The U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) is issuing this Alert to urge financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity, including involving the A7 Network. The A7 Network is a global wholesale sanctions evasion and money laundering service with ties to Russia, leveraged by a wide range of illicit actors, including Iran and its terrorist proxies. The A7 Network’s well-established and far-reaching digital asset channels are an appealing tool for a wide range of threat actors. Analysis of BSA data also indicates that Iranian actors are leveraging the A7 Network, including the Central Bank of Iran and Iran’s Islamic Revolutionary Guard Corps (IRGC).

FinCEN is issuing this Alert concurrently with a finding and notice of proposed rulemaking pursuant to section 9714(a) of the Combating Russian Money Laundering Act, finding transactions involving any company operating outside of the United States that is controlled by the A7 Network to be a class of transactions of primary money laundering concern.

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