On October 1, 2026, the U.S. Department of the Treasury took unprecedented action against the A7 Network as part of Operation Economic Outcast. The A7 Network is a shadow banking network with ties to Russia used by the Iranian regime to evade sanctions.
According to the Treasury, the A7 Network has developed a global web of Sub-Agents, which are companies purposely 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.
In conjunction with the sanctions, FinCEN issued a finding and notice of proposed rulemaking, finding transactions involving any company operating outside of the United States that is controlled by the A7 Network to be a class of transactions of primary money laundering concern in connection with Russian illicit finance. The proposed rule proposes the imposition of a prohibition on certain transmittals of funds, by any covered financial institution, involving that class of transactions.
Written comments on the notice of proposed rulemaking will be accepted until November 4, 2026.
The Treasury’s press release can be found here.
The proposed rule can be found here.