Operation Economic Outcast Takes Unprecedented Action Against Sanctions Evasion Network Used by Iran

WASHINGTON—Today, as part of Operation Economic Outcast, the U.S. Department of the Treasury took unprecedented action against the A7 Network, a shadow banking network with ties to Russia used by the Iranian regime to evade sanctions.

Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule that would prohibit transmittals of funds regarding transactions involving the A7 Network’s Sub-Agents.
Additionally, FinCEN issued an Alert to help financial institutions detect and report suspicious activity related to the A7 Network.
Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the A7 Network as a significant transnational criminal organization.

“Treasury is dismantling the financial infrastructure that allows Iran and other adversaries to evade sanctions, move illicit funds, and undermine the integrity of the global financial system,” said Secretary of the Treasury Scott Bessent. “Today’s action targeting A7 continues Treasury’s unprecedented efforts to isolate Iran and its financial enablers and sends a clear message that if you facilitate illicit finance for America’s adversaries, you will lose access to the U.S. financial system.”

The A7 Network was created and backed by U.S.-sanctioned persons in order to evade sanctions. It has developed a global web of Sub-Agents, companies that are purpose-built to disguise payments linked to sanctioned sectors and persons as ordinary commercial activity. The A7 Network has been leveraged by Iran, including Iran’s Islamic Revolutionary Guard Corps. Today’s actions build on the August 14, 2025 designation of several A7 Network entities, such as A7 LLC and Old Vector LLC, by exposing the broader network itself to U.S. sanctions.

THE A7 NETWORK’S FACILITATION OF RUSSIAN ILLICIT FINANCE: CREATING A PARALLEL FINANCIAL SYSTEM

As set out in the notice of proposed rulemaking, the A7 Network’s Sub-Agents are a constellation of companies based in third-country jurisdictions designed to receive and remit payments to facilitate transactions for the A7 Network. These Sub-Agents form a core layer of the A7 Network’s operational architecture as a purpose-built sanctions evasion and money laundering mechanism connected to Russian illicit finance and exploited by other illicit finance threat actors, including Iran. The public comment period will close 30 days after the NPRM is published in the Federal Register.

The A7 Network exploits the international financial system by leveraging Sub-Agents, falsified trade documents, falsified import-export records, and misleading goods descriptions to make sanctioned or illicit payments appear to be ordinary commercial activity. By its own account, as of January 2026, the A7 Network claimed to process more than 2,000 transactions a day with a total transaction volume of more than 7.5 trillion rubles, the U.S. dollar equivalent of $91.5 billion or approximately 13 percent of the Russian Federation’s 2025 foreign trade transactions.

Today’s notice of proposed rulemaking, issued pursuant to section 9714(a) of the Combating Russian Money Laundering Act, is not limited to Russian sanctions evasion. The same A7 Network Sub-Agents that enable Russian illicit finance created pathways for other actors, including the Central Bank of Iran, the IRGC, and Iran-backed terrorist organizations, to move funds through the international financial system. Beyond state actors, A7 Network Sub-Agents also catered to cybercriminals, including ransomware and procurement actors seeking to obtain restricted goods, to move funds through the international financial system. FinCEN’s investigation identified that the A7 Network’s Sub-Agents processed more than $17 billion between January 2025 and June 2026, aggregated globally.

In addition, A7 Network Sub-Agents have been used to facilitate Iranian oil sales and weapons procurement efforts. For example, one A7 Network Sub-Agent directly transacted with entities involved in Iran’s “shadow fleet”—the network of tankers, shipping companies, and front companies used to transport and sell Iranian oil in contravention of U.S. and international sanctions; that same A7 Network Sub-Agent and its sister company received nearly $140 million from entities involved in Iranian sanctions evasion. A separate A7 Network Sub-Agent transferred approximately $1.6 million to a company linked to Iranian sanctions evasion and weapons procurement efforts.

FINCEN ISSUING KEY INDICATORS OF A7 NETWORK ACTIVITY

FinCEN’s Alert will assist financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity and specifies a list of red flags to assist in identifying activity involving the A7 Network. The Alert describes the A7 Network’s use of foreign companies to facilitate its access to international payment systems.

FinCEN’s Notice of Proposed Rulemaking can be found here.

FinCEN’s Alert can be found here.

Today’s action follows the United Kingdom’s National Crime Agency’s August 31, 2026 Alert on A7 which describes the use of the A7 Network to facilitate sanctions evasion and illicit financial activity involving Russia and Iran.

For questions on FinCEN’s Notice of Proposed Rulemaking or Alert, please contact FinCEN at http://www.fincen.gov/contact.

A7 DESIGNATED AS TRANSNATIONAL CRIMINAL ORGANIZATION

Today, OFAC is complementing FinCEN’s action against the A7 Network by sanctioning it as a significant transnational criminal organization. As described above, the A7 Network is a shadow banking network with ties to Russia that utilizes money laundering methodologies to fraudulently move vast sums of money in violation of sanctions and other laws in the jurisdictions in which it operates. The A7 Network is led by Ilan Mironovich Shor, a sanctioned and convicted criminal fraudster, and includes a constellation of companies known as Sub-Agents that it uses to disguise illicit transactions as legitimate trade. Today’s action in furtherance of Operation Economic Outcast underscores the A7 Network’s financial support of Iran’s Islamic Revolutionary Guard Corps, as well as Iranian proxies, such as Hamas. Furthermore, the A7 Network has been linked to Nobitex, Iran’s largest digital asset exchange, which OFAC designated on June 2, 2026, and has also facilitated transactions related to North Korean hacks of cryptocurrency exchanges and other illicit actors.

The A7 Network’s Sub-Agents are wholly controlled by A7 Network individuals. A7 Network Sub-Agents’ websites and bank accounts are controlled by A7 Network staff, who access Sub-Agent financial accounts using custom-built Virtual Private Networks that mask their true location and permit the rapid execution of payments.

The A7A5 token is a blocked, ruble-backed token issued by Old Vector LLC, which OFAC designated on August 14, 2025 and is part of the A7 Network. The A7 Network created the token for its members to evade sanctions and transact internationally while generating revenue for sanctioned infrastructure providers that profit from the token’s circulation.

SANCTIONS IMPLICATIONS OF TODAY’S OFAC ACTION AGAINST THE A7 NETWORK

As a result of today’s action, 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 U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.

Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person. Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions.

Individuals located in the United States or abroad who provide information to about sanctions violations to FinCEN’s whistleblower incentive program may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding $1,000,000. As highlighted in FinCEN’s recent Bulletin, this includes information about violations of the Bank Secrecy Act or OFAC-administered sanctions programs that may involve the use of Iranian proxies and facilitators operating outside of Iran.

For more information on today’s sanctions action, click here.

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