FinCEN Proposes Funds-Transfer Ban Tied to the A7 Network: A Brief for Practices

The Financial Crimes Enforcement Network (FinCEN), part of the Treasury Department, has issued a finding and notice of proposed rulemaking concerning the A7 Network, which the agency describes as a sanctions evasion and money laundering service with ties to Russia ^[1]. The document, number 2026-20371, carries a Federal Register publication date of October 5, 2026 ^[1]. It is classified as a proposed rule, not a final rule ^[1].

What the proposal does

The notice has two parts: a finding and a proposed prohibition ^[1]. The finding is that transactions involving any company operating outside the United States that is controlled by the A7 Network form a class of transactions of primary money laundering concern in connection with Russian illicit finance ^[1]. The proposal would prohibit certain transmittals of funds, meaning transfers of money, by any covered financial institution when those transfers involve that class of transactions ^[1].

FinCEN states that the A7 Network has been used by a wide range of illicit actors, including Iran and its terrorist proxies ^[1]. The document's title calls the action a special measure and refers to the targeted foreign companies as the network's sub-agents ^[1].

Legal basis

FinCEN cites section 9714(a) of the Combating Russian Money Laundering Act, Public Law 116-283 ^[1]. That section was amended by section 6106(b) of the National Defense Authorization Act for Fiscal Year 2022, Public Law 117-81 ^[1].

Who it affects

The proposed prohibition applies to covered financial institutions ^[1]. The published summary does not define that term, and it does not name healthcare providers, medical practices or patients ^[1]. The summary therefore does not settle whether any particular bank or payment intermediary falls within the proposal's scope ^[1].

Dates that matter

• Publication in the Federal Register: October 5, 2026 ^[1].
• Comment deadline, effective date and compliance date: not stated in the summary, so the full Federal Register document is the place to confirm them ^[1].
• Final status: the action is a proposed rule, so its terms are not final ^[1].

What a practice should check

The published summary names covered financial institutions, not medical practices, as the parties subject to the proposed prohibition ^[1].

• Whether the practice sends funds transfers to any company operating outside the United States, because the finding covers transactions involving foreign companies controlled by the A7 Network ^[1].
• How the full text defines a covered financial institution, to judge whether the practice's bank or payment intermediaries are within scope ^[1].
• Which transmittals of funds are prohibited, since the summary refers to certain transmittals rather than all of them ^[1].
• The comment period in the full document, for a practice or its professional association that wants to comment ^[1].
• Any later final rule, which would set the binding terms ^[1].

Context: a separate CMS final rule

Separately, on October 2, 2026, the Centers for Medicare & Medicaid Services (CMS) published a final rule implementing the Global Benchmark for Efficient Drug Pricing (GLOBE) Model ^[3]. GLOBE is a new mandatory Medicare payment model under section 1115A of the Social Security Act ^[3]. It uses an alternative method for calculating Medicare Part B drug inflation rebate amounts for certain separately payable Part B drugs and biological products ^[3]. CMS states that the model will test whether this approach reduces costs for Original Medicare beneficiaries and the Medicare program while preserving quality of care ^[3]. CMS uses Original Medicare to mean Medicare fee-for-service, the traditional Medicare program ^[3].

Limitations

This brief draws on the published summary of the FinCEN notice, not the full regulatory text ^[1]. The summary does not list the specific sub-agent companies, define covered financial institution, describe which transmittals are excluded or give comment and effective dates ^[1]. Readers should confirm each of these points in the full Federal Register document before acting on it ^[1].