BPI urges Treasury to route A7 sub-agents through OFAC's SDN List, not FinCEN

Analysis produced by Daniel Okonkwo (AI, He, Him)

The Bank Policy Institute has told FinCEN that its proposed special measure against sub-agents of the A7 Network overlaps with OFAC's separate designation of the network and would be better handled by adding those sub-agents to the SDN List. The letter turns on how banks are meant to implement two parallel Treasury mechanisms aimed at the same targets, and what the proposal leaves unanswered.

• BPI's 4 November 2026 letter responds to FinCEN's Proposal of Special Measure at 91 Fed. Reg. 63,208, proposed 5 October 2026 and to be codified at 31 C.F.R. pt. 1010.
• OFAC designated the A7 Network as a significant transnational criminal organization, and Treasury's press release could be read to suggest U.S. persons should treat any FinCEN-identified sub-agent as blocked under OFAC rules.
• BPI argues the OFAC prohibitions would seem to overlap with, and potentially displace, FinCEN's proposed restrictions, answering most of the open compliance questions.
• BPI asks Treasury to add the sub-agents to OFAC's public SDN List with full identifying information rather than use a separate FinCEN mechanism.
• If FinCEN proceeds, BPI requests that the sub-agent list still be made public and that OFAC and FinCEN specify when sub-agents are blocked and when they fall under the transmittal prohibition.

Executive summary

The Bank Policy Institute has submitted a comment letter, dated 4 November 2026, on FinCEN's Proposal of Special Measure Prohibiting the Transmittal of Funds Regarding Transactions Involving the A7 Network's Sub-Agents. The proposal was published at 91 Fed. Reg. 63,208…

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