Policy
FinCEN Wants Banks to Block a List of Companies It Won't Publish
The proposed rule against Russia's A7 Network, scheduled for the Federal Register on October 5, names six Dubai trading firms and then says the operative list of banned "Sub-Agents" will reach 347,926 covered institutions only through FinCEN's secure portal, because publishing it would let the network swap in new companies. The two earlier section 9714 actions were orders against single exchanges. This one is a notice-and-comment rule against a class of transactions, and it counts the ruble stablecoin A7A5 as currency.
The document that matters this week is not the press release. On October 1 the Treasury Department announced that OFAC had designated the A7 Network, the payments operation built by fugitive Moldovan oligarch Ilan Shor and Russia's state defense bank Promsvyazbank, as a significant transnational criminal organization. Secretary Scott Bessent said Treasury "is dismantling the financial infrastructure that allows Iran and other adversaries to evade sanctions." Most coverage stopped there. The same day FinCEN released a 50-page notice of proposed rulemaking, scheduled for Federal Register publication on October 5, and that is where the new idea lives.
The rule would find that transactions involving any company outside the United States that is controlled by the A7 Network, which FinCEN calls a "Sub-Agent," are "a class of transactions of primary money laundering concern in connection with Russian illicit finance," and would prohibit every covered financial institution from "engaging in a transmittal of funds involving any A7 Network Sub-Agent," including to or from "any account or CVC address administered by or on behalf of" one. The definition section names six companies, all of them Dubai-based trading firms, "and any other entity identified by FinCEN as a Sub-Agent of the A7 Network." Then it explains how an institution will learn who the others are.
A blocklist delivered by secure message
FinCEN says it "would share that list with covered financial institutions through FinCEN's 'FI-Portal,' a secure messaging system," that the list "will be updated periodically, both to add additional Sub-Agents as well as to remove Sub-Agents," and that the prohibition applies "only as to those entities identified on that list." The reason for keeping it off the public record is stated plainly. FinCEN "has assessed that a broader public distribution of the list would undermine the purposes of the proposed rule—allowing the A7 Network to circumvent the proposed special measure through additional and new Sub-Agents."
That is a different shape from the two previous uses of this authority. Section 9714 of the Combating Russian Money Laundering Act lets the Treasury Secretary act against institutions or "classes of transactions" tied to Russian illicit finance, using either the five special measures of section 311 of the Patriot Act or a sixth, a ban on transmittals of funds. FinCEN's first use was an order against the exchange Bitzlato on January 18, 2023, effective February 1 of that year. The second was an order against the exchange PM2BTC on September 26, 2024. Both named one company and banned transmittals to it. The A7 action is the first the desk has found that targets a class defined by control rather than by name, and the first to go through notice and comment. FinCEN says it chose a rulemaking over an order specifically so that institutions could "comment on the proposed mechanisms through which FinCEN will identify Sub-Agents." Comments are due 30 days after publication, to docket FINCEN-2026-0265.
The rule does include a safety valve. An entity that believes it has been wrongly listed may petition for reconsideration, and if it succeeds "FinCEN would update the list accordingly." Institutions would not be barred from telling a customer that a payment was refused because a party is on the list. What the rule does not provide is any way for a counterparty, a journalist or a court to read the list itself.
Six names, $67 million, and a few hundred more
The six companies FinCEN does name come with figures from its own analysis of "public and nonpublic information." Power Sphere LLC-FZ, an electronics supplier, "processed USD 61 million in illicit funds tied to Russian trade-based money laundering and procurement activities in the energy sector" between September 2023 and July 2025. The others are smaller, down to Pearl Bridge, a precious-metals trader that moved "approximately USD 30,000" in April 2025. Gimli Trade LLC-FZ, which FinCEN says kept a ruble account at Promsvyazbank, was already sanctioned by the United Kingdom on December 18, 2025. All six were identified as A7 entities a year ago in the Centre for Information Resilience's report "A7 Abroad," which the rule cites for each.
The six Sub-Agents named in the proposed rule
| Company (all Dubai, UAE) | FinCEN's figure | Window |
|---|---|---|
| Power Sphere LLC-FZ | $61 million | Sep 2023 – Jul 2025 |
| Hydrofusion Resources FZ-LLC | $3.6 million | May – Jun 2025 |
| Gimli Trade LLC-FZ | $1.5 million | May – Jun 2025 |
| Galadriel Trading FZCO | more than $946,000 | May – Jul 2025 |
| Sigizmund FZCO | $41,000 | Jul – Sep 2025 |
| Pearl Bridge | about $30,000 | Apr 2025 |
The scale of what is not named is in the same document. As of June 2026, FinCEN says, the network "has created or acquired hundreds of Sub-Agents, with bank accounts at approximately 435 financial institutions in at least 83 countries," formed or bought in Hong Kong, Indonesia, the Kyrgyz Republic, the Seychelles, Türkiye and the UAE, and represented on paper as owned by third-country nationals. In aggregate they "processed more than 17 billion in USD-denominated transactions between January 2025 and June 2026." Two unnamed ones carry the Iran allegations that gave the operation its name: one Sub-Agent and a sister company "received nearly USD 140 million from entities involved in Iranian sanctions evasion" between July 2023 and October 2025, and another sent "approximately USD 1.6 million" to "a company linked to Iranian sanctions evasion and weapons procurement efforts." The companion alert says Bank Secrecy Act data "indicates that Iranian actors are leveraging the A7 Network, including the Central Bank of Iran" and the IRGC, and asks filers to tag reports with the key term FIN-2026-A7NETWORK.
A stablecoin that counts as currency
The crypto half of the rule is A7A5, the ruble-backed token issued by Kyrgyz-registered Old Vector LLC on Tron and Ethereum, whose contract addresses the NPRM prints in a footnote. FinCEN "found that more than 180 entities processed A7A5 transactions worth at least USD 179.1 billion, between February 2025 and June 2026," almost all of it through the sanctioned exchanges Garantex and Grinex. The number is larger than any the analytics firms have published, and the firms have spent a year arguing about what A7A5's volume means. TRM Labs' June "A7 Leaks" report, which the rule cites, counted about $110 billion in A7A5 volume and put roughly a third of it down to circular transfers. Elliptic's July post-mortem dates the peak to July 2025, above $1 billion a day, and the trough to June 2026, a daily average of $24.3 million, with no new issuance after July 23, 2025. Crystal Intelligence's August analysis found 94.5 percent of the supply in a single Tron wallet created on May 18, 2026, weeks after Grinex halted.
FinCEN reads the same chart and draws the same conclusion. After "an alleged hack of Grinex in April 2026," it writes, "A7A5 has been consolidated into unhosted wallets, suggesting the A7 Network may be moving away from using sanctioned exchanges." Elliptic put the Grinex loss at more than a billion rubles, around $15 million, on April 16. The alert adds a line that U.S. compliance teams will want to read twice: "U.S. financial institutions are unlikely to directly see A7A5 transactions, as they primarily move between sanctioned entities." What they may see instead, it says, are "wrapped" tokens pegged to A7A5 on chains where it is not native, reached through decentralized finance applications, and third-country over-the-counter brokers "newly created or dramatically expanding their stablecoin trading operations."
Two drafting choices make the token reachable at all. The rule defines "transmittals of funds" as "the sending and receiving of funds, including convertible virtual currency," overriding the narrower definition elsewhere in FinCEN's regulations, and then adds: "Despite having legal tender status in at least one jurisdiction, for the purpose of this NPRM, the A7A5 stablecoin is included as a type of CVC." The rule does not say which jurisdiction. The point of the sentence is that a token backed by rubles at a Russian bank cannot escape a ban on crypto transfers by calling itself money. FinCEN also explains why it skipped the correspondent-account measure it has used against foreign banks for twenty years: that measure "would not address the movement of funds outside the traditional banking relationship," because A7A5 transactions "do not rely on the correspondent banking system."
Who has to comply
The rule's own impact table puts the population of covered institutions at 347,926, of which 332,068 are money services businesses, a category that includes every registered crypto exchange and transmitter. FinCEN "conservatively estimates" that only ten percent, about 35,000, would face more than a de minimis burden, and argues the cost is low because the systems institutions already use to screen OFAC lists "are expected to be easily modified." That argument assumes the screening list arrives through the same pipes. It will not. It arrives by portal, and the rule asks for comment on exactly that.
The OFAC designation, meanwhile, already does part of the work. The Treasury release says that as a result of the TCO designation, transactions involving Sub-Agents "acting for or on behalf of the A7 Network" are blocked property, and the NPRM says an institution that blocks under OFAC rules "would be deemed to comply" with the special measure. The release also notes the A7A5 token is itself blocked property through Old Vector, that the network "has been linked to Nobitex," the Iranian exchange OFAC designated on June 2, and that the United Kingdom's National Crime Agency issued its own alert on A7 on August 31. By Treasury's count, A7 had handled 7.5 trillion rubles, about $91.5 billion, by January 2026, and 13 percent of Russia's 2025 foreign trade.
The Take
A sanctions list you cannot read is a new instrument, and FinCEN deserves credit for saying so out loud and asking for comment instead of issuing an order. The reasoning is sound as far as it goes: A7 builds Sub-Agents faster than anyone can designate them, and publishing the names is a free tip-off. But the design has a cost that the 50 pages do not weigh. Every prior blocklist in this field, from the SDN list to the Bitzlato order, could be checked by the person being blocked, by their bank's correspondent, and by a reporter. This one can be checked only by the roughly 348,000 institutions who are told to obey it, who in turn may tell a customer they are on it but not show them the page. The petition process is the only door, and it opens from the inside. The crypto detail is the one to watch. By defining A7A5 as convertible virtual currency despite its "legal tender status in at least one jurisdiction," FinCEN has written a rule that follows a ruble token wherever it is wrapped or bridged, and it has told compliance teams the token will mostly show up as something else. That is the right description of how sanctioned stablecoins actually move. It is also an open-ended mandate to screen for a token nobody on the U.S. side is likely to see directly, against a list nobody outside the portal can audit.