The Treasury Department's Financial Crimes Enforcement Network (FinCEN) has proposed a rule that would bar U.S. banks and other covered financial institutions from sending or receiving funds through named sub-agents of the A7 Network. FinCEN describes the network as a Russia-linked sanctions-evasion and money-laundering operation. The proposal was filed for public inspection October 2 and is scheduled to be published in the Federal Register on October 5, 2026 — it is not yet in effect.
Who FinCEN names
The proposed rule text defines the "A7 Network" as "the core grouping of entities and persons involved in the operation of a Russian-Kyrgyzstan based sanctions evasion and money laundering network," naming A7 LLC, A71 LLC, A7 Agent LLC, Old Vector LLC, Garantex, Grinex, InDeFi Bank, ExVed, Mendeleev, Ilan Shor and Promsvyazbank. The sub-agents it names are Galadriel Trading FZCO, Gimli Trade LLC-FZ, Hydrofusion Resources FZ-LLC, Pearl Bridge, Power Sphere LLC-FZ and Sigizmund FZCO, plus any other entity FinCEN identifies as a sub-agent. That working list would not be public: FinCEN says it would pass the list to covered institutions through a secure messaging system and update it periodically, because wider distribution "would undermine the purposes of the proposed rule." A listed entity could petition FinCEN by email to be taken off. These are FinCEN's characterizations in a proposal, and the document charges no one with a crime.
What the prohibition would require
The rule text would prohibit a covered financial institution from "engaging in a transmittal of funds involving any A7 Network Sub-Agent," including any transfer from or to a sub-agent, or from or to any account or virtual-currency address administered by or on behalf of one. For this section, "transmittals of funds" means the sending and receiving of funds "including convertible virtual currency," and the proposal counts the A7A5 stablecoin as such a currency.
Three duties follow. When a transmittal is prohibited, or is blocked under OFAC sanctions, the institution must notify "affected persons associated with the transmittal of funds" with which it maintains a direct commercial relationship. On screening, an institution "shall take a risk-based approach when deciding what, if any, other due diligence measures it reasonably must adopt." On records, it must document its compliance with that notification duty, and the rule would add no reporting requirement "not otherwise required to be reported by law or regulation."
"Covered financial institution" borrows the Bank Secrecy Act's existing definition of "financial institution" at 31 CFR 1010.100(t) — a category the proposal's own cost tables spread across banks, broker-dealers, money services businesses, casinos and mutual funds.
The authority FinCEN cites
FinCEN points to Section 9714(a) of the Combating Russian Money Laundering Act (Public Law 116-283), as amended by Section 6106(b) of the National Defense Authorization Act for Fiscal Year 2022 (Public Law 117-81). It applies once the Treasury secretary finds "reasonable grounds" that a class of transactions is "of primary money laundering concern in connection with Russian illicit finance." The document says that section carries six special measures: the five set out in 31 U.S.C. 5318A(b), commonly known as Section 311 of the USA PATRIOT Act, and, in addition to those, one "prohibiting, or imposing conditions upon, certain transmittals of funds." This proposal uses that last measure.
What came before
The proposal follows an October 1, 2026 action in which Treasury's Office of Foreign Assets Control sanctioned the A7 Network, which the document says was designated for being a foreign person that "constitutes a significant Transnational Criminal Organization." The document's background section also cites an August 14, 2025 Treasury sanctions action against a cryptocurrency exchange and network. Those were sanctions designations; this is an NPRM — a notice of proposed rulemaking, the formal first step before a rule can take effect.
What it would not do
FinCEN says nothing in the proposal should be read to "modify, impair, or otherwise affect" a covered institution's existing Bank Secrecy Act obligations, including the filing of Suspicious Activity Reports, or the sanctions OFAC administers. Where a duty to block property under existing OFAC sanctions appears to conflict with this measure, the document says the institution should comply with the blocking obligation and would then be "deemed to comply" with the special measure. The proposal is not final; it is open for public comment.
The dates
The DATES line of the public-inspection copy prints a placeholder, "[INSERT DATE 30 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER]," rather than a calendar date, and FinCEN says it is "requesting comments for 30 days after the publication of this NPRM." By this desk's count, if the October 5 publication date holds, that places the deadline on November 4, 2026. Comments may be submitted one of two ways: through regulations.gov, or by mail to FinCEN, P.O. Box 39, Vienna, VA 22183, referring to docket FINCEN-2026-0265.