FinCEN wants a secret list of A7's front companies. It has published six names and says there are hundreds

Two things happened to the A7 Network on 1 October 2026, and only one of them is law. OFAC added the network to the SDN List as a significant transnational criminal organisation. The same day FinCEN found that transactions involving any foreign company the network controls are of primary money laundering concern, and proposed to bar US financial institutions from transmitting funds for them.

A7 is a payment service launched in September 2024 by the Moldovan fugitive Ilan Shor and Promsvyazbank, Russia's state defence bank. FinCEN says its core is three Russian companies, A7 LLC and its subsidiaries A71 LLC and A7 Agent LLC, all three sanctioned by the United States, the European Union and the United Kingdom. As of January 2026 the network claimed more than 2,000 transactions a day and a running total of 7.5 trillion roubles, about $91.5 billion. FinCEN puts that at nearly 13 percent of Russia's 2025 foreign trade.

The mechanics are in the alert. A customer in Russia or Iran gives A7 the details of a purchase. A7 settles the debt inside its own books, using promissory notes called veksels, and then puts a Sub-Agent on the invoice as the paying party. The payment leaves from a non-Russian bank account through ordinary correspondent banking. To the bank it looks like trade. Between 30 September 2024 and 22 July 2025, FinCEN says, A7's clients bought more than 3,200 of those notes, worth more than $25 billion.

We counted the entries OFAC tied to A7 on 1 October. There is one; every other new entry that day is Iran-related. In full, it reads: A7 NETWORK, Russia; Kyrgyzstan; Nigeria; Zimbabwe; Organization Established Date 2024; Target Type Criminal Organization; [TCO]. It carries no address, no alias and no identifier.

FinCEN's alert says all property of the A7 Network, "including transactions involving Sub-Agents acting for or on behalf of the A7 Network", is blocked when it is in the United States or held by a US person. So the law already reaches the Sub-Agents. The list does not. A name-screening system looking at an invoice from a Dubai trading company has nothing to match against, because the blocked party is a network with one row and no names.

That gap is what the proposed rule is for.

The proposed rule would ban any covered institution from sending or receiving funds involving an A7 Network Sub-Agent, or an account or crypto address run for one. "Covered financial institution" takes the Bank Secrecy Act meaning. FinCEN counts 347,926 of them, 332,068 of which are money services businesses, and expects about 35,000 to bear more than a trivial burden.

But the duty is limited to a list. FinCEN would give covered institutions the names through its FI-Portal and says the obligation applies "only as to those entities identified on that list". FinCEN will update it in both directions. Its stated reason for keeping it secret is that a public list would let the network "circumvent the proposed special measure through additional and new Sub-Agents".

Four other features matter before the comment deadline.

• An institution that rejects or blocks a payment must notify the affected persons it has a direct commercial relationship with, directly or through other institutions. It may say the reason is the list, and it must keep a record of the notice.
• A company on the list can petition for removal, by email to FinCEN. FinCEN promises a written decision.
• Institutions are expected to apply "an appropriate screening mechanism", and FinCEN gives commercial sanctions-screening software as the example.
• If the ban and an OFAC blocking duty conflict, the institution blocks, and that counts as compliance with the ban.

The proposed definition lists six companies "including, but not limited to". FinCEN's account of each is below. Five are described as Dubai-based; Hydrofusion Resources FZ-LLC only as UAE-based.

Add FinCEN's six figures together and you get about $67 million. FinCEN gives no total and the periods do not line up, so treat that as our arithmetic. Its own aggregate is that the Sub-Agents as a whole moved more than $17 billion in dollars between January 2025 and June 2026. The six are examples, not the population. Two unnamed Sub-Agents carry more weight in the document. One, with a sister company, received nearly $140 million from entities involved in Iranian sanctions evasion between July 2023 and October 2025. Another sent about $1.6 million to a company linked to Iranian weapons procurement.

A marketing consultancy and a grain trader sit on the same list as an electronics supplier that "purportedly trades" in energy. FinCEN says A7 tailors Sub-Agents to the industries it moves payments for. The alert also says it sometimes fails to match them to a customer's business profile, which is one of its red flags.

The rule's text mentions a sanctions listing for only one of the six. Gimli Trade LLC-FZ was sanctioned by the United Kingdom on 18 December 2025, FinCEN says. It also held an account at Promsvyazbank in Russia for rouble transactions, the one direct Russian link the document gives for any of the six. For the other five, the document records no listing, though absence from a document is not evidence of absence from a list. Power Sphere's illicit flows start in September 2023, a year before A7 formally launched.

FinCEN says Sub-Agents are "typically represented to be owned or managed by non-Russian third-country nationals" but are in fact controlled by A7. The jurisdictions it gives as examples are Hong Kong, Indonesia, the Kyrgyz Republic, the Seychelles, Türkiye and the United Arab Emirates. The proposed rule adds that Sub-Agents "do not have any Russians on the board of directors or as shareholders".

OFAC's 50 percent rule reaches a company that blocked persons own half or more of, directly or indirectly. It does not ask who runs it. FinCEN's own footnote says control-based blocking exists only in some programmes, Cuba and Sudan among them. Treasury's position is that a Sub-Agent's transactions for A7 are blocked anyway, as A7's property. The reach of the law is not the problem. No bank can see A7 behind an Indonesian shareholder and a Dubai trade licence. FinCEN's stated reason for the rule is that Sub-Agents are "by design, challenging to readily identify", and a list it controls is how it proposes to fix that.

The alert gives screening teams a usable set of checks, in three groups.

On Sub-Agent behaviour, eight flags. They include a recently formed company that suddenly sends large payments, and payments routed through several shells with no clear purpose. Two concern infrastructure. One is a customer whose email domain resolves to servers tied to muzpan.com or sodkamus.com, two domains FinCEN links to VPN infrastructure run by Shor's IT companies. The other is a customer whose website is blank and served from 159.100.19.150/152 or 159.100.19.203/214.

On invoices, five flags: a template unlike earlier ones, vague or implausibly priced goods, an analogue company stamp on a digital document, stray Cyrillic characters, and signs that AI altered the document.

On digital assets, four flags, starting with any exposure to A7A5 or "wrapped" versions of it. The alert says more than 180 entities processed at least $179.1 billion of A7A5 between February 2025 and June 2026. After an alleged hack of the Grinex exchange in April 2026, it says, the token was consolidated into unhosted wallets.

The rule is aimed at US institutions. Nothing in it makes a European payment firm a covered institution.

But a euro-area exporter paying a Dubai supplier in dollars is sending the payment through a US bank, and after a final rule that bank will hold a list the exporter cannot read. If the bank rejects the payment, the rule's notice goes to the party it has a direct relationship with. FinCEN describes this as a notice to correspondent account holders, and allows it to be passed on indirectly through other institutions. For most cross-border payments that means your bank hears first, and you hear from your bank.

FinCEN also says in the proposal that it wants financial institutions "throughout the world" to cut Sub-Agents off. Expect questions from your own bank about Dubai, Hong Kong and Kyrgyz counterparties.

Screen counterparties against the six names, with common variants of each (for example Pearl Bridge with and without a suffix). A hit is a reason to stop and ask. A miss says only that none of the six names appeared in your data.

Then look at the counterparties no list can help with. Pull payers and payees formed in the past two years in the six jurisdictions above, and ask who controls each, not only who owns it. Register extracts and beneficial-ownership filings answer that better than a sanctions list.

Add the alert's checks to onboarding: the email domain and the website's hosting range. They cost little.

If you handle crypto, ask whether any customer has traded A7A5 or its wrapped versions, or has made large stablecoin payments for oil or dual-use goods.

If the list worries you, the comment period runs to 4 November. FinCEN asks three questions in particular: whether a prohibition is the right tool, how the notice to account holders should work, and how far due diligence should go. Comments are public and are published as received.

This post reports what FinCEN, OFAC and Treasury published between 1 and 5 October 2026. We read the proposed rule as FinCEN released it, checked its publication details against the Federal Register record, and read the FinCEN alert, the Treasury release and the OFAC recent-actions page.

We have not seen the Sub-Agent list and cannot say how many names it holds. We did not verify the EU and UK listings of A7 LLC, or the UK listing of Gimli Trade, against EU or UK sources; they come from FinCEN's text. The dollar figures for the six companies are FinCEN's assessments of illicit funds, not audited turnover. We did not check what any private screening product returns for these names. The proposed rule may change before it is final, and the six names may not survive comments.