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.