FinCEN Alert on A7 Network
FinCEN recently issued an Alert (FIN-2026-Alert007) regarding suspicious activity associated with the A7 Network. Essentially, …the A7 Network provides a financial services infrastructure for customers in Russia and other heavily sanctioned jurisdictions, such as Iran, which enables them to make cross-border payments in both fiat currency and digital assets while obscuring the sanctions nexus from U.S. and foreign financial institutions. Its global ambitions and self-described role as a sanctions-resistant payment service provider have made it a conduit for illicit activity associated with a wide range of threat actors, including North Korea (DPRK); Iran-backed terrorist organizations; cybercriminals and ransomware actors; and the IRGC (aka Iran’s Islamic Revolutionary Guard Corps).
The Alert provides an in-depth analysis of how the A7 Network operates as well as 17 red flag indicators to help financial institutions to detect, prevent and report such activity. FinCEN requests that financial institutions reference this Alert in SAR field 2 (“Filing Institution Note to FinCEN”) and the narrative by including the key term “FIN-2026-A7NETWORK”.
Published 2026/10/07
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!