Audit log

Every state-changing event for A7 Network: moderation decisions on community submissions, plus corrections and updates from the news pipeline. URL-based decisions are designed to carry three independent witnesses — the original source, an Internet Archive snapshot, and a Solana memo signed by our publicly-disclosed publisher key. Archive coverage is still being backfilled, so each decision below reports its own snapshot status rather than assuming one exists.

1. #1publishby system:backfill

   2026-10-04 12:04:04Z
   Score: ? → ? (no score change)
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   ●mainnet-betaslot 453,251,100

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   2MSnjvkG4R5m…6R6ySG4qcopyexplorer ↗

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   34hHHSK7xcEE…yjHUT8UZcopysha256 → base58

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   {"actor":"system:backfill","investigation_id":"385a7eb0-2dee-4d8d-ac08-180a6aa8d713","kind":"publish","page_slug":"a7-network","published_at":"2026-10-04T12:04:04.500Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"A7 Network","sections":[{"content":"On October 1, 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) designated A7 Network a 'significant transnational criminal organization' under Operation Economic Outcast. The same day, FinCEN issued a Finding and Notice of Proposed Rulemaking (NPRM) under Section 9714 of the Combating Russian Money Laundering Act, proposing 31 CFR 1010.668, which would prohibit all approximately 348,000 covered U.S. financial institutions — including crypto exchanges, banks, and broker-dealers — from transmitting funds or convertible virtual currency involving identified A7 Sub-Agents. The proposed rule entered a 30-day public comment period (Docket FINCEN-2026-0265). FinCEN simultaneously issued a financial institution alert detailing red flags for detecting A7 activity. Treasury stated the network processes more than 2,000 transactions per day, representing roughly 7.5 trillion rubles (approximately $91.5 billion), which Treasury estimates at about 13 percent of Russia's total 2025 foreign trade. FinCEN separately assessed that A7 Sub-Agents processed more than $17 billion in dollar-denominated transfers between January 2025 and June 2026. A7 LLC and Old Vector LLC (issuer of the A7A5 token) had each been previously sanctioned by OFAC on August 14, 2025.","heading":"OFAC Designation and U.S. Enforcement","severity":"critical","sources":[{"credibility":1,"name":"U.S. Treasury press release: Operation Economic Outcast (official)","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0644"},{"credibility":1,"name":"FinCEN Alert on A7 Network (PDF)","type":"regulatory","url":"https://www.fincen.gov/system/files/2026-10/FinCEN-Alert-A7-Network.pdf"},{"credibility":2,"name":"TRM Labs: FinCEN Moves to Cut the A7 Network's Sub-Agents Off From the U.S. Financial System","type":"research","url":"https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system"},{"credibility":2,"name":"crypto.news: U.S. sanctions A7 Network after $17B in transfers","type":"news_article","url":"https://crypto.news/u-s-sanctions-a7-network-after-17b-in-transfers/"}]},{"content":"A7 Network is composed of three Russia-based core entities — A7 LLC, A71 LLC, and A7 Agent LLC — jointly owned by Ilan Mironovich Shor and Promsvyazbank. The network operates internationally through a web of shell companies FinCEN designates as Sub-Agents: companies registered and nominally managed by non-Russian nationals in third-country jurisdictions, but controlled in practice by A7 personnel in Moscow. As of June 2026, approximately 435 financial institutions across at least 83 countries maintained accounts for A7 Sub-Agents, concentrated in the UAE, Hong Kong, Kyrgyzstan, Turkey, Indonesia, and the Seychelles. Operationally, A7 staff in Moscow access foreign bank accounts via custom virtual private networks (VPNs) designed to make transactions appear to originate from Dubai, Hong Kong, or Bishkek. Payments are disguised as ordinary commercial activity through falsified trade documents, fabricated import-export records, and misleading product descriptions. A primary financial instrument is the veksel, or promissory note, a Russian form of bill of exchange: between September 2024 and July 2025, clients purchased over 3,200 veksels worth more than $25 billion. A7A5 functions as a parallel internal accounting mechanism, with TRM Labs finding that roughly one-third of reported on-chain A7A5 volume stems from circular transfers within a narrow wallet cluster.","heading":"Network Structure and Operational Mechanics","severity":"critical","sources":[{"credibility":2,"name":"TRM Labs: FinCEN Moves to Cut the A7 Network's Sub-Agents Off From the U.S. Financial System","type":"research","url":"https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system"},{"credibility":1,"name":"U.S. Treasury press release: Operation Economic Outcast (official)","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0644"},{"credibility":2,"name":"Cense: A7A5 — inside Russia's emerging blockchain financial infrastructure","type":"research","url":"https://www.cense.com/news/a7a5-a-thematic-study/"}]},{"content":"A7A5 is a ruble-backed stablecoin issued by Old Vector LLC, a company registered in the Kyrgyz Republic. The token operates on both the Tron and Ethereum public blockchains. Reserves are held at Promsvyazbank, Russia's state-owned defense bank, which was sanctioned by Western governments because of its close ties to Russia's defense sector. A7A5 was promoted internally as a stablecoin beyond Western financial control. According to Elliptic's analysis of leaked A7 internal documents, A7A5 transferred approximately $102 billion in its first year of operation. TRM Labs found more than 180 entities processed A7A5 transactions worth at least $179.1 billion between February 2025 and June 2026, though TRM assessed that approximately $35 billion of reported A7A5 volume consisted of circular transfers between network addresses used for internal bookkeeping rather than genuine payment flows. Elliptic reported a sharp decline in A7A5 usage following initial exposure and sanctions, with daily average volume falling approximately 96 percent from a July 2025 peak to $24.3 million per day in June 2026. Old Vector LLC was designated by OFAC on August 14, 2025.","heading":"A7A5 Stablecoin — Blockchain Infrastructure","severity":"critical","sources":[{"credibility":2,"name":"TRM Labs: On-Chain Analysis of Russia's Cryptocurrency Connections (A7 Leaks)","type":"on_chain","url":"https://www.trmlabs.com/resources/blog/the-a7-leaks-trms-on-chain-analysis-of-russias-cryptocurrency-connections"},{"credibility":2,"name":"Elliptic: The A7 leaks — The role of crypto in Russian sanctions evasion and election interference","type":"research","url":"https://www.elliptic.co/insights/the-a7-leaks-the-role-of-crypto-in-russian-sanctions-evasion-and-election-interference/"},{"credibility":2,"name":"Cense: A7A5 — inside Russia's emerging blockchain financial infrastructure","type":"research","url":"https://www.cense.com/news/a7a5-a-thematic-study/"},{"credibility":2,"name":"Scorechain: EU Sanctions A7A5 Stablecoin and Tightens Rules on Crypto Compliance","type":"news_article","url":"https://www.scorechain.com/blog/eu-sanctions-a7a5-stablecoin-tightens-crypto-compliance"}]},{"content":"A7 Network is led by Ilan Mironovich Shor, described by the U.S. Treasury as a sanctioned and convicted criminal fraudster. Shor is a Moldovan oligarch who has been a fugitive from Moldovan justice following his conviction in connection with the 2014 theft of approximately $1 billion from Moldovan banks. He has been under U.S. OFAC sanctions and is a known ally of the Russian government. Shor co-founded A7 alongside Promsvyazbank and has been publicly identified in leaked internal A7 documents as the network's principal architect. Shor reportedly presented A7's transaction volumes to Vladimir Putin in early September 2024. The EU added A7A5 project head Leonid Shumakov and Promsvyazbank chairman Mikhail Dorofeev to its sanctions lists as part of the 21st sanctions package in July 2026.","heading":"Key Individual: Ilan Mironovich Shor","severity":"critical","sources":[{"credibility":1,"name":"U.S. Treasury press release: Operation Economic Outcast (official)","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0644"},{"credibility":2,"name":"Radio Free Europe/Radio Liberty: A7, Company Implicated In Sanctions Evasion, Reportedly Linked To Russian Oligarchs","type":"news_article","url":"https://www.rferl.org/a/russia-cryptocurrency-a7a5-ilan-shor-investigation-sanction-evasion/33746026.html"},{"credibility":2,"name":"CoinDesk: EU hits Russia with 21st sanctions package targeting $120B crypto network","type":"news_article","url":"https://www.coindesk.com/policy/2026/07/24/eu-hits-russia-with-massive-21st-sanctions-package-targeting-usd120b-crypto-network"}]},{"content":"TRM Labs' on-chain analysis of the A7 Leaks identified direct cryptocurrency flows linking A7-controlled addresses to multiple sanctioned and designated entities. One A7 address received more than $65 million in direct transfers from an address attributed to Iran's Islamic Revolutionary Guard Corps (IRGC). Another A7 address received approximately $5 million from Hamas-linked sources. At least $590,000 in proceeds from the hacks of cryptocurrency exchanges BTCTurk and Woo X — both attributed to North Korean government hackers — moved through a series of intermediaries before reaching A7-controlled addresses. Treasury separately stated that one A7 Sub-Agent received nearly $140 million from entities involved in Iranian sanctions evasion between July 2023 and October 2025, and another transferred approximately $1.6 million linked to Iranian weapons procurement. TRM Labs also identified TokenSpot, a Kyrgyz exchange, operating on shared infrastructure with Grinex, finding that A7, Grinex, and Garantex combined represent 28 percent of TokenSpot's outgoing volume. The total identified flow between A7 and sanctioned entities (IRGC, Hamas, Houthis, and Iranian intermediaries) was assessed at $176.6 million by TRM Labs.","heading":"On-Chain Connections to Sanctioned and Illicit Actors","severity":"critical","sources":[{"credibility":2,"name":"TRM Labs: On-Chain Analysis of Russia's Cryptocurrency Connections (A7 Leaks)","type":"on_chain","url":"https://www.trmlabs.com/resources/blog/the-a7-leaks-trms-on-chain-analysis-of-russias-cryptocurrency-connections"},{"credibility":1,"name":"U.S. Treasury press release: Operation Economic Outcast (official)","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0644"}]},{"content":"The European Union sanctioned components of the A7 Network in its 21st package of restrictive measures, adopted on July 23, 2026. The package included 218 listings — 48 individuals and 170 entities — and added four A7-related designations, including A7 Agent LLC, A71 LLC, A7A5 project head Leonid Shumakov, and Promsvyazbank chairman Mikhail Dorofeev. The EU's 21st package also extended transaction bans to 14 crypto-related service platforms based in Georgia, Panama, the UAE, the Marshall Islands, Kyrgyzstan, and Belarus. The UK's National Crime Agency (NCA) and National Economic Crime Centre (NECC) issued Flash Alert 0808-NECC on August 31, 2026, described as the UK's first industry-wide sanctions alert to the entire regulated sector rather than a limited group of firms. The NCA alert specifically described A7's use of promissory notes, shell companies, payment service providers, SWIFT, and A7A5 to circumvent sanctions, and noted that OFSI had identified payments to UK-incorporated beneficiaries. The UK simultaneously announced it would double the maximum financial penalty available to the Office of Financial Sanctions Implementation from 50 percent to 100 percent of the value of a sanctions breach.","heading":"EU and UK Sanctions and Regulatory Actions","severity":"critical","sources":[{"credibility":1,"name":"CoinDesk: EU hits Russia with 21st sanctions package targeting $120B crypto network","type":"regulatory","url":"https://www.coindesk.com/policy/2026/07/24/eu-hits-russia-with-massive-21st-sanctions-package-targeting-usd120b-crypto-network"},{"credibility":1,"name":"LexisNexis UK: NCA and NECC issue flash alert detailing A7 sanctions evasion network","type":"regulatory","url":"https://www.lexisnexis.co.uk/legal/news/nca-necc-issue-flash-alert-detailing-a7-sanctions-evasion-network-compliance-risks"},{"credibility":2,"name":"GlobalSanctions.com: UK NCA issues industry-wide alert on A7 Russia sanctions evasion network","type":"news_article","url":"https://globalsanctions.com/2026/09/uk-nca-issues-industry-wide-alert-on-a7-russia-sanctions-evasion-network/"},{"credibility":2,"name":"Decrypt: EU Sanctions A7 Crypto Network Tied to Russian Election Interference","type":"news_article","url":"https://decrypt.co/330338/eu-sanctions-a7-crypto-network-tied-to-russian-election-interference"}]},{"content":"Elliptic's analysis of the A7 Leaks, published around the time of Moldova's October 2024 parliamentary elections, alleged that wallets linked to A7 received $8 billion in stablecoins and that the network was used to finance Russian election interference activities in Eastern Europe. Cryptopolitan and crypto.news reported that the leaked A7 internal documents revealed Shor-controlled businesses used A7A5 and the broader network infrastructure to move funds allegedly tied to influencing election outcomes in Moldova and potentially other Eastern European states. These allegations are based on analysis of leaked documents and on-chain data; no criminal conviction or court ruling on election interference charges has been reported as of October 2026.","heading":"Election Interference Allegations","severity":"high","sources":[{"credibility":2,"name":"Elliptic: The A7 leaks — The role of crypto in Russian sanctions evasion and election interference","type":"research","url":"https://www.elliptic.co/insights/the-a7-leaks-the-role-of-crypto-in-russian-sanctions-evasion-and-election-interference/"},{"credibility":2,"name":"Cryptopolitan: A7 leaks reveal Russia's influence over Eastern European elections with crypto","type":"news_article","url":"https://www.cryptopolitan.com/a7-leaks-russia-influence-elections-crypto/"},{"credibility":2,"name":"crypto.news: A7 leaks expose $8B crypto pipeline fueling Russia's shadow politics","type":"news_article","url":"https://crypto.news/a7-leaks-expose-8b-crypto-pipeline-fueling-russias-shadow-politics/"}]},{"content":"The multi-jurisdictional enforcement actions against A7 Network create direct compliance obligations for crypto exchanges, banks, payment processors, and broker-dealers globally. FinCEN's proposed rule would require covered U.S. financial institutions to screen against a confidential list of A7 Sub-Agents maintained on the FinCEN FI Portal, block or reject fund transmittals involving those Sub-Agents, and file suspicious activity reports. The breadth of A7's Sub-Agent network — 435 financial institutions across 83 countries — means that counterparty exposure may exist at institutions that passed standard know-your-customer checks because Sub-Agents are nominally registered as ordinary commercial entities. OFAC offers whistleblower rewards for information leading to penalties exceeding $1 million. TRM Labs identified TokenSpot, a Kyrgyz exchange, as operating on overlapping infrastructure with A7-linked entities and noted it remained unsanctioned as of the publication of TRM's analysis. Any crypto platform that has processed A7A5 transactions or maintained accounts for identified Sub-Agents faces potential sanctions exposure.","heading":"Compliance Risk for Financial Institutions and Crypto Platforms","severity":"high","sources":[{"credibility":2,"name":"TRM Labs: FinCEN Moves to Cut the A7 Network's Sub-Agents Off From the U.S. Financial System","type":"research","url":"https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system"},{"credibility":1,"name":"U.S. Treasury press release: Operation Economic Outcast (official)","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0644"},{"credibility":2,"name":"CoinCentral: U.S. Treasury Sanctions A7 Network Over $17 Billion in Illicit Crypto and Fiat Transfers","type":"news_article","url":"https://coincentral.com/u-s-treasury-sanctions-a7-network-over-17-billion-in-illicit-crypto-and-fiat-transfers"}]}],"sources_used":[{"credibility":1,"name":"U.S. Treasury: Operation Economic Outcast (official press release)","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0644"},{"credibility":1,"name":"FinCEN Alert on A7 Network (PDF)","type":"regulatory","url":"https://www.fincen.gov/system/files/2026-10/FinCEN-Alert-A7-Network.pdf"},{"credibility":2,"name":"TRM Labs: On-Chain Analysis of Russia's Cryptocurrency Connections (A7 Leaks)","type":"on_chain","url":"https://www.trmlabs.com/resources/blog/the-a7-leaks-trms-on-chain-analysis-of-russias-cryptocurrency-connections"},{"credibility":2,"name":"TRM Labs: FinCEN Moves to Cut the A7 Network's Sub-Agents Off From the U.S. Financial System","type":"research","url":"https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system"},{"credibility":2,"name":"Elliptic: The A7 Leaks — The role of crypto in Russian sanctions evasion and election interference","type":"research","url":"https://www.elliptic.co/insights/the-a7-leaks-the-role-of-crypto-in-russian-sanctions-evasion-and-election-interference/"},{"credibility":1,"name":"CoinDesk: EU hits Russia with 21st sanctions package targeting $120B crypto network","type":"news_article","url":"https://www.coindesk.com/policy/2026/07/24/eu-hits-russia-with-massive-21st-sanctions-package-targeting-usd120b-crypto-network"},{"credibility":1,"name":"LexisNexis UK: NCA and NECC issue flash alert detailing A7 sanctions evasion network","type":"regulatory","url":"https://www.lexisnexis.co.uk/legal/news/nca-necc-issue-flash-alert-detailing-a7-sanctions-evasion-network-compliance-risks"},{"credibility":2,"name":"GlobalSanctions.com: UK NCA issues industry-wide alert on A7 Russia sanctions evasion network","type":"news_article","url":"https://globalsanctions.com/2026/09/uk-nca-issues-industry-wide-alert-on-a7-russia-sanctions-evasion-network/"},{"credibility":2,"name":"Decrypt: EU Sanctions A7 Crypto Network Tied to Russian Election Interference","type":"news_article","url":"https://decrypt.co/330338/eu-sanctions-a7-crypto-network-tied-to-russian-election-interference"},{"credibility":2,"name":"Cryptopolitan: A7 leaks reveal Russia's influence over Eastern European elections with crypto","type":"news_article","url":"https://www.cryptopolitan.com/a7-leaks-russia-influence-elections-crypto/"},{"credibility":2,"name":"crypto.news: A7 leaks expose $8B crypto pipeline fueling Russia's shadow politics","type":"news_article","url":"https://crypto.news/a7-leaks-expose-8b-crypto-pipeline-fueling-russias-shadow-politics/"},{"credibility":2,"name":"Radio Free Europe/Radio Liberty: A7, Company Implicated In Sanctions Evasion, Reportedly Linked To Russian Oligarchs","type":"news_article","url":"https://www.rferl.org/a/russia-cryptocurrency-a7a5-ilan-shor-investigation-sanction-evasion/33746026.html"},{"credibility":2,"name":"Cense: A7A5 — inside Russia's emerging blockchain financial infrastructure","type":"research","url":"https://www.cense.com/news/a7a5-a-thematic-study/"},{"credibility":2,"name":"Scorechain: EU Sanctions A7A5 Stablecoin and Tightens Rules on Crypto Compliance","type":"news_article","url":"https://www.scorechain.com/blog/eu-sanctions-a7a5-stablecoin-tightens-crypto-compliance"},{"credibility":2,"name":"CoinCentral: U.S. Treasury Sanctions A7 Network Over $17 Billion in Illicit Crypto and Fiat Transfers","type":"news_article","url":"https://coincentral.com/u-s-treasury-sanctions-a7-network-over-17-billion-in-illicit-crypto-and-fiat-transfers"},{"credibility":2,"name":"Cryptopolitan: Kremlin-backed A7 mixed bank transfers and crypto to evade sanctions","type":"news_article","url":"https://www.cryptopolitan.com/kremlin-backed-a7-mixed-bank-transfers-and-crypto-to-evade-sanctions/"},{"credibility":2,"name":"The Insider / theins.press: EU sanctions A7 cryptocurrency network and Russian banking executive","type":"news_article","url":"https://theins.press/en/news/295295"}],"summary":"A7 Network is a Russia-linked cross-border payment and shadow banking network established in late 2024 by sanctioned Moldovan oligarch Ilan Mironovich Shor and Russian state defense bank Promsvyazbank (PSB). The network operates through a constellation of shell companies known as Sub-Agents across more than 83 countries and issues a ruble-backed stablecoin called A7A5 on Tron and Ethereum. On October 1, 2026, the U.S. Treasury's OFAC designated A7 Network a significant transnational criminal organization and FinCEN proposed a rulemaking to prohibit U.S. financial institutions from transmitting funds involving its Sub-Agents; the EU and UK had issued related sanctions and alerts in the preceding months.","timeline":[{"date":"2024-09-01","event":"A7 Network formally launched by Ilan Mironovich Shor and Promsvyazbank (PSB), Russia's state-owned defense bank, alongside VEB.RF (Russian State Development Corporation). Network begins facilitating cross-border payments for Russian entities excluded from the formal banking system.","source":"GlobalSanctions.com / UK NCA Flash Alert summary","source_url":"https://globalsanctions.com/2026/09/uk-nca-issues-industry-wide-alert-on-a7-russia-sanctions-evasion-network/"},{"date":"2024-09-01","event":"Ilan Shor reportedly presents A7's transaction volumes to Vladimir Putin, citing 7.5 trillion rubles ($89 billion) in settled cross-border transactions within approximately ten months of operation.","source":"crypto.news / A7 Leaks reporting","source_url":"https://crypto.news/a7-leaks-expose-8b-crypto-pipeline-fueling-russias-shadow-politics/"},{"date":"2025-08-14","event":"OFAC designates A7 LLC and Old Vector LLC (issuer of the A7A5 ruble-backed stablecoin). This is the first U.S. sanctions action directly targeting A7 Network entities.","source":"U.S. Treasury Operation Economic Outcast press release","source_url":"https://home.treasury.gov/news/press-releases/sb0644"},{"date":"2026-06-02","event":"OFAC designates Nobitex, Iran's largest digital asset exchange, which Treasury links to A7 Network's Iran-facing operations.","source":"U.S. Treasury Operation Economic Outcast press release","source_url":"https://home.treasury.gov/news/press-releases/sb0644"},{"date":"2026-07-23","event":"EU adopts its 21st package of restrictive measures against Russia, adding four A7-linked designations (A7 Agent LLC, A71 LLC, Leonid Shumakov, Mikhail Dorofeev) and extending transaction bans to 14 crypto platforms in third countries.","source":"CoinDesk","source_url":"https://www.coindesk.com/policy/2026/07/24/eu-hits-russia-with-massive-21st-sanctions-package-targeting-usd120b-crypto-network"},{"date":"2026-08-31","event":"UK National Crime Agency and National Economic Crime Centre issue Flash Alert 0808-NECC — the UK's first industry-wide sanctions alert — warning the entire regulated sector about A7's methods, including use of promissory notes, shell companies, VPNs, and A7A5.","source":"LexisNexis UK / GlobalSanctions.com","source_url":"https://globalsanctions.com/2026/09/uk-nca-issues-industry-wide-alert-on-a7-russia-sanctions-evasion-network/"},{"date":"2026-09-26","event":"Elliptic flags the A7 Leaks — a trove of internal A7 documents — revealing on-chain and operational details of the network, including alleged election interference activity and $8 billion in stablecoin flows through associated wallets.","source":"Elliptic","source_url":"https://www.elliptic.co/insights/the-a7-leaks-the-role-of-crypto-in-russian-sanctions-evasion-and-election-interference/"},{"date":"2026-10-01","event":"OFAC designates A7 Network a significant transnational criminal organization under Operation Economic Outcast. FinCEN simultaneously issues a proposed rulemaking (31 CFR 1010.668) to prohibit U.S. financial institutions from transmitting funds involving A7 Sub-Agents, and issues a financial institution alert with red flags for detection.","source":"U.S. Treasury / FinCEN","source_url":"https://home.treasury.gov/news/press-releases/sb0644"}]},"v":1}

   Verify offline (run on your own machine)

   python -m src.verify_decision a280bd07-563e-4215-8d32-59d8738bc4b1copy