What A7A5 actually is
A7A5 is a rouble-referenced stablecoin, issued by a Kyrgyzstan-registered company called Old Vector, that launched in February 2025 and, within months, was processing tens of billions of dollars in volume across a network built around Garantex, a previously-sanctioned Russian exchange, and its successor Grinex. Every major blockchain analytics provider that has looked at it, TRM Labs, Chainalysis, and a joint TRM/Open Source Centre investigation, treats it as connected to sanctions evasion at scale.
What makes this case worth a dedicated guide isn't the existence of a sanctioned stablecoin, that's a familiar story. It's the shape of the infrastructure. A7A5 doesn't read as a legitimate token that criminals later exploited; it reads as purpose-built settlement infrastructure, issued from a jurisdiction with looser sanctions exposure, routed through an exchange network with continuity from an already-sanctioned predecessor, at a scale consistent with institutional rather than retail use. That's the thesis this guide holds to throughout: a state-aligned financial ecosystem appears capable of creating its own settlement infrastructure when conventional financial rails are restricted, not simply "criminals used crypto." The distinction matters because it changes what a practitioner should actually be looking for, continuity of control and personnel across supposedly separate entities, not just a transaction that happens to touch a flagged address.
Three regulators have acted on this network, the US Treasury's Office of Foreign Assets Control (OFAC), the UK's Office of Financial Sanctions Implementation (OFSI), and the Council of the European Union, each on its own timeline, under its own legal mechanism, reaching different entities. OFSI implements the sanctions; the current designations themselves sit on the UK Sanctions List, not the older OFSI Consolidated List, which closed 28 January 2026. None of the three designates the A7A5 token itself as a sanctioned "person," including the EU. The EU is the only one of the three that restricts the token directly, but it does so through a wholly separate legal tool, a transaction-ban listing, not a person-designation. Getting that distinction right is most of what this guide is for.
Work through the methodology section before citing any A7A5 volume figure in a report, there are four legitimate, non-additive numbers in circulation and picking the wrong one, or summing them, will misstate the case. Then work the sanctions-status section entity by entity; do not skip to a single yes/no answer.
This is not the Shadow Fleet
FinCrimeRadar's existing Shadow Fleet guides cover a genuinely different sanctions-evasion network: vessel-based physical infrastructure, oil tankers, flag-of-convenience registration, ship-to-ship transfers, AIS spoofing, and fraudulent insurance arrangements used to move sanctioned Russian oil. A7A5 is crypto-native settlement infrastructure, a stablecoin and its exchange network. Both are examples of purpose-built sanctions-evasion infrastructure in the general sense, and both involve Russia-linked sanctions circumvention, but the actors, mechanisms, and evidence bases are entirely unrelated. Do not conflate the two when researching either.
Four numbers, none of them wrong, none of them additive
Every serious piece of analysis on A7A5 cites a volume figure. Four different, legitimate figures exist, from two providers (TRM Labs, Chainalysis), covering different objects, different windows, and different methodologies. None of them is "the" number. Presenting one as definitive, or adding them together, misstates what's actually known.
| Provider & date | Period | Object measured | Metric (verbatim) | Value |
|---|---|---|---|---|
| TRM Labs, 28 Jan 2026 | CY2025 | A7A5 token itself | "processed more than USD 72 billion in total volume" | $72bn |
| TRM Labs, 28 Jan 2026 | CY2025 | Broader A7 wallet cluster (standard clustering) | "linked to at least USD 39 billion" | $39bn |
| TRM Labs, 17 Feb 2026 | CY2025 (leak-derived) | Leak-attributed address group | "associated with at least USD 83 billion in direct volume" | $83bn |
| Chainalysis, 5 Mar 2026 | ~10 months (Feb 2025 launch) | A7A5 token itself | "processed $93.3 billion in transactions" | $93.3bn |
These are non-additive for three separate reasons, not one. The $72bn and $39bn figures measure different objects (the token specifically versus the broader wallet cluster) using the same CY2025 window. The $83bn figure uses a different methodology entirely, leak-derived attribution rather than standard on-chain clustering, and TRM does not state whether that address set overlaps with, sits inside, or is wholly separate from the $39bn cluster; treat that relationship as genuinely unresolved, not as containment or addition. The $93.3bn Chainalysis figure covers a shorter, differently-dated window from a different provider, so it isn't directly comparable to the $72bn TRM figure even though both measure the token itself. Caution: a secondary summary of the Chainalysis report misattributes TRM's $72bn figure as part of "the total sanctions evasion volume" inside its own Chainalysis write-up; that blended figure should never be cited.
TRM Labs and the Open Source Centre jointly published "The A7 Leaks" on 12 June 2026, based on leaked internal A7 documents. The article is internally inconsistent about what it's actually measuring: its introduction cites "A7's on-chain volume of over USD 166 billion" as a broader-network figure, its body reframes the same $166bn as A7A5-specific while noting "roughly USD 35B appears to stem from circular transfers," and its FAQ cites a third figure, "USD 110 billion," for what it calls A7A5's on-chain volume, with "roughly one-third" of that figure (~$37bn) not quite matching the body's ~$35bn circular-transfer estimate.
Do not treat $166bn as comparable to the four-row table above. Do not assume it represents A7A5 specifically rather than the broader A7 network, or vice versa, the source itself supports neither reading consistently. Do not subtract the circular-transfer estimate from either $166bn or $110bn to manufacture a corrected net figure; TRM does not disclose enough methodology to justify that arithmetic. This is a source-quality problem, not a fifth data point to reconcile against the table.
A sixth figure exists, from a different kind of source entirely: the UK government's own 20 August 2025 press release states A7A5 "has moved $9.3bn on a dedicated crypto exchange in just four months." This is a government attribution, not a blockchain-analytics figure, covering roughly February to June 2025, a different window again from every figure above. It doesn't slot into the table and shouldn't be forced to; its existence, and the fact that it comes from a government source rather than an analytics provider, is the point worth noting.
You're drafting an internal risk memo on A7A5 exposure and need to cite a total volume figure. A colleague suggests using "$93.3bn processed" since it's the largest, most recent-sounding number and "gives leadership the full picture."
"A7A5 is sanctioned" is not a precise statement
The precision point this section exists to make: sanctions law designates persons, issuers, exchanges, individuals, not token contracts. Neither OFAC's nor OFSI's blocking-sanctions models treat the A7A5 token itself as a designated "person," and neither does the EU's, on that specific point. The EU restricts the token through an entirely different legal instrument: it lists A7A5 on Annex LIII, a crypto-asset transaction-ban list, structurally separate from the EU's own person-designation list under Regulation 269/2014. The EU is the only jurisdiction of the three with an instrument-level transaction ban reaching the token itself, but that ban is not, and should not be described as, a "designation" of the token as a person, including by the EU's own mechanism. Keep three ideas separate throughout: "the token is on Annex LIII, subject to a transaction ban" (EU only); "the token's issuer and ecosystem participants are designated as persons" (true, on differing entity lists, across OFAC, OFSI, and the EU); and these are legally distinct tracks even within the EU's own regime. Collapsing any of this into "A7A5 is sanctioned" loses exactly the distinction that determines what a screening system should actually flag.
| Entity | OFAC (US) | UK | EU | Basis |
|---|---|---|---|---|
| A7A5 token itself | Not named | Not named | Listed, Annex LIII | EU: transaction-ban list (Art. 5ba), a separate legal track from person-designation, not itself a "designation" |
| Old Vector (issuer) | Designated | Designated per secondary sources; primary UK date not independently confirmed this session | Designated | OFAC: material assistance to A7 (E.O. 13694). EU: Reg 269/2014 via 2025/2035, entity 645, 23 Oct 2025, "partially owned" financing structure with PSB Bank |
| Grinex | Designated | Designated | Designated by name | OFAC: owned/controlled by Garantex (derivative). EU: Reg 269/2014 via 2025/2035, entity 650, 23 Oct 2025, named directly as "a crypto-currency exchange... major trading platform" for A7A5, confirmed against the regulation's own text, not inferred |
| A7 LLC | Designated | Designated per secondary sources (UK Sanctions List ref. RUS2718); exact primary designation date not independently confirmed this session | Designated by name | OFAC: material assistance to Garantex (direct finding). EU: Reg 269/2014 via 2025/2035, entity 683, 23 Oct 2025, named directly, "partially owned by PSB Bank," co-created A7A5 |
| A71 LLC / A7 Agent LLC | Designated | Designated, 16 June 2026 | Corroborated (23 July 2026) via a specialised sanctions-data aggregator; not independently confirmed against the primary EU annex text this session | OFAC: owned/controlled by A7 (derivative). UK date confirmed directly against the primary GOV.UK designation list for that date |
| Garantex | Re-designated | Designated per secondary sources (widely reported 4 May 2022); not independently confirmed against the primary UK list this session | Designated per secondary sources (widely reported Feb 2025, 16th package); not independently confirmed against EUR-Lex this session | OFAC: originally E.O. 14024 (2022), additionally E.O. 13694 (2025), dual basis |
| Mendeleev | Designated | Designated, 26 May 2026 | Not verified this session | OFAC: acting for/on behalf of Garantex (derivative). UK date confirmed directly against the primary GOV.UK designation list for that date |
| Mira Serda, Karavatsky | Designated | Not confirmed in sources checked | Not verified this session | OFAC: acting for/on behalf of Garantex (derivative). Their UK status genuinely diverges from Mendeleev's in what was checked, not assumed to match his |
| Meer / CJSC Tengricoin | Not on the current SDN list | Designated, Aug 2025 | Designated, 23 Apr 2026 | UK and EU designations sit roughly eight months apart; this is a live, evolving picture across two of the three regimes, not a single static snapshot, and OFAC still shows no hit as of the full current-list check performed for this guide |
Why the Meer row matters more than a footnote
Meer is the practitioner-relevant example in this whole table, and it has kept moving. It was UK-designated in August 2025, EU-designated roughly eight months later in April 2026, and still does not appear on OFAC's current Specially Designated Nationals list, confirmed by downloading and searching that list's complete current export directly rather than relying on the original press release's silence alone. A screening process that checks only OFAC, or infers that a UK or EU designation implies an equivalent US one, will miss this entirely, and would have kept missing it even after the EU caught up. The correct practitioner response isn't to assume any one regulator is "more complete" or "usually first"; it's to check every applicable list independently, per entity, on a recurring basis, because the picture genuinely changes over time.
The EU's different mechanism
Article 5ba of Council Regulation (EU) No 833/2014, inserted by Council Regulation (EU) 2025/2033 and effective 25 November 2025, prohibits engaging, directly or indirectly, in any transaction involving a crypto-asset listed on Annex LIII, currently A7A5. This is structurally different from a person-designation: it restricts the instrument by adding it to a distinct list, not by naming a person. Separately, and on a different legal basis, Regulation (EU) No 269/2014, via Council Implementing Regulation (EU) 2025/2035 (23 October 2025), individually designates Old Vector (the issuer), A7 LLC, and Grinex as persons, each named directly in the regulation's own annex text, not merely described functionally, person-level designations distinct from the Annex LIII listing. No equivalent instrument-level ban exists under either the US or UK regimes verified for this guide.
This also matters for enforcement in practice, not just classification. FATF's own reporting on stablecoin cross-chain activity notes that interoperability across blockchains can weaken an issuer's ability to freeze or blacklist a token where it circulates elsewhere as a wrapped or bridged representation. That FATF finding establishes a technical and architectural relationship, how issuer control mechanisms actually work across chains, not a legal interpretation of whether a wrapped or bridged token would fall within Article 5ba's own prohibition. Whether the EU's transaction ban, or any freeze request under the other regimes, actually reaches such a representation is a separate legal question this guide's sanctions research does not resolve, and FATF is not authority for that legal question regardless.
Your screening system flags a counterparty connected to "Meer" as a sanctioned entity, sourced from a UK Sanctions List check. A colleague at a US-only correspondent bank says their own OFAC SDN screening shows no hit and asks whether your alert is a false positive.
Four patterns, four cards
FAQ
Is A7A5 sanctioned?
If Grinex is designated by OFAC, is it automatically designated everywhere else?
Why does it matter that Old Vector's designation is a "direct finding" while others are "derivative"?
Does the EU's Article 5ba ban reach a wrapped or bridged version of A7A5 on another blockchain?
At a glance
Four patterns, the risk that makes each one look routine, the signal that gives it away, and the response that fits.
Primary sources
Volume figures, entity designations, and regulatory mechanisms were checked directly against the primary releases below on 30 August 2026, not against secondary summaries alone, except where a specific entry says otherwise. Where a fact rests only on secondary corroboration, that is stated in the text at the point it's used, not implied by its presence in this list.
- US Department of the Treasury (OFAC), Treasury Sanctions Network Providing Revenue for Russia's War Machine, 14 August 2025.
- OFAC Specially Designated Nationals list, complete current export, downloaded and searched directly 30 August 2026.
- UK Government (FCDO), UK targets sanctions circumvention and crypto networks exploited by Russia, 20 August 2025.
- UK Government, List of Russia sanctions designations, 26 May 2026.
- UK Government, List of Russia sanctions designations, 16 June 2026.
- Council of the European Union, press release on the 19th sanctions package, 23 October 2025.
- Council Implementing Regulation (EU) 2025/2035 of 23 October 2025, EUR-Lex, full annex text.
- TRM Labs, 2026 Crypto Crime Report, 28 January 2026.
- TRM Labs, Stablecoins at Scale: Broad Adoption and Highly Concentrated Illicit Networks, 17 February 2026.
- TRM Labs and the Open Source Centre, The A7 Leaks: TRM's On-Chain Analysis of Russia's Cryptocurrency Connections, 12 June 2026.
- Chainalysis, 2026 Crypto Crime Report, 5 March 2026.
- FATF, Targeted Report on Stablecoins and Unhosted Wallets – Peer-to-Peer Transactions, March 2026.
- FinCrimeRadar, Vessel Sanctions Fundamentals: What the Shadow Fleet Actually Is and The Shadow Fleet Investigation Playbook, 24 August 2026.
Not yet independently confirmed against primary text, flagged rather than assumed: the EUR-Lex text of Council Regulation (EU) 2025/2033 itself (the Article 5ba/Annex LIII amendment, distinct from source 7's person-designation regulation); the EUR-Lex annex text of Council Implementing Regulation (EU) 2026/1843 (23 July 2026) for A71 LLC and A7 Agent LLC's EU listing by name; Garantex's original UK (widely reported 4 May 2022) and EU (widely reported February 2025) designation dates; A7 LLC's exact UK designation date; and Meer/CJSC Tengricoin's EU designation (23 April 2026), corroborated via Kyrgyz news reporting rather than the primary EU regulation text.
Precision is the whole job here.
A7A5 rewards careful practitioners and punishes sloppy ones. The volume figures are all legitimate and all easy to misuse. The sanctions status is real and precise, and gets flattened into something less useful every time someone says "A7A5 is sanctioned" instead of naming which entity, which regulator, which mechanism. FinCrimeRadar's screening tool checks sanctions, PEP, and adverse media exposure for the entities in this network and beyond, free, no signup required.