2 and in the narrative.3
• Report any blocked property to OFAC.1
• Decide whether to comment on FinCEN's proposal before 4 November 2026.2

What is still open

How Cogentic helps

A7-style evasion only shows up when identity, transaction and trade evidence are looked at together. A customer's KYC profile, their A7A5 exposure and an odd invoice can each look minor on their own. Cogentic brings KYC, KYT, investigations and reporting into one workflow, on the providers you already use. Alerts become cases with the evidence attached, ready for a SAR.