Proposal of Special Measure Prohibiting the Transmittal of Funds Regarding Transactions Involving the A7 Network’s Sub-Agents
Key claim: The Treasury’s FinCEN proposes to bar U.S. banks and other covered financial institutions from sending or receiving funds involving any foreign company controlled by the A7 Network, a Russia-linked money-laundering and sanctions-evasion service used by Iran and other illicit actors.
Abstract
(Proposed Rule · Treasury Department, Financial Crimes Enforcement Network) FinCEN is issuing a finding and notice of proposed rulemaking, pursuant to section 9714(a) of the Combating Russian Money Laundering Act (Public Law 116-283), as amended by section 6106(b) of the National Defense Authorization Act for Fiscal Year 2022 (Public Law 117-81), finding transactions involving any company operating outside of the United States that is controlled by the A7 Network, a sanctions evasion and money laundering service with ties to Russia, leveraged by a wide range of illicit actors, including Iran and its terrorist proxies, to be a class of transactions of primary money laundering concern in connection with Russian illicit finance and proposing the imposition of a prohibition on certain transmittals of funds, by any covered financial institution, involving that class of transactions.
Why this matters
FinCEN’s Section 311 special-measure authority is one of the sharpest unilateral tools in U.S. AML/sanctions enforcement, cutting a target off from the U.S. financial system without needing OFAC designation. Extending it to a foreign non-bank laundering network and its sub-agents — rather than a specific bank or jurisdiction — tests how broadly the authority can reach into informal value-transfer and shell-company ecosystems. Covered U.S. banks, money service businesses, and other institutions would have to screen counterparties against A7-controlled entities and block transmittals.