A7 Abroad: Sanctions evasion as a service

CIR

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CIR

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Executive summary

  • A7 is a political and commercial enterprise aimed at enabling large-scale evasion of sanctions levelled against Russia, in particular sanctions relating to Russia’s invasion and war against Ukraine. It claims to have moved over US $86 billion in transactions in less than a year of operation.
  • A7 is led and majority-owned by convicted fraudster Ilan Shor. It is co-owned and substantially financed by Promsvyazbank (PSB), a heavily sanctioned Russian state-owned military bank, and VEB.RF, a Russian state-owned development corporation and investment company which is also heavily sanctioned.
  • A7 uses multiple methodologies for sanctions evasion. A previous report by the Centre for Information Resilience (CIR) covered one method, the creation and promotion of a cryptocurrency in Kyrgyzstan. The current report details A7’s suspected main methodology for moving payments in the face of Western sanctions: a network of foreign shell companies and promissory notes. This methodology is essentially a form of trade-based money laundering.
  • A7 claims to have over 30 shell companies in its network of ‘payer companies’. CIR has identified at least ten companies which appear highly likely to be connected to this network, as well as several others with a lower level of confidence. All but two of the companies identified by CIR with a high level of confidence are registered (or purport to be registered) in the UAE.
  • A7 has been engaged in an aggressive campaign to grow its public profile and expand its operations in Russia and internationally. This campaign has been supported by high-level political figures, including President Putin, indicating A7’s significance to the Kremlin’s geopolitical objectives.
  • A7’s target market ranges from large companies to small businesses and individuals. It advertises international import-export services, currency exchange, international payments and purchases and, passive income generation. It claims to be processing ~1,500 transactions daily and to have over
    10,000 customers.
  • Trade with China has emerged as the dominant focus of A7’s activities to date. 78% of A7 transactions went through Chinese jurisdictions according to figures shared by the company in August 2025. A7 is also expanding into Africa, with the opening of offices in Nigeria and Zimbabwe.
  • Questions remain about A7’s other activities. Further research will be needed to comprehensively understand how funding flows through the organisation’s network, the potential role of financial institutions in enabling its operations and any linkages to Russian political interference schemes.

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