U.S. Treasury Targets A7 Network Over Iran Sanctions Evasion

Shibbir Ahmed, Washington DC —  The U.S. Department of the Treasury announced a broad set of actions Thursday targeting the A7 Network, a shadow banking network that Treasury says has ties to Russia and has been used by Iran and other illicit actors to evade sanctions and move funds through the international financial system. The measures were announced as part of Operation Economic Outcast and involve both the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC).

FinCEN issued a notice of proposed rulemaking that would prohibit certain financial transactions involving the A7 Network’s Sub-Agents. The agency also released an alert outlining indicators that financial institutions can use to identify and report potentially suspicious activity associated with the network. Separately, OFAC designated the A7 Network as a significant transnational criminal organization.

Treasury Targets A7 Network’s Financial Structure

According to Treasury, the A7 Network was created and backed by individuals already subject to U.S. sanctions. The department said the network established a global network of companies, referred to as Sub-Agents, to disguise payments connected to sanctioned sectors and individuals as routine commercial transactions. Treasury said the network has been used by Iran, including the Islamic Revolutionary Guard Corps (IRGC), as well as other illicit financial actors.

The latest measures build on Treasury’s August 14, 2025, designation of several A7-related entities, including A7 LLC and Old Vector LLC. Treasury officials said the broader action is intended to disrupt the network’s ability to provide financial services that facilitate sanctions evasion.

Billions in Transactions Identified

FinCEN said its investigation found that A7 Network Sub-Agents processed more than $17 billion between January 2025 and June 2026. Treasury said the network allegedly used third-country companies, falsified trade documentation, manipulated import-export records and misleading descriptions of goods to make sanctioned or illicit payments appear to be legitimate commercial transactions.

According to Treasury, the A7 Network claimed that by January 2026 it was processing more than 2,000 transactions a day, with total transaction volume exceeding 7.5 trillion Russian rubles. Treasury estimated the value at approximately $91.5 billion, equivalent to about 13% of Russia’s 2025 foreign trade transactions.

Alleged Links to Iranian Oil and Weapons Procurement

Treasury also said A7 Network Sub-Agents were used in transactions connected to Iranian oil sales and weapons procurement. One Sub-Agent, according to the department, transacted directly with entities associated with Iran’s so-called shadow fleet—a network of tankers, shipping companies and front companies used to transport and sell Iranian oil in violation of sanctions.

Treasury said the Sub-Agent and a related company received nearly $140 million from entities involved in Iranian sanctions-evasion activity. In a separate case cited by Treasury, another A7 Sub-Agent transferred approximately $1.6 million to a company linked to Iranian sanctions evasion and weapons procurement.

FinCEN Issues Alert to Financial Institutions

FinCEN’s new alert provides financial institutions with indicators designed to help identify potentially suspicious transactions associated with the A7 Network. The agency said the network uses foreign companies to gain access to international payment systems and facilitate the movement of funds. The proposed FinCEN rule was issued under Section 9714(a) of the Combating Russian Money Laundering Act. The public will have 30 days to submit comments after the notice is published in the Federal Register.

OFAC Designates A7 as Significant Transnational Criminal Organization

OFAC’s designation places the A7 Network under U.S. sanctions as a significant transnational criminal organization. Treasury identified Ilan Mironovich Shor, whom it described as a sanctioned and convicted fraudster, as the leader of the network. The department said the network operates through a group of Sub-Agent companies that allegedly disguise illicit transactions as legitimate trade.

Treasury also alleged that the network has provided financial support to Iran’s IRGC and Iranian proxy groups, including Hamas. The department said the A7 Network has also been linked to Nobitex, an Iranian digital-asset exchange designated by OFAC in June 2026, and has facilitated transactions associated with North Korean cryptocurrency exchange hacks and other illicit activities.

A7A5 Token Included in Sanctions Action

Treasury said the A7A5 token, a ruble-backed digital token issued by Old Vector LLC, is part of the A7 Network and is subject to U.S. blocking sanctions. According to OFAC, the token was created to facilitate international transactions while helping network participants evade sanctions and generate revenue for sanctioned infrastructure providers.

Potential Consequences for U.S. and Foreign Persons

Following OFAC’s action, property and interests in property belonging to the A7 Network that are located in the United States or controlled by U.S. persons are blocked and must be reported to OFAC. U.S. persons are generally prohibited from conducting transactions involving blocked property unless specifically authorized by OFAC or otherwise exempt.

Treasury warned that violations of U.S. sanctions can result in civil or criminal penalties. OFAC can also impose civil penalties on a strict-liability basis. The department further warned that non-U.S. persons may face sanctions exposure if they cause U.S. persons to violate sanctions or engage in activities designed to evade U.S. sanctions. The latest measures represent an expanded U.S. effort to disrupt financial networks that authorities say facilitate sanctions evasion and illicit finance involving Iran, Russia and other actors.