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ARTICLE · 23 OCTOBER 2026

Targeting Iran Finance, Treasury Sanctions Russia-Linked Sanctions Evasion A7 Network

Ballard Spahr LLP
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The Treasury Department's Financial Crimes Enforcement Network and Office of Foreign Assets Control have launched coordinated enforcement actions targeting the A7 Network, a sophisticated global financial infrastructure allegedly designed to help sanctioned entities from Russia, Iran, and North Korea move funds through the international banking system.

GlobalGovernment, Public Sector
Katherine L. Oaks
Katherine L. Oaks
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On October 1, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) Office of Foreign Assets Control (OFAC) took joint actions against the A7 Network, a global financial services infrastructure designed to evade sanctions, “to isolate Iran and its financial enablers,” as part of Operation Economic Outcast against Iran.

FinCEN NPRM

FinCEN issued a notice of proposed rulemaking (NPRM), under section 9714(a) of the Combatting Russian Money Laundering Act, finding transactions involving any company operating outside of the United States “that is controlled by the A7 Network” (i.e., any identified “Sub-Agent”) to be a class of transactions of primary money laundering concern in connection with Russian illicit finance. The finding means that the companies, designed to receive and remit payments to facilitate transactions for the network, present a material risk of facilitating fund transfers designed to evade sanctions by illicit actors like Russian and Iranian persons

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