Finding and NPRM: Special measure regarding transactions involving the A7 Network's sub-agents (91 FR 63208) (Part 1 of 2)

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

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2026-10-05

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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

63208                  Federal Register / Vol. 91, No. 191 / Monday, October 5, 2026 / Proposed Rules

                                                CONSUMER PRODUCT SAFETY                                 information about joining the webinar.                present and, in accordance with the
                                                COMMISSION                                              All other individuals who wish to                     requirement in section 9 of the CPSA,
                                                                                                        attend the meeting virtually but are not              the Commission is providing a forum for
                                                16 CFR Parts 1112 and 1265                              presenting should register using the                  oral opportunity to make an oral
                                                [Docket No. CPSC–2025–0012]                             same internet link provided above                     presentation, see the information under
                                                                                                        before the start of the hearing.                      the DATES and ADDRESSES sections of
                                                RIN 3041–AE10                                                                                                 this document.1 Each oral presentation
                                                                                                        FOR FURTHER INFORMATION CONTACT: For
                                                                                                        further information about the subject                 will be limited to 5 minutes, excluding
                                                Safety Standard for Lithium-Ion                                                                               time for questioning by the
                                                Batteries Used in Micromobility                         matter of this hearing, contact Jay
                                                                                                        Kadiwala, Project Manager, Electrical                 Commissioners or CPSC staff. Oral
                                                Products and Electrical Systems of                                                                            presentations must be limited to matters
                                                Micromobility Products Containing                       Engineer, Office of Risk Reduction,
                                                                                                        Consumer Product Safety Commission,                   within the scope of the NPRM identified
                                                Such Batteries                                                                                                in this notice. To avoid duplicate
                                                                                                        National Product Testing and
                                                AGENCY: Consumer Product Safety                         Evaluation Center, 5 Research Place,                  presentations, groups or participants
                                                Commission.                                             Rockville, MD 20850; telephone: (301)                 with substantially similar comments
                                                ACTION: Announcement of opportunity                     987–2517; email: [email protected].                  should designate a spokesperson, and
                                                for oral presentation of comments.                      For information about the hearing                     the presiding officer may impose
                                                                                                        procedure to make an oral presentation,               additional reasonable restrictions as
                                                SUMMARY: The Consumer Product Safety                                                                          necessary for the orderly and efficient
                                                                                                        contact Alberta E. Mills, Office of the
                                                Commission (Commission or CPSC) is                      Secretary; telephone: 301–504–7479;                   conduct of the hearing.
                                                providing an opportunity for interested                 email: [email protected].                              Alberta E. Mills,
                                                parties to present oral comments on the
                                                notice of proposed rulemaking (NPRM)                    SUPPLEMENTARY INFORMATION:                            Secretary, Consumer Product Safety
                                                                                                                                                              Commission.
                                                the Commission issued for a safety                      I. Background
                                                                                                                                                              [FR Doc. 2026–20296 Filed 10–2–26; 8:45 am]
                                                standard for lithium-ion batteries. Oral
                                                                                                           On June 24, 2026, the Commission                   BILLING CODE 6355–01–P
                                                presentations must be limited to matters
                                                                                                        published an NPRM in the Federal
                                                within the scope of the NPRM. Any oral
                                                                                                        Register, proposing to issue a safety
                                                comments will become part of the
                                                                                                        standard for lithium-ion batteries used               DEPARTMENT OF THE TREASURY
                                                rulemaking record.
                                                                                                        in micromobility products under the
                                                DATES: The virtual meeting will begin at
                                                                                                        Consumer Product Safety Act (CPSA; 15                 Financial Crimes Enforcement Network
                                                10 a.m. Eastern time on October 21,                     U.S.C. 2051–2089), and seeking written
                                                2026. Any individual interested in                      comments. 91 FR 38162. The NPRM                       31 CFR Part 1010
                                                making an oral presentation must                        seeks to address the unreasonable risk of
                                                submit a request to make an oral                                                                              RIN 1506–AB77
                                                                                                        injury and death associated with
                                                presentation to the Office of the                       micromobility products due to hazards
                                                Secretary, along with the written text of                                                                     Proposal of Special Measure
                                                                                                        such as thermal runaway of lithium                    Prohibiting the Transmittal of Funds
                                                the oral presentation. Request must be                  cells, which can lead to fires,
                                                received no later than 5 p.m. Eastern                                                                         Regarding Transactions Involving the
                                                                                                        explosions, gas releases, burns,                      A7 Network’s Sub-Agents
                                                time on October 15, 2026. All attendees                 overheating, and smoke inhalation. The
                                                planning to present must pre-register no                NPRM proposes that electrical systems                 AGENCY: Financial Crimes Enforcement
                                                later than 5 p.m. Eastern time on                       using lithium-ion batteries in                        Network (FinCEN), Treasury.
                                                October 15, 2026, at the website in                     micromobility products comply with                    ACTION: Notice of proposed rulemaking.
                                                ADDRESSES.
                                                                                                        applicable voluntary standards, with                  SUMMARY: FinCEN is issuing a finding
                                                ADDRESSES: The opportunity to present                   modifications. The NPRM is available                  and notice of proposed rulemaking,
                                                oral presentation of comments will be                   at: https://www.federalregister.gov/                  pursuant to section 9714(a) of the
                                                held virtually as a webinar meeting at                  documents/2026/06/24/2026-12749/                      Combating Russian Money Laundering
                                                https://events.gcc.teams.microsoft.com/                 safety-standard-for-lithium-ion-                      Act (Public Law 116–283), as amended
                                                event/49fa92df-dd39-4c16-803b-cd59                      batteries-used-in-micromobility-                      by section 6106(b) of the National
                                                dd7847b8@7f5de26c-a63d-475c-9b6c-                       products-and-electrical-systems-of.                   Defense Authorization Act for Fiscal
                                                4126a914e132?source=
                                                                                                        II. The Public Hearing                                Year 2022 (Public Law 117–81), finding
                                                copyLinkLegacyShareLinkDialog.                                                                                transactions involving any company
                                                Attendance is free of charge. Requests to                 The Administrative Procedure Act (5                 operating outside of the United States
                                                make oral presentations must provide                    U.S.C. 551–562) and section 9 of the                  that is controlled by the A7 Network, a
                                                the written text of oral presentations to               CPSA require the Commission to                        sanctions evasion and money
                                                the Office of the Secretary, with the                   provide interested parties with an                    laundering service with ties to Russia,
                                                caption, ‘‘Lithium-Ion Battery NPRM;                    opportunity to submit ‘‘written data,                 leveraged by a wide range of illicit
                                                Oral Presentation,’’ by email to cpsc-os@               views, or arguments’’ regarding a                     actors, including Iran and its terrorist
                                                cpsc.gov. All attendees planning to                     proposed rule. 5 U.S.C. 553(c); see 15                proxies, to be a class of transactions of
                                                present must pre-register for the                       U.S.C. 2058(d)(2). The NPRM invited                   primary money laundering concern in
                                                webinar online at: https://                             such written comments. In addition,                   connection with Russian illicit finance

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                                                events.gcc.teams.microsoft.com/event/                   section 9 of the CPSA requires the                    and proposing the imposition of a
                                                49fa92df-dd39-4c16-803b-cd59                            Commission to provide interested                      prohibition on certain transmittals of
                                                dd7847b8@7f5de26c-a63d-475c-9b6c-                       parties ‘‘an opportunity for oral                     funds, by any covered financial
                                                4126a914e132?source=copyLinkLegacy                      presentation of data, views, or                       institution, involving that class of
                                                ShareLinkDialog, no later than 5 p.m.                   arguments.’’ 15 U.S.C. 2058(d)(2). The                transactions.
                                                Eastern time on October 15, 2026. After                 Commission must keep a transcript of
                                                registering, presenters will receive a                  such oral presentations. Id. The                        1 The Commission voted 3–0 to publish this

                                                confirmation email containing                           Commission received requests to                       notification.

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                                                                        Federal Register / Vol. 91, No. 191 / Monday, October 5, 2026 / Proposed Rules                                                   63209

                                                DATES: Written comments on the notice                   transactions present a material risk of                special measures one through four, the
                                                of proposed rulemaking must be                          facilitating funds transfers designed to               Secretary may impose additional
                                                submitted on or before November 4,                      evade sanctions by illicit actors,                     recordkeeping, information collection,
                                                2026.                                                   including Russian and Iranian persons                  and reporting requirements on covered
                                                ADDRESSES: Comments must be                             that have been designated by Treasury’s                financial institutions.6 Through special
                                                submitted in one of the following two                   Office of Foreign Assets Control                       measure five, the Secretary, in
                                                ways (please choose only one of the                     (OFAC), such as the Islamic                            consultation with the Secretary of State,
                                                ways listed):                                           Revolutionary Guard Corps (IRGC), and                  the Attorney General, and the Chairman
                                                  • Federal E-rulemaking Portal:                        intended to support illicit activities,                of the Board of Governors of the Federal
                                                https://www.regulations.gov. If you are                 including sanctions evasion involving                  Reserve System, may ‘‘prohibit, or
                                                reading this document on                                or benefitting Russian and Iranian                     impose conditions upon, the opening or
                                                federalregister.gov, you may use the                    clients.                                               maintaining in the United States of a
                                                green ‘‘SUBMIT A PUBLIC COMMENT’’                                                                              correspondent account or payable-
                                                                                                        II. Background
                                                button beneath this rulemaking’s title to                                                                      through account’’ for or on behalf of a
                                                submit a comment to the regulations.gov                 A. Statutory Provisions                                foreign banking institution, if such
                                                docket.                                                    Section 9714(a) of the Combating                    correspondent account or payable-
                                                  • Mail: Financial Crimes Enforcement                  Russian Money Laundering Act (Pub. L.                  through account involves the class of
                                                Network, P.O. Box 39, Vienna, VA                        116–283), as amended by section                        transactions found to be of primary
                                                22183. Refer to Docket Number                           6106(b) of the National Defense                        money laundering concern.7 In addition
                                                FINCEN–2026–0265 in the submission.                     Authorization Act for Fiscal Year 2022                 to the special measures set out in 31
                                                  Do not include any personally                                                                                U.S.C. 5318A, section 9714 also
                                                                                                        (Pub. L. 117–81) (section 9714),2
                                                identifiable information (such as name,                                                                        provides that the Secretary may impose
                                                                                                        provides, in relevant part, that, if the
                                                address, or other contact information) or                                                                      a special measure prohibiting, or
                                                                                                        Secretary of the Treasury (Secretary)
                                                confidential business information that                                                                         imposing conditions upon, certain
                                                                                                        ‘‘determines that reasonable grounds
                                                you do not want publicly disclosed. All                                                                        transmittals of funds.8
                                                                                                        exist for concluding that . . . one or
                                                comments are public records; they are
                                                                                                        more classes of transactions within, or                B. A7 Network and its Sub-Agents
                                                publicly displayed exactly as received,
                                                                                                        involving, a jurisdiction outside the
                                                and will not be deleted, modified, or
                                                                                                        United States . . . is of primary money                   The OFAC-sanctioned transnational
                                                redacted. Comments may be submitted
                                                                                                        laundering concern in connection with                  criminal organization (TCO), A7
                                                anonymously. Follow the search
                                                                                                        Russian illicit finance,’’ the Secretary               Network, is a global wholesale sanctions
                                                instructions on https://
                                                                                                        may, ‘‘by order, regulation, or otherwise              evasion and money laundering service
                                                www.regulations.gov to view public
                                                                                                        as permitted by law’’: (1) require                     with ties to Russia, leveraged by a wide
                                                comments.
                                                                                                        domestic financial institutions and                    range of illicit actors, including Iran and
                                                FOR FURTHER INFORMATION CONTACT:                        domestic financial agencies to take 1 or               its terrorist proxies. Approximately 80
                                                FinCEN’s Regulatory Support Section by                  more of the special measures described                 percent of Russian banks have been
                                                submitting an inquiry at                                in 31 U.S.C. 5318A(b); 3 or (2) prohibit,              sanctioned by the United States, United
                                                www.fincen.gov/contact.                                 or impose conditions upon, certain                     Kingdom, and European Union since
                                                SUPPLEMENTARY INFORMATION:                              transmittals of funds (as defined by the               2022, and numerous key Russian banks
                                                I. Summary of Notice of Proposed                        Secretary) by any domestic financial                   have lost their access to the Society of
                                                Rulemaking                                              institution or domestic financial agency,              Worldwide Interbank Financial
                                                                                                        if such transmittal of funds involves any              Telecommunication (SWIFT).9 U.S.,
                                                   This notice of proposed rulemaking                   such class of transaction. The authority               European Union (EU), and/or United
                                                (NPRM) (1) sets forth FinCEN’s finding                  of the Secretary to administer both                    Kingdom (UK) sanctions and the
                                                that transactions involving any                         section 9714 and the Bank Secrecy Act                  resulting ‘‘de-SWIFTing’’ of Russian
                                                company operating outside of the                        (BSA) has been delegated to FinCEN.4                   banks have significantly curtailed
                                                United States that is controlled by the                    Pursuant to section 9714, the                       Russia’s connectivity to the
                                                A7 Network 1 (a ‘‘Sub-Agent’’ and,                      Secretary may impose one or more of six                international financial system, leaving a
                                                collectively, the ‘‘Sub-Agents’’), are a                special measures. First, the Secretary                 void for the A7 Network to fill. Against
                                                class of transactions of primary money                  may impose any of the five special                     that backdrop and although the A7
                                                laundering concern in connection with                   measures provided for in 31 U.S.C.                     Network markets itself as merely an
                                                Russian illicit finance; and (2) proposes               5318A(b), commonly known as section                    alternative payment system, the A7
                                                prohibiting certain transmittals of funds               311 of the USA PATRIOT Act.5 Through                   Network was formally launched in
                                                involving that class of transactions by                                                                        September 2024 as a purpose-built
                                                any covered financial institution. As set                  2 Section 9714 (as amended) may be found in a       mechanism to evade Western sanctions
                                                out in this NPRM, transactions                          note to 31 U.S.C. 5318A.                               imposed in response to Russia’s further
                                                involving any Sub-Agent fall within a                      3 See infra note [4].
                                                                                                           4 Pursuant to Treasury Order 180–01, the
                                                class of transactions of primary money                                                                         United States is of primary money laundering
                                                                                                        authority of the Secretary to administer the BSA,
                                                laundering concern in connection with                   including, but not limited to, 31 U.S.C. 5318A, has    concern, to require domestic financial institutions
                                                Russian illicit finance, as such                        been delegated to the Director of FinCEN. U.S.         and domestic financial agencies to take certain
                                                                                                        Department of the Treasury, Treasury Order 180–01      ‘‘special measures.’’ Regarding the ‘‘special
                                                  1 On October 1, 2026, the Department of the           (Jan. 14, 2020). On August 11, 2022, and in            measures’’ that might be imposed, section 9714

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                                                                                                        accordance with Treasury Order 101–05 and 31           references the five special measures set out in 31
                                                Treasury’s Office of Foreign Assets Control (OFAC)
                                                                                                        U.S.C. 321(b), Treasury’s Under Secretary for          U.S.C. 5318A(b)(1)–(5).
                                                sanctioned the A7 Network pursuant to Executive                                                                   6 31 U.S.C. 5318A(b)(1)–(4).
                                                Order 13581, as amended by Executive Order              Terrorism & Financial Intelligence re-delegated to
                                                                                                                                                                  7 31 U.S.C. 5318A(b)(5).
                                                13863, for being a foreign person that constitutes a    the Director of FinCEN the authority of the
                                                                                                        Secretary under section 9714.                             8 See section 9714(a)(2).
                                                significant Transnational Criminal Organization.
                                                See U.S. Department of the Treasury, Operation             5 See 31 U.S.C. 5318A. 31 U.S.C. 5318A grants the      9 Congressional Research Service, Russia’s War on

                                                Economic Outcast Takes Unprecedented Action             Secretary the authority, upon finding that             Ukraine: Financial and Trade Sanctions (Feb. 22,
                                                Against Sanctions Evasion Network Used by Iran          reasonable grounds exist for concluding that one or    2023), at p. 2, https://www.congress.gov/crs-
                                                (Oct. 1, 2026).                                         more financial institutions operating outside of the   product/IF12062.

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                                                63210                   Federal Register / Vol. 91, No. 191 / Monday, October 5, 2026 / Proposed Rules

                                                invasion of Ukraine in 2022.10 However,                  United States, EU, and UK.14 These                      these persons described above that are
                                                as a self-described sanctions-resistant                  entities administer the network with                    in the United States or in the possession
                                                payment service provider, the A7                         and through several Russia- and Kyrgyz                  or control of U.S. persons are blocked
                                                Network has evolved into a conduit for                   Republic-based persons, including                       and must be reported to OFAC. In
                                                illicit activity associated with a wide                  businesses and digital asset exchanges                  addition, any entities that are owned,
                                                range of threat actors, including North                  subject to sanctions imposed by OFAC                    directly or indirectly, individually or in
                                                Korea (DPRK);Iran-backed terrorist                       and the UK (as well as, in most cases,                  the aggregate, 50 percent or more by one
                                                organizations; cybercriminals and                        the EU), including Old Vector LLC,                      or more blocked persons are also
                                                ransomware actors; and the IRGC.11                       Garantex, Grinex, Independent                           blocked. Unless authorized by a general
                                                   The A7 Network’s creation was driven                  Decentralized Finance Smartbank and                     or specific license issued by OFAC, or
                                                by two U.S.-, EU- and UK-designated                      Ecosystem (InDeFi Bank), ExVed, and                     exempt, OFAC’s regulations generally
                                                parties: fugitive Moldovan oligarch Ilan                 Garantex co-founder Sergey Mendeleev                    prohibit all transactions by U.S. persons
                                                Shor 12 and Russia’s state-owned                         (Mendeleev).15 Collectively, these                      or within (or transiting) the United
                                                defense bank Promsvyazbank Public                        entities leverage companies transacting                 States that involve any property or
                                                Joint Stock Company (PSB).13 The core                    in both fiat currency and digital assets                interests in property of designated or
                                                of the A7 Network is formed by three                     in complex trade-based money                            otherwise blocked persons. In addition,
                                                Russia-based companies—A7 Liability                      laundering schemes to enable illicit
                                                Company (A7 LLC), and its subsidiaries,                                                                          financial institutions and other persons
                                                                                                         actors to access the international
                                                A71 Limited Liability Company (A71                                                                               that engage in certain transactions or
                                                                                                         financial system.16
                                                LLC) and A7 Agent Limited Liability                         Significantly (and as noted above),                  activities with these sanctioned entities
                                                Company (A7 Agent LLC)—which are                         OFAC has designated the founders and                    and individuals may expose themselves
                                                jointly owned by Ilan Shor and PSB and                   these core components and enablers, as                  to sanctions, including making of any
                                                subject to sanctions imposed by the                      well as sanctioning the A7 Network as                   contribution or provision of funds,
                                                                                                         a significant TCO.17 As a result, all                   goods, or services by, to, or for the
                                                   10 At least some elements of the A7 Network had       property and interests in property of                   benefit of any designated person, or the
                                                a job posting listed in early 2026, seeking                                                                      receipt of any contribution or provision
                                                candidates with experience using SWIFT, and the             14 U.S. Department of the Treasury, Press Release,   of funds, goods, or services from any
                                                company has hired staff from major Russian
                                                banks—including OFAC-sanctioned Gazprombank,
                                                                                                         Treasury Sanctions Cryptocurrency Exchange and          such person, or be subject to an
                                                                                                         Network Enabling Sanctions Evasion and Cyber            enforcement action.
                                                VTB Bank, and Sberbank—suggesting that the A7            Criminals (Aug. 14, 2025), https://
                                                Network is intended to supplant the role previously
                                                filled by Russia’s heavily sanctioned banking sector.
                                                                                                         home.treasury.gov/news/press-releases/sb0225;              Building on these actions, FinCEN
                                                                                                         FCDO, UK Sanctions List, Several entities, https://     assesses that the A7 Network has
                                                HeadHunter, Manager for work with large and              search-uk-sanctions-list.service.gov.uk/
                                                medium-sized businesses (last accessed July 1,           ?searchValue=promsvyazbank, https://search-uk-          created, and continues to operate, a
                                                2026), https://hh.ru/vacancy/134528312?query=            sanctions-list.service.gov.uk/?searchValue=             financial network to further and enable
                                                A7+SWIFT&hhtmfrom=vacancy_search_list; Open              A7%2520llc; European Union Sanctions Tracker,
                                                Source Centre, The Big Shor: A7 and the illusion
                                                                                                                                                                 widespread sanctions evasion and the
                                                                                                         Ilan Shor, https://data.europa.eu/apps/
                                                of Russian financial innovation (2026), at p. 25,        eusanctionstracker/subjects/153809.
                                                                                                                                                                 laundering of billions of dollars tied to
                                                https://static.opensourcecentre.org/assets/osc_a7_          15 See FCDO, UK Sanctions List, Several entities,    illicit activity. When A7 LLC was
                                                big_shor.pdf.                                            https://search-uk-sanctions-list.service.gov.uk/        founded in 2024, PSB issued a press
                                                   11 See generally TRM Labs, ‘‘The A7 Leaks: TRM’s
                                                                                                         designations/RUS3614/Individual; https://               release touting the new service as a way
                                                On-Chain Analysis of Russia’s Cryptocurrency             www.gov.uk/government/news/uk-targets-
                                                Connections’’ (June 12, 2026).                           sanctions-circumvention-and-crypto-networks-            to ‘‘support Russian foreign trade
                                                   12 Ilan Shor was designated by OFAC in October
                                                                                                         exploited-by-russia. European Union Sanctions           participants and their trading partners
                                                2022, pursuant to E.O. 14024, for his involvement        tracker, Several entities, https://data.europa.eu/      amid anti-Russian sanctions pressure,’’
                                                in Russian malign influence operations in Moldova.       apps/eusanctionstracker/subjects/179337, https://
                                                He was previously arrested on money laundering           data.europa.eu/apps/eusanctionstracker/subjects/
                                                                                                                                                                 indicating that sanctions evasion is part
                                                and embezzlement charges related to a 2014 theft         172907, https://data.europa.eu/apps/                    of the business model.18 Speaking at the
                                                valued at approximately USD 1 billion from               eusanctionstracker/subjects/179375.                     Russia-China Mutually Beneficial
                                                Moldovan banks. U.S. Department of the Treasury,            16 See U.S. Department of the Treasury, Press
                                                                                                                                                                 Cooperation forum (ROSTKI) in August
                                                Press Release, Treasury Targets Corruption and the       Release, Treasury Sanctions Cryptocurrency
                                                Kremlin’s Malign Influence Operations in Moldova         Exchange and Network Enabling Sanctions Evasion
                                                                                                                                                                 2025, A7 LLC’s Vice President Mikhail
                                                (Oct. 26, 2022), https://home.treasury.gov/news/         and Cyber Criminals (Aug. 14, 2025), https://           Tolkunov described A7’s core
                                                press-releases/jy1049. Ilon Shor was also                home.treasury.gov/news/press-releases/sb0225; U.S.      capabilities:
                                                sanctioned by the United Kingdom on December 8,          Department of the Treasury, Press Release, Treasury
                                                2022. See UK Foreign, Commonwealth and                   Targets Corruption and the Kremlin’s Malign                ‘‘The company ‘A7’ was created by PSB
                                                Development Office (FCDO), Uk Sanctions List,            Influence Operations in Moldova (Oct. 26, 2022),        Bank [in 2025] and operates in the field of
                                                https://search-uk-sanctions-list.service.gov.uk/         https://home.treasury.gov/news/press-releases/          cross border transfers . . . the service allows
                                                designations/GAC0029/Individual.                         jy1049; U.S. Department of the Treasury, Press
                                                                                                                                                                 you to create a personal account remotely
                                                   13 PSB was designated by OFAC in February             Release, Treasury Sanctions Russia-Based Hydra,
                                                2022, pursuant to E.O. 14024, for issuing billions       World’s Largest Darknet Market, and Ransomware-         and transfer funds within one day with
                                                of dollars in financial support for Russian defense      Enabling Virtual Currency Exchange Garantex (Apr.       minimal fees. Document management is
                                                sector companies in its role as Russia’s state defense   5, 2022), https://home.treasury.gov/news/press-         carried out electronically . . . The platform
                                                bank. U.S. Department of the Treasury, Press             releases/jy0701; U.S. Department of the Treasury,       was created for transfers in any currency,
                                                Release, U.S. Treasury Imposes Immediate                 Press Release, U.S. Treasury Imposes Immediate
                                                                                                         Economic Costs in Response to Actions in the            including dollars, yuan, dirhams, and euros.
                                                Economic Costs in Response to Actions in the
                                                Donetsk and Luhansk Regions (Feb. 22, 2022),             Donetsk and Luhansk Regions (Feb. 22, 2022),            Transfers are completely secure, as our entire
                                                https://home.treasury.gov/news/press-releases/           https://home.treasury.gov/news/press-releases/          financial infrastructure is built on an
                                                jy0602. PSB was later redesignated in January 2025,      jy0602.                                                 independent architecture and is not tied to
                                                pursuant to E.O. 13662, for operating in the                17 On October 1, 2026, the Department of the

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                                                                                                                                                                 international payment systems. This means
                                                financial services sector of the Russian Federation      Treasury’s Office of Foreign Assets Control (OFAC)
                                                economy. U.S. Department of the Treasury, Press          sanctioned the A7 Network pursuant to Executive
                                                Release, Treasury Disrupts Russia’s Sanctions            Order 13581, as amended by Executive Order                 18 Promsvyazbank, PSB has launched a unique

                                                Evasion Schemes (Jan. 15, 2025), https://                13863, for being a foreign person that constitutes a    mechanism for crossborder settlements for foreign
                                                home.treasury.gov/news/press-releases/jy2785; see        significant Transnational Criminal Organization.        trade between Russian companies and
                                                also Open Source Centre, The Big Shor: A7 and the        See U.S. Department of the Treasury, Operation          counterparties from any country (Oct. 8, 2024),
                                                Illusion of Russian Financial Innovation (2026), at.     Economic Outcast Takes Unprecedented Action             https://www.oreanda-news.com/en/finansy/
                                                p. 9, https://static.opensourcecentre.org/assets/osc_    Against Sanctions Evasion Network Used by Iran          promsvyazbank-has-launched-a-mechanism-for-
                                                a7_big_shor.pdf.                                         (Oct. 1, 2026).                                         cross-border-settlements/article1531534/.

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                                                                        Federal Register / Vol. 91, No. 191 / Monday, October 5, 2026 / Proposed Rules                                                       63211

                                                we are not threatened by any unilateral                  based company reportedly used the A7                     Shor stated that ‘‘A7 plans to operate
                                                restrictions.’’ 19                                       Network to obfuscate transactions                        everywhere.’’ 28
                                                As of January 2026, the A7 Network                       related to the purchase of Russian gas                   III. Finding That Transactions
                                                claimed to process more than 2,000                       supplies for Türkiye following the                      Involving any Sub-Agent of the A7
                                                transactions per day with a historical                   imposition of sanctions on Russian bank                  Network Are a Class of Transactions of
                                                total transaction volume of more than                    Gazprombank, which typically handles                     Primary Money Laundering Concern in
                                                7.5 trillion rubles (RUB), the equivalent                energy transactions.24                                   Connection With Russian Illicit Finance
                                                of USD 91.5 billion. This would amount
                                                                                                            The scope of the A7 Network’s                            Based on public and non-public
                                                to nearly 13 percent of the Russian
                                                Federation’s 2025 foreign trade                          activities is only possible through its                  information available to FinCEN,
                                                transactions, meaning that nearly one in                 global network of Sub-Agents. Shortly                    FinCEN finds that reasonable grounds
                                                eight dollars of Russia’s foreign trade                  after its establishment, the A7 Network                  exist for concluding that transactions
                                                allegedly flows through A7’s Network.20                  began aggressively expanding into new                    involving any Sub-Agent of the A7
                                                   There are indications that the Russian                jurisdictions and forming companies—                     Network are a class of transactions of
                                                government perceives the A7 Network                      ‘‘Sub-Agents’’—controlled by the A7                      primary money laundering concern in
                                                to be a strategically important                          Network and designed to receive and                      connection with Russian illicit finance,
                                                enterprise. In September 2025 Russian                    remit payments to facilitate transactions                as such transactions present a material
                                                President Vladimir Putin attended the                    for the A7 Network. The first Sub-                       risk of facilitating funds transfers
                                                virtual ribbon cutting for the opening of                Agents were established in the Kyrgyz                    designed to evade sanctions by illicit
                                                an A7 Network office in Vladivostok,                     Republic, and the A7 Network has since                   actors, including Russian and Iranian
                                                Russia.21 Several oligarchs with close                   established Sub-Agents across Central                    persons that have been designated by
                                                ties to the Kremlin have reportedly used                                                                          OFAC, and intended to support illicit
                                                                                                         and East Asia, Africa, Europe, and the
                                                the A7 Network to make international                                                                              activities, including sanctions evasion
                                                                                                         Middle East.25
                                                payments, including UK-sanctioned                                                                                 involving or benefitting Russian and
                                                Roman Abramovich, OFAC-sanctioned                           The A7 Network has indicated it                       Iranian clients. In making this finding,
                                                former Federal Security Service Director                 plans to expand its global footprint,                    FinCEN has considered the relevant
                                                Nikolai Patrushev, OFAC-sanctioned                       potentially enhancing its reach and                      evidence in light of factors identified in
                                                Arkady Rotenberg, and businesses                         ability to move funds outside of the                     31 U.S.C. 5318A(c)(2)(B), taking into
                                                linked to UK-sanctioned Leonid                           formal financial system into currently                   account the specific circumstances of
                                                Mikkelson.22 Moreover, two OFAC-                         untapped regions, including Latin                        money laundering activities in
                                                sanctioned Russian financial                             America.26 Until recently, the A7                        connection with Russian illicit finance
                                                institutions maintain an interest in the                 Network only had a physical presence                     and the protection of U.S. national
                                                A7 Network, PSB and VEB.RF (VEB),                        in Russia, but in the fall of 2025 the                   security and the U.S. financial system.
                                                Russia’s state-owned development                         company announced the opening of its                     While FinCEN is under no obligation
                                                bank.23 Additionally, a Kyrgyzstan-                      first overseas offices in Nigeria and                    pursuant to section 9714 to consider any
                                                                                                         Zimbabwe and signaled aspirations to                     particular factor or set of factors when
                                                  19 Kommersant, Investment Cooperation Between
                                                                                                         further expand in Africa.27 In June 2026,                making a finding that a financial
                                                Russia and China: Growth Points. Kommersants                                                                      institution operating outside of the
                                                Session at the Third Russia-China International                                                                   United States is of primary money
                                                Forum (Aug. 19, 2025), at p. 2, https://                 Information Resilience, A7 Abroad: How A7 Sells
                                                www.events.kommersant.ru/events/sessiya-na-              International Sanctions Evasion as a Service (Oct.
                                                                                                                                                                  laundering concern in connection with
                                                rostki-2025.                                             2025), at p. 5, https://www.info-res.org/app/            Russian illicit finance, it nonetheless
                                                  20 Centre for Information Resilience, A7 in Africa     uploads/2025/10/A7-Abroad-FINAL-Copy.pdf. VEB            finds these factors instructive in guiding
                                                (Apr. 2, 2026), at p. 3, https://www.info-res.org/app/   was sanctioned by OFAC in 2022 at the same time          the analysis set forth below.29
                                                uploads/2026/04/A7-Africa-Final.pdf.                     as PSB. U.S. Department of the Treasury, U.S.
                                                  21 Radio Free Europe/Radio Liberty, A7, Company        Treasury Imposes Immediate Economic Costs in
                                                                                                                                                                     28 Reuters, Russia’s A7 transborder payments
                                                Implicated In Sanctions Evasion, Reportedly Linked       Response to Actions in the Donetsk and Luhansk
                                                                                                         Regions (Feb. 22, 2022), https://home.treasury.gov/      company plans global expansion (June 4, 2026),
                                                To Russian Oligarchs (Apr. 30, 2026), https://                                                                    https://www.reuters.com/business/finance/russias-
                                                www.rferl.org/a/russia-cryptocurrency-a7a5-ilan-         news/press-releases/jy0602. UK Foreign,
                                                                                                         Commonwealth and Development Office Sanctions            a7-transborder-payments-company-plans-global-
                                                shor-investigation-sanction-evasion/33746026.html.                                                                expansion-2026-06-04/.
                                                  22 Radio Free Europe/Radio Liberty, A7, Company        List, Roman Abrahmovich, (March 10, 2022)
                                                                                                                                                                     29 31 U.S.C. 5318A(c)(2)(B) provides, as relevant
                                                Implicated In Sanctions Evasion, Reportedly Linked       https://search-uk-sanctions-list.service.gov.uk/
                                                                                                         designations/RUS1126/Individual.                         here, that in making a finding that reasonable
                                                To Russian Oligarchs (Apr. 30, 2026), https://                                                                    grounds exist for concluding that a class of
                                                                                                            24 Radio Free Europe/Radio Liberty, A7, Company
                                                www.rferl.org/a/russia-cryptocurrency-a7a5-ilan-                                                                  transactions within, or involving, a jurisdiction
                                                shor-investigation-sanction-evasion/33746026.html;       Implicated In Sanctions Evasion, Reportedly Linked
                                                                                                                                                                  outside the United States is of primary money
                                                UK Foreign, Commonwealth and Development                 To Russian Oligarchs (Apr. 30, 2026), https://
                                                                                                                                                                  laundering concern and to apply one or more of
                                                Office Sanctions List, Roman Arkadyevich                 www.rferl.org/a/russia-cryptocurrency-a7a5-ilan-         special measures one through four to such a
                                                Abramovich (Mar. 10, 2022), https://search-uk-           shor-investigation-sanction-evasion/33746026.html.       financial institution, the Secretary shall consider
                                                                                                            25 Open Source Centre, The Big Shor: A7 and the
                                                sanctions-list.service.gov.uk/designations/                                                                       such information as the Secretary determines to be
                                                RUS0270/Individual; U.S. Department of the               Illusion of Russian Financial Innovation (2026), at.     relevant, including the following potentially
                                                Treasury, Treasury Designates Russian Oligarchs,         pp. 25–26, https://static.opensourcecentre.org/          relevant factors:
                                                Officials, and Entities in Response to Worldwide         assets/osc_a7_big_shor.pdf.                                 (1) The extent to which such financial
                                                Malign Activity (Apr. 6, 2018), https://                    26 See Centre for Information Resilience, A7
                                                                                                                                                                  institutions, transactions, or types of accounts are
                                                home.treasury.gov/news/press-releases/sm0338;            Abroad: How A7 Sells International Sanctions             used to facilitate or promote money laundering in
                                                U.S. Department of the Treasury, Treasury                Evasion as a Service (Oct. 2025), at p.8, https://       or through the jurisdiction, including any money
                                                Sanctions Russian Officials, Members Of The              www.info-res.org/app/uploads/2025/10/A7-Abroad-          laundering activity by organized criminal groups,
                                                Russian Leadership’s Inner Circle, And An Entity         FINAL-Copy.pdf; see also Alexander Osipovich,            international terrorists, or entities involved in the

lotter on DSK8BHNXB4PROD with PROPOSALS1
                                                For Involvement In The Situation In Ukraine (Mar.        ‘‘Russia’s Hottest Startup Is a State-Backed             proliferation of weapons of mass destruction or
                                                20, 2014), https://home.treasury.gov/news/press-         Sanctions Evasion Network,’’ The Wall Street             missiles;
                                                releases/jl23331; UK Foreign, Commonwealth and           Journal (Aug. 7, 2026), https://www.wsj.com/world/          (2) The extent to which such institutions,
                                                Development Office Sanctions List, Leonid                russia/russias-hottest-startup-is-a-state-backed-        transactions, or types of accounts are used for
                                                Viktorovich Mikhelson (Apr. 6, 2022), https://           sanctions-evasion-network-7afc488c?mod=article_          legitimate business purposes in the jurisdiction;
                                                search-uk-sanctions-list.service.gov.uk/                 inline.                                                  and
                                                designations/RUS1126/Individual.                            27 Centre for Information Resilience, A7 in Africa       (3) The extent to which such action is sufficient
                                                  23 PSB pledged its ownership stake in A7 LLC to        (Apr. 2, 2026), at p. 2, https://www.info-res.org/app/   to ensure, with respect to transactions involving the
                                                VEB as collateral for loans to A7 LLC. Centre for        uploads/2026/04/A7-Africa-Final.pdf.                                                                 Continued

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                                                63212                  Federal Register / Vol. 91, No. 191 / Monday, October 5, 2026 / Proposed Rules

                                                A. The Extent to Which Transactions                     (UAE). Although on paper, these                         provided by IT companies controlled by
                                                Involving any Sub-Agent of the A7                       companies are typically represented to                  Ilan Shor and have operated on the
                                                Network Are a Class of Transactions of                  be owned or managed by non-Russian                      domains muzpan.com and
                                                Primary Money Laundering Concern in                     third-country nationals, they are                       sodkamus.com and often appear to have
                                                Connection With Russian Illicit Finance                 ultimately controlled by with the A7                    IP addresses in Dubai, Hong Kong, or
                                                   As indicated above, the A7 Network                   Network.31 Once established, Sub-                       the Kyrgyz Republic, thereby disguising
                                                provides a financial services                           Agents provide the A7 Network with                      the connection to Russia.35 Thus, there
                                                infrastructure for clients in Russia and                access to correspondent banking                         is often no clear indication of a
                                                other heavily sanctioned jurisdictions,                 relationships and foreign-currency                      connection between a Sub-Agent and
                                                such as Iran, that enables those clients                liquidity, enabling the A7 Network to                   the A7 Network’s clients, including, in
                                                to make cross-border payments in both                   transmit value through the international                particular, clients in the heavily
                                                fiat currency and digital assets while                  financial system without a Russian or                   sanctioned jurisdiction, on whose behalf
                                                obscuring the sanctions nexus from U.S.                 other sanctioned customer appearing in                  the Sub-Agent is transacting. Sub-Agent
                                                and foreign financial institutions.                     the payment chain and commonly                          transactions, however, are likely to
                                                Importantly, a crucial feature of the A7                causing financial institutions to be                    exhibit typical money laundering
                                                Network’s financial services                            unwitting accomplices.                                  indicators, including transactions in
                                                infrastructure is, and remains, its use of,                In a typical A7 Network transaction,                 unusually high volumes shortly after the
                                                and reliance on, its Sub-Agents, offering               the A7 Network customer satisfies its                   company is formed, inconsistencies
                                                the A7 Network and its clients a means                  payment obligation through the A7                       between goods descriptions and
                                                of obfuscating the involvement of                       Network’s internal settlement system,                   supplier business profiles, unusual
                                                Russian or other sanctioned actors in                   while a Sub-Agent located outside of                    payment routing through A7 Network-
                                                payments that appear to financial                       Russia appears as the contracting or                    controlled companies, and falsified or
                                                institutions as ordinary commercial                     paying party on invoices, sales                         AI-altered invoices.36
                                                activity.                                               agreements, and payment instructions to                    FinCEN assesses that the layer of
                                                                                                        the ultimate supplier of a good. In                     obfuscation provided by Sub-Agents has
                                                1. The A7 Network’s Sub-Agents                          essence, this is a form of trade-based                  enabled the A7 Network to circumvent
                                                   Although the core operations of the                  money laundering that leverages Sub-                    U.S. sanctions and anti-money
                                                A7 Network are directed by A7 LLC and                   Agents, falsified trade documents, false                laundering and countering the financing
                                                its subsidiaries, working with and                      import-export records, and misleading                   of terrorism (AML/CFT) controls,
                                                through several Russia- and Kyrgyz                      goods descriptions. In many cases,                      tainting the global financial system with
                                                Republic-based businesses and digital                   funds may be transferred between                        billions in illicit funds stemming from,
                                                asset exchanges, the A7 Network’s Sub-                  multiple Sub-Agents to create additional                among other activities, Russian and
                                                Agents are a critical element within the                layers of obfuscation before arriving at                Iranian sanctions evasion.
                                                Network’s financial services                            the final destination.32 Through this
                                                                                                                                                                2. The A7 Network’s Use of Financial
                                                infrastructure, allowing the Network to                 process, the Sub-Agents provide the A7
                                                                                                                                                                Instruments Facilitates Illicit Cross-
                                                obfuscate the source and parties to                     Network with access to correspondent
                                                                                                                                                                Border Trade
                                                transactions, to access foreign                         banking relationships, access to the
                                                                                                        SWIFT network, and foreign-currency                        In a typical fiat transaction, the A7
                                                currencies, to make payments appear as
                                                                                                        liquidity, enabling it to transmit value                Network facilitates international trade
                                                ordinary commercial activity, and to
                                                                                                        through the international financial                     through extensive use of financial
                                                circumvent applicable sanctions and
                                                                                                        system without a Russian customer                       instruments, including bills of exchange
                                                other restrictions.                                                                                             or promissory notes (referred to as
                                                   As noted above, shortly after its                    appearing in the payment chain.33
                                                                                                           While funds are typically moved                      veksels in Russian), that record value
                                                establishment, the A7 Network began
                                                                                                        between companies by Moscow-based                       inside the Network. Specifically, an A7
                                                aggressively expanding into new
                                                                                                        A7 Network personnel, the A7 Network                    Network customer provides the A7
                                                jurisdictions and forming Sub-Agents,
                                                                                                        leverages Virtual Private Networks                      Network with information necessary to
                                                with the first Sub-Agents established in
                                                                                                        (VPNs) to create the illusion that these                execute the transaction, which may
                                                Kyrgyz Republic, followed by expansion
                                                                                                        individuals are located outside of Russia               include supplier information and trade
                                                across Central and East Asia, Africa,
                                                                                                        and obscuring the connection between                    documentation. The A7 Network then
                                                Europe, and the Middle East.30 As of                                                                            satisfies its customer’s payment
                                                                                                        Russia and the Sub-Agents.34 These
                                                June 2026, the A7 Network has created                                                                           obligation through A7 Network-
                                                                                                        VPNs typically depend on infrastructure
                                                or acquired hundreds of Sub-Agents,                                                                             controlled settlement mechanisms that
                                                with bank accounts at approximately                        31 See Open Source Centre, The Big Shor: A7 and      record value inside the Network.37
                                                435 financial institutions in at least 83               the Illusion of Russian Financial Innovation (2026),    Between September 30, 2024 and July
                                                countries.                                              at p. 33, https://static.opensourcecentre.org/assets/
                                                   To establish the Sub-Agents, the A7                  osc_a7_big_shor.pdf.
                                                                                                                                                                   35 See Open Source Centre, The Big Shor: A7 and
                                                                                                           32 A7 Abroad: How A7 Sells International
                                                Network forms, acquires, or partners                                                                            the Illusion of Russian Financial Innovation (2026),
                                                                                                        Sanctions Evasion as a Service (Oct. 2025), at p. 16,
                                                with companies in third countries—                      https://www.info-res.org/app/uploads/2025/10/A7-        at pp. 26, 39, https://static.opensourcecentre.org/
                                                such as Hong Kong, Indonesia, the                       Abroad-FINAL-Copy.pdf.                                  assets/osc_a7_big_shor.pdf.
                                                                                                                                                                   36 See Alexander Osipovich, ‘‘Russia’s Hottest
                                                Kyrgyz Republic, the Seychelles,                           33 Open Source Centre, The Big Shor: A7 and the

                                                                                                        illusion of Russian financial innovation (2026), at     Startup Is a State-Backed Sanctions Evasion
                                                Türkiye, and the United Arab Emirates                                                                          Network,’’ The Wall Street Journal (Aug. 7, 2026).
                                                                                                        pp. 41–42, https://static.opensourcecentre.org/
                                                                                                                                                                For more information about the use of AI to alter

lotter on DSK8BHNXB4PROD with PROPOSALS1
                                                                                                        assets/osc_a7_big_shor.pdf.
                                                jurisdiction and institutions operating in the             34 See Centre for Information Resilience, A7A5:      or generate fraudulent documents in furtherance of
                                                jurisdiction, that the purposes of this subchapter      Circumventing sanctions with stablecoin                 illicit finance schemes, see FinCEN, FIN–2024–
                                                continue to be fulfilled, and to guard against          cryptocurrency (June 25, 2025), at p. 15, https://      Alert004, ‘‘FinCEN Alert on Fraud Schemes
                                                international money laundering and other financial      www.info-res.org/app/uploads/2025/06/A7A5-              Involving Deepfake Media Targeting Financial
                                                crimes.                                                 Report-June-2025-Final-Draft-1.pdf; Open Source         Institutions’’ (Nov. 14, 2024), at pp. 3–5.
                                                   30 Open Source Centre, The Big Shor: A7 and the                                                                 37 See Open Source Centre, The Big Shor: A7 and
                                                                                                        Centre, The Big Shor: A7 and the Illusion of Russian
                                                Illusion of Russian Financial Innovation (2026), at     Financial Innovation (2026), at pp. 28, 68, https://    the Illusion of Russian Financial Innovation (2026),
                                                pp. 25–26, https://static.opensourcecentre.org/         static.opensourcecentre.org/assets/osc_a7_big_          at pp. 30–31, https://static.opensourcecentre.org/
                                                assets/osc_a7_big_shor.pdf.                             shor.pdf.                                               assets/osc_a7_big_shor.pdf.

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                                                                         Federal Register / Vol. 91, No. 191 / Monday, October 5, 2026 / Proposed Rules                                                       63213

                                                22, 2025, the A7 Network’s clients                          The A7 Network also reportedly                         restricted or less dependable.48 Kyrgyz
                                                purchased more than 3,200 bills of                       maintains reserves of currency in                         Republic-registered, OFAC-sanctioned
                                                exchange worth the equivalent of more                    foreign bank accounts, to pay                             digital assets firm Old Vector LLC
                                                than USD 25 billion, indicating that                     individuals and entities outside of                       worked with digital assets exchange
                                                there is robust demand for A7 Network’s                  Russia without the need for cross-border                  Garantex, Garantex’s successor
                                                services.38 These bills of exchange are                  transactions. The A7 Network keeps                        exchange Grinex, and others in the
                                                purchased by companies and traders—                      records of the money it receives from its                 creation, issuance, and trading of the
                                                becoming the customer’s credit within                    clients in Russia, and the money it                       A7A5 token.49 A7 Network created the
                                                the system—and each purchase gets                        sends to external parties to maintain                     A7A5 stablecoin for Russian clients of
                                                them on the A7 Network’s ledger,                         adequate funding on both sides of the                     OFAC-designated A7 LLC, a firm that
                                                reducing the need to do direct                           border and balance the books, enabling                    provides cross-border settlement
                                                international bank transfers and helping                 the Russian clients of the A7 Network                     platforms frequently used for sanctions
                                                to avoid scrutiny by banks. The A7                       to evade sanctions and avoid                              evasion.50 Although A7A5 is issued by
                                                Network then assigns a foreign Sub-                      disruption.43 FinCEN assesses                             Kyrgyzstan-based Old Vector, each coin
                                                Agent to appear as the contracting or                    transactions involving the A7 Network’s                   is backed by ruble deposits held at PSB,
                                                paying party on invoices, sales                          Sub-Agents enable its clients to send or                  meaning for every A7A5 transaction,
                                                agreements, and payment instructions.                    receive money to nearly any country                       there is a corresponding nexus to a
                                                This enables the payment to be executed                  and in nearly any currency—including,                     sanctioned Russian bank.51
                                                from non-Russian bank accounts                           U.S. dollars, yuan, dirhams, and euros—                      The A7A5 tokens are used to conduct
                                                through correspondent banking and                        by using banks that have correspondent                    transactions outside of the formal
                                                SWIFT channels.39                                        relationships with larger financial                       financial system. The token serves as an
                                                   In particular, the A7 Network has                     institutions that, but for obfuscation by                 internal accounting method for the
                                                honed its process for executing                          the A7 Network, would not engage in                       network, moving across internal
                                                international payments through                           these transactions, permitting illicit                    addresses to maintain a balanced ledger,
                                                complex financial arrangements and its                   actors access to a money laundering                       effectively acting as part of a broader
                                                constellation of enabling Sub-Agents.                    platform and decreasing the risk of this                  mirror system,52 to the international
                                                The typical process requires a customer                  activity being identified by investigating
                                                                                                                                                                      48 See U.S. Department of the Treasury, Press
                                                to provide the A7 Network with                           authorities.44
                                                                                                                                                                   Release, Treasury Sanctions Cryptocurrency
                                                documentation outlining the foreign                         Using these settlement mechanisms,                     Exchange and Network Enabling Sanctions Evasion
                                                counterparty requiring payment and                       the A7 Network’s clients have                             and Cyber Criminals (Aug. 14, 2025), https://
                                                attendant bank details, description of                   reportedly been able to transact with                     home.treasury.gov/news/press-releases/sb0225.
                                                the goods being bought, and price. The                   counterparties in Africa, Asia, Europe,                      49 Garantex, which had been previously

                                                A7 Network then matches the intended                     North America, and South America                          sanctioned as a prolific money launderer for
                                                                                                                                                                   Russian cybercriminals and other illicit actors,
                                                transaction with a relevant Sub-Agent in                 despite the restrictive sanctions on                      executed a scheme to move its funds to a successor
                                                its global network, many of which are                    Russian banks.45                                          exchange, Kyrgyzstan-based Grinex, following
                                                industry-specific to provide plausible                                                                             disruptive action by U.S. law enforcement in March
                                                                                                         3. The A7 Network’s Creation and Use                      2025. Garantex allowed its customers who lost their
                                                cover for transactions.40 These Sub-
                                                                                                         of the A7A5 Stablecoin                                    funds following the law enforcement disruptions to
                                                Agents do not have any Russians on the                                                                             regain access to their accounts using the A7A5
                                                board of directors or as shareholders                       In parallel with its fiat settlement                   token. See Treasury Press Release, ‘‘Treasury
                                                and their bank accounts are managed by                   mechanism, the A7 Network may use                         Sanctions Russia-Based Hydra, World’s Largest
                                                A7 Network staff in Russia via VPNs, all                 digital assets, including A7A5, a ruble-                  Darknet Market, and Ransomware-Enabling Virtual
                                                                                                                                                                   Currency Exchange Garantex’’ (Apr. 5, 2026); see
                                                to appear as if the companies are being                  backed stablecoin that operates on the                    also Aug. 2025 Treasury Press Release, supra note
                                                operated from within the country of                      Tron and Ethereum blockchains,46 47 to                    2. See also Etherscan, Contract, ‘‘Token A7A5’’
                                                registration.41 The A7 Network then                      transfer value across A7 Network-linked                   (accessed Aug. 17, 2026).
                                                uses software that generates fake                        actors where banking channels are                            50 U.S. Department of the Treasury, Press Release,

                                                                                                                                                                   Treasury Sanctions Cryptocurrency Exchange and
                                                invoices and trade documents to make                                                                               Network Enabling Sanctions Evasion and Cyber
                                                the transactions seem legitimate—                          43 Id. at p. 46.
                                                                                                                                                                   Criminals (Aug. 14, 2025), https://
                                                including by stripping any reference to                    44 Id. at pp. 52–53.
                                                                                                                                                                   home.treasury.gov/news/press-releases/sb0225;
                                                                                                            45 Open Source Centre, The Big Shor: A7 and the        A7A5, Homepage, https://www.a7a5.kg/trade_and_
                                                Russia.42
                                                                                                         illusion of Russian financial innovation (2026), at       earn?chain=tron%3Flang%3Den. https://
                                                                                                         pp. 25, 34, 37,https://static.opensourcecentre.org/       www.a7a5.kg/trade_and_
                                                  38 Id. at pp. 30–31.
                                                                                                         assets/osc_a7_big_shor.pdf.                               earn?chain=tron%3Flang%3Den.
                                                   39 Id., at. pp. 32–34. Several sanctioned Russian        46 The A7A5 tokens operate from smart contracts           51 A7A5, Why A7A5, at p. 1, https://
                                                financial institutions were removed from the             with addresses at 0x6fA0BE17e4beA2fCfA22                  www.a7a5.kg/why_a7a5; Chainalysis, How A7A5
                                                SWIFT system in March 2022 shortly after its full-       ef89BF8ac9aab0AB0fc9 and TLeVfrdym8RoJre                  and Grinex Enable The Russian Shadow Crypto
                                                scale invasion of Ukraine, making it significantly       J23dAGyfJDygRtiWKBZ. See https://etherscan.io/            Economy (Aug. 14, 2025), at pp. 2–3, https://
                                                harder for Russian financial institutions to conduct     token/0x6fA0BE17e4beA2fCfA22ef89BF8ac                     www.chainalysis.com/blog/a7a5-grinex-russian-
                                                cross-border transactions. See SWIFT, ‘‘An update        9aab0AB0fc9#code; https://tronscan.org/token20/           crypto-economy-ofac-sanctions-august-2025/.
                                                to our message for the Swift Community’’ (Mar. 20,       TLeVfrdym8RoJreJ23dAGyfJDygRtiWKBZ/code.                     52 The term ‘‘mirror transactions’’ or ‘‘mirror
                                                2022), https://www.swift.com/news-events/news/              47 Stablecoins are a type of digital asset for which   transfer’’ is used by U.S. law enforcement to
                                                message-swift-community.                                 the value of the token is tied to another asset,          describe a money laundering typology involving
                                                   40 Open Source Centre, The Big Shor: A7 and the
                                                                                                         typically a fiat currency such as the U.S. dollar.        foreign currency exchange. The process typically
                                                illusion of Russian financial innovation (2026), at      Stablecoins are appealing to illicit actors due to        happens within Chinese underground banking and
                                                p. 41, https://static.opensourcecentre.org/assets/       their relative liquidity, ease of settlement, and         black market peso exchange schemes and usually

lotter on DSK8BHNXB4PROD with PROPOSALS1
                                                osc_a7_big_shor.pdf. The A7 Network’s Sub-Agents         exchange rate stability. See U.S. Department of the       involves a money broker or an accountant who
                                                are tailored, insofar as it is possible, to the          Treasury, 2026 National Proliferation Financing           conducts two equal, but separate, transactions
                                                industries for which they are moving payments to         Risk Assessment (Mar. 2026), at p. 16, https://           involving at least two parties who often are
                                                avoid scrutiny from financial institutions. However,     home.treasury.gov/system/files/246/2026-                  unaware of each other. In this scheme, the broker
                                                there are some indications that the A7 Network at        NPFRA.pdf; see also U.S. Department of the                or accountant makes payments to each party using
                                                times struggles to match Sub-Agents with specific        Treasury, 2026 National Money Laundering Risk             the other parties’ currency, ‘‘mirroring’’ or
                                                customer business profiles. Id. at p. 20.                Assessment (Mar. 2026), at pp. 52–53, https://            balancing the transactions. In the instance of the A7
                                                   41 Id. at pp. 33, 39.
                                                                                                         home.treasury.gov/system/files/246/2026-                  Network, transactions within Russia using the
                                                   42 Id. at pp. 41–42.                                  NMLRA.pdf.                                                                                            Continued

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                                                63214                    Federal Register / Vol. 91, No. 191 / Monday, October 5, 2026 / Proposed Rules

                                                payments that the network makes.53                        the necessary liquidity to operate, the                     are often accessed through decentralized
                                                This broader mirror system also                           A7 Network uses its Sub-Agents or other                     finance applications.61
                                                involves the use of the aforementioned                    trusted intermediary entities, such as                         The A7 Network’s well-established
                                                bills of exchange, known as ‘‘veksels’’.                  digital asset exchanges. This includes                      and far-reaching digital asset channels
                                                According to public and nonpublic                         over-the-counter digital asset brokers                      are an appealing tool for a wide range
                                                information, the tokens are used for                      (OTCs) 58 outside of Russia operating in                    of threat actors. Analysis of public and
                                                transfers within Russia that represent                    jurisdictions of concern for A7 Network                     nonpublic information reveals that
                                                foreign payments and are made through                     activity—especially firms that are newly                    Iranian actors are leveraging the A7
                                                nested digital asset wallets and financial                created or dramatically expanding their                     Network, including the Central Bank of
                                                accounts held in the name of A7                           stablecoin trading operations—which                         Iran and the IRGC. Other illicit actors
                                                Network Sub-Agents. On the other side                     could serve as A7 Network liquidity                         known to have used this network
                                                of the mirror trading system, the A7                      providers.59 In addition, FinCEN                            include North Korea (DPRK); Iran-
                                                Network employs its Sub-Agents to                                                                                     backed terrorist organizations;
                                                                                                          analysis indicates that U.S. financial
                                                conduct fiat transactions—including                                                                                   cybercriminals and ransomware
                                                                                                          institutions may encounter use of
                                                U.S. dollars, yuan, dirhams, and euros—                                                                               actors.62
                                                                                                          derivative or ‘‘wrapped’’ tokens distinct                      4. The A7 Network’s Sub-Agents Are
                                                through the international financial                       from but ‘‘pegged’’ to the A7A5 token
                                                system. FinCEN, through analysis of                                                                                   Used in Furtherance of International
                                                                                                          that serve as a representation of the                       Money Laundering and Sanctions
                                                available financial data, found that more                 A7A5 token on a blockchain to which
                                                than 180 entities processed A7A5                                                                                      Evasion in Connection With Russian
                                                                                                          A7A5 is not native; 60 wrapped tokens                       Illicit Finance
                                                transactions worth at least USD 179.1
                                                billion, between February 2025 and June                                                                                  As demonstrated above, the A7
                                                2026. Historically, almost all of these
                                                                                                          ; see also Elliptic, ‘‘The fall of A7A5: how sanctions      Network’s Sub-Agents play a key role in
                                                                                                          strangled the ruble stablecoin’’ (July 29. 2026),           enabling, and facilitating, the A7
                                                transactions were processed through                       Centre for Information Resilience ‘‘A7A5:
                                                U.S.-, EU-, and/or UK-sanctioned                          Circumventing sanctions with stablecoin                     Network’s activities. Based on analysis
                                                entities, including Garantex and Grinex,                  cryptocurrency’’ (June 25, 2025), at p. 9, https://         of public and nonpublic information,
                                                                                                          www.info-res.org/app/uploads/2025/06/A7A5-                  FinCEN assesses that, in the aggregate,
                                                and likely involved touchpoints with                      Report-June-2025-Final-Draft-1.pdf.                         the A7 Network’s Sub-Agents have
                                                Russian banks; 54 however following an                       58 OTCs are money services businesses (MSBs)
                                                                                                                                                                      processed more than 17 billion in USD-
                                                alleged hack of Grinex in April 2026,55                   that conduct peer-to-peer exchanges of digital assets
                                                                                                          for fiat currency, or digital assets for digitals assets,   denominated transactions between
                                                A7A5 has been consolidated into
                                                                                                          between two parties without the use of a centralized        January 2025 and June 2026. Moreover,
                                                unhosted wallets, suggesting the A7                       digital asset exchange and usually involving large          FinCEN has identified and assessed
                                                Network may be moving away from                           volumes. As part of the money laundering process,           hundreds of Sub-Agents of the A7
                                                using sanctioned exchanges.56                             illicit actors often seek to convert digital assets,
                                                                                                          specifically stablecoins, into fiat currency via            Network, finding that, based on public
                                                   The A7 Network has most often used
                                                                                                          diffuse networks of OTC brokers in third countries.         and nonpublic information, these Sub-
                                                the A7A5 tokens as a non-freezable,                       These OTCs can receive substantial fees from illicit        Agents have (1) extensively facilitated
                                                bridging asset to convert into other,                     actors for providing cash-out services that leverage        transactions on behalf of, and for the
                                                more widely accepted digital assets,                      proxy accounts to circumvent digital asset service
                                                                                                                                                                      benefit of, sanctioned Russian persons;
                                                such as the stablecoin Tether (USDT),                     providers’ Customer Due Diligence (CDD) processes
                                                                                                          or exploit providers with weaker AML/CFT                    (2) supported Russia’s military
                                                and which may then be converted to the                    controls, among other tactics. See U.S. Department          operations in Africa; (3) enabled Iranian
                                                fiat currency of the customers choosing                   of the Treasury, 2026 National Money Laundering             sanctions evasion, including
                                                as another means of settling payments                     Risk Assessment (Mar. 2026), at p. 50, https://
                                                                                                                                                                      transactions involving entities involved
                                                internationally.57 In order to maintain                   home.treasury.gov/system/files/246/2026-
                                                                                                          NMLRA.pdf.                                                  in the ‘‘shadow fleet’’ that Iran uses to
                                                                                                             59 The A7A5 token is only available for purchase         illicitly sell oil; and (4) assisted at least
                                                A7A5 token ‘‘mirror’’ movements of fiat currency
                                                through ‘‘Sub-Agents,’’ balancing the transactions
                                                                                                          on a small number of exchanges, most of which are           one company involved in procurement
                                                                                                          sanctioned by the U.S., EU and/or UK; however, it           for Iran’s weapons programs.
                                                while ensuring that the counterparties remain
                                                                                                          is also traded using peer-to-peer exchangers and
                                                completely firewalled from one another. See
                                                                                                          decentralized exchanges. See Centre for Information
                                                                                                                                                                         For instance, publicly identified 63
                                                Treasury, ‘‘2024 National Money Laundering Risk                                                                       Sub-Agents that FinCEN assesses
                                                                                                          Resilience ‘‘A7A5: Circumventing sanctions with
                                                Assessment’’ (Feb. 2024), at pp. 29–30. For more
                                                information about Chinese underground banking
                                                                                                          stablecoin cryptocurrency’’ (June 25, 2025), at pp.         engaged in illicit activity include:
                                                and the black market peso exchange, see FinCEN,
                                                                                                          12–13, https://www.info-res.org/app/uploads/2025/              • Power Sphere LLC–FZ. Power
                                                                                                          06/A7A5-Report-June-2025-Final-Draft-1.pdf.                 Sphere LLC–FZ is a Dubai, UAE-based
                                                FIN–2025–A003, ‘‘FinCEN Advisory on the Use of               60 A ‘‘wrapped’’ token is a digital asset that
                                                Chinese Money Laundering Networks by Mexico-
                                                                                                          represents another digital asset on a non-native
                                                                                                                                                                      electronics supplier that purportedly
                                                Based Transnational Criminal Organizations to                                                                         trades in energy products, agricultural
                                                Launder Illicit Proceeds’’ (Aug. 28, 2025).               blockchain where the original asset is not offered.
                                                   53 See June 2026 TRM Labs Report, supra note 12.       For example, a ‘‘wrapped’’ A7A5 token may offer             products, consumer goods, and food and
                                                   54 See TRM Labs, ‘‘The A7 Leaks: TRM’s On-
                                                                                                          trading of a representation of A7A5 on a blockchain         beverages.64 However, FinCEN’s
                                                                                                          other than A7A5’s native blockchains. Wrapped
                                                Chain Analysis of Russia’s Cryptocurrency                 tokens maintain a peg to the original asset, which
                                                Connections’’ (June 12, 2026), https://                                                                                 61 See Ethereum Foundation, ‘‘Wrapped ether
                                                                                                          is traditionally locked by a smart contract or
                                                www.trmlabs.com/resources/blog/the-a7-leaks-trms-         maintained in a digital vault. See Securities and           (WETH),’’ https://ethereum.org/wrapped-eth/ (last
                                                on-chain-analysis-of-russias-cryptocurrency-              Exchange Commission and Commodity Futures                   accessed Aug. 20, 2026).
                                                connections.                                              Trading Commission, 17 CFR parts 231 RIN 3235–
                                                                                                                                                                        62 See TRM Labs, ‘‘The A7 Leaks: TRM’s On-
                                                   55 See Elliptic, ‘‘The fall of A7A5: how sanctions                                                                 Chain Analysis of Russia’s Cryptocurrency
                                                                                                          AN56 and 241 and 17 CFR part 1 RIN 3038–AF67,
                                                strangled the ruble stablecoin’’ (July 29. 2026),         ‘‘Application of the Federal Securities Laws to             Connections’’ (June 12, 2026), https://
                                                https://www.elliptic.co/insights/the-fall-of-a7a5-        Certain Types of Crypto Assets and Certain                  www.trmlabs.com/resources/blog/the-a7-leaks-trms-
                                                how-sanctions-strangled-the-ruble-stablecoin/.            Transactions Involving Crypto Assets’’ (Mar. 23,            on-chain-analysis-of-russias-cryptocurrency-

lotter on DSK8BHNXB4PROD with PROPOSALS1
                                                   56 See Hannah Curtis, ‘‘One wallet now holds
                                                                                                          2026), https://www.sec.gov/files/rules/interp/2026/         connections.
                                                94.5% of A7A5’s supply,’’ Crystal Intelligence (July                                                                    63 All of the Sub-Agents discussed below were
                                                                                                          33-11412.pdf. Wrapped tokens may also be created
                                                30, 2026), https://crystalintelligence.com/               on the same blockchain as the original token to             identified as Sub-Agents of the A7 Network. See
                                                stablecoin/one-wallet-now-holds-94-5-of-a7a5s-            make them compatible with decentralized                     Centre for Information Resilience, A7 Abroad: How
                                                supply/.                                                  exchanges. See Centre for Information Resilience            A7 Sells International Sanctions Evasion as a
                                                   57 See Elliptic, ‘‘A7A5: The ruble-backed              ‘‘A7A5: Circumventing sanctions with stablecoin             Service (Oct. 2025), at pp. 19–20, https://www.info-
                                                stablecoin crosses $100 billion in transactions’’ (Jan.   cryptocurrency’’ (June 25, 2025), at p. 13, https://        res.org/app/uploads/2025/10/A7-Abroad-FINAL-
                                                21, 2026), https://www.elliptic.co/insights/a7a5-the-     www.info-res.org/app/uploads/2025/06/A7A5-                  Copy.pdf.
                                                ruble-backed-stablecoin-100-billion-in-transactions/      Report-June-2025-Final-Draft-1.pdf.                           64 Id. at p. 19.

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                                                                           Federal Register / Vol. 91, No. 191 / Monday, October 5, 2026 / Proposed Rules                                                  63215

                                                analysis of public and non-public                           illicit funds tied to Russian export                  B. The Extent to Which Transactions
                                                information identified that between                         control evasion.                                      Involving any Sub-Agent of the A7
                                                September 2023 and July 2025, Power                            • Sigizmund FZCO. Sigizmund FZCO                   Network Involve Legitimate Business
                                                Sphere LLC–FZ processed USD 61                              is a Dubai, UAE-based marketing                       Activity
                                                million in illicit funds tied to Russian                    management, research, and support                        In reaching its finding, FinCEN has
                                                trade-based money laundering and                                                                                  considered the extent to which
                                                                                                            consultancy firm.70 FinCEN’s analysis
                                                procurement activities in the energy                                                                              transactions involving any Sub-Agent
                                                                                                            of public and non-public information
                                                sector.                                                                                                           are used for legitimate business
                                                   • Hydrofusion Resources FZ–LLC.                          determined that between July and
                                                                                                            September 2025, Sigizmund FZCO                        purposes.72 As discussed above, the A7
                                                Hydrofusion Resources FZ–LLC is a                                                                                 Network’s Sub-Agents are used to
                                                UAE-based energy commodities trader                         processed USD 41,000 in illicit funds
                                                                                                                                                                  facilitate illicit activities by illicit actors.
                                                that also purportedly trades in various                     tied to Russian sanctions evasion,
                                                                                                                                                                  Although some components of the A7
                                                other products, such as food and                            including the acquisition of dual-use
                                                                                                                                                                  Network, including its known Sub-
                                                beverages, electronics, and heavy                           goods.                                                Agents, may offer services that could
                                                machinery.65 FinCEN’s analysis of                              • Pearl Bridge. Pearl Bridge is a                  potentially be used by licit actors, the
                                                public and non-public information                           Dubai, UAE-based trading firm that                    A7 Network’s own creators,
                                                determined that between May and June                        purportedly specializes in precious                   acknowledge its services are expressly
                                                2025, Hydrofusion Resource FZ–LLC                           metals, commodities, and other general                designed to circumvent U.S. and
                                                processed USD 3.6 million in illicit                        trade.71 FinCEN’s analysis of public and              international sanctions placed on the
                                                funds tied to Russian trade-based money                     non-public information determined that                operators, owners, and enablers of the
                                                laundering activity.                                        in April 2025, Pearl Bridge processed                 A7 Network 73 and licit actors would
                                                   • Gimli Trade LLC–FZ. Gimli Trade                                                                              have access to other, more established
                                                                                                            approximately USD 30,000 in illicit
                                                LLC–FZ is a Dubai, UAE-based trading                                                                              channels through which they might
                                                                                                            funds tied to suspected Russian
                                                firm that purportedly trades in food and                                                                          direct financial activity. Accordingly,
                                                                                                            sanctions evasion activity.
                                                beverages, household goods, cosmetic                                                                              given the extensive flow of illegitimate
                                                products, machinery, oil trading, and                       Additionally, based on analysis of                    funds through the A7 Network, FinCEN
                                                general trading.66 The company                              public and nonpublic information, there               assesses that the need to protect U.S.
                                                maintained an account at PSB in Russia,                     are indications that certain Sub-Agents               financial institutions from the money
                                                which was used to make ruble-                               have facilitated Iranian sanctions                    laundering risks presented by the A7
                                                denominated transactions.67 Gimli                           evasion efforts. One Sub-Agent engaged                Network outweighs any potential
                                                Trade LLC–FZ was sanctioned by the                          in direct transactions with other Sub-                legitimate utility its services may
                                                United Kingdom on December 18, 2025,                        Agents and entities associated with                   provide.
                                                for its involvement in providing                            Iran’s shadow fleet—a network of oil
                                                financial support to the Russian                                                                                  C. The Extent to Which This Proposed
                                                                                                            tankers, shipping companies, and front                Action Would Guard Against the Risks
                                                government.68 FinCEN’s analysis of                          companies used to transport and sell
                                                public and non-public information                                                                                 Posed by Transactions Involving any
                                                                                                            Iranian oil—indicating that Iranian                   Sub-Agent of the A7 Network
                                                determined that between May and June
                                                                                                            actors have used the A7 Network and its                  A finding that transactions involving
                                                2025, Gimli Trade LLC–FZ processed
                                                                                                            infrastructure, including its Sub-Agents,             any Sub-Agent of the A7 Network are a
                                                USD 1.5 million in illicit funds tied to
                                                Russian sanctions evasion.                                  in connection with sanctions-evasion                  class of transactions of primary money
                                                   • Galadriel Trading FZCO. Galadriel                      activity. Between July 2023 and October               laundering concern in connection with
                                                Trading FZCO is a Dubai, UAE-based                          2025, the same A7 Sub-Agent and one                   Russian illicit finance establishes—and
                                                agricultural trading firm that                              of its sister companies received nearly               emphasizes—the significant illicit
                                                purportedly trades commodities such as                      USD 140 million from entities involved                finance risks posed by the A7 Network
                                                wheat, corn, barley, chickpeas, and                         in Iranian sanctions evasion. In a                    and its Sub-Agents. This finding will
                                                vegetable oils.69 FinCEN’s analysis of                      separate instance, based on public and                place U.S. and foreign financial
                                                public and non-public information                           nonpublic information, FinCEN assess                  institutions and regulators on notice to
                                                determined that between May and July                        that another A7 Network Sub-Agent                     guard against those risks.74 Moreover, as
                                                2025, Galadriel Trading FZCO                                transferred approximately USD 1.6                     Sub-Agents of the A7 Network are, by
                                                processed more than USD 946,000 in                          million, between January 2024 and                     design, challenging to readily identify,
                                                                                                            September 2025, to a company linked to                such a finding—in combination with a
                                                  65 Id. at p. 20.
                                                                                                            Iranian sanctions evasion and weapons                 prohibition on certain transmittals of
                                                   66 Centre for Information Resilience, A7 Abroad:
                                                                                                            procurement efforts.                                  funds by covered financial
                                                How A7 Sells International Sanctions Evasion as a                                                                 institutions—will safeguard the U.S.
                                                Service (Oct. 2025), at p. 20, https://www.info-               Across fiat and digital asset-based                financial system, by assisting financial
                                                res.org/app/uploads/2025/10/A7-Abroad-FINAL-                settlement mechanisms, the A7
                                                Copy.pdf.                                                                                                         institutions in identifying Sub-Agent
                                                   67 Open Source Centre, The Big Shor: A7 and the          Network’s well-established and far-                   and severing access.
                                                illusion of Russian financial innovation (2026), at         reaching constellation of Sub-Agents
                                                p. 34, https://static.opensourcecentre.org/assets/          have provided a tool for threat actors to             IV. Proposed Special Measure
                                                osc_a7_big_shor.pdf.                                        engage in a wide array of illicit activity,             Having found that transactions
                                                   68 UK Foreign, Commonwealth and Development

                                                Office, Gimli Trade LLC–FZ (Dec. 18, 2025), https://        including sanctions evasion.                          involving any Sub-Agent of the A7

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                                                search-uk-sanctions-list.service.gov.uk/
                                                                                                                                                                    72 See 31 U.S.C. 5318A(c)(2)(B)(ii).
                                                designations/RUS3177/Entity?utm_content=&utm_
                                                medium=email&utm_name=&utm_                                                                                         73 Kommersant, Investment Cooperation Between
                                                                                                              70 Centre for Information Resilience, A7 Abroad:
                                                source=govdelivery.                                                                                               Russia and China: Growth Points. Kommersants
                                                   69 Centre for Information Resilience, A7 Abroad:
                                                                                                            How A7 Sells International Sanctions Evasion as a     Session at the Third Russia-China International
                                                How A7 Sells International Sanctions Evasion as a           Service (Oct. 2025), at p. 19, https://www.info-      Forum (Aug. 19, 2025), at p. 2, https://
                                                Service (Oct. 2025), at p. 19, https://www.info-            res.org/app/uploads/2025/10/A7-Abroad-FINAL-          www.events.kommersant.ru/events/sessiya-na-
                                                res.org/app/uploads/2025/10/A7-Abroad-FINAL-                Copy.pdf.                                             rostki-2025.
                                                Copy.pdf.                                                     71 Id.                                                74 See 31 U.S.C. 5318A(c)(2)(B)(iii).

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                                                63216                  Federal Register / Vol. 91, No. 191 / Monday, October 5, 2026 / Proposed Rules

                                                Network are a class of transactions of                  action is specifically designed to                    insulate the U.S. financial system from
                                                primary money laundering concern in                     address a significant money laundering                international money laundering and
                                                connection with Russian illicit finance,                threat to the U.S. and international                  other financial crimes, further ongoing
                                                FinCEN proposes imposing a                              financial systems premised on the                     U.S. efforts to curtail suspected
                                                prohibition on certain transmittals of                  Secretary’s determination that                        sanctions evasion and related illicit
                                                funds involving any of the A7 Network’s                 transactions involving any Sub-Agent of               activity tied to Russian and Iranian
                                                Sub-Agents.75 In making this                            the A7 Network poses an unacceptable                  illicit finance, and sever a significant
                                                determination and assessing which                       risk of money laundering and other                    pathway that facilitates circumvention
                                                special measures may be appropriate,                    financial crimes.                                     of U.S. and other sanctions, supporting
                                                FinCEN has considered the relevant                         Further, this action is intended to                the efficacy of U.S. sanctions and
                                                evidence in light of factors identified in              encourage other jurisdictions—as well                 complementing previous actions taken
                                                31 U.S.C. 5318A(a)(4)(B). While FinCEN                  as financial institutions throughout the              by the U.S. government.
                                                is under no obligation pursuant to                      world—to take similar steps to sever the
                                                                                                        A7 Network and its Sub-Agents from the                B. Whether the Proposed Special
                                                section 9714(a) to consider any
                                                                                                        international financial system.                       Measure Would Create Undue Burdens
                                                particular factor or set of factors in
                                                                                                           Notwithstanding the differing                      on Any Legitimate Activity of the A7
                                                selecting one or more special measures,
                                                                                                        purposes of the existing sanctions and                Network’s Sub-Agents or Third Parties
                                                it nonetheless finds these factors
                                                instructive in guiding the analysis set                 the special measure proposed in this                     FinCEN has considered whether the
                                                forth below.76                                          NPRM, the proposed special measure is                 proposed prohibition on certain
                                                   As noted above, OFAC has not only                    intended to apply in concert, not                     transmittals of funds would create a
                                                designated the A7 Network as a                          conflict with the existing sanctions.                 significant competitive disadvantage,
                                                significant TCO, but also designated,                   Covered financial institutions should                 including any undue cost or burden
                                                and imposed restrictions upon, certain                  block and report to OFAC any accounts                 associated with compliance, for
                                                core actors and components of the A7                    or transactions that are blocked                      financial institutions organized or
                                                Network—namely, A7 LLC, A71 LLC,                        pursuant to any applicable OFAC                       licensed in the United States as affected
                                                A7 Agent LLC, Old Vector LLC,                           sanctions authority, and to the extent                third parties, as well as the extent to
                                                Garantex, Grinex, InDeFi Bank, ExVed,                   required or necessary, continue to                    which the action could have a
                                                Mendeleev, Ilan Shor, and PSB, as well                  maintain any blocked accounts in                      significant adverse systemic impact on
                                                as certain other persons whose property                 accordance with the Reporting                         legitimate business activities involving
                                                and interests in property have been                     Procedures and Penalties Regulations,                 the A7 Network’s Sub-Agents. As noted
                                                blocked, by designation, order, or by                   31 CFR part 501. And, for avoidance of                above, FinCEN assesses that to the
                                                operation of law. The proposed                          doubt, if there is an apparent conflict               extent the A7 Network Sub-Agents are
                                                imposition of a special measure would                   between an obligation to block property               engaged in licit activity, such activity is
                                                reinforce those existing restrictions, and              or interests in property under existing               relatively minimal compared to the
                                                importantly, the purposes served by this                OFAC sanctions and the requirements of                sanctions evasion and illicit financial
                                                proposed action differ from the                         this proposed special measure, covered                activity that flows through these Sub-
                                                purposes of the existing economic                       financial institutions should comply                  Agents. Moreover, these Sub-Agents
                                                sanctions. Apart from the rationale and                 with the obligation to block and, in                  operate companies in a variety of
                                                purposes of the existing sanctions, this                doing so, would be deemed to comply                   industries and the disperse nature of
                                                                                                        with the requirements of this proposed                these businesses underscores that any
                                                  75 In connection with this action, and consistent     special measure.                                      overall impacts from any decrease in
                                                with 31 U.S.C. 5318A(a)(4)(A), FinCEN consulted                                                               legitimate commercial or financial
                                                with staff at the following Departments and             A. Whether the Proposed Special
                                                                                                                                                              activity by these Sub-Agents is likely de
                                                agencies with regard to the proposed rule and           Measure Would Address the Money
                                                prohibition: the Department of Justice; the                                                                   minimis.
                                                                                                        Laundering Concern in a Manner                           When considering the anticipated
                                                Department of State; the Board of Governors of the
                                                Federal Reserve System; the Federal Deposit
                                                                                                        Consistent With U.S. National Security                burden on covered financial
                                                Insurance Corporation; the Securities and Exchange      and Foreign Policy Interests                          institutions, FinCEN assesses that the
                                                Commission; the Commodity Futures Trading
                                                Commission; the Office of the Comptroller of the
                                                                                                           FinCEN has considered the effect this              proposed prohibition is unlikely to
                                                Currency; and the National Credit Union                 proposed special measure will have on                 impose a significant competitive
                                                Administration. Neither the Departments nor             U.S. national security and foreign                    disadvantage on any one particular
                                                agencies objected to the issuance of this NPRM          policy, as well as the extent to which                financial institution organized or
                                                based on the information provided to staff at the
                                                time of this consultation.
                                                                                                        multilateral groups or other nations                  licensed in the United States as a
                                                  76 31 U.S.C. 5318A(a)(4)(B) provides, as relevant     have taken similar action.77 Given that               consequence of business forgone due to
                                                here, that in selecting which special measure(s) to     the A7 Network’s Sub-Agents’                          the proposed prohibition given that the
                                                take, the Secretary shall consider:                     association with sanctioned persons and               A7 Network’s Sub-Agents uses of
                                                  (1) Whether similar action has been or is being       other actors involved in illicit activity,            hundreds of Sub-Agents across a wide
                                                taken by other nations or multilateral groups;                                                                number of financial institutions,
                                                                                                        for the purpose of furthering sanctions
                                                  (2) Whether the imposition of any particular
                                                special measure would create a significant              evasion, FinCEN assesses that imposing                globally. Further, compliance with the
                                                competitive disadvantage, including any undue cost      a prohibition on certain transmittals of              proposed prohibition on certain
                                                or burden associated with compliance, for financial     funds involving the A7 Network’s Sub-                 transmittals of funds set out in this
                                                institutions organized or licensed in the United        Agents is necessary to safeguard U.S.                 NPRM should not require tools or
                                                States;

lotter on DSK8BHNXB4PROD with PROPOSALS1
                                                                                                        national security and the U.S. financial              competencies other than those already
                                                  (3) The extent to which the action or the timing
                                                of the action would have a significant adverse          system, as well as serve key U.S.                     employed by domestic financial
                                                systemic impact on the international payment,           national security objectives.                         institutions to maintain their current
                                                clearance, and settlement system, or on legitimate      Specifically, prohibiting certain                     AML/CFT compliance programs and/or
                                                business activities involving the particular                                                                  sanctions compliance programs. To
                                                jurisdiction, institution, class of transactions, or
                                                                                                        transmittals of funds involving any of
                                                type of account; and                                    the A7 Network’s Sub-Agents would                     ensure that minimal additional burden
                                                  (4) The effect of the action on United States                                                               would attach to compliance with the
                                                national security and foreign policy.                     77 See 31 U.S.C. 5318A(a)(4)(B)(i), (iv).           proposed rule, FinCEN has elected to

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                                                                         Federal Register / Vol. 91, No. 191 / Monday, October 5, 2026 / Proposed Rules                                                    63217

                                                provide for the rejection of certain                       processing transmittals of funds                    evasion through the A7 Network’s Sub-
                                                transmittals of funds that are received                    involving the A7 Network’s Sub-Agents.              Agents, and to prevent the A7 Network’s
                                                from or originate with A7 Network Sub-                     Those special measures would allow                  Sub-Agents from using the U.S.
                                                Agents and outline the steps a covered                     such transfers to continue to benefit               financial system to enable illicit
                                                financial institution should take in such                  illicit actors connected to Russian illicit         financial activity. The subsections
                                                circumstances to satisfy the proposed                      finance and Iranian sanctions evasion.              below discuss the respective portions of
                                                requirements. Further, upon issuance of                    Further, prohibiting or placing                     the proposed rule, which is separately
                                                a Final Rule, FinCEN is prepared to aid                    conditions upon the opening or                      presented in Section IX. Importantly,
                                                covered financial institutions in                          maintaining in the United States of                 nothing in this NPRM should be
                                                compliance with this NPRM, by                              correspondent accounts or payable-                  construed to modify, impair, or
                                                providing additional information                           through accounts for or on behalf of the            otherwise affect any requirements or
                                                regarding known Sub-Agents, as                             A7 Network’s Sub-Agents, as described               obligations to which a covered financial
                                                appropriate, through a secure                              in 31 U.S.C 5318A(b)(5) would be                    institution is subject pursuant to the
                                                communications channel and proposes                        similarly inadequate. Neither                       BSA, including, but not limited to, the
                                                to limit the obligation on covered                         prohibiting nor imposing conditions on              filing of Suspicious Activity Reports, or
                                                financial institutions to prohibit certain                 such accounts would safeguard the U.S.              other applicable laws or regulations,
                                                transmittals to only those entities on the                 financial system to the same degree as              such as the sanctions administered and
                                                provisioned list(s), which may be                          prohibiting transmittals of funds, as               enforced by OFAC.
                                                updated over time, as FinCEN, for                          such a special measure would not
                                                                                                                                                               A. Definitions
                                                instance, identifies additional Sub-                       address the movement of funds outside
                                                Agents.                                                    of a strict correspondent or payable-               1. A7 Network
                                                                                                           through relationship, for example,                     The term ‘‘A7 Network’’ means the
                                                C. Whether Any Other Reasonable
                                                                                                           through the movement of funds outside               core grouping of entities and persons
                                                Alternatives or Special Measures Would
                                                                                                           the traditional banking relationship,               involved in the operation of a Russian-
                                                Adequately Address the Money
                                                                                                           including because the types of CVC                  Kyrgyzstan based sanctions evasion and
                                                Laundering Concern
                                                                                                           transactions, namely A7A5-related                   money laundering network including:
                                                   In assessing the appropriate special                    transactions (which are an integral part            A7 LLC, A71 LLC, A7 Agent LLC, Old
                                                measure to impose, FinCEN considered                       of the A7 Network’s business model), do             Vector LLC, Garantex, Grinex, InDeFi
                                                alternatives to a prohibition on certain                   not rely on the correspondent banking               Bank, Mendeleev, Ilan Shor, and PSB,
                                                transmittal of funds, including the                        system. FinCEN therefore assesses that              and any other persons whose property
                                                imposition of one or more of the first                     such a prohibition is the most                      and interests in property have been
                                                five special measures. Having                              appropriate special measure to protect              blocked, by designation, order, or by
                                                considered these alternatives, FinCEN                      the U.S. financial system.                          operation of law, in light of their
                                                assesses, for the reasons set out below,
                                                                                                           D. Whether the Proposed Prohibition                 connection to the A7 Network.79
                                                that a special measure prohibiting
                                                certain transmittals of funds involving                    Should Be Imposed by Order or                       2. A7 Network Sub-Agents
                                                the A7 Network’s Sub-Agents is the                         Regulation
                                                                                                                                                                  The proposed rule would define the
                                                most appropriate means to adequately                         Pursuant to section 9714, the                     A7 Network Sub-Agents as including,
                                                address the illicit finance risks posed by                 Secretary may impose specified special              but not limited to, the following:
                                                the A7 Network’s Sub-Agents and the                        measures, including a prohibition on                Galadriel Trading FZCO, Gimli Trade
                                                need to prevent it from accessing the                      certain transmittals of funds, ‘‘by order,          LLC–FZ, Hydrofusion Resources FZ–
                                                U.S. financial system. None of the                         regulation or otherwise as permitted by             LLC, Pearl Bridge, Power Sphere LLC–
                                                special measures set out in 31 U.S.C.                      law.’’ In determining the appropriate               FZ, and Sigizmund FZCO, and any
                                                5318A—special measures one through                         approach in this instance, FinCEN                   other entity identified by FinCEN as a
                                                five—would effectively address the                         considered imposing special measures                Sub-Agent of the A7 Network.
                                                illicit finance threat posed by the A7                     by order or regulation, taking into                    As suggested in this definition, to
                                                Network’s Sub-Agents.78 Any additional                     account the nature of the underlying                facilitate identifying entities that are
                                                recordkeeping, information collection,                     threat, and determined that proceeding
                                                or reporting requirements, as described                    by an NPRM is the most appropriate                     79 Persons whose property and interests in

                                                in 31 U.S.C 5318A(b)(1)–(4), would be                      course of action, as that approach                  property are blocked pursuant to an Executive
                                                insufficient to guard against the risks                                                                        Order or regulations administered by OFAC
                                                                                                           appropriately balances the risks posed              (blocked persons) are considered to have an interest
                                                posed by covered financial institutions                    by the A7 Network, with the interest in             in all property and interests in property of an entity
                                                                                                           ensuring that covered financial                     in which such blocked persons own, whether
                                                  78 Likewise, imposing conditions on transmittals
                                                                                                           institutions have an opportunity to                 individually or in the aggregate, directly or
                                                of funds, pursuant to section 9714(a)(2), would be                                                             indirectly, a 50 percent or greater interest.
                                                insufficient to address the threat. While imposing         comment on the proposed mechanisms                  Consequently, any entity owned in the aggregate,
                                                conditions, rather than a full prohibition, may be         through which FinCEN will identify                  directly or indirectly, 50 percent or more by one or
                                                appropriate in circumstances where the institution         Sub-Agents (as discussed below).                    more blocked persons is itself considered to be a
                                                provides services for legitimate business that are           A copy of this NPRM will be                       blocked person. The property and interests in
                                                not easily replicated or where a complete                                                                      property of such an entity are blocked regardless of
                                                prohibition on transactional activity would                published in the Federal Register. To               whether the entity itself is listed in the annex to an
                                                otherwise unduly harm legitimate economic                  the extent the A7 Network’s Sub-Agents              Executive order or otherwise placed on OFAC’s List
                                                activity, the A7 Network’s Sub-Agents provide a            or parties have information relevant to             of Specially Designated Nationals. Accordingly, a

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                                                service that, by design, is intended to benefit            this NPRM, they may submit it to                    U.S. person generally may not engage in any
                                                sanctioned persons. And, to the extent that the A7                                                             transactions with such an entity, unless authorized
                                                Network carries on any legitimate activity, FinCEN         FinCEN at http://www.fincen.gov/                    by OFAC. In certain OFAC sanctions programs (e.g.,
                                                assesses that such services would be easily                contact.                                            Cuba and Sudan), there is a broader category of
                                                obtainable for legitimate customers through other                                                              entities whose property and interests in property
                                                providers. Accordingly, in this case the value of any      V. Section-by-Section Analysis                      are blocked based on, for example, ownership or
                                                legitimate activity it may conduct is outweighed by                                                            control. See OFAC, Revised Guidance on Entities
                                                the significant proportion of illicit financial activity
                                                                                                             The goal of this proposed rule is to              Owned by Persons Whose Property and Interests in
                                                identified and its lack of mandatory Know Your             combat and deter illicit activity,                  Property are Blocked (Aug. 13, 2014), https://
                                                Customer controls.                                         including Russian and Iranian sanctions             ofac.treasury.gov/media/6186/download?inline.

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                                                63218                  Federal Register / Vol. 91, No. 191 / Monday, October 5, 2026 / Proposed Rules

                                                deemed Sub-Agents of the A7 Network,                    status. Despite having legal tender status            institutions from declining CVC
                                                FinCEN would be prepared to provide—                    in at least one jurisdiction, for the                 transfers originating at addresses
                                                through secure means—covered                            purpose of this NPRM, the A7A5                        outside of their control, and compliant
                                                financial institutions with additional                  stablecoin is included as a type of CVC.              institutions may find themselves in
                                                information regarding known A7 Sub-                                                                           receipt of CVC that, despite a desire and
                                                                                                        4. Covered Financial Institution
                                                Agents, as appropriate, and proposes                                                                          effort to limit such exposure, would
                                                limiting the obligation on covered                         The term ‘‘covered financial                       implicate the proposed prohibition.80
                                                financial institutions to prohibit certain              institution’’ has the same meaning as                 As such, proposed section
                                                transmittals only as to those entities                  ‘‘financial institution’’ in 31 CFR                   1010.668(b)(1)(i) allows covered
                                                identified on that list. Specifically,                  1010.100(t).                                          financial institutions the flexibility to
                                                FinCEN would share that list with                       5. Transmittals of Funds                              act with discretion based on the facts
                                                covered financial institutions through                                                                        and circumstances of a particular
                                                FinCEN’s ‘‘FI-Portal,’’ a secure                           The term ‘‘transmittals of funds’’                 transaction and comply with the
                                                messaging system that FinCEN and                        means the sending and receiving of                    proposed prohibition, even where the
                                                covered financial institutions utilize to               funds, including CVC. For avoidance of                originating address is no longer
                                                securely exchange information, as                       doubt, the definition of ‘‘transmittals of            accessible. Moreover, by providing for
                                                appropriate. That list will be updated                  funds’’ proposed here would only apply                the rejection of CVC, this order ensures
                                                periodically, both to add additional                    to section 1010.668. The definition of                that covered financial institutions will
                                                Sub-Agents as well as to remove Sub-                    transmittal of funds’’ in section                     not be subject to an undue cost or
                                                Agents. Given the nature of the A7                      1010.100(ddd) would not apply to                      burden associated with compliance.
                                                Network and its operations (as                          section 1010.668.                                        Further, as the proposed special
                                                discussed above), FinCEN is opting to                   6. Recipient                                          measure is intended to apply in concert,
                                                securely provide this list only to                                                                            not conflict, with the existing sanctions,
                                                                                                           The Term ‘‘Recipient’’ means the                   a note to proposed section
                                                covered financial institutions, as
                                                                                                        person to be paid by the recipient’s                  1010.668(b)(1) provides that covered
                                                FinCEN has assessed that a broader
                                                                                                        covered financial institution.                        financial institutions should block and
                                                public distribution of the list would
                                                undermine the purposes of the proposed                  7. Meaning of Other Terms                             report to OFAC any accounts or
                                                rule—allowing the A7 Network to                            All terms used but not otherwise                   transactions that are blocked pursuant
                                                circumvent the proposed special                         defined herein shall have the meaning                 to any applicable OFAC sanctions
                                                measure through additional and new                      set forth in 31 CFR Chapter X, 31 U.S.C.              authority, and to the extent required or
                                                Sub-Agents.                                             5312, and 21 U.S.C. 2302.                             necessary, continue to maintain any
                                                   Importantly, as proposed in this                                                                           blocked accounts in accordance with
                                                NPRM, that list would identify known                    B. 1010.668(b)—Prohibition on Certain                 the Reporting Procedures and Penalties
                                                Sub-Agents, for the purposes of                         Transmittals of Funds for Covered                     Regulations, 31 CFR part 501. As noted
                                                compliance with the proposed special                    Financial Institutions                                above and for avoidance of doubt, if
                                                measure, and covered financial                          1. Prohibition on Certain Transmittals of             there is an apparent conflict between an
                                                institutions would only be prohibited                   Funds                                                 obligation to block property or interests
                                                from engaging in certain transmittals of                                                                      in property under existing OFAC
                                                funds involving those Sub-Agents.                          Proposed section 1010.668(b)(1)                    sanctions and the requirements of this
                                                Covered financial institutions would                    prohibits covered financial institutions              proposed special measure, covered
                                                not, however, be prohibited from                        from engaging in a transmittal of funds               financial institutions should comply
                                                disclosing that, in the context of any                  involving any A7 Network Sub-Agent,                   with the obligation to block and, in
                                                particular transaction, they have                       including any transmittal of funds from               doing so, would be deemed to comply
                                                declined to proceed with the transaction                or to an A7 Network Sub-Agent, or from                with the requirements of this proposed
                                                because of party has been identified on                 or to any account or CVC address                      special measure.
                                                FinCEN’s list. Rather, as discussed                     administered by or on behalf of an A7
                                                                                                        Network Sub-Agent.                                    2. Notification
                                                below covered financial institutions
                                                would be required to affected persons                      In order to ensure that compliance                    As a corollary to the prohibition set
                                                associated with the transmittal of funds                with the proposed prohibition on                      forth in proposed section
                                                with which the covered financial                        certain transmittals of funds requires no             1010.668(b)(1), proposed section
                                                institution maintains a direct                          tools or competencies other than those                1010.668(b)(2) provides that, if a
                                                commercial relationship.                                already employed by covered financial                 covered financial institution knows or
                                                   And, as discussed below, should an                   institutions to maintain their current                has reason to believe a transmittal of
                                                entity seek to challenge being identified               AML/CFT compliance programs,                          funds involves any A7 Network Sub-
                                                as a Sub-Agent, FinCEN has set out a                    FinCEN has elected to provide at                      Agent and that such transmittal of funds
                                                process by which the aggrieved party                    proposed section 1010.668(b)(1)(i) for                is prohibited pursuant to paragraph
                                                may petition for reconsideration of their               the rejection of certain transmittals of              (b)(1), the covered financial institution
                                                inclusion on the list. Should an                        CVC that are received from or originate               must notify affected persons associated
                                                aggrieved identified Sub-Agent                          at A7 Network Sub-Agent or from an                    with the transmittal of funds with
                                                successfully challenge the                              account or CVC address administered by
                                                determination, FinCEN would update                      or on behalf of an A7 Network Sub-                       80 FinCEN notes that CVC payment systems are

                                                                                                                                                              often designed to limit the control of specific

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                                                the list accordingly.                                   Agent and outline the steps a covered
                                                                                                                                                              financial institutions over transactions and to
                                                                                                        financial institution should take in such             prevent rejections of funds by persons or entities
                                                3. Convertible Virtual Currency (CVC)                   circumstances. In providing for the                   other than the sender of funds. As a result, although
                                                   The term ‘‘convertible virtual                       rejection of CVC under certain limited                covered financial institutions may institute an
                                                currency (CVC)’’ means a medium of                      circumstances, FinCEN acknowledges                    internal prohibition on the sending of CVC
                                                                                                                                                              transactions to another address or entity, FinCEN
                                                exchange that either has an equivalent                  that, at this time, there may be                      assesses that there are few, if any, readily available
                                                value as currency, or acts as a substitute              technological limitations that may limit              ways for covered financial institutions to ‘‘reject’’
                                                for currency, but lacks legal tender                    or preclude covered financial                         incoming CVC transactions (prior to receipt).

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                                                                       Federal Register / Vol. 91, No. 191 / Monday, October 5, 2026 / Proposed Rules                                                  63219

                                                which the covered financial institution                 procedures designed to identify                         3. The appropriate scope of the due
                                                maintains a direct commercial                           transactions involving, and any use of                diligence requirement in this proposed
                                                relationship. The purpose of this                       any account to process transactions                   rule.
                                                requirement is to ensure that persons                   involving, any A7 Network Sub-Agent.
                                                                                                                                                              VI. Executive Order 14294
                                                affected by the proposed prohibition                    A covered financial institution would be
                                                have an opportunity to understand the                   expected to apply an appropriate                        Section 5 of Executive Order 14294
                                                nature and impact of the proposed                       screening mechanism to identify a                     directs that all future