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

> FinCEN proposes barring covered financial institutions from certain funds transfers involving A7 Network-controlled companies abroad. Practices are not named; this brief covers what the notice does and what to verify.

iPMS Practice Desk · 2026-10-04 · https://blog.myipms.app/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].

## References

1. federalregister.gov. Proposal of Special Measure Prohibiting the Transmittal of Funds Regarding Transactions Involving the A7 Network's Sub-Agents. Accessed October 4, 2026. https://www.federalregister.gov/documents/2026/10/05/2026-20371/proposal-of-special-measure-prohibiting-the-transmittal-of-funds-regarding-transactions-involving
3. federalregister.gov. Global Benchmark for Efficient Drug Pricing (GLOBE) Model. Accessed October 4, 2026. https://www.federalregister.gov/documents/2026/10/02/2026-20281/global-benchmark-for-efficient-drug-pricing-globe-model