Trouble A7: FinCEN Proposes Fund Transmittal Ban on Firms in Russia-Linked Network

FinCEN proposed barring covered financial institutions from sending or receiving funds involving companies tied to the A7 Network, a Russia-linked service that helps Iran and other sanctioned parties move money.

The proposal, issued under the Combating Russian Money Laundering Act, finds that dealings with any non-U.S. company the network controls (a "Sub-Agent") are of primary money laundering concern. The ban would apply to listed Sub-Agents.

With the proposal, FinCEN issued an alert urging financial institutions, as defined in 31 U.S.C. 5312 ("Definitions and application"), to detect and report suspicious activity tied to the network. OFAC separately sanctioned the network.

Comments on the proposal are due November 4, 2026.