According to ChainCatcher, the U.S. Treasury Department’s Office of Foreign Assets Control has identified the Russian shadow banking network A7 Network as a major transnational criminal organization, listing its relevant addresses in Russia, Kyrgyzstan, Nigeria and Zimbabwe. The Financial Crimes Enforcement Bureau has proposed a separate draft rule that prohibits U.S. institutions from participating in any fund transmission involving the network's "sub-agent companies." The scope of application covers convertible virtual currencies and is not limited to legal currencies. It is expected to bind approximately 348,000 institutions, including multiple cryptocurrency exchanges.
The proposal relies on six special measures granted by Section 9714 of the Russian Money Laundering Act, and ultimately selects the sixth one, a funds transmission ban. The fifth item of current account restrictions is considered to leave loopholes: research by blockchain intelligence company TRM Labs shows that A7A5’s transactions completely bypassed the correspondent banking system, and is regarded by the Financial Crimes Enforcement Agency as a core link in its business model. A7A5 is a ruble-backed token issued by Old Vector registered in Kyrgyzstan, running on Tron and Ethereum, with reserves stored in the Russian state-owned defense bank Promsvyazbank.
The Financial Crimes Enforcement Bureau stated that between February 2025 and June 2026, more than 180 entities handled at least $179.1 billion in A7A5. Historically, almost all of it flowed through the sanctioned exchanges Garantex and Grinex, which are often used as a non-freezing bridge to transfer into USDT and then into legal tender.