FinCEN A7 Network Special Measure: Prohibiting Sub-Agent Transmittals

On 1 October 2026 FinCEN released a notice of proposed rulemaking under section 9714(a) of the Combating Russian Money Laundering Act that would add a new 31 CFR 1010.668 and prohibit every covered US financial institution from sending or receiving funds, including convertible virtual currency (CVC), in transactions involving the A7 Network’s Sub-Agents. The FinCEN A7 Network special measure rests on a finding that transactions involving any company outside the United States controlled by the A7 Network, which FinCEN describes as a sanctions evasion and money laundering service with ties to Russia, are a class of transactions of primary money laundering concern in connection with Russian illicit finance.

The same day, Treasury’s Office of Foreign Assets Control (OFAC) designated the A7 Network as a significant transnational criminal organization, and FinCEN issued Alert FIN-2026-Alert007 with a SAR key term for A7-related filings. FinCEN’s own regulatory impact analysis counts 347,926 potentially affected institutions. The proposal would run on a list of Sub-Agents that FinCEN shares privately through its FI-Portal, and it adds a notification duty, a risk-based special due diligence requirement and a record of each notification. Comments go to docket FINCEN-2026-0265 (RIN 1506-AB77) and close 30 days after the notice appears in the Federal Register.

Three instruments with three different legal statuses arrived together. The OFAC blocking is in force, the Alert is a filing request, and the special measure is a proposal that binds no one until FinCEN finalises it.

Related reading: EU 21st Sanctions Package: What Screening Desks Must Update

Key dates for the FinCEN A7 Network special measure

• 14 August 2025: OFAC designated A7 Limited Liability Company, A71 Limited Liability Company, A7 Agent Limited Liability Company and related actors under Executive Order 13694, according to the FinCEN Alert. Treasury’s October 2026 release dates Old Vector LLC’s designation to the same day.
• 18 December 2025: the United Kingdom sanctioned Gimli Trade LLC-FZ, one of the six Sub-Agents named in the proposed rule text.
• 1 October 2026: OFAC designated the A7 Network under Executive Order 13581, as amended by Executive Order 13863; FinCEN released the NPRM in pre-publication form and issued FIN-2026-Alert007.
• Federal Register publication: pending when the pre-publication text was released. The notice states that it may change slightly in the Federal Register review process and that the published version is the official document.
• Comment deadline: 30 days after Federal Register publication, for both the rule (regulations.gov or mail) and the Paperwork Reduction Act collection (reginfo.gov).
• Application: none yet. Section 1010.668 would bind covered institutions only once FinCEN issues a final rule, and the proposal does not state an effective date.

The narrow point in that calendar is the comment clock. It starts on the Federal Register publication date, and the pre-publication PDF carries a bracketed placeholder where the closing date will go. A 30-day window is short for a rule that touches payment screening, CVC operations and customer communications at once, and FinCEN says it chose 30 days to balance notice against the national security risk of continued processing.

Section 9714 and the sixth special measure

Section 9714(a), as amended by section 6106(b) of the National Defense Authorization Act for Fiscal Year 2022 and carried as a note to 31 U.S.C. 5318A, lets the Secretary act where reasonable grounds exist for concluding that a financial institution operating outside the United States, or a class of transactions within or involving a jurisdiction outside the United States, is of primary money laundering concern in connection with Russian illicit finance. The Secretary’s authority under section 9714 was re-delegated to the Director of FinCEN on 11 August 2022.

The statute gives FinCEN six options. Special measures one to four are the recordkeeping, information collection and reporting measures in 31 U.S.C. 5318A(b)(1) to (4), the provision practitioners know as section 311 of the USA PATRIOT Act. Special measure five, in 5318A(b)(5), prohibits or conditions correspondent and payable-through accounts. Section 9714 adds a sixth: prohibiting, or imposing conditions on, certain transmittals of funds.

FinCEN explains why it rejected the first five. Recordkeeping and reporting measures would let the transfers continue. A correspondent-account measure would miss value moving outside a correspondent or payable-through relationship, and FinCEN points to A7A5 transactions, which it calls integral to the network’s business model and which do not rely on correspondent banking. Conditions on transmittals were also considered and set aside, because the Sub-Agents’ service is built to benefit sanctioned persons.

The form of this action differs from the two earlier section 9714 actions. FinCEN’s January 2023 order on the exchange Bitzlato, the first order under section 9714(a), took effect on 1 February 2023, and its September 2024 order on the exchanger PM2BTC took effect on 11 October 2024, the day it was published in the Federal Register. Both targeted one named institution by order. The A7 finding covers a class of transactions, and FinCEN chose a proposed rule so that covered institutions can comment on the mechanism for identifying Sub-Agents. Until a final rule issues, 1010.668 imposes nothing.

How the Sub-Agent model reaches US institutions

FinCEN’s background section describes a network formally launched in September 2024 and created by Ilan Shor and Promsvyazbank (PSB), Russia’s state-owned defense bank. Its core is three Russia-based companies, A7 LLC, A71 LLC and A7 Agent LLC, which work with Old Vector LLC, the exchanges Garantex and Grinex, InDeFi Bank, ExVed and Garantex co-founder Sergey Mendeleev.

The Sub-Agents are the part a US institution can actually touch. The network forms, acquires or partners with companies in third countries such as Hong Kong, Indonesia, the Kyrgyz Republic, the Seychelles, Türkiye and the United Arab Emirates. On paper they are typically owned or managed by non-Russian nationals; FinCEN says they are controlled by the A7 Network. As of June 2026 FinCEN counts hundreds of them, with bank accounts at approximately 435 financial institutions in at least 83 countries.

The payment pattern is trade-shaped. A customer settles inside the network, often through bills of exchange (veksels), and a Sub-Agent outside Russia appears as the contracting or paying party on invoices, sales agreements and payment instructions to the supplier. Funds can pass through several Sub-Agents before reaching the beneficiary. FinCEN describes the A7A5 token as part of a mirror system, with transfers inside Russia matched by fiat payments that Sub-Agents make abroad, a structure close to the underground banking channels covered in our note on FATF’s hawala and underground banking report.

Two volume figures in the NPRM measure different things and should not be added together. FinCEN assesses that Sub-Agents processed more than USD 17 billion in USD-denominated transactions between January 2025 and June 2026. Separately, its analysis found more than 180 entities processing A7A5 transactions worth at least USD 179.1 billion between February 2025 and June 2026.

The six Sub-Agents named in the proposed definition are all described as Dubai or UAE-based, with FinCEN’s estimates of illicit flows attached:

• Power Sphere LLC-FZ, an electronics supplier: USD 61 million between September 2023 and July 2025.
• Hydrofusion Resources FZ-LLC, an energy commodities trader: USD 3.6 million in May and June 2025.
• Gimli Trade LLC-FZ, a trading firm with an account at PSB: USD 1.5 million in May and June 2025.
• Galadriel Trading FZCO, an agricultural trader: more than USD 946,000 between May and July 2025, tied to export control evasion.
• Sigizmund FZCO, a consultancy: USD 41,000 between July and September 2025, including dual-use goods acquisition.
• Pearl Bridge, a precious metals and commodities trader: approximately USD 30,000 in April 2025.

Pearl Bridge appears in the proposed definition without a legal-form suffix. That is a small drafting detail with a screening consequence. A two-word name without a registered legal form gives a matching engine less to anchor on, so the identifiers FinCEN supplies with its list will matter for how that entry is tuned.

Covered financial institutions under 31 CFR 1010.100(t)

The proposal gives “covered financial institution” the meaning of “financial institution” in 31 CFR 1010.100(t): each agent, agency, branch or office within the United States of a person doing business as, among others, a bank, a broker or dealer in securities, a money services business (MSB), a casino or card club, a futures commission merchant or introducing broker in commodities, or a mutual fund. FinCEN’s Table 1 counts 8,988 banks and persons subject to bank supervision, 3,277 broker-dealers, 332,068 MSBs, 1,304 casinos and card clubs, 954 futures commission merchants and introducing brokers, 1,335 mutual funds and no telegraph companies beyond those already counted.

FinCEN expects the weight to fall on a small subset. It estimates that about 10 percent, 34,793 institutions, would carry more than a de minimis burden. Within that group, it assumes 128 institutions with foreign correspondent accounts carry the full set of obligations: 66 banks with a federal functional regulator, 12 banks without one, 29 broker-dealers, 9 futures commission merchants or introducing brokers and 12 mutual funds.

The MSB figure contains a terminology trap. FinCEN’s count includes approximately 307,212 agent MSBs, and in MSB regulation an “agent” is a separate business that an issuer authorises to sell its money transmission services. An A7 “Sub-Agent” is defined differently: a company outside the United States controlled by the A7 Network. A US agent MSB is itself a covered financial institution that would screen for Sub-Agents, so procedures that already use “agent” in the MSB sense need the A7 term defined separately.

The definition is also territorial. Section 1010.100(t) reaches offices within the United States, and the proposal does not extend 1010.668 to a group’s non-US branches or subsidiaries. How those entities treat A7 exposure depends on OFAC’s reach, local sanctions regimes and group policy, none of which the NPRM addresses.

Transmittal of funds, redefined for one section

Proposed 1010.668(a)(5) defines “transmittals of funds” as “the sending and receiving of funds, including convertible virtual currency” and states that this definition applies in place of the general one in 1010.100(ddd). The substitution matters more than it looks. The general definition describes a series of transactions beginning with a transmittor’s transmittal order and excludes electronic fund transfers as defined in the Electronic Fund Transfer Act, along with other funds transfers made through an automated clearinghouse, an automated teller machine or a point-of-sale system.

The 1010.668 definition appears to carry no equivalent exclusion. On that reading, an ACH credit, a card-funded payout or a domestic account-to-account transfer involving a listed Sub-Agent sits inside the prohibition alongside wires and CVC transfers. FinCEN does not discuss the point, and a firm whose screening covers wires but not ACH or card rails should treat it as an open scoping question for the comment letter.

There is no value threshold either. The travel rule in 31 CFR 1010.410(f) applies to transmittals of USD 3,000 or more, so smaller payments may carry thinner party data, yet the proposed prohibition applies at any amount. The operative text reaches any transmittal “involving” a Sub-Agent, including transmittals from or to a Sub-Agent or from or to “any account or CVC address administered by or on behalf of” one.

The CVC definition also carries an oddity. It describes CVC as lacking legal tender status and then states that, “despite having legal tender status in at least one jurisdiction,” A7A5 is included as a type of CVC for this rule. Whatever the intent, the effect is clear enough for screening purposes: A7A5 is inside the definition.

The Sub-Agent list sits in FinCEN’s FI-Portal

The proposed definition of “A7 Network Sub-Agents” means businesses “including, but not limited to” the six named companies “and any other entity identified by FinCEN as a Sub-Agent of the A7 Network.” The preamble then narrows the duty: FinCEN would provide covered institutions with information on known Sub-Agents through the FI-Portal, which it describes as a secure messaging system it uses with covered institutions, and it proposes to limit the prohibition to entities on that list. The list would be updated periodically, both to add and to remove names.

FinCEN is keeping the list private on purpose. Its stated concern is that public distribution would let the network replace exposed companies with new Sub-Agents. The consequence for screening teams is that the six names in the proposed rule text are a floor. A control built only on those six would fall short of the obligation as proposed, because the operative list is the one delivered through the portal.

The NPRM describes the FI-Portal as a channel FinCEN and covered institutions already use. It does not explain how the list would reach a covered institution in Table 1 that has no existing FI-Portal relationship, a question that matters most for the 332,068 MSBs in FinCEN’s count. That is a practical question worth putting to FinCEN in the comment period, because a list-based obligation is only as complete as its distribution.

The proposal lets institutions say why they declined. Covered institutions would not be prohibited from disclosing that a transaction was refused because a party appears on FinCEN’s list. Listed companies can petition for removal under proposed 1010.668(b)(3) by email to Globalinvestigations@fincen.gov, presenting arguments or evidence that the basis for listing is insufficient or that circumstances have changed. FinCEN may ask for more information, may decline a requested meeting, and will issue a written decision; a successful petition leads to an updated list. Whether institutions would receive any reason for a removal, or only the revised list, the proposal leaves unsaid.

Blocking, rejecting and returning A7A5 and other CVC

Proposed 1010.668(b)(1)(i) deals with incoming CVC that a covered institution cannot stop in advance. An institution is deemed not to have violated the prohibition where, on determining that it received CVC from a Sub-Agent or from an account or address administered for one, it blocks the CVC if other authorities require that, or rejects the transaction, so that the intended recipient cannot access the CVC, returning it to the Sub-Agent or the originating address.

FinCEN’s footnote 80 is candid about why this exists: CVC systems are often designed to stop anyone other than the sender from rejecting funds, so there are “few, if any, readily available ways” to reject incoming CVC before receipt. The section-by-section analysis of this NPRM (the discussion of proposed § 1010.668(b)(1)(i), pages 34 to 35 of the pre-publication PDF) adds that the provision lets institutions act with discretion based on the facts and circumstances and comply with the prohibition “even where the originating address is no longer accessible.” The proposed regulatory text, however, describes the rejection route as preventing the intended recipient from accessing the CVC and returning it to the A7 Network Sub-Agent, or to the account or CVC address from which it originated. How that returning step works where the originating address no longer works is not spelled out in the text, and the comment period is the place to ask for clarification.

OFAC sits on top. Note 1 to paragraph (b)(1) says covered institutions should block and report to OFAC any property blocked under OFAC authorities in line with 31 CFR part 501, and the preamble resolves conflicts in OFAC’s favour: an institution that complies with a blocking obligation would, under the proposal, be deemed to comply with the special measure. Treasury describes A7A5 as a blocked token issued by Old Vector LLC, and FinCEN’s Alert states that OFAC considers it blocked property due to Old Vector LLC’s interest. The likely outcome is that, for A7A5 itself, the blocking branch will usually apply, and the reject-and-return branch is for CVC from listed addresses where no other authority requires blocking.

Two crypto details from the NPRM affect the address side of screening. FinCEN warns that US institutions may meet derivative or “wrapped” tokens pegged to A7A5 on other blockchains, often accessed through decentralized finance applications. And after an alleged hack of Grinex in April 2026, A7A5 was consolidated into unhosted wallets, which FinCEN says suggests the network may be moving away from sanctioned exchanges; the wider unhosted-wallet problem is set out in our article on the FATF stablecoins and unhosted wallets report.

Notification duties and the SAR confidentiality line

Proposed 1010.668(b)(2) is the duty most likely to generate customer contact. If a transmittal is prohibited under paragraph (b)(1), or blocked consistent with Note 1, the covered institution must notify affected persons associated with the transmittal with which it maintains a direct commercial relationship. For a US correspondent bank, the direct relationship in a cross-border payment runs to the foreign respondent that sent or was due to receive it, and FinCEN’s PRA section describes the notices as aiding cooperation from foreign account holders. For an MSB, the affected person may be its own customer.

The preamble and the text describe the trigger differently. The section-by-section analysis says notification applies if an institution “knows or has reason to believe” a transmittal involves a Sub-Agent and is prohibited. The proposed regulatory text carries no knowledge standard; it attaches to any transmittal that is prohibited or blocked. A reporting team writing its procedure needs to know which version survives. On the text as drafted, the duty would also attach to a transaction identified as prohibited only after the fact.

FinCEN keeps the mechanics light. Notice can be given directly or indirectly through other intermediaries, by mail, fax or e-mail, and no certification from the recipient is required. Proposed 1010.668(b)(5)(i) requires each institution to document its compliance with the notification requirement, while (b)(5)(ii) confirms the rule creates no new reporting obligation. The preamble’s description of the recordkeeping duty cross-refers to (b)(3), the petition paragraph, while the regulatory text refers to the notification requirement generally; the text is the version to build to.

The notice does not loosen SAR confidentiality. Under 31 U.S.C. 5318(g)(2) and the parallel rules, such as 31 CFR 1020.320(e) for banks and 1022.320(d) for MSBs, a SAR and any information that would reveal its existence stay confidential. The NPRM says nothing in it modifies SAR obligations. A notice that a payment was refused because a party is on FinCEN’s Sub-Agent list is permitted; a notice that mentions, or lets the reader infer, a SAR filing falls under the SAR confidentiality prohibition. FinCEN has asked for comment on the form and scope of the notice, and the proposal prescribes no content.

Special due diligence and the screening build

Proposed 1010.668(b)(4) asks each covered institution to take a risk-based approach when deciding what, if any, other due diligence measures it reasonably must adopt to guard against processing prohibited transmittals. The preamble fills that in. Due diligence should include risk-based procedures to identify transactions involving Sub-Agents and any use of an account to process them, and an institution would be expected to screen for a Sub-Agent appearing as originator or beneficiary or otherwise referenced in a way its normal screening can detect. FinCEN gives commercially available OFAC screening software as an example of a suitable mechanism.

The cost model depends on that assumption. In its Regulatory Flexibility Act discussion FinCEN says covered institutions would “simply incorporate the list into their existing screening tools and processes.” Its Paperwork Reduction Act estimate (pages 51 to 52 of the pre-publication PDF) puts the burden at eight hours a year for each of the 128 institutions with expanded obligations and four hours for each of 34,665 others, about 139,700 hours and approximately USD 17,740,000 a year in total. FinCEN concludes the rule is not economically significant under section 3(f) of Executive Order 12866 and certifies that it would not have a significant impact on a substantial number of small entities.

Whether four hours is realistic depends on what the list contains, which the NPRM does not specify. A portal list with names only, delivered outside the vendor feed that carries the SDN list, implies a separate ingestion job, matching thresholds for suffix-free names and a decision on free-text payment fields. If the list also carries account numbers or CVC addresses, the address-screening side of a crypto or MSB business needs its own feed. FinCEN’s PRA section asks for comment on exactly this: the accuracy of its burden estimate and the start-up, operating and maintenance costs of the collection.

The Alert supplies the risk-based layer around the list. FinCEN’s red flags fall into three groups:

• Sub-Agent use: transactions with suspected Sub-Agents or shell companies in the Kyrgyz Republic or other jurisdictions of concern, payments routed through several shell companies for no clear purpose, a recently formed company suddenly moving unusually high volumes, and goods descriptions that do not fit the supplier’s business profile. Access from IP addresses on VPN infrastructure tied to the domains muzpan[.]com or sodkamus[.]com, or e-mail domains resolving to their mail servers, also counts.
• Mis-invoicing: invoice templates that differ from previously observed standards, vague product details or implausible prices, out-of-place Cyrillic characters in English documents, an analog company stamp on an otherwise digital document, and signs of AI-generated or AI-altered documents.
• Digital asset abuse: historic direct or indirect exposure to A7A5 or wrapped versions of it, stablecoins sent to suspected Sub-Agents, stablecoin payments for commodities such as dual-use goods or oil, and OTC desks with sudden unexplained growth in jurisdictions with A7 touchpoints.

FinCEN also gives two IP ranges, 159.100.19.150/152 and 159.100.19.203/214, as indicators for customer websites and account access that warrant additional scrutiny. The IP and domain indicators only work if login and device data reaches whoever reviews A7 alerts. Türkiye appears in the NPRM among the jurisdictions where Sub-Agents are formed; for correspondent teams already revisiting that file, our note on the FATF Türkiye mutual evaluation covers the country-level findings.

What already applies before any final rule

“Proposed” describes only one of the three instruments. Treasury’s 1 October 2026 release states that, as a result of the designation, all property and interests in property of the A7 Network, “including transactions involving Sub-Agents acting for or on behalf of the A7 Network,” that are in the United States or in the possession or control of US persons are blocked and must be reported to OFAC. The NPRM repeats OFAC’s 50 percent rule: an entity owned 50 percent or more, directly or indirectly, by blocked persons is itself blocked, whether or not it is listed.

The Alert’s SAR request applies now as well. FinCEN asks institutions to include the key term “FIN-2026-A7NETWORK” in SAR field 2 (Filing Institution Note to FinCEN) and in the narrative when reporting activity related to the A7 Network. The NPRM confirms that nothing in it modifies BSA obligations, including SAR filing.

The special measure would add something OFAC does not. Treasury states that the OFAC blocking of the A7 Network’s property and interests in property includes transactions involving Sub-Agents acting for or on behalf of the network. That is distinct from proposed section 1010.668, under which FinCEN proposes to prohibit covered financial institutions from specified transmittals involving Sub-Agents identified on FinCEN’s list. A FinCEN listing would not, by itself, establish that the Sub-Agent is an OFAC-blocked person. The proposal also carries a criminal-liability statement under Executive Order 14294: willful violations of a final rule may be subject to criminal penalties under 31 U.S.C. 5322, with 31 CFR 1010.840 setting a mens rea of willfulness.

FinCEN’s three questions and the comment routes

FinCEN invites comment on every aspect of the proposal and names three specific matters: its choice of a prohibition on transmittals of funds instead of special measures one to five or conditions; the form and scope of the notice required under the rule; and the appropriate scope of the due diligence requirement. Each of the open points above maps onto one of them, from the knowledge standard in the notice duty to the content and delivery of the list.

Comments on the rule go through regulations.gov or by mail to FinCEN at P.O. Box 39, Vienna, VA 22183, citing docket FINCEN-2026-0265. Comments on the information collection go to OMB through reginfo.gov. Comments are published exactly as received, so the NPRM warns against including personal information or confidential business information; anonymous comments are accepted. FinCEN also invites data on its population estimates, including whether the “persons subject to supervision by any state or Federal bank supervisory authority” category adds institutions not already counted elsewhere.

Frequently Asked Questions

Does the prohibition reach a US bank acting only as an intermediary in a payment to a listed Sub-Agent?

As drafted, yes. The prohibition covers any transmittal “involving” a listed Sub-Agent, and the preamble expects screening to catch a Sub-Agent appearing as originator, beneficiary or reference in a way normal screening detects. The notice duty is narrower: the intermediary notifies only the affected persons with which it has a direct commercial relationship, typically the bank that sent the instruction.

What if a listed Sub-Agent is also owned 50 percent or more by an OFAC-blocked person?

The OFAC obligation governs. The institution blocks and reports under 31 CFR part 501 and, under the proposal, would be deemed to comply with the special measure. The proposed notice duty still applies, because paragraph (b)(2) covers transmittals blocked consistent with Note 1 as well as those prohibited outright.

Would the rule require closing accounts of customers who dealt with Sub-Agents in the past?

The text contains no account-closure requirement. It prohibits transmittals and asks for risk-based due diligence on the use of accounts to process them. Historic direct or indirect A7A5 exposure is an Alert red flag, so past dealings feed the institution’s own risk assessment and SAR decisioning; any exit decision remains a risk-based call.

Is inbound CVC from a customer’s unhosted wallet that once held A7A5 automatically prohibited?

The prohibition attaches to transmittals from or to a listed Sub-Agent or an account or CVC address administered by or on behalf of one. Indirect exposure through a customer’s own wallet is a red flag under the Alert, which calls for review and, where warranted, a SAR. Whether the specific address is administered for a Sub-Agent is the question that decides the prohibition.

Does FinCEN share the Sub-Agent list with non-US banks?

The proposal provides the list only to covered financial institutions through the FI-Portal. Foreign respondent banks would learn of refusals through the notices US institutions send, which may say that a party appears on FinCEN’s list. FinCEN says the action is intended to encourage other jurisdictions and institutions worldwide to take similar steps, but the proposal does not provide for wider distribution of the list.

If a listed company petitions for removal, can a covered institution resume payments while FinCEN reviews it?

The proposal ties the obligation to the list and says FinCEN would update the list after a successful challenge. Nothing in the text suspends a listing while a petition is pending, so the reasonable reading is that the prohibition continues until the company drops off the list FinCEN distributes.

Does the special measure create a new FinCEN filing?

No new report. Proposed 1010.668(b)(5)(ii) states that the rule requires no reporting beyond what other law or regulation already requires. The new record is the documentation of each notification under (b)(5)(i); A7-related SARs continue under existing SAR rules, with the Alert’s key term.

Related Articles

• EU 21st Sanctions Package: What Screening Desks Must Update: the EU’s July 2026 Russia package, its asset-freeze additions and the screening changes it requires of EU financial firms.
• FATF Stablecoins and Unhosted Wallets Report: AML/CFT Implications for EU Firms: FATF’s March 2026 findings on stablecoins and peer-to-peer transfers and what they mean for AML controls.
• FATF on Hawala and Underground Banking: AML Red Flags: the September 2026 FATF report on hawala and underground banking as professional laundering channels.
• FATF Türkiye Mutual Evaluation 2026: Refreshing the Respondent File: country-level FATF findings that correspondent banking teams can feed into respondent reviews.
• FINMA Russia Sanctions: The 20 August 2026 Measures: the Swiss implementation of Russia sanctions and the separate Liechtenstein reporting framework.

Key Takeaways

• Watch for RIN 1506-AB77 in the Federal Register: publication day fixes the 30-day comment deadline for docket FINCEN-2026-0265.
• OFAC blocking of the A7 Network’s property and interests in property has applied since 1 October 2026, and Treasury states that this includes transactions involving Sub-Agents acting for or on behalf of the A7 Network; Treasury also describes A7A5 as a blocked token. This does not mean that every FinCEN-listed Sub-Agent is itself blocked. Proposed 1010.668 would apply only after FinCEN issues a final rule.
• FinCEN asks for FIN-2026-A7NETWORK in SAR field 2 and the narrative of A7-related filings from 1 October 2026.
• Plan a separate ingestion route for the FI-Portal Sub-Agent list, and confirm portal access before a final rule lands.
• Decide in advance how inbound CVC covered by a final rule would be handled: where an applicable OFAC authority independently requires blocking, block and report under that authority; otherwise apply the final section 1010.668 treatment, including any permitted reject-and-return mechanism.
• Prepare an affected-person notice template that references FinCEN’s list and never a SAR, with a log that evidences each notice sent.
• Test FinCEN’s four-hour and eight-hour annual burden figures against your own screening build before the comment window closes.

Sources and References

• FinCEN, Proposal of Special Measure Prohibiting the Transmittal of Funds Regarding Transactions Involving the A7 Network’s Sub-Agents, notice of proposed rulemaking, RIN 1506-AB77, docket FINCEN-2026-0265 (pre-publication version, 1 October 2026): fincen.gov NPRM (PDF)
• FinCEN, FinCEN Alert on the A7 Network, FIN-2026-Alert007 (1 October 2026): fincen.gov Alert (PDF)
• FinCEN news release, Operation Economic Outcast Takes Unprecedented Action Against Sanctions Evasion Network Used by Iran (1 October 2026): fincen.gov news release
• U.S. Department of the Treasury press release, Operation Economic Outcast Takes Unprecedented Action Against Sanctions Evasion Network Used by Iran (1 October 2026): home.treasury.gov press release sb0644
• FinCEN, 311 and 9714 Special Measures (list of actions): fincen.gov special measures page
• FinCEN news release, FinCEN Identifies Virtual Currency Exchange Bitzlato as a “Primary Money Laundering Concern” in Connection with Russian Illicit Finance (18 January 2023): fincen.gov news release
• FinCEN news release, Treasury Takes Coordinated Actions Against Illicit Russian Virtual Currency Exchanges and Cybercrime Facilitator (26 September 2024): fincen.gov news release
• FinCEN, Imposition of Special Measure Prohibiting the Transmittal of Funds Involving PM2BTC, 89 FR 82499 (11 October 2024): govinfo.gov PM2BTC order
• 31 CFR Part 1010, General Provisions (7-1-25 edition), sections 1010.100(t), 1010.100(ddd), 1010.410(f) and 1010.840: govinfo.gov 31 CFR Part 1010 (PDF)
• 31 CFR Part 1020, Rules for Banks (7-1-25 edition), section 1020.320(e), confidentiality of SARs: govinfo.gov 31 CFR Part 1020 (PDF)
• 31 CFR Part 1022, Rules for Money Services Businesses (7-1-25 edition), section 1022.320(d), confidentiality of SARs: govinfo.gov 31 CFR Part 1022 (PDF)
• 31 U.S.C. 5318, Compliance, exemptions, and summons authority, subsection (g)(2), notification prohibited (2023 edition): govinfo.gov 31 U.S.C. 5318
• 31 U.S.C. 5322, Criminal penalties (2023 edition): govinfo.gov 31 U.S.C. 5322
• FinCEN, Registration of Money Services Business (RMSB) Electronic Filing Instructions, definition of “agent”: fincen.gov RMSB instructions (PDF)

Preparing for a final A7 Sub-Agent rule

The next fixed date is the Federal Register publication of RIN 1506-AB77, and the 30-day comment deadline follows from it. Before then, three artifacts hold their value whatever the final text says: an inventory of every payment and CVC channel that would need to screen against a list delivered through the FI-Portal, a notice template cleared for SAR confidentiality, and, for any institution that wants FinCEN to change the knowledge standard, the return-of-CVC wording or the list distribution, a comment filed under docket FINCEN-2026-0265 before that deadline.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.