FinCEN proposes ban on funds transfers with A7 Network agents, naming six UAE firms

The US Financial Crimes Enforcement Network (FinCEN) proposed on 1 October to bar US financial institutions from handling funds transfers involving the "Sub-Agents" of the A7 Network, a Russia-linked payments service whose Sub-Agent companies hold bank accounts at about 435 financial institutions in at least 83 countries, according to its alert. The Treasury's Office of Foreign Assets Control (OFAC) designated the network the same day as a transnational criminal organisation, its recent actions notice shows. The proposal was published in the Federal Register on 5 October, with comments due by 4 November.

FinCEN is acting under section 9714(a) of the Combating Russian Money Laundering Act. It finds that transactions involving any Sub-Agent are a class of transactions of primary money laundering concern, the notice says. Covered financial institutions would be barred from transmittals of funds from or to a Sub-Agent, or from or to any account or virtual currency address administered for one. They would have to notify affected parties with which they have a direct commercial relationship and apply risk-based due diligence. FinCEN says it will give the list of Sub-Agents only to covered institutions, through a secure messaging system, and will update it to add and remove entities.

The Sub-Agents FinCEN names

The A7 Network claimed more than 2,000 transactions a day and about 7.5 trillion roubles, or about $91.5 billion, in historical volume as of January 2026, according to the Treasury release. The notice says Sub-Agents processed more than $17 billion between January 2025 and June 2026, and the alert says more than 180 entities handled at least $179.1 billion in A7A5, the rouble-backed token the network created, between February 2025 and June 2026.

The notice names six Sub-Agents, all in the United Arab Emirates and five of them in Dubai:

• Power Sphere LLC-FZ, an electronics supplier, which FinCEN says processed about $61 million between September 2023 and July 2025, tied to Russian trade-based money laundering and energy-sector procurement.
• Hydrofusion Resources FZ-LLC, an energy commodities trader, $3.6 million in May and June 2025.
• Gimli Trade LLC-FZ, a general trading firm, $1.5 million in May and June 2025. The UK sanctioned it on 18 December 2025.
• Galadriel Trading FZCO, an agricultural trader, more than $946,000 from May to July 2025.
• Sigizmund FZCO, a marketing and consultancy firm, $41,000, and Pearl Bridge, a precious metals trader, about $30,000.

The notice does not name a Sub-Agent in Türkiye, although it lists Türkiye, with Hong Kong, Indonesia, the Kyrgyz Republic, the Seychelles and the UAE, among the places where A7 companies are formed.

The Kyrgyz link

The alert, numbered FIN-2026-Alert007, says "The Kyrgyz Republic plays a central role in both the A7 Network's fiat and digital asset activities". It describes Old Vector LLC, the issuer of A7A5, as Kyrgyz-registered and OFAC-sanctioned. It says numerous Kyrgyz-registered entities affiliated with the network "maintain bank accounts" and that the state-owned Trading Company of the Kyrgyz Republic (TKKR) "illustrates this typology". "Through TKKR and other Sub-Agents, the A7 Network accessed the Kyrgyz Republic's financial sector", it says. A footnote records that OFAC designated Kyrgyzstan-based Keremet Bank in January 2025. The OFAC entry lists the network's locations as Russia, Kyrgyzstan, Nigeria and Zimbabwe, according to the notice.

What institutions are asked to do

Property of the network in US jurisdiction is blocked, and entities 50 per cent or more owned by blocked persons are also blocked, according to Treasury. The alert asks institutions to include "FIN-2026-A7NETWORK" in field 2 of suspicious activity reports. Its red flags include transactions with "suspected shell companies located in Kyrgyz Republic" and stablecoin payments for commodities not usually traded with digital assets, such as oil or petroleum products. The alert says the network uses Sub-Agents so that payments can move through non-Russian bank accounts and correspondent banking channels.

Treasury presents the action as part of Operation Economic Outcast and quotes Secretary Scott Bessent: "Treasury is dismantling the financial infrastructure that allows Iran and other adversaries to evade sanctions". The notice says one Sub-Agent and a sister company received nearly $140 million from entities involved in Iranian sanctions evasion between July 2023 and October 2025. The UK, which sanctioned banks, entities and individuals linked to A7 on 26 May, issued its own alert on 31 August and named Central Asia and West Africa as focus areas for the third-country enablers the network depends on.