US moves against the A7 Network, a shadow banking network Treasury says Iran uses to evade sanctions
On 1 October 2026, OFAC sanctioned the network and FinCEN proposed cutting its sub-agents off from US fund transfers, alongside a new alert for banks.
On 1 October 2026, the US Treasury took three steps against what it calls the A7 Network, a shadow banking network with ties to Russia that the Iranian regime uses to evade sanctions. The action is part of Treasury's Operation Economic Outcast.
First, OFAC sanctioned the A7 Network as a significant transnational criminal organization. Second, FinCEN proposed a rule that would prohibit transfers of funds involving the network's sub-agents. Third, FinCEN issued an alert to help financial institutions detect and report activity connected to the network.
The FinCEN announcement does not give dollar figures for this network.
Why it matters to AML professionals
When FinCEN issues an alert like this, AML professionals are expected to use it: screen and monitor for the patterns it describes and reference it in any related SAR. A proposed funds-transfer ban also means payment and correspondent banking teams should check now whether any counterparties could be sub-agents.
Red flags in this case
- Payments routed through intermediaries in third countries with no clear link to the stated trade
- Front companies with little real activity acting as payers for unrelated businesses
- Counterparties whose ownership or location is hard to confirm
- Activity matching the patterns described in the FinCEN alert on the A7 Network
Sources
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