The new US rule covers crypto addresses, not just bank accounts

The FinCEN A7 Network rule, a proposed special measure, appeared in the Federal Register on 5 October. Comments close on 4 November, the regulation number is 1506-AB77, and OFAC's own designations of A7 took effect on 1 October.

“a sanctions evasion and money laundering service with ties to Russia, leveraged by a wide range of illicit actors, including Iran and its terrorist proxies”

— FinCEN, Заключение от 5 октября 2026

The sentence that reaches you

The prohibition reads: «A covered financial institution is prohibited from engaging in a transmittal of funds involving any A7 Network Sub-Agent, including any transmittal of funds from or to an A7 Network Sub-Agent, or from or to any account or CVC address administered by or on behalf of an A7 Network Sub-Agent.» CVC address means a crypto address. The bank channel and the wallet channel carry the same prohibition, and the party on the list may be your exchanger rather than you.

The proposal also says covered institutions would not be barred from telling a customer that they declined a transaction because a party appears on FinCEN's list. Your exchange is allowed to tell you why it stopped the transfer, and you can ask it to.

Third time in four years

Section 9714 has produced two prior special measures: Bitzlato on 18 January 2023, and PM2BTC on 26 September 2024, 617 days later. A7 arrives 735 days after that. Both earlier orders named one institution. This one names a network and a list of sub-agents. A buyer can check a name against a list; a buyer cannot check whether a company is controlled by A7.

180 entities, $179.1bn, 515 days

FinCEN counted more than 180 entities processing at least $179.1bn of A7A5 between February 2025 and June 2026. Across those 515 days that averages $348m a day. The sub-agents also moved more than $17bn in dollar transactions, which works out at $31m a day. A Senate count last week put 84% of 846 sanctioned Iranian wallets on a single token, so the concentration here is not unusual.

A7A5 is a ruble-backed token on Tron and Ethereum, issued by Old Vector with Garantex and its successor Grinex. It has $461m outstanding today, and the venues CoinGecko tracks reported $3,610 of trading in the last 24 hours.

$348m a day against $3,610 a day is a factor of 96,000. The money moved between counterparties rather than across an order book. No chart would have shown a buyer anything, which is the same pattern as the Dubai broker that cleared $4bn without a website.

What to do with that

Ask your exchanger and your exchange which list they screen against and what they do with inbound transfers from each other. Keep order IDs, receipts and transaction hashes, because the support desk that freezes a transfer asks for exactly those. The rate you are quoted says nothing about who sends the coins.

Informational material, not investment advice. The measure is a proposal and is open to comment until 4 November, so its final wording may change.