A7 is a major Kremlin-backed Russian sanctions-evasion network that claims to have moved USD 114.5 billion in transactions in its first year of operation in 2025, amounting to roughly 19% of Russia’s overall foreign trade. A7 and many of its affiliated entities have been sanctioned by the US, UK, EU, and other jurisdictions. In September 2026, the UK Chancellor and the National Crime Agency announced a ‘nationwide alert’ for A7, the first ever to be issued.
A7A5 is a Kyrgyzstan-registered stablecoin cryptocurrency created and operated by A7 as part of its sanctions-evasion infrastructure. A7 and A7A5’s Kyrgyz issuer, Old Vector, are sanctioned across multiple jurisdictions, including the EU, US, and UK. CIR’s previous reports on A7 and A7A5 provide further details on the network, including its links to Kyrgyzstan.
CIR has identified open-source evidence of multiple connections between Tsunami Payments, a digital payments company registered in Kyrgyzstan, and A7A5. Direct links between Tsunami Payments’ digital infrastructure and A7A5 remain live as of August 2026 and indicate close technical ties.
CIR has identified Tsunami Payments’ original owners as Russian cryptocurrency entrepreneurs linked to multiple other businesses in Kyrgyzstan and internationally. This includes the TokenSpot cryptocurrency exchange, which TRM Labs linked to the A7 network. It also includes an extensive Russian-origin international payments network called Alfabit.
CIR has also identified apparent links between Tsunami Payments’ current and former directors and significant national cryptocurrency initiatives in Kyrgyzstan. Tsunami Payments’ original registered director is also a member of the Board of Directors for Bereket Bank, Kyrgyzstan’s first bank focused on cryptocurrency assets. Bereket Bank is co-owned by Kyrgyz President Sadyr Japarov’s son.
Tsunami Payments’ director between September 2025 and August 2026 appears to have had overlapping connections with KGST. KGST is a stablecoin pegged to Kyrgyzstan’s currency the som and has been billed by President Japarov as a “national” cryptocurrency, despite being issued by a privately owned company.
As of 4 September 2026, Tsunami Payments’ newly appointed director is Kenzhebek Avasovich Takyrbashov. Takyrbashov is a former Chairman of the Board of Ayil Bank (renamed ABank in March 2026), a major state-owned bank which has been accused of facilitating A7’s operations. He is also a former member of the Board of Directors for the state-owned OJSC Capital Bank.
Understanding Tsunami Payments’ links to A7 and its position in the wider context of cryptocurrency in Kyrgyzstan is significant for two reasons. Firstly, identifying and countering third-party companies facilitating A7’s operations is critical to combating Russia’s sanctions-evasion apparatus.
Secondly, Tsunami Payments’ links to Kyrgyzstan’s emerging and politically connected cryptocurrency sector raise questions about how illicit finance networks like A7 can embed themselves within financial systems and industries in third countries. Understanding these networks is critical if governments are to ensure sanctions remain robust and effective.
CIR has not identified and does not impute evidence of illegal activity by any of the individuals or companies named in this report. Further investigation will be needed to determine whether Tsunami Payments has assisted A7A5 with sanctions evasion, and what, if any, connections there may be between A7 and the range of entities connected to Tsunami Payments.