A7 Sub-Agents (e.g. UK, Seychelles, Jersey, etc.): the risk and the money-laundering exposure of being one

FinCEN says the A7 Network’s payments depend on third-country companies, which it calls Sub-Agents. The Sub-Agent appears as the contracting or paying party on the invoice, the sales agreement and the payment instruction. Moscow-based A7 personnel typically move the funds, often over a VPN, so the sanctioned customer never appears in the chain.

Being that company, or the person who forms, directs or banks it, is not a paperwork role.

• Under the UK Proceeds of Crime Act 2002 and the Proceeds of Crime (Jersey) Law 1999, that role is capable of being an arrangement offence if the person knows or suspects that the arrangement facilitates control of criminal property.

• Under the Seychelles Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020, the same facts can constitute money laundering: a foreign sanctions breach can be criminal conduct unless the Attorney General certifies otherwise, and concealing, transferring, or possessing the resulting property is the offence.

In all three places, the mental element still has to be proved. The US label does not supply it.

What does Treasury mean by Sub-Agent?

• On 1 October 2026, OFAC designated the A7 Network a significant transnational criminal organisation. The same day, FinCEN proposed a special measure that would bar covered US institutions from sending or receiving funds, including convertible virtual currency, to or from any company outside the United States that A7 controls. The proposed rule was published on 5 October 2026. Comments run for 30 days.

• FinCEN’s definition is functional, not geographic. A Sub-Agent is any non-US company controlled by A7 and used to receive and remit payments so that a Russian or Iranian customer never appears in the chain. A7 forms, buys or partners with companies in places such as

  • Hong Kong, Indonesia, the Kyrgyz Republic,

  • Seychelles, Türkiye, and the United Arab Emirates”.

• On paper, the owners and directors are typically non-Russian. FinCEN says control sits with A7.

• FinCEN only names six Sub-Agents in the public rule, and all six are UAE free-zone firms. The rest sit on a list FinCEN shares with covered banks and other institutions through its secure FI-Portal, not in the Federal Register. FinCEN’s reason, as reported by TRM Labs, is that a public list would let A7 stand up replacement companies faster. Institutions would only have to block transmittals involving entities on that list.

• The six named in secondary reports of the rule, with the flows FinCEN attributes, are:

  • Power Sphere LLC-FZ, Dubai, electronics supplier: $61 million, September 2023 to July 2025, tied to Russian trade-based money laundering and energy-sector procurement.

  • Hydrofusion Resources FZ-LLC, UAE, energy commodities: $3.6 million, May to June 2025.

  • Gimli Trade LLC-FZ, Dubai: $1.5 million, May to June 2025. The UK sanctioned it on 18 December 2025.

  • Galadriel Trading FZCO, Dubai, agricultural trader: more than $946,000, May to July 2025, tied to Russian export-control evasion.

  • Sigizmund FZCO: $41,000, July to September 2025, on TRM’s account including dual-use goods.

  • Pearl Bridge: about $30,000, named by TRM Labs. This name was not in the Federal Register extract checked here.

  • Sources:

    • Federal Register proposed rule: https://www.federalregister.gov/documents/2026/10/05/2026-20371/proposal-of-special-measure-prohibiting-the-transmittal-of-funds-regarding-transactions-involving

    • TRM Labs, including the sixth name and the FI-Portal point: https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system

    • Zyphe summary of the private list: https://www.zyphe.com/resources/news/a7-network-sanctions-fincen-sub-agents-october-2026

• As of June 2026, FinCEN says there were hundreds of Sub-Agents, banked at about 435 institutions in at least 83 countries, moving more than $17 billion in dollar transactions from January 2025 to June 2026. Those figures are FinCEN’s assessment of the whole web.

How is the role performed?

In FinCEN’s account of a typical deal:

• The customer settles inside A7.

• A Sub-Agent outside Russia is the contracting party on the invoice, the sales agreement and the payment instruction.

• Funds often pass through more than one Sub-Agent.

• Moscow staff operate the accounts over VPNs on infrastructure FinCEN ties to Ilan Shor, on the domains muzpan.com and sodkamus.com. Logins often resolve to Dubai, Hong Kong or the Kyrgyz Republic.

• Trade documents are false, goods descriptions do not match the supplier, and some invoices show signs of AI alteration.

The bank sees ordinary commercial activity. That is the point of the structure.

Legal consequences of being the Sub-Agent - London, Victoria or St Helier

The US label does not, by itself, convict the nominee in London, Victoria or St Helier. It does, however, describe conduct that

• Maps directly onto existing money-laundering offences.

• Knowledge or suspicion is the line.

• A shelf company with no knowledge is a different case from a director who signs the invoice knowing the goods are not his and the payer is a sanctioned Russian buyer.

United Kingdom — Proceeds of Crime Act 2002

• Sanctions evasion is a criminal offence. Property obtained by or in connection with that offence may constitute criminal property.

• Section 327: concealing, disguising, converting, transferring or removing criminal property. Putting a sub-agent's name on the payment chain is capable of being a disguise of ownership and a transfer.

• Section 328: entering into or becoming concerned in an arrangement which the person knows or suspects facilitates the acquisition, retention, use or control of criminal property by another. This is the offence that best fits the Sub-Agent role. The nominee, the corporate service provider who sets the company up for that purpose, and the accountant who runs the account can each be “concerned in” the arrangement.

• Section 329: acquiring, using or possessing criminal property. The adequate-consideration exception in section 329(2) does not cleanse the property, and it does not apply to sections 327 or 328. Paying a market price for the goods is not a defence to concealing or arranging.

• Section 330: failure to disclose, in the regulated sector, where the person knows or suspects, or has reasonable grounds for knowing or suspecting, that another person is engaged in money laundering, and the information came in the course of business. A corporate service provider or bank that forms or banks the company and does not report is in this frame. The disclosure defence to the principal offences depends on a report to the NCA before the act, or as soon as practicable, and on having the required consent where relevant.

• Section 333A: tipping off. Warning the customer that a report has been made is a separate offence.

• The maximum penalty on indictment for the principal offences is 14 years. Confiscation follows a conviction.

• Companies can be prosecuted. Under the Economic Crime and Corporate Transparency Act 2023, a senior manager’s offence can be the company’s offence if committed within the actual or apparent scope of their authority.

• Circumvention of UK financial sanctions is a separate offence under the Russia (Sanctions) (EU Exit) Regulations 2019. Intentionally participating in activities, knowing that the object or effect is to circumvent a prohibition or to enable or facilitate contravention, does not require the person to be the designated party. A Sub-Agent that is the paying face of a prohibited payment is in that territory. OFSI civil monetary penalties do not require the criminal standard.

Jersey

• The Proceeds of Crime (Jersey) Law 1999 creates equivalent offences of dealing with criminal property and of entering into arrangements for its acquisition, retention, use or control, plus failure-to-disclose and tipping-off offences for financial services businesses.

• The Money Laundering (Jersey) Order 2008 and the AML/CFT/CPF Handbook require customer due diligence, ongoing monitoring, and the filing of a SAR with the FIU Jersey.

• Forming or administering a company whose sole function is to front sanctioned trade, with knowledge or suspicion, may constitute both a principal offence and a breach of the Order.

• Sanctions implementation sits under the Sanctions and Asset-Freezing (Jersey) Law 2019. A Jersey corporate service provider does not get a different answer because the company was incorporated in Seychelles or elsewhere.

Seychelles

• Seychelles does not apply UK, US or EU sanctions. A director in Victoria is not guilty of those foreign sanctions offences by forming or running a Seychelles company.

• The Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020, is separate.

  • “Criminal conduct” includes an act or omission against the law of another country, done there or elsewhere, UNLESS the Attorney General certifies that action in Seychelles would not be in the public interest.

• A known payment front for trade that breaches UK, US or EU sanctions can therefore be criminal conduct for Seychelles money-laundering purposes. The company being an international business company is not a defence.

• Source for the definition as published by the FIU: https://seychellesfiu.sc/other/

Who carries the risk, in practice

• The nominee director who signs or lends their name, knowing the trade is not theirs.

• The corporate service provider that incorporates the company, provides the registered office, and files the annual return, while Moscow runs the bank account.

• The bank or EMI that keeps the account after the red flags are present: new company, sudden volume, goods that do not match the profile, payments through related intermediaries, logins from muzpan.com or sodkamus.com, AI-altered invoices.

• The customer who uses the Sub-Agent. The legal exposure is not confined to the front company.

What should firms do?

• Read the primary texts, not a summary.

• Screen A7 LLC, A7 Agent, Old Vector, Ilan Shor, Promsvyazbank and VEB. Do not stop there. The Sub-Agent isn't designed to match those names.

• Add the FinCEN red flags to transaction monitoring:

  • Newly formed third-country trader,

  • Volume out of line with stated trade,

  • Goods mismatch,

  • Layered related-party routing,

  • VPN domains above,

  • Invoice anomalies.

• For existing Seychelles, UAE, Hong Kong, Kyrgyz, Turkish and Indonesian companies administered or banked in Jersey (or elsewhere), ask who instructs payments and from where.

  • A Moscow instructor on a VPN is the fact pattern FinCEN describes.

    • An instructor, in ordinary corporate-services use, is the person who tells the nominee director or the corporate service provider what to sign and where to pay.

    • FinCEN says the funds are typically moved between companies by Moscow-based A7 Network personnel. Those people operate the Sub-Agent bank accounts from Moscow via VPNs, so the login appears to come from Dubai, Hong Kong, or the Kyrgyz Republic.

    • The VPN infrastructure is tied to IT companies controlled by Ilan Shor, on the domains muzpan.com and sodkamus.com.

• Report where the statutory test is met. In Jersey, to the FIU.

  • In the UK regulated sector, to the NCA.

  • Do not tip off.

• Do not treat the proposed US ban as already in force. Do treat the underlying conduct as already capable of being a money-laundering offence here.

This note is a compliance briefing, not legal advice. Exposure turns on knowledge, suspicion and the facts of the arrangement.

Sources

• US Treasury press release, 1 October 2026: https://home.treasury.gov/news/press-releases/sb0644

• FinCEN proposed rule, Federal Register, 5 October 2026: https://www.federalregister.gov/documents/2026/10/05/2026-20371/proposal-of-special-measure-prohibiting-the-transmittal-of-funds-regarding-transactions-involving

• OFAC designation notice: https://thefederalregister.org/documents/2026-20395/notice-of-ofac-sanctions-action

• UK National Crime Agency / NECC A7 alert PDF, as linked by Comsure: https://www.nationalcrimeagency.gov.uk/who-we-are/publications/826-necc-a7-sanctions-evasion-mechanism/file.pdf

• Comsure, “A7: Jersey flags NCA warning on Russia’s hidden payment rail”: https://www.comsuregroup.com/news/a7-jersey-flags-nca-warning-on-russia-s-hidden-payment-rail/

• TRM Labs on the Sub-Agent structure: https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system

• Kharon briefing: https://www.kharon.com/brief/a7-treasury-department-money-laundering-sanctions

• Zyphe summary of named Sub-Agents: https://www.zyphe.com/resources/news/a7-network-sanctions-fincen-sub-agents-october-2026

• Decrypt report on the TCO designation: https://decrypt.co/379921/us-designates-russias-a7-network-as-transnational-criminal-organisation

• UK trade-based money laundering legal framework: https://www.gov.uk/guidance/trade-based-money-laundering-tbml-handbook/legal-framework

• Proceeds of Crime Act 2002: https://www.legislation.gov.uk/ukpga/2002/29/contents

• Russia (Sanctions) (EU Exit) Regulations 2019: https://www.legislation.gov.uk/uksi/2019/855/contents

• Economic Crime and Corporate Transparency Act 2023: https://www.legislation.gov.uk/ukpga/2023/56/contents

• Proceeds of Crime (Jersey) Law 1999: https://www.jerseylaw.je/laws/current/Pages/08.780.aspx

• Sanctions and Asset-Freezing (Jersey) Law 2019: https://www.jerseylaw.je/laws/current/Pages/17.750.aspx

Seychelles registry entry for AA7 GROUP LTD, not identified in the FinCEN rule: https://commercialregister.sc/seychelles/aa7-group-ltd/