Analysis
The steps have different legal effects. The OFAC designation blocks covered property and interests in property in the United States or in the possession or control of U.S. persons, including transactions involving sub-agents acting for or on behalf of A7, subject to applicable sanctions rules. FinCEN’s proposed special measure is not yet final or operative. Its alert separately asks financial institutions to identify and report suspicious activity and gives indicators for monitoring. The distinction matters for payment intermediaries, correspondent banking and compliance teams: apply the current sanctions rules, and track the proposed rule through Federal Register publication before treating it as a new binding prohibition.
What remains uncertain
Treasury and FinCEN describe A7 as a sanctions-evasion and money-laundering network based on agency analysis, BSA data, open-source reporting and law-enforcement information. Those underlying allegations are attributed to the agencies. The proposal is pending Federal Register publication, so its final text and exact comment deadline are not yet available.
Sources
- Treasury announcement ↗Official release
- FinCEN proposed rule ↗Official source · PDF
- FinCEN alert ↗Official source · PDF