{"investigation":{"slug":"a7a5-stablecoin-old-vector","entity_name":"A7A5 Stablecoin / Old Vector","trust_score":0,"severity_base":null,"score_modifier":-10,"confidence":0.97,"status":"published","content_type":"investigation","summary":"A7A5 is a Russian ruble-pegged stablecoin issued by Kyrgyzstan-registered Old Vector LLC on Ethereum and TRON, created by A7 LLC, a Moscow payments firm 51% owned by sanctioned Moldovan fugitive Ilan Shor and 49% by sanctioned Promsvyazbank. It has been designated or banned by the United States, European Union, United Kingdom and other jurisdictions for alleged use in Russian sanctions evasion, and is linked on-chain to the Garantex and Grinex exchanges. Reported volumes run from tens to hundreds of billions of dollars cumulatively, though usage reportedly collapsed by about 96% after enforcement in 2025-2026.","sections":[{"content":"A7A5 is a ruble-pegged stablecoin issued by Old Vector LLC, a Kyrgyzstan-registered company incorporated in Bishkek on December 13, 2024 (registration number 311479-3301-OOO, Tax ID 01312202410041; OFAC lists two Bishkek addresses), on behalf of A7 LLC, a Moscow-based cross-border payments company that was established to facilitate cross-border transfers for Russian clients facing Western sanctions. Sources differ on A7's founding: October 2024 with a registered address at Lesnaya Street 9, Moscow (OpenSanctions), or September 2024 (FinCEN/TRM Labs). A7 LLC is 51% owned by Ilan Shor and 49% by Promsvyazbank (PSB); OpenSanctions records indicate Shor held his stake until at least November 2024. PSB is Russia's eighth-largest bank, nationalized in 2008 and repurposed as a lender to the military-industrial complex, and is sanctioned by the US, EU and UK. Pyotr Fradkov, head of PSB since 2018 and son of former prime minister Mikhail Fradkov, is reported as A7's co-executive alongside Shor. Subsidiaries include A71 LLC and A7 Agent LLC (both designated by OFAC on August 14, 2025); A7 also operates under aliases including A7 OOO, A7-Broker and A7-Ekspluation Management Company, and received loans from the state development institution VEB.RF according to OpenSanctions. RFE/RL reported that Vladimir Putin took part in the opening of an A7 branch in Vladivostok in September 2025 at the Eastern Economic Forum, where Shor presented A7; accounts differ on whether he attended in person or by virtual ceremony, which researchers cited as evidence of high-level Kremlin backing.","heading":"Issuer, Ownership and Corporate Structure","sources":[{"url":"https://www.rferl.org/a/russia-cryptocurrency-moldova-kyrgyzstan-a7-sanctions/33609918.html","name":"The Fugitive Oligarch, The Cryptocurrency, And A 'Wild' Kremlin-Blessed Sanctions Evasion Scheme - RFE/RL","type":"news_article","credibility":1},{"url":"https://www.elliptic.co/blog/the-a7-leaks-the-role-of-crypto-in-russian-sanctions-evasion-and-election-interference","name":"The A7 Leaks: The role of crypto in Russian sanctions evasion and election interference - Elliptic","type":"research","credibility":2},{"url":"https://home.treasury.gov/news/press-releases/jy1049","name":"Treasury Targets Corruption and Kremlin Malign Influence in Moldova","type":"regulatory","credibility":1},{"url":"https://en.wikipedia.org/wiki/Ilan_Shor","name":"Ilan Shor - Wikipedia","type":"other","credibility":2},{"url":"https://www.europeaninterest.eu/moldovan-fugitive-oligarch-ilan-shor-in-russias-sanctions-circumvention-deal-reveals-an-ft-investigation/","name":"Moldovan fugitive oligarch Ilan Shor in Russia's sanctions circumvention deal - European Interest","type":"news_article","credibility":2},{"url":"https://www.opensanctions.org/entities/NK-ZoBhzZv7NdLLmjMYu9QXxg/","name":"A7 Limited Liability Company — OpenSanctions","type":"regulatory","credibility":1},{"url":"https://www.info-res.org/reports/a7a5-circumventing-sanctions-with-stablecoin-cryptocurrency/","name":"A7A5: Circumventing sanctions with stablecoin cryptocurrency - Centre for Information Resilience","type":"research","credibility":2},{"url":"https://www.elliptic.co/blog/ofac-targets-use-of-stablecoins-for-russian-sanctions-evasion","name":"OFAC targets use of stablecoins for Russian sanctions evasion - Elliptic","type":"research","credibility":2},{"url":"https://www.elliptic.co/blog/a7a5-the-ruble-backed-stablecoin-100-billion-in-transactions","name":"A7A5: The ruble-backed stablecoin crosses $100 billion in transactions - Elliptic","type":"research","credibility":2},{"url":"https://www.coindesk.com/policy/2025/08/14/ofac-sanctions-crypto-network-behind-ruble-backed-stablecoin-and-shuttered-exchange-garantex","name":"OFAC Sanctions Crypto Network Behind Ruble-Backed Stablecoin and Shuttered Exchange Garantex — CoinDesk","type":"news_article","credibility":2},{"url":"https://cryptovalleyjournal.com/glossary/a7a5/","name":"A7A5: ruble-backed stablecoin, issuer and sanctions status (Crypto Valley Journal)","type":"news_article","credibility":2},{"url":"https://www.elliptic.co/insights/the-rise-of-a7a5-the-ruble-stablecoin-now-transfers-1-billion-per-day/","name":"The Rise of A7A5: The Ruble Stablecoin Now Transfers $1 Billion Per Day (Elliptic)","type":"research","credibility":2}],"severity":"critical"},{"content":"Ilan Shor (born March 6, 1987, Tel Aviv) is the 51% shareholder of A7 LLC. A Moldovan-born businessman and politician, he fled Moldova in 2019 (or after an earlier conviction, per other accounts), went first to Israel and then Russia, which granted him citizenship in 2024. Moldovan courts convicted him in connection with the 2014 theft of about $1 billion from three Moldovan banks, often called the 'theft of the century' (roughly one-eighth of Moldova's GDP); reports give the conviction as an in absentia conviction in 2023, with the Court of Appeal of Chisinau sentencing him on April 13, 2023 to 15 years and confiscation of assets valued at EUR 254 million, while another account cites a 2017 conviction (see contradictions). OFAC designated him an SDN in October 2022 for undermining Moldovan democratic institutions on behalf of Russia, and he is sanctioned by the EU, UK and Switzerland. Pyotr Fradkov heads PSB and co-heads A7. Sergey Mendeleev, co-founder of Garantex, controlled InDeFi Bank and Exved (a Tether-based payments platform), also created a separate ruble-backed token called Cryptorouble (RUBT), and was designated by OFAC on August 14, 2025. Aleksandr Mira Serda, Garantex co-owner and CCO, was indicted on March 7, 2025, arrested in India and designated on August 14, 2025; Pavel Karavatsky, a Garantex co-owner and regional director, was also designated. The U.S. State Department offered rewards of up to $5 million for information on Mira Serda and up to $1 million for other Garantex leaders. Aleksej Besciokov, a Lithuanian national, was indicted alongside Mira Serda.","heading":"Key Named Individuals","sources":[{"url":"https://home.treasury.gov/news/press-releases/sb0225","name":"Treasury Sanctions Cryptocurrency Exchange and Network Enabling Sanctions Evasion and Cyber Criminals","type":"regulatory","credibility":1},{"url":"https://www.rferl.org/a/russia-cryptocurrency-moldova-kyrgyzstan-a7-sanctions/33609918.html","name":"The Fugitive Oligarch, The Cryptocurrency, And A 'Wild' Kremlin-Blessed Sanctions Evasion Scheme - RFE/RL","type":"news_article","credibility":1},{"url":"https://www.intellinews.com/moldovan-oligarch-ilan-shor-funded-by-russian-abramovich-key-to-kremlin-s-sanctions-evasion-network-450400/","name":"Moldovan oligarch Ilan Shor funded by Russian Abramovich, key to Kremlin's sanctions-evasion network - bne IntelliNews","type":"news_article","credibility":2},{"url":"https://www.rferl.org/a/russia-cryptocurrency-a7a5-ilan-shor-investigation-sanction-evasion/33746026.html","name":"A7, Company Implicated In Sanctions Evasion, Reportedly Linked To Russian Oligarchs — RFE/RL","type":"news_article","credibility":1},{"url":"https://www.bitcoinsensus.com/news/business/a7-leak-and-ilan-shor-crypto-for-sanctions-evasion-and-elections-in-moldova","name":"A7 Leak and Ilan Shor: Crypto for Sanctions Evasion and Elections in Moldova — Bitcoinsensus","type":"news_article","credibility":2},{"url":"https://www.elliptic.co/blog/the-a7-leaks-the-role-of-crypto-in-russian-sanctions-evasion-and-election-interference","name":"The A7 Leaks: The role of crypto in Russian sanctions evasion and election interference - Elliptic","type":"research","credibility":2},{"url":"https://www.opensanctions.org/entities/NK-ZoBhzZv7NdLLmjMYu9QXxg/","name":"A7 Limited Liability Company — OpenSanctions","type":"regulatory","credibility":1},{"url":"https://www.europeaninterest.eu/moldovan-fugitive-oligarch-ilan-shor-in-russias-sanctions-circumvention-deal-reveals-an-ft-investigation/","name":"Moldovan fugitive oligarch Ilan Shor in Russia's sanctions circumvention deal - European Interest","type":"news_article","credibility":2},{"url":"https://www.opensanctions.org/entities/Q4526147/","name":"Ilan Shor (OpenSanctions)","type":"regulatory","credibility":1},{"url":"https://babel.ua/en/texts/129142-the-gray-cardinal-of-moldova-created-and-runs-a-crypto-empire-that-helps-russians-circumvent-western-sanctions-and-hide-their-money-meet-ilan-shor","name":"The Gray Cardinal of Moldova Created and Runs a Crypto Empire (Babel.ua)","type":"news_article","credibility":2}],"severity":"critical"},{"content":"Old Vector LLC, A7 LLC, and related subsidiaries are subject to sanctions from multiple jurisdictions. On August 14, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) designated Old Vector LLC (Kyrgyzstan), A7 Limited Liability Company (Russia), A71 LLC (Russia), and A7 Agent LLC (Russia) under Executive Order 13694 as amended, for their roles in developing and distributing the A7A5 token in connection with the sanctioned exchange Garantex and its successor Grinex. The United Kingdom designated A7 and Old Vector on May 26, 2025 as part of a broader package targeting 18 entities including HTX/Huobi, citing A7A5's role in Russian sanctions evasion. The European Union included A7A5, its developer, Old Vector, and primary trading venue Grinex in its 19th Russia sanctions package adopted October 23, 2025; transactions involving A7A5 were formally prohibited across EU member states beginning November 25, 2025. Canada, Switzerland (SECO), Ukraine's National Security and Defense Council, France, and Belgium have also listed Old Vector and related entities on their respective sanctions lists. OFAC's SDN registration for Old Vector lists it at two Bishkek, Kyrgyzstan addresses, with registration number 311479-3301-OOO and Tax ID 01312202410041. Other accounts add details: the UK FCDO first designated A7 LLC in May 2025 (20 May per OpenSanctions) and the EU designated A7 LLC in July 2025 in a Ukraine-related package, before the 19th package; New Zealand also listed the entities. OFAC's action froze assets tied to more than a dozen identified crypto addresses and, according to one account, A7A5 tokens are treated as blocked property because of Old Vector's ownership interest. Reporting put the token's use at roughly $1 billion in transactions per day at the time of designation. The EU described A7A5 as 'a form of cryptocurrency created with Russian state support frequently used to circumvent Russian sanctions and finance activities supporting the war'; it was reportedly the EU's first outright ban on a named crypto token. Some secondary reporting gives November 12 rather than November 25, 2025 as the effective date of the EU ban. The EU's 20th package, adopted in 2026, introduced a ban on all crypto asset transactions with Russian and Belarusian providers. In August 2026 the UK NCA and NECC issued Flash Alert 0808-NECC to financial institutions on the A7 Network's sanctions-evasion methods, and the UK's OFSI doubled its maximum penalty for sanctions breaches from 50% to 100% of breach value. On October 1, 2026, the US Treasury designated the A7 Network as a significant transnational criminal organization (in part under Iran-related authorities after confirming use by Iran's IRGC and central bank), and FinCEN issued a Finding and NPRM under the Combating Russian Money Laundering Act identifying A7 Network Sub-Agents as a class of transactions of primary money laundering concern, with a proposed rule (31 CFR 1010.668) that would bar US financial institutions from transmitting funds to or from them.","heading":"Sanctions Designations","sources":[{"url":"https://home.treasury.gov/news/press-releases/sb0225","name":"Treasury Sanctions Cryptocurrency Exchange and Network Enabling Sanctions Evasion and Cyber Criminals","type":"regulatory","credibility":1},{"url":"https://ofac.treasury.gov/recent-actions/20250814","name":"OFAC Recent Actions - August 14, 2025","type":"regulatory","credibility":1},{"url":"https://www.opensanctions.org/entities/NK-BWSfTq3iX7YzFrwPyiszKh/","name":"Old Vector LLC - OpenSanctions","type":"regulatory","credibility":1},{"url":"https://coingeek.com/uk-targets-a7a5-stablecoin-huobi-htx-for-russian-sanctions-evasion/","name":"UK targets A7A5 stablecoin, Huobi/HTX for Russian sanctions evasion - CoinGeek","type":"news_article","credibility":2},{"url":"https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/","name":"EU 19th Russia Sanctions Package - Council of the EU","type":"regulatory","credibility":1},{"url":"https://www.elliptic.co/blog/ofac-targets-use-of-stablecoins-for-russian-sanctions-evasion","name":"OFAC targets use of stablecoins for Russian sanctions evasion - Elliptic","type":"research","credibility":2},{"url":"https://www.gov.uk/government/news/uk-targets-sanctions-circumvention-and-crypto-networks-exploited-by-russia","name":"UK targets sanctions circumvention and crypto networks exploited by Russia — GOV.UK","type":"regulatory","credibility":1},{"url":"https://www.coindesk.com/business/2026/05/26/uk-sanctions-huobi-and-ruble-stablecoin-issuer-in-crackdown-on-russia-crypto-networks","name":"UK sanctions Huobi and ruble stablecoin issuer in crackdown on Russia crypto networks — CoinDesk","type":"news_article","credibility":2},{"url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion","name":"UK Designates Huobi, Exmo, Bitpapa and 11 Other Entities for Russian Crypto Sanctions Evasion — TRM Labs","type":"research","credibility":2},{"url":"https://www.elliptic.co/blog/eu-20th-sanctions-package-targets-the-architecture-of-crypto-sanctions-evasion","name":"The EU's 20th sanctions package targets the architecture of crypto sanctions evasion — Elliptic","type":"research","credibility":2},{"url":"https://www.scorechain.com/blog/eu-sanctions-a7a5-stablecoin-tightens-crypto-compliance","name":"EU Sanctions A7A5 Stablecoin and Tightens Rules on Crypto Compliance — Scorechain","type":"news_article","credibility":2},{"url":"https://www.opensanctions.org/entities/NK-ZoBhzZv7NdLLmjMYu9QXxg/","name":"A7 Limited Liability Company — OpenSanctions","type":"regulatory","credibility":1},{"url":"https://www.coindesk.com/policy/2025/08/14/ofac-sanctions-crypto-network-behind-ruble-backed-stablecoin-and-shuttered-exchange-garantex","name":"OFAC Sanctions Crypto Network Behind Ruble-Backed Stablecoin and Shuttered Exchange Garantex — CoinDesk","type":"news_article","credibility":2},{"url":"https://www.trmlabs.com/resources/blog/garantex-grinex-and-the-a7a5-token-a-deep-dive-into-sanctions-evasion-networks","name":"Garantex, Grinex, and the A7A5 Token: A Deep Dive into Sanctions Evasion Networks - TRM Labs","type":"research","credibility":2},{"url":"https://www.skadden.com/insights/publications/2025/11/eu-adopts-19th-sanctions-package","name":"EU Adopts 19th Russia Sanctions Package Alongside New Sanctions Being Imposed by US and UK (Skadden)","type":"research","credibility":2},{"url":"https://www.bloomberg.com/news/articles/2025-10-06/eu-mulls-sanctions-against-russia-linked-stablecoin-a7a5","name":"EU Mulls Sanctions Against Russia-Linked Stablecoin A7A5 (Bloomberg)","type":"news_article","credibility":1},{"url":"https://www.coinex.com/en/academy/detail/3367-eus-19th-sanctions-package-expands-to-crypto-providers-and-russian-stablecoins","name":"EU's 19th Sanctions Package Expands to Crypto Providers and Russian Stablecoins (CoinEx)","type":"news_article","credibility":2},{"url":"https://meduza.io/en/news/2026/10/02/u-s-designates-russia-linked-sanctions-evasion-payment-network-a7-a-significant-transnational-criminal-organization","name":"U.S. Designates Russia-Linked A7 Network a Significant Transnational Criminal Organization (Meduza)","type":"news_article","credibility":2},{"url":"https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system","name":"FinCEN Moves to Cut the A7 Network's Sub-Agents Off From the US Financial System (TRM Labs)","type":"research","credibility":2},{"url":"https://fintelegram.com/a7-sanctions-evasion-network-nca-alert/","name":"UK Warns Banks Over Russia's A7 Sanctions-Evasion Network (FinTelegram)","type":"news_article","credibility":2},{"url":"https://globalsanctions.com/2026/09/uk-nca-issues-industry-wide-alert-on-a7-russia-sanctions-evasion-network/","name":"UK NCA Issues Industry-Wide Alert on A7 Russia Sanctions Evasion Network (Global Sanctions)","type":"regulatory","credibility":1}],"severity":"critical"},{"content":"On May 26, 2026, the UK Foreign, Commonwealth & Development Office (FCDO) announced a package of 18 designations — 14 companies and four individuals — targeting what it called the \"Kremlin-backed A7 network,\" which it said exploits Kyrgyzstan's financial system to bypass Western sanctions, finance military procurement, and process oil-sale proceeds to fund Russia's war economy. The UK government stated the A7 network \"claimed to have moved more than $90 billion last year — equivalent to roughly half of Russia's yearly military expenditure.\" Reporting on the package (Moscow Times, Euromaidan Press, Chainalysis, Elliptic) states the designated entities included the cryptocurrency exchange HTX (formerly Huobi), Russian-speaking-trader-focused exchange EXMO, and Bitpapa, alongside a Kyrgyz bank and Georgian exchanges, though the UK government's own press release reviewed for this report did not name HTX, EXMO or Bitpapa explicitly and did not use the term \"A7A5\" — it referred to the broader A7 network and unnamed \"major global cryptocurrency exchange\" and Kyrgyz bank. Foreign Secretary Yvette Cooper was quoted: \"The UK is adapting and strengthening our approach to target the evolving tactics Russia is using to evade restrictions.\"\n\nThe UK FCDO's May 26, 2026 package — the most expansive UK crypto sanctions action to date — designated 18 entities and individuals as part of the A7 network ecosystem. Designated entities include Huobi Global S.A. (HTX), which TRM Labs reported sent over $4.9 billion to Russian-network entities since 2021 and $838 million to A7 in 2025 alone; Exmo Exchange; Bitpapa IC FZC LLC (already under OFAC 2024 and Ukraine 2025 sanctions); Rapira Group LLC (alleged $543 million in bilateral flows); ABCex; Aifory Pro LLC (alleged $3 billion in ruble-to-crypto onramp activity); Grinex; Eurasian Savings Bank (Kyrgyzstan); Old Vector LLC; Virtual Assets Issuer (issuer of the USDKG gold-backed stablecoin); Arvix LLC; Meer cryptocurrency exchange; CJSC Tengricoin; Old Vector LLC; Capital Bank of Central Asia; and several associated individuals including Sergey Mendeleev, Igor Gorin, Irina Akopyan, and Liran Cohen. The UK package was the first application of Regulation 17A banking-style sanctions to crypto exchanges, requiring UK firms to freeze funds and trace transactions across blockchain hops, taking effect immediately upon announcement.\n\nFollowing its May 2026 UK designation, HTX (formerly Huobi) publicly rejected the allegation that it had helped build Russia's \"illicit financial infrastructure,\" with a company spokesperson stating that A7A5 had applied for a listing on the exchange and that the application was \"explicitly rejected\" after HTX's internal due-diligence and compliance review. The UK's Foreign Office did not publish specific evidence of an HTX–A7 cooperation link in the material reviewed for this report, so HTX's denial and the underlying UK allegation both remain contested; this is presented as an allegation on both sides pending fuller disclosure.","heading":"UK Sanctions Package of May 2026 and HTX Dispute","sources":[{"url":"https://www.gov.uk/government/news/uk-cracks-down-on-backdoor-russian-sanctions-evasion-with-tough-new-measures","name":"UK cracks down on backdoor Russian sanctions evasion with tough new measures (GOV.UK)","type":"regulatory","credibility":1},{"url":"https://www.themoscowtimes.com/2026/05/26/britain-imposes-new-sanctions-on-russian-crypto-infrastructure-a92856","name":"Britain Imposes New Sanctions on Russian Crypto Infrastructure (The Moscow Times)","type":"news_article","credibility":2},{"url":"https://euromaidanpress.com/2026/05/26/uk-sanctions-crypto-exchanges-and-a7-network/","name":"UK sanctions crypto exchanges and A7 network in crackdown on Russian evasion systems — Euromaidan Press","type":"news_article","credibility":2},{"url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/","name":"UK Sanctions Crypto Companies With Russia Ties — Chainalysis","type":"research","credibility":2},{"url":"https://www.elliptic.co/insights/uk-designates-cryptoasset-exchanges-in-sweeping-new-sanctions-package/","name":"UK designates cryptoasset exchanges including HTX in sweeping new sanctions package targeting Russia (Elliptic)","type":"research","credibility":2},{"url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion","name":"UK Designates Huobi, Exmo, Bitpapa and 11 Other Entities for Russian Crypto Sanctions Evasion — TRM Labs","type":"research","credibility":2},{"url":"https://www.gov.uk/government/news/uk-targets-sanctions-circumvention-and-crypto-networks-exploited-by-russia","name":"UK targets sanctions circumvention and crypto networks exploited by Russia — GOV.UK","type":"regulatory","credibility":1},{"url":"https://www.technology.org/2026/05/27/uk-sanctions-russia-a7-crypto-networks/","name":"UK Sanctions 18 Crypto Firms Helping Russia Dodge War Restrictions — Technology.org","type":"news_article","credibility":2},{"url":"https://www.coindesk.com/markets/2026/05/27/crypto-exchange-htx-rejects-u-k-sanction-allegations-says-it-refused-ruble-stablecoin-listing","name":"Crypto exchange HTX rejects U.K. sanction allegations, says it refused ruble stablecoin listing — CoinDesk","type":"news_article","credibility":2}],"severity":"critical"},{"content":"A7A5 operates as a ruble-denominated stablecoin on the Ethereum and TRON public blockchains, claiming a 1:1 backing by ruble deposits held at Promsvyazbank (PSB). Russian and Kyrgyz entities facing Western sanctions cannot access SWIFT-connected correspondent banking; A7A5 provides a blockchain-native settlement layer that bypasses this restriction entirely. Unlike USDT (Tether), which froze approximately $28 million in Garantex-controlled wallets in March 2025 at the request of Western authorities, A7A5 was deliberately designed without a centralized freeze or burn capability accessible to Western regulators. Smart contract controls over wallet freezes are held by Russian and Kyrgyz developers, placing the token outside the reach of US, EU, or UK enforcement mechanisms short of secondary sanctions. On-chain analysis by Chainalysis and TRM Labs demonstrates that A7A5 trading volumes spike sharply on weekday business hours and drop nearly to zero on weekends, consistent with institutional cross-border settlement use rather than retail speculation. The primary trading venue has been Grinex LLC (itself designated by OFAC on August 14, 2025), supplemented by Meer Exchange (Kyrgyzstan) and the A7A5 decentralized exchange. The A7A5 system also enables users to convert between rubles and USDT, providing a cash-out pathway into dollar-denominated assets. PSB debit card purchasing through A7A5 processed approximately $26 million. A product called Stablepay allows A7A5 holders to pay for overseas subscriptions using a virtual debit card, further extending the token's utility outside Russia's borders.\n\nThe stablecoin functions as a mirror settlement system: Russian customers transfer value internally via A7A5 tokens, while A7 Sub-Agents in third countries execute matching fiat payments in dollars, euros, yuan, or dirhams on their behalf, stripping Russia-identifying references from trade documents. FinCEN noted that staff operating these sub-agent accounts used VPNs to appear located in jurisdictions where they sought banking services. The A7A5 issuer also injected over $1.3 billion in USDT liquidity into its own decentralized exchange to facilitate A7A5-to-USDT conversion, enabling Russian entities to access dollar-denominated assets. Other analysis notes that A7A5 operates primarily on TRON (about 99% of circulating tokens) with a smaller Ethereum presence; the Ethereum contract is 0x6fA0BE17e4beA2fCfA22ef89BF8ac9aab0AB0fc9, a wrapped version (wA7A5) is at 0x0d57436f2d39c0664c6f0f2e349229483f87ea38, and the TRON contract is TLeVfrdym8RoJreJ23dAGyfJDygRtiWKBZ.","heading":"Mechanism of Sanctions Evasion","sources":[{"url":"https://www.trmlabs.com/resources/blog/garantex-grinex-and-the-a7a5-token-a-deep-dive-into-sanctions-evasion-networks","name":"Garantex, Grinex, and the A7A5 Token: A Deep Dive into Sanctions Evasion Networks - TRM Labs","type":"research","credibility":2},{"url":"https://www.chainalysis.com/blog/a7a5-grinex-russian-crypto-economy-ofac-sanctions-august-2025/","name":"How A7A5 and Grinex Enable The Russian Shadow Crypto Economy - Chainalysis","type":"research","credibility":2},{"url":"https://www.elliptic.co/blog/a7a5-the-ruble-backed-stablecoin-100-billion-in-transactions","name":"A7A5: The ruble-backed stablecoin crosses $100 billion in transactions - Elliptic","type":"research","credibility":2},{"url":"https://ftfa-sao.org/how-russia-uses-cryptocurrency-to-bypass-western-sanctions-the-a7a5-token-and-hidden-networks","name":"How Russia Uses Cryptocurrency to Bypass Western Sanctions: The A7A5 Token and Hidden Networks","type":"research","credibility":2},{"url":"https://docs.a7a5.io/a7a5-token/token-contracts","name":"A7A5 Token Contracts (Official Docs)","type":"official","credibility":3},{"url":"https://etherscan.io/address/0x6fA0BE17e4beA2fCfA22ef89BF8ac9aab0AB0fc9","name":"A7A5 Token - Etherscan","type":"on_chain","credibility":1},{"url":"https://info.arkm.com/research/a7a5-russia-stablecoin-ruble-what-is-explained-2026","name":"A7A5: The Ruble Stablecoin Linked To A Growing Shadow Economy — Arkham Intelligence","type":"on_chain","credibility":2},{"url":"https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system","name":"FinCEN Moves to Cut the A7 Network's Sub-Agents Off From the US Financial System (TRM Labs)","type":"research","credibility":2},{"url":"https://www.bitget.com/news/detail/12560605259432","name":"Sanctioned Ruble Stablecoin A7A5 Gains Top 3 Spot in Tron Activity (Bitget News)","type":"news_article","credibility":2}],"severity":"critical"},{"content":"Garantex Europe OU was a cryptocurrency exchange originally registered in Estonia that relocated operations to Moscow's Federation Tower in 2019. OFAC first designated Garantex in April 2022 for processing over $100 million in illicit transactions linked to ransomware actors (Conti, LockBit, Ryuk, Black Basta, NetWalker, Phoenix Cryptolocker), darknet market Hydra, and cybercriminals. Garantex lost its Estonian operating license in February 2022 due to anti-money laundering deficiencies and continued operating illegally. On March 6, 2025, a multinational law enforcement operation led by the U.S. Secret Service, with coordination from the FBI, German BKA, Dutch National Police, Finnish National Bureau of Investigation, and Estonian National Criminal Police, seized Garantex's primary web domains (garantex.org, garantex.io, garantex.academy) and froze over $26 million in cryptocurrency. On March 7, 2025, the DOJ unsealed indictments against Aleksandr Mira Serda (Russian national, Garantex co-owner and CCO; later arrested in India) and Lithuanian national Aleksej Besciokov. TRM Labs on-chain analysis identifies a key wallet address (TNDjh6WGLYyWmkh8vfu42bXVHUqFNQ3rDq) labeled by OFAC as Garantex-controlled that began moving funds into A7A5 in January 2025, weeks before the March takedown, suggesting foreknowledge of the forthcoming enforcement action. Following the Garantex seizure, Grinex LLC was promoted as a continuation platform offering 'familiar functionality.' Grinex was incorporated in Kyrgyzstan in December 2024 and listed A7A5 from launch; it was designated by OFAC on August 14, 2025. Former Garantex customers reportedly received A7A5 token credits equivalent to frozen balances as a mechanism for fund recovery.\n\nChainalysis and TRM Labs further report that after the March 2025 disruption, a large quantity of A7A5 was transferred from Old Vector to Garantex and burned on March 10, 2025, with an equivalent amount immediately minted and deposited into a wallet associated with Old Vector, ultimately reaching Grinex. TRM Labs noted that flows to the post-Garantex ecosystem (Rapira, Aifory Pro, Grinex.io, ABCex, A7 and Old Vector) rose more than tenfold, from about $111 million in the 26 months before the takedown to $1.13 billion in the 14 months after. A7A5 was described as the bridge enabling customer migration from Garantex to Grinex and as designed to facilitate recovery of funds frozen by the Garantex shutdown.","heading":"Connection to Garantex and Grinex","sources":[{"url":"https://www.secretservice.gov/newsroom/releases/2025/03/us-secret-service-seizes-russian-cryptocurrency-exchange-websites","name":"U.S. Secret Service Seizes Russian Cryptocurrency Exchange Websites","type":"regulatory","credibility":1},{"url":"https://techcrunch.com/2025/03/06/russian-crypto-exchange-garantex-seized-by-law-enforcement-operation/","name":"Russian crypto exchange Garantex seized by law enforcement operation - TechCrunch","type":"news_article","credibility":1},{"url":"https://home.treasury.gov/news/press-releases/sb0225","name":"Treasury Sanctions Cryptocurrency Exchange and Network Enabling Sanctions Evasion and Cyber Criminals","type":"regulatory","credibility":1},{"url":"https://www.trmlabs.com/resources/blog/garantex-grinex-and-the-a7a5-token-a-deep-dive-into-sanctions-evasion-networks","name":"Garantex, Grinex, and the A7A5 Token: A Deep Dive into Sanctions Evasion Networks - TRM Labs","type":"research","credibility":2},{"url":"https://www.opensanctions.org/entities/NK-nCCRCEZeb4t4Rz8QxUji3C/","name":"GRINEX LLC - OpenSanctions","type":"regulatory","credibility":1},{"url":"https://www.chainalysis.com/blog/a7a5-grinex-russian-crypto-economy-ofac-sanctions-august-2025/","name":"How A7A5 and Grinex Enable The Russian Shadow Crypto Economy - Chainalysis","type":"research","credibility":2},{"url":"https://www.icij.org/news/2025/09/cryptocurrency-exchange-garantex-lives-on-despite-sanctions-new-report-unveils/","name":"Cryptocurrency exchange Garantex lives on despite sanctions — ICIJ","type":"news_article","credibility":1}],"severity":"critical"},{"content":"A7A5 launched in January 2025 and grew rapidly. CertiK's blockchain intelligence analysis found that cumulative on-chain transactions exceeded $110 billion by approximately May 2026. Elliptic reported that aggregate transactions crossed $100 billion, with $17.3 billion in exchange volumes across primary trading pairs: A7A5/rubles ($11.2 billion) and A7A5/USDT ($6.1 billion). Approximately 250,000 transactions have been recorded from 41,300 distinct accounts, with the holder count rising from approximately 13,000 wallets in February 2025 to 29,000 wallets by May 2026 per CertiK, and to 35,500 accounts as of July 2025 per Elliptic. Peak daily transfer volumes reached $1.5 billion, declining to approximately $500 million daily following sanctions. Chainalysis reported $51 billion in processed volume in its August 2025 analysis. As of mid-2026, approximately 42.5 billion A7A5 tokens were in circulation, valued at approximately $547 million at the prevailing ruble exchange rate. CertiK noted that A7A5 captured approximately 43% of the global non-US dollar stablecoin market at its peak. The Ethereum contract address for A7A5 is 0x6fA0BE17e4beA2fCfA22ef89BF8ac9aab0AB0fc9. A wrapped version (wA7A5) is deployed at 0x0d57436f2d39c0664c6f0f2e349229483f87ea38 on Ethereum. After Uniswap blocklisted A7A5 in November 2025, DEX liquidity provision dropped from approximately $150 million daily to $0.5 million weekly.\n\nEarlier and alternative figures: as of mid-2025 there were 39-41 billion A7A5 in circulation worth about $500-521 million, ranking it around the 20th-largest stablecoin (Arkham Intelligence reported growth from 11 billion to 39 billion tokens during 2025); cumulative volume exceeded $51 billion through July 2025 (Chainalysis); the week of July 21, 2025 was the peak, with about 524.8 billion tokens worth $6.66 billion moved; individual transactions above $100 million, including one above $413 million, were documented; exchange volume split about 61% A7A5/ruble and 39% A7A5/USDT; and the UK government's May 2026 notice said the token processed $9.3 billion on a dedicated exchange in four months after launch. FinCEN's October 1, 2026 NPRM found that over 180 entities processed at least $179.1 billion in A7A5 transactions between February 2025 and June 2026, and A7 claimed historical volume above $91.5 billion (roughly one-eighth of Russia's 2025 foreign trade). The network's sub-agents held accounts at about 435 financial institutions in more than 83 countries as of June 2026 and processed over $17 billion in dollar-denominated transactions between January 2025 and June 2026. Russia's central bank reportedly recognized A7A5 as a 'digital financial asset' in October 2025 (Arkham Intelligence).","heading":"Transaction Volumes and Market Data","sources":[{"url":"https://crypto-economy.com/a7a5-stablecoin-keeps-growing/","name":"A7A5 Stablecoin Keeps Growing, Moving $110B Even Under Sanctions: CertiK - Crypto Economy","type":"research","credibility":2},{"url":"https://www.elliptic.co/blog/a7a5-the-ruble-backed-stablecoin-100-billion-in-transactions","name":"A7A5: The ruble-backed stablecoin crosses $100 billion in transactions - Elliptic","type":"research","credibility":2},{"url":"https://www.tradingview.com/news/cointelegraph:6e755cb2c094b:0-russian-ruble-stablecoin-a7a5-grows-despite-western-sanctions-certik/","name":"Russian ruble stablecoin A7A5 grows despite Western sanctions: CertiK - TradingView/CoinTelegraph","type":"news_article","credibility":2},{"url":"https://etherscan.io/address/0x6fA0BE17e4beA2fCfA22ef89BF8ac9aab0AB0fc9","name":"A7A5 Token - Etherscan","type":"on_chain","credibility":1},{"url":"https://www.coingecko.com/en/coins/a7a5","name":"A7A5 Price - CoinGecko","type":"other","credibility":2},{"url":"https://www.elliptic.co/blog/the-rise-of-a7a5-the-ruble-stablecoin-now-transfers-1-billion-per-day","name":"The rise of A7A5: the Ruble stablecoin now transfers $1 billion per day — Elliptic","type":"research","credibility":2},{"url":"https://www.chainalysis.com/blog/a7a5-grinex-russian-crypto-economy-ofac-sanctions-august-2025/","name":"How A7A5 and Grinex Enable The Russian Shadow Crypto Economy - Chainalysis","type":"research","credibility":2},{"url":"https://info.arkm.com/research/a7a5-russia-stablecoin-ruble-what-is-explained-2026","name":"A7A5: The Ruble Stablecoin Linked To A Growing Shadow Economy — Arkham Intelligence","type":"on_chain","credibility":2},{"url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/","name":"UK Sanctions Crypto Companies With Russia Ties — Chainalysis","type":"research","credibility":2},{"url":"https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system","name":"FinCEN Moves to Cut the A7 Network's Sub-Agents Off From the US Financial System (TRM Labs)","type":"research","credibility":2},{"url":"https://www.elliptic.co/insights/the-rise-of-a7a5-the-ruble-stablecoin-now-transfers-1-billion-per-day/","name":"The Rise of A7A5: The Ruble Stablecoin Now Transfers $1 Billion Per Day (Elliptic)","type":"research","credibility":2},{"url":"https://foreignpolicy.com/2026/03/31/russia-sanctions-evasion-cryptocurrency-a7a5-kyrgyzstan-exports-dual-use-technology/","name":"Russia's Secret, Sanctions-Busting Cryptocurrency Empire (Foreign Policy)","type":"news_article","credibility":1},{"url":"https://www.cryptotimes.io/2026/10/02/us-treasury-blocks-russia-linked-a7-network-iran-used-to-move-money/","name":"US Treasury Blocks Russia-Linked A7 Network Iran Used to Move Money (Crypto Times)","type":"news_article","credibility":2},{"url":"https://www.tftc.io/a7-network-tco-designation-ruble-stablecoin-179-billion-operation-economic-outcast","name":"Treasury Designates A7 Network TCO as Ruble Stablecoin Moved $179B (TFTC)","type":"news_article","credibility":2},{"url":"https://www.elliptic.co/blog/the-fall-of-a7a5-how-sanctions-strangled-the-ruble-stablecoin","name":"The fall of A7A5: how sanctions strangled the ruble stablecoin (Elliptic)","type":"research","credibility":2},{"url":"https://en.cryptonomist.ch/2026/07/29/a7a5-stablecoin-collapse/","name":"A7A5 Stablecoin Collapse: 96% Wiped as U.S., EU, and U.K. Sanctions Hit (Cryptonomist)","type":"news_article","credibility":2},{"url":"https://crypto.news/russia-built-a-sanctions-proof-stablecoin-the-data-says-it-is-dying/","name":"Russia Built a Sanctions-Proof Stablecoin. The Data Says It Is Dying (Crypto News)","type":"news_article","credibility":2}],"severity":"high"},{"content":"According to Elliptic, A7A5 transaction volumes fell approximately 96% from their July 2025 peak, dropping to roughly $24.3 million by June 2026, and no new tokens were minted after July 23, 2025, indicating collapsing demand. Elliptic reports that from late September 2025 onward, users attempting to convert A7A5 into USDT reported having funds frozen or flagged upon receipt at global exchanges. In November 2025, Uniswap removed A7A5 from its decentralized exchange. In April 2026, Grinex — by then the primary remaining trading venue — disabled card-based account top-ups, and on April 16, 2026, Grinex disclosed a security breach in which more than 1 billion rubles were reportedly stolen, further undermining the token's remaining liquidity. Elliptic assesses that while A7A5's smart contracts remain technically operational, the token is \"no longer serving its purpose of enabling Russian individuals and businesses to make cross-border payments despite sanctions.\" Separately, CoinDesk reported in May 2026 that A7A5's operators claimed the token could survive even if sanctions were eventually lifted, framing it as a durable financial-infrastructure project rather than a sanctions-evasion vehicle alone — a characterization that is disputed by Western regulators' stated rationale for designating it. One account adds that mainstream exchanges began screening A7A5-linked deposits, CoinGecko showed effectively zero volume after the October 2026 TCO designation, and TRM Labs identified TokenSpot, an unsanctioned Kyrgyz exchange sharing infrastructure with Grinex, as a remaining channel with $6.7 billion in volume, with A7/Grinex/Garantex comprising about 28% of its outgoing transfers as of mid-2026. This sits in tension with accounts of Grinex remaining the primary venue until its April 2026 breach (see contradictions).","heading":"Post-Sanctions Collapse in Usage","sources":[{"url":"https://www.elliptic.co/blog/the-fall-of-a7a5-how-sanctions-strangled-the-ruble-stablecoin","name":"The fall of A7A5: how sanctions strangled the ruble stablecoin (Elliptic)","type":"research","credibility":2},{"url":"https://www.coindesk.com/policy/2026/05/24/a-russian-stablecoin-built-to-dodge-sanctions-says-it-can-survive-even-if-they-re-lifted","name":"Ruble-pegged stablecoin A7A5 says it has a business even if sanctions end — CoinDesk","type":"news_article","credibility":2},{"url":"https://en.cryptonomist.ch/2026/07/29/a7a5-stablecoin-collapse/","name":"A7A5 Stablecoin Collapse: 96% Wiped as U.S., EU, and U.K. Sanctions Hit (Cryptonomist)","type":"news_article","credibility":2},{"url":"https://crypto.news/russia-built-a-sanctions-proof-stablecoin-the-data-says-it-is-dying/","name":"Russia Built a Sanctions-Proof Stablecoin. The Data Says It Is Dying (Crypto News)","type":"news_article","credibility":2},{"url":"https://www.coingecko.com/en/coins/a7a5","name":"A7A5 Price - CoinGecko","type":"other","credibility":2},{"url":"https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system","name":"FinCEN Moves to Cut the A7 Network's Sub-Agents Off From the US Financial System (TRM Labs)","type":"research","credibility":2}],"severity":"high"},{"content":"All major centralized exchanges rejected A7A5 listing applications due to secondary sanctions exposure. A7A5's director for Regulatory and Overseas Affairs, Oleg Ogienko, confirmed the company approached multiple major centralized platforms, all of which rejected the listing. HTX (formerly Huobi) stated explicitly that A7A5's application was rejected following its internal due diligence and compliance review. In response to CEX rejections, A7A5 pivoted to decentralized finance infrastructure. The stablecoin operates on A7A5's own decentralized exchanges on TRON and Ethereum, and is also available on Curve and Uniswap. Daily trading volumes between A7A5 and USDT on the A7A5 DEX grew to approximately $150 million per day at peak, with USDT liquidity provided by A7A5's issuer, which injected an estimated $1.2–1.3 billion in USDT into DEX pools since July 11, 2025. The DEX pivot means A7A5 remained actively accessible to retail users via permissionless DeFi protocols without compliance warnings on those platforms. Ogienko stated publicly that 'our business model runs on DeFi infrastructure' and expressed openness to future CEX partnerships, while asserting: 'we do not do illegal things.' The stablecoin offers holders approximately 13.5% yield in additional A7A5 tokens, reflecting Russian interest rates, sourced from 50% of the interest earned on backing deposits.","heading":"DeFi Pivot and Retail Accessibility","sources":[{"url":"https://www.coindesk.com/markets/2026/05/27/crypto-exchange-htx-rejects-u-k-sanction-allegations-says-it-refused-ruble-stablecoin-listing","name":"Crypto exchange HTX rejects U.K. sanction allegations, says it refused ruble stablecoin listing — CoinDesk","type":"news_article","credibility":2},{"url":"https://www.coindesk.com/markets/2026/02/16/we-do-not-do-illegal-things-inside-a-u-s-sanctioned-stablecoin-issuer-s-race-to-build-a-crypto-giant","name":"'We do not do illegal things': Inside the sanctioned stablecoin issuer A7A5's race to build a crypto giant — CoinDesk","type":"news_article","credibility":2},{"url":"https://www.coindesk.com/policy/2026/05/24/a-russian-stablecoin-built-to-dodge-sanctions-says-it-can-survive-even-if-they-re-lifted","name":"Ruble-pegged stablecoin A7A5 says it has a business even if sanctions end — CoinDesk","type":"news_article","credibility":2},{"url":"https://www.elliptic.co/blog/the-rise-of-a7a5-the-ruble-stablecoin-now-transfers-1-billion-per-day","name":"The rise of A7A5: the Ruble stablecoin now transfers $1 billion per day — Elliptic","type":"research","credibility":2}],"severity":"high"},{"content":"Old Vector LLC, Grinex LLC, and Meer Exchange are all registered in Kyrgyzstan. Kyrgyzstan passed a 'On Virtual Assets' law in January 2022, creating a licensing framework for virtual asset service providers; by October 2024, 126 VASP licenses had been issued with $4.2 billion in transaction volumes among licensed providers in seven months. Kyrgyzstan's deepening bilateral trade relationship with Russia following the February 2022 invasion of Ukraine, its role as a transit hub for goods (including dual-use electronics) moving from China to Russia, and its relatively permissive regulatory environment have made it a significant node in Russian sanctions evasion infrastructure. Old Vector and Grinex entities were registered at addresses that have been characterized as residential or shell-like in nature. British Members of Parliament urged the UK government to impose sanctions on Kyrgyz officials alleged to have facilitated Russian crypto evasion, as reported by the Organized Crime and Corruption Reporting Project (OCCRP). The Centre for Information Resilience published a dedicated report on A7A5's use of Kyrgyz infrastructure to circumvent Western sanctions.","heading":"Role of Kyrgyzstan as Operational Hub","sources":[{"url":"https://www.occrp.org/en/news/uk-lawmakers-demand-sanctions-on-kyrgyz-officials-over-russian-crypto-evasion","name":"British MPs Urge Sanctions on Kyrgyz Leaders Aiding Russian Sanctions Evasion - OCCRP","type":"news_article","credibility":1},{"url":"https://www.trmlabs.com/resources/blog/garantex-grinex-and-the-a7a5-token-a-deep-dive-into-sanctions-evasion-networks","name":"Garantex, Grinex, and the A7A5 Token: A Deep Dive into Sanctions Evasion Networks - TRM Labs","type":"research","credibility":2},{"url":"https://www.info-res.org/reports/a7a5-circumventing-sanctions-with-stablecoin-cryptocurrency/","name":"A7A5: Circumventing sanctions with stablecoin cryptocurrency - Centre for Information Resilience","type":"research","credibility":2}],"severity":"high"},{"content":"Ilan Shor is a Moldovan political figure and businessman who was convicted in Moldova in 2017 for involvement in the 2014 theft of approximately $1 billion from three Moldovan banks. Following his conviction, Shor fled first to Israel and then to Russia, which granted him citizenship. He was sanctioned by the United States in 2022 for aiding Russia in efforts to undermine democratic elections in Moldova. OpenSanctions records indicate Shor held a 51% ownership stake in A7 LLC, with Promsvyazbank holding the remaining 49%. The Centre for Information Resilience and Elliptic investigations documented shared digital infrastructure linking A7 and A7A5 to domains previously used in Shor's political activities targeting Moldova. Moldovan police have documented Shor and Promsvyazbank's alleged use of cryptocurrency payments — including through the Toncoin-based Taito application — to pay political activists and influence Moldovan voters during the 2024 presidential election and EU membership referendum. OpenSanctions records the sanctioning rationale as A7 LLC being 'established by Ilan Shor, together with multiple financial companies in Moscow, partnering with Russian state entities' to offer 'payments in exchange for votes.'\n\nOn September 3, 2025, a data leak from A7's internal systems was disclosed publicly. Elliptic's analysis of the leaked data documented a wallet holding $677 million in inflows through a single identified A7-affiliated address, and identified total stablecoin inflows of at least $8 billion into A7 wallets since early 2024. The leak also revealed internal applications used to manage political activist payments in Moldova: the Taito app for managing and paying activists, a Callcenter app for political polling, and a Toncoin-based bot for cryptocurrency payments to identified individuals. Unusual wallet activity was observed on August 14, 2025 — the same day as OFAC's designation — suggesting the infrastructure may have been altered following awareness of the pending action. The ICIJ reported in September 2025 that Garantex effectively continued operations through successor infrastructure despite the March 2025 law enforcement action.","heading":"Moldovan Political Influence and the September 2025 Data Leak","sources":[{"url":"https://www.rferl.org/a/russia-cryptocurrency-a7a5-ilan-shor-investigation-sanction-evasion/33746026.html","name":"A7, Company Implicated In Sanctions Evasion, Reportedly Linked To Russian Oligarchs — RFE/RL","type":"news_article","credibility":1},{"url":"https://www.bitcoinsensus.com/news/business/a7-leak-and-ilan-shor-crypto-for-sanctions-evasion-and-elections-in-moldova","name":"A7 Leak and Ilan Shor: Crypto for Sanctions Evasion and Elections in Moldova — Bitcoinsensus","type":"news_article","credibility":2},{"url":"https://www.elliptic.co/blog/the-a7-leaks-the-role-of-crypto-in-russian-sanctions-evasion-and-election-interference","name":"The A7 Leaks: The role of crypto in Russian sanctions evasion and election interference - Elliptic","type":"research","credibility":2},{"url":"https://www.opensanctions.org/entities/NK-ZoBhzZv7NdLLmjMYu9QXxg/","name":"A7 Limited Liability Company — OpenSanctions","type":"regulatory","credibility":1},{"url":"https://www.icij.org/news/2025/09/cryptocurrency-exchange-garantex-lives-on-despite-sanctions-new-report-unveils/","name":"Cryptocurrency exchange Garantex lives on despite sanctions — ICIJ","type":"news_article","credibility":1}],"severity":"high"},{"content":"A7A5 claims 1:1 backing by ruble deposits held in accounts at Promsvyazbank (PSB). Promsvyazbank is a Russian state-owned bank that has been sanctioned by the US, UK, EU, and allied governments for financing Russia's defense industry and assisting in sanctions evasion. PSB is described by multiple regulators as the primary bank servicing Russia's military-industrial complex. The use of a sanctioned bank as the exclusive reserve custodian for A7A5's backing creates direct counterparty exposure to sanctioned entities for any holder of the token. Russia's central bank additionally recognized A7A5 as a 'digital financial asset' in October 2025, per Arkham Intelligence reporting. A7 LLC also received loans from VEB.RF, the Russian state development institution, according to OpenSanctions records. The CoinDesk May 2024 article noted A7A5 was tied to Russia's sanctioned Promsvyazbank, which the Centre for Information Resilience confirmed 'was sanctioned for financing Russia's defense sector.'\n\nA7A5's operators have commissioned an audit from Kreston Bishkek, a member of the Kreston Global accounting network, which reportedly concluded the circulating token supply is fully backed by ruble-denominated fiat reserves, with tokens minted only after matching ruble deposits are confirmed. However, this audit's underlying reserves reportedly sit at a Russian bank that no Western accounting firm can independently verify, in a currency subject to Russian capital controls, meaning the backing claims are verifiable only through the issuer's own disclosures and a non-Western auditor. This is a material limitation on the reliability of the ''fully backed'' claim and is treated as a low-to-medium confidence claim.\n\nA7A5's director for Regulatory and Overseas Affairs, Oleg Ogienko, has publicly asserted that A7A5 is fully compliant with the regulations of Kyrgyzstan and Russia, and that the project does not violate any Financial Action Task Force (FATF) principles. Ogienko stated A7A5 has embedded KYC and AML mechanisms and undergoes regular audits. He acknowledged in a May 2026 interview that Russia's pending stablecoin legislation could be commercially unviable if enacted in its current draft form, noting concerns about the cap restricting retail non-qualified investors to approximately $4,000 annually. Ogienko stated that the company participates in Russian State Duma consultations on digital asset frameworks. However, operating under Kyrgyz regulation while serving a network of entities subject to international sanctions does not insulate the project or its users from legal exposure in sanctioning jurisdictions. Multiple legal analysts have noted that while using Russian-linked crypto to bypass sanctions is not unlawful in Kyrgyzstan or Russia, it constitutes a sanctions violation for US, UK, and EU persons. The issuance entity Old Vector LLC is itself a designated SDN.","heading":"Reserve Backing, Audit and Compliance Claims","sources":[{"url":"https://www.info-res.org/reports/a7a5-circumventing-sanctions-with-stablecoin-cryptocurrency/","name":"A7A5: Circumventing sanctions with stablecoin cryptocurrency - Centre for Information Resilience","type":"research","credibility":2},{"url":"https://www.elliptic.co/blog/ofac-targets-use-of-stablecoins-for-russian-sanctions-evasion","name":"OFAC targets use of stablecoins for Russian sanctions evasion - Elliptic","type":"research","credibility":2},{"url":"https://www.chainalysis.com/blog/a7a5-grinex-russian-crypto-economy-ofac-sanctions-august-2025/","name":"How A7A5 and Grinex Enable The Russian Shadow Crypto Economy - Chainalysis","type":"research","credibility":2},{"url":"https://www.coindesk.com/markets/2026/02/16/we-do-not-do-illegal-things-inside-a-u-s-sanctioned-stablecoin-issuer-s-race-to-build-a-crypto-giant","name":"'We do not do illegal things': Inside the sanctioned stablecoin issuer A7A5's race to build a crypto giant — CoinDesk","type":"news_article","credibility":2},{"url":"https://www.coindesk.com/policy/2026/05/24/a-russian-stablecoin-built-to-dodge-sanctions-says-it-can-survive-even-if-they-re-lifted","name":"Ruble-pegged stablecoin A7A5 says it has a business even if sanctions end — CoinDesk","type":"news_article","credibility":2},{"url":"https://www.coindesk.com/markets/2026/05/27/crypto-exchange-htx-rejects-u-k-sanction-allegations-says-it-refused-ruble-stablecoin-listing","name":"Crypto exchange HTX rejects U.K. sanction allegations, says it refused ruble stablecoin listing — CoinDesk","type":"news_article","credibility":2},{"url":"https://crypto.news/the-ruble-backed-stablecoin-a7a5-passes-audit-fully-backed/","name":"The ruble-backed stablecoin A7A5 passes audit, fully backed (crypto.news)","type":"news_article","credibility":2},{"url":"https://coingape.com/blog/as-stablecoin-giants-delay-audits-ruble-pegged-a7a5-gets-audited-and-verifies-its-peg/","name":"As Stablecoin Giants Delay Audits, Ruble-Pegged A7A5 Gets Audited and Verifies Its Peg (CoinGape)","type":"news_article","credibility":2}],"severity":"high"},{"content":"Following OFAC's August 2025 designations, Uniswap blocklisted A7A5 in November 2025, causing DEX liquidity to collapse from approximately $150 million daily to $0.5 million weekly. The Chainalysis 2026 Crypto Crime Report referenced A7A5 and Grinex as major components of the Russian shadow crypto economy. EU's 20th Russia sanctions package (adopted in 2026) introduced a sweeping ban on all crypto asset transactions with Russian and Belarusian providers. Russia retaliated against critics of A7A5: on June 3, 2026, Russia's Foreign Ministry added Alexander Browder, a 17-year-old British student and son of anti-corruption campaigner Bill Browder, to its sanctions list after Browder published a Henry Jackson Society report in March 2026 exposing alleged illicit crypto laundering operations including A7A5. Russia's Ministry of Finance simultaneously published a competing narrative that A7A5 is a legitimate trade tool not intended for sanctions circumvention; this characterization is disputed by OFAC, the EU, UK FCDO, and multiple blockchain analytics firms. The A7A5 stablecoin aims, according to its developers, to position itself as a general trade settlement instrument; regulators in Western jurisdictions have not accepted this framing.\n\nOn June 4, 2026, Russia's Foreign Ministry announced sanctions against Alexander Browder, a 17-year-old British researcher and founder of the Global Cryptocurrency Laundering Database, along with four other British nationals, banning them from entering Russia. The action followed a report Browder authored for the Henry Jackson Society think tank, titled \"Confronting the Illicit-Finance Hydra in Crypto Markets: Protecting Retail Investors and Disrupting Hostile Government Exploitation,\" which alleged approximately $350 billion had been laundered globally via crypto by states including Russia, Iran and North Korea, and which identified A7A5 as \"one of the most prevalent issues facing the West\" in that context. Russia's Foreign Ministry described the report as spreading \"defamatory speculations and false information.\" Browder is the son of Sir Bill Browder, a prominent Kremlin critic previously banned from Russia. Browder called his sanctioning \"a badge of honour.\" Note: available reporting identifies this individual by name (Alexander Browder) and age (17); the scout's description of him only as \"a researcher\" without the identifying detail is confirmed accurate but incomplete.","heading":"Regulatory and Industry Response; Counter-Sanctioning of Critics","sources":[{"url":"https://www.coindesk.com/policy/2026/06/04/russia-sanctions-british-teenager-for-alleging-a7a5-use-in-funding-ukraine-war","name":"Russia sanctions British teenager for alleging A7A5 use in funding Ukraine war - CoinDesk","type":"news_article","credibility":1},{"url":"https://www.euronews.com/my-europe/2026/06/04/british-teenager-sanctioned-by-russia-over-his-report-on-alleged-moscow-backed-crypto-laun","name":"British teenager sanctioned by Russia over his report on alleged Moscow-backed crypto laundering - Euronews","type":"news_article","credibility":1},{"url":"https://www.trmlabs.com/resources/blog/eu-adopts-20th-sanctions-package-on-russia----including-a-sweeping-ban-on-all-crypto-asset-transactions-with-russian-and-belarusian-providers","name":"EU Adopts 20th Sanctions Package on Russia Including Sweeping Ban on Crypto - TRM Labs","type":"regulatory","credibility":1},{"url":"https://cryptobriefing.com/a7a5-stablecoin-sanctions-trade-tool/","name":"A7A5 stablecoin aims to evolve beyond sanctions as trade tool - Crypto Briefing","type":"news_article","credibility":2},{"url":"https://www.chainalysis.com/blog/crypto-sanctions-2026/","name":"Crypto Sanctions: 2026 Crypto Crime Report - Chainalysis","type":"research","credibility":2},{"url":"https://www.themoscowtimes.com/2026/06/05/i-touched-a-nerve-british-teenager-banned-from-russia-over-work-on-crypto-sanctions-evasion-a92940","name":"'I Touched a Nerve': British Teenager Banned From Russia Over Work on Crypto Sanctions Evasion - The Moscow Times","type":"news_article","credibility":1}],"severity":"high"},{"content":"Holding, trading, or facilitating transactions involving A7A5 exposes financial institutions and crypto exchanges to severe regulatory and legal risk across US, EU, and UK jurisdictions. Under OFAC's August 2025 designation, A7A5 tokens are treated as blocked property and any US-person transaction involving them is prohibited. The EU's 19th sanctions package imposes a direct, named prohibition on A7A5 effective November 25, 2025. FinCEN's October 2026 NPRM, if finalized as proposed rule 31 CFR 1010.668, would extend prohibitions to fiat transmittals to or from A7 sub-agents. TRM Labs and FinCEN identified red flags that compliance programs should screen for, including: newly formed UAE, Hong Kong, Kyrgyz, Turkish, or Seychelles trading companies with sudden volume spikes; goods descriptions that diverge across invoices; use of multiple financial intermediaries; AI-altered invoices; and on-chain exposure to A7A5 contract addresses on Ethereum or Tron, wrapped A7A5 on other chains, or OTC desks in jurisdictions of concern. The UK's OFSI simultaneously doubled its maximum financial penalty for sanctions breaches from 50% to 100% of the breach value, announced alongside the August 2026 NCA flash alert on A7.","heading":"Compliance Risk for Exchanges and Financial Institutions","sources":[{"url":"https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system","name":"FinCEN Moves to Cut the A7 Network's Sub-Agents Off From the US Financial System (TRM Labs)","type":"research","credibility":2},{"url":"https://globalsanctions.com/2026/09/uk-nca-issues-industry-wide-alert-on-a7-russia-sanctions-evasion-network/","name":"UK NCA Issues Industry-Wide Alert on A7 Russia Sanctions Evasion Network (Global Sanctions)","type":"regulatory","credibility":1},{"url":"https://www.skadden.com/insights/publications/2025/11/eu-adopts-19th-sanctions-package","name":"EU Adopts 19th Russia Sanctions Package Alongside New Sanctions Being Imposed by US and UK (Skadden)","type":"research","credibility":2},{"url":"https://www.elliptic.co/blog/crypto-regulatory-affairs-eu-sanctions-target-a7a5-ruble-backed-stablecoin","name":"Crypto Regulatory Affairs: EU Sanctions Target A7A5 Ruble-Backed Stablecoin (Elliptic)","type":"research","credibility":2}],"severity":"critical"}],"timeline":[{"date":"2014","event":"Approximately $1 billion stolen from three Moldovan banks in an operation later linked to Ilan Shor.","source":"Ilan Shor (OpenSanctions)","source_url":"https://www.opensanctions.org/entities/Q4526147/"},{"date":"2022-04","event":"OFAC first designates Garantex for processing over $100 million in illicit transactions linked to ransomware actors and darknet markets.","source":"Treasury Sanctions Cryptocurrency Exchange and Network Enabling Sanctions Evasion and Cyber Criminals","source_url":"https://home.treasury.gov/news/press-releases/sb0225"},{"date":"2022-10","event":"OFAC designates Ilan Shor as a Specially Designated National for undermining Moldovan democratic institutions and elections on behalf of Russia.","source":"Treasury Targets Corruption and Kremlin Malign Influence in Moldova","source_url":"https://home.treasury.gov/news/press-releases/jy1049"},{"date":"2023-04","event":"Court of Appeal of Chisinau sentences Ilan Shor to 15 years imprisonment for fraud and money laundering; EUR 254 million in assets ordered confiscated.","source":"Ilan Shor (OpenSanctions)","source_url":"https://www.opensanctions.org/entities/Q4526147/"},{"date":"2024-09","event":"A7 Network reportedly founded by Ilan Shor and Promsvyazbank (September 2024 per FinCEN/TRM Labs; October 2024 per OpenSanctions).","source":"FinCEN Moves to Cut the A7 Network's Sub-Agents Off From the US Financial System (TRM Labs)","source_url":"https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system"},{"date":"2024-10","event":"A7 LLC incorporated in Moscow with Ilan Shor as majority owner (51%) and Promsvyazbank as minority owner (49%), stated purpose of facilitating cross-border financial transfers for Russian clients facing Western sanctions.","source":"A7 Limited Liability Company — OpenSanctions","source_url":"https://www.opensanctions.org/entities/NK-ZoBhzZv7NdLLmjMYu9QXxg/"},{"date":"2024-12","event":"Old Vector LLC is incorporated in Bishkek, Kyrgyzstan, with registration number 311479-3301-OOO.","source":"Old Vector LLC - OpenSanctions","source_url":"https://www.opensanctions.org/entities/NK-BWSfTq3iX7YzFrwPyiszKh/"},{"date":"2024-12","event":"Grinex incorporated in Kyrgyzstan by an individual with no known prior history in the exchange business — later identified as an alleged Garantex successor platform.","source":"Garantex, Grinex, and the A7A5 Token: A Deep Dive into Sanctions Evasion Networks - TRM Labs","source_url":"https://www.trmlabs.com/resources/blog/garantex-grinex-and-the-a7a5-token-a-deep-dive-into-sanctions-evasion-networks"},{"date":"2024-12","event":"Grinex incorporated in Kyrgyzstan; Meer exchange domain registered.","source":"Garantex, Grinex, and the A7A5 Token: A Deep Dive into Sanctions Evasion Networks - TRM Labs","source_url":"https://www.trmlabs.com/resources/blog/garantex-grinex-and-the-a7a5-token-a-deep-dive-into-sanctions-evasion-networks"},{"date":"2025-01","event":"A7A5, described as the first ruble-backed stablecoin, launches on Ethereum and TRON, issued by Old Vector for A7 LLC; Garantex-controlled wallets begin moving funds into A7A5 weeks before the March 2025 takedown. Some sources give February 2025.","source":"The Fugitive Oligarch, The Cryptocurrency, And A 'Wild' Kremlin-Blessed Sanctions Evasion Scheme - RFE/RL","source_url":"https://www.rferl.org/a/russia-cryptocurrency-moldova-kyrgyzstan-a7-sanctions/33609918.html"},{"date":"2025-02","event":"A7A5 holder count stands at approximately 13,000 wallets.","source":"Russian ruble stablecoin A7A5 grows despite Western sanctions: CertiK - TradingView/CoinTelegraph","source_url":"https://www.tradingview.com/news/cointelegraph:6e755cb2c094b:0-russian-ruble-stablecoin-a7a5-grows-despite-western-sanctions-certik/"},{"date":"2025-03","event":"Garantex's domains (garantex.org, garantex.io, garantex.academy) are seized by a multinational operation led by the U.S. Secret Service and over $26 million is frozen; DOJ unseals indictments against Aleksandr Mira Serda and Aleksej Besciokov (March 7); A7A5 is subsequently burned from Garantex wallets and re-minted to Old Vector/Grinex (March 10); Grinex is promoted as successor.","source":"U.S. Secret Service Seizes Russian Cryptocurrency Exchange Websites","source_url":"https://www.secretservice.gov/newsroom/releases/2025/03/us-secret-service-seizes-russian-cryptocurrency-exchange-websites"},{"date":"2025-05","event":"UK designates A7 LLC (20 May per OpenSanctions); one source dates the UK's 18-target package including HTX/Huobi to May 26, 2025, which other sources date to May 26, 2026.","source":"UK targets A7A5 stablecoin, Huobi/HTX for Russian sanctions evasion - CoinGeek","source_url":"https://coingeek.com/uk-targets-a7a5-stablecoin-huobi-htx-for-russian-sanctions-evasion/"},{"date":"2025-07","event":"A7A5 issuer begins injecting USDT liquidity into DEX pools (about $1.2-1.3 billion in total by mid-2025); EU designates A7 LLC in a Ukraine-related package (July 15); peak weekly activity in the week of July 21 (about $6.66 billion).","source":"The rise of A7A5: the Ruble stablecoin now transfers $1 billion per day — Elliptic","source_url":"https://www.elliptic.co/blog/the-rise-of-a7a5-the-ruble-stablecoin-now-transfers-1-billion-per-day"},{"date":"2025-07-23","event":"Last new A7A5 tokens minted, per Elliptic's later analysis, marking the peak of the token's active use.","source":"The fall of A7A5: how sanctions strangled the ruble stablecoin (Elliptic)","source_url":"https://www.elliptic.co/blog/the-fall-of-a7a5-how-sanctions-strangled-the-ruble-stablecoin","date_evidence":"no new tokens were minted after July 23, 2025"},{"date":"2025-08-14","event":"OFAC designates Old Vector, A7 LLC, A71, A7 Agent, Grinex, Sergey Mendeleev, Aleksandr Mira Serda, Pavel Karavatsky, InDeFi Bank and Exved under E.O. 13694; Garantex re-designated under cyber authorities. Daily volumes fall from peaks above $1.5 billion to about $500 million.","source":"OFAC Sanctions Crypto Network Behind Ruble-Backed Stablecoin and Shuttered Exchange Garantex — CoinDesk","source_url":"https://www.coindesk.com/policy/2025/08/14/ofac-sanctions-crypto-network-behind-ruble-backed-stablecoin-and-shuttered-exchange-garantex","date_evidence":"The announcement was made on August 14, 2025."},{"date":"2025-09","event":"Vladimir Putin takes part in the opening of an A7 branch in Vladivostok (in person per one account, virtual per another); Ilan Shor presents A7. Internal A7 data is leaked (September 3), documenting $8 billion in stablecoin inflows since early 2024.","source":"The Fugitive Oligarch, The Cryptocurrency, And A 'Wild' Kremlin-Blessed Sanctions Evasion Scheme - RFE/RL","source_url":"https://www.rferl.org/a/russia-cryptocurrency-moldova-kyrgyzstan-a7-sanctions/33609918.html"},{"date":"2025-10","event":"Russia's central bank reportedly recognizes A7A5 as a 'digital financial asset' (Arkham Intelligence).","source":"A7A5: The Ruble Stablecoin Linked To A Growing Shadow Economy — Arkham Intelligence","source_url":"https://info.arkm.com/research/a7a5-russia-stablecoin-ruble-what-is-explained-2026"},{"date":"2025-10-23","event":"EU adopts its 19th sanctions package, designating A7A5, Old Vector and Grinex and banning transactions involving A7A5 (in force November 25, 2025; one source says November 12).","source":"EU 19th Russia Sanctions Package - Council of the EU","source_url":"https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/","date_evidence":"On 23 October 2025, the Council of the EU adopted its 19th package of sanctions against Russia."},{"date":"2025-11","event":"Uniswap blocklists/removes A7A5; DEX liquidity provision falls from about $150 million daily to $0.5 million weekly.","source":"A7A5: The ruble-backed stablecoin crosses $100 billion in transactions - Elliptic","source_url":"https://www.elliptic.co/blog/a7a5-the-ruble-backed-stablecoin-100-billion-in-transactions"},{"date":"2026-02","event":"CoinDesk interview with A7A5 regulatory director Oleg Ogienko, who claims FATF and Kyrgyz compliance and says the company 'does not do illegal things'.","source":"'We do not do illegal things': Inside the sanctioned stablecoin issuer A7A5's race to build a crypto giant — CoinDesk","source_url":"https://www.coindesk.com/markets/2026/02/16/we-do-not-do-illegal-things-inside-a-u-s-sanctioned-stablecoin-issuer-s-race-to-build-a-crypto-giant"},{"date":"2026-03","event":"Alexander Browder (17, son of Bill Browder) publishes a Henry Jackson Society report 'Confronting the Illicit-Finance Hydra in Crypto Markets' exposing A7A5 and alleging approximately $350 billion laundered by Russia and other states through crypto.","source":"Russia sanctions British teenager for alleging A7A5 use in funding Ukraine war - CoinDesk","source_url":"https://www.coindesk.com/policy/2026/06/04/russia-sanctions-british-teenager-for-alleging-a7a5-use-in-funding-ukraine-war"},{"date":"2026-04-16","event":"Grinex, the primary remaining A7A5 trading venue, discloses a security breach with over 1 billion rubles reportedly stolen.","source":"The fall of A7A5: how sanctions strangled the ruble stablecoin (Elliptic)","source_url":"https://www.elliptic.co/blog/the-fall-of-a7a5-how-sanctions-strangled-the-ruble-stablecoin","date_evidence":"On April 16, 2026, Grinex announced \"a major security breach\" with over 1 billion rubles stolen"},{"date":"2026-05","event":"CertiK reports over $110 billion in cumulative on-chain transactions and about 43% of the non-US-dollar stablecoin market; holders reach 29,000 wallets. CoinDesk reports Ogienko saying the business could survive sanctions being lifted.","source":"Russian ruble stablecoin A7A5 grows despite Western sanctions: CertiK - TradingView/CoinTelegraph","source_url":"https://www.tradingview.com/news/cointelegraph:6e755cb2c094b:0-russian-ruble-stablecoin-a7a5-grows-despite-western-sanctions-certik/"},{"date":"2026-05","event":"HTX publicly denies the UK's allegations, saying it rejected A7A5's listing application.","source":"Crypto exchange HTX rejects U.K. sanction allegations, says it refused ruble stablecoin listing — CoinDesk","source_url":"https://www.coindesk.com/markets/2026/05/27/crypto-exchange-htx-rejects-u-k-sanction-allegations-says-it-refused-ruble-stablecoin-listing"},{"date":"2026-05-26","event":"UK FCDO sanctions 18 entities and individuals tied to the 'Kremlin-backed A7 network', alleging it moved over $90 billion the prior year; first application of Regulation 17A banking-style sanctions to crypto exchanges.","source":"UK cracks down on backdoor Russian sanctions evasion with tough new measures (GOV.UK)","source_url":"https://www.gov.uk/government/news/uk-cracks-down-on-backdoor-russian-sanctions-evasion-with-tough-new-measures","date_evidence":"Sanctions came into force immediately on 26 May 2026"},{"date":"2026-06","event":"Russia's Foreign Ministry sanctions Alexander Browder (17) and four other UK nationals (June 3 or June 4 per differing accounts) after his Henry Jackson Society report; A7A5 volumes fall to about $24.3 million, down about 96% from the July 2025 peak.","source":"Russia sanctions British teenager for alleging A7A5 use in funding Ukraine war - CoinDesk","source_url":"https://www.coindesk.com/policy/2026/06/04/russia-sanctions-british-teenager-for-alleging-a7a5-use-in-funding-ukraine-war","date_evidence":"Russia sanctions British teenager for alleging A7A5 use in funding Ukraine war"},{"date":"2026-08","event":"UK NCA and NECC issue Flash Alert 0808-NECC on the A7 Network; OFSI doubles the maximum penalty to 100% of breach value.","source":"UK NCA Issues Industry-Wide Alert on A7 Russia Sanctions Evasion Network (Global Sanctions)","source_url":"https://globalsanctions.com/2026/09/uk-nca-issues-industry-wide-alert-on-a7-russia-sanctions-evasion-network/"},{"date":"2026-10","event":"US Treasury designates the A7 Network as a significant transnational criminal organization; FinCEN issues a Finding and NPRM, reporting $179.1 billion in A7A5 transactions across 180+ entities between February 2025 and June 2026.","source":"FinCEN Moves to Cut the A7 Network's Sub-Agents Off From the US Financial System (TRM Labs)","source_url":"https://www.trmlabs.com/resources/blog/fincen-moves-to-cut-the-a7-networks-sub-agents-off-from-the-us-financial-system"}],"sources_used":[{"url":"https://home.treasury.gov/news/press-releases/sb0225","name":"Treasury Sanctions Cryptocurrency Exchange and Network Enabling Sanctions Evasion and Cyber Criminals","type":"regulatory","archive_url":"http://web.archive.org/web/20260723141303/https://home.treasury.gov/news/press-releases/sb0225","credibility":1,"archive_timestamp":"2026-07-23T14:13:03+00:00"},{"url":"https://ofac.treasury.gov/recent-actions/20250814","name":"OFAC Recent Actions - August 14, 2025","type":"regulatory","archive_url":"http://web.archive.org/web/20260529112959/https://ofac.treasury.gov/recent-actions/20250814","credibility":1,"archive_timestamp":"2026-05-29T11:29:59+00:00"},{"url":"https://www.opensanctions.org/entities/NK-BWSfTq3iX7YzFrwPyiszKh/","name":"Old Vector LLC - OpenSanctions","type":"regulatory","archive_url":"http://web.archive.org/web/20260318050912/https://www.opensanctions.org/entities/NK-BWSfTq3iX7YzFrwPyiszKh/","credibility":1,"archive_timestamp":"2026-03-18T05:09:12+00:00"},{"url":"https://www.opensanctions.org/entities/NK-nCCRCEZeb4t4Rz8QxUji3C/","name":"GRINEX LLC - OpenSanctions","type":"regulatory","archive_url":"http://web.archive.org/web/20260219122817/https://www.opensanctions.org/entities/NK-nCCRCEZeb4t4Rz8QxUji3C/","credibility":1,"archive_timestamp":"2026-02-19T12:28:17+00:00"},{"url":"https://www.secretservice.gov/newsroom/releases/2025/03/us-secret-service-seizes-russian-cryptocurrency-exchange-websites","name":"U.S. Secret Service Seizes Russian Cryptocurrency Exchange Websites","type":"regulatory","archive_url":"http://web.archive.org/web/20260529112959/https://www.secretservice.gov/newsroom/releases/2025/03/us-secret-service-seizes-russian-cryptocurrency-exchange-websites","credibility":1,"archive_timestamp":"2026-05-29T11:29:59+00:00"},{"url":"https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/","name":"EU 19th Russia Sanctions Package - Council of the EU","type":"regulatory","archive_url":"http://web.archive.org/web/20260706013534/https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/","credibility":1,"archive_timestamp":"2026-07-06T01:35:34+00:00"},{"url":"https://home.treasury.gov/news/press-releases/jy1049","name":"Treasury Targets Corruption and Kremlin Malign Influence in Moldova","type":"regulatory","archive_url":"http://web.archive.org/web/20260724074037/https://home.treasury.gov/news/press-releases/jy1049","credibility":1,"archive_timestamp":"2026-07-24T07:40:37+00:00"},{"url":"https://www.trmlabs.com/resources/blog/garantex-grinex-and-the-a7a5-token-a-deep-dive-into-sanctions-evasion-networks","name":"Garantex, Grinex, and the A7A5 Token: A Deep Dive into Sanctions Evasion Networks - TRM 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