Iran Evades US Sanctions Through Shadow Banking Sanctions Evasion

[ABS News Service/03.10.2026]

The Treasury Department yesterday took what it called “unprecedented” action against the A7 Network, a shadow banking network with ties to Russia used by the Iranian regime to evade sanctions.

Treasury’s Office of Foreign Assets Control sanctioned the A7 Network as a significant transnational criminal organization.

Treasury also proposed a rule that would prohibit transmittals of funds regarding transactions involving the A7 Network’s Sub-Agents. And issued an Alert to help financial institutions detect and report suspicious activity related to the A7 Network.

“Treasury is dismantling the financial infrastructure that allows Iran and other adversaries to evade sanctions, move illicit funds, and undermine the integrity of the global financial system,” Treasury Secretary Scott Bessent said. “Today’s action targeting A7 continues Treasury’s unprecedented efforts to isolate Iran and its financial enablers and sends a clear message that if you facilitate illicit finance for America’s adversaries, you will lose access to the US financial system.”

The A7 Network was created and backed by U.S.-sanctioned persons in order to evade sanctions, Treasury said. The network has developed a global web of Sub-Agents, companies that are purpose-built to disguise payments linked to sanctioned sectors and persons as ordinary commercial activity. The A7 Network has been leveraged by Iran, including Iran’s Islamic Revolutionary Guard Corps.

The A7 Network’s Sub-Agents are a constellation of companies based in third-country jurisdictions designed to receive and remit payments to facilitate transactions for the A7 Network. These Sub-Agents form a core layer of the A7 Network’s operational architecture as a purpose-built sanctions evasion and money laundering mechanism connected to Russian illicit finance and exploited by other illicit finance threat actors, including Iran.

The A7 Network exploits the international financial system by leveraging Sub-Agents, falsified trade documents, falsified import-export records and misleading goods descriptions to make sanctioned or illicit payments appear to be ordinary commercial activity, Treasury said.

By its own account, as of January 2026, the A7 Network claimed to process more than 2,000 transactions a day with a total transaction volume of more than 7.5 trillion rubles or about $91.5 billion – approximately 13 percent of the Russian Federation’s 2025 foreign trade transactions.