# FinCEN proposes a virtual-currency transfer prohibition involving A7 sub-agents

> FinCEN released a section 9714 finding and proposed rule addressing A7 Network sub-agents.

- URL: https://riadefi.com/regulation/2026-10-01-fincen-a7-network-sub-agent-transfer-prohibition/
- Posture: Proposal · not in effect
- Authorities: Financial Crimes Enforcement Network
- Event date: 2026-10-01
- Version: 1, published 2026-10-02 (first published 2026-10-02)
- Advisor-relevant: no

This entry records a proposal. It does not change the law unless it is adopted.

## What changed

FinCEN released a section 9714 finding and proposed rule addressing A7 Network sub-agents. Proposed section 1010.668 would prohibit covered financial institutions from transfers involving listed sub-agents or their administered accounts and CVC addresses, expressly covering A7A5. It proposes counterparty notification, risk-based due diligence, and notification records. These proposed duties are not yet effective; existing OFAC restrictions remain separate.

## Who it affects

- Covered financial institutions processing relevant transfers
- Digital-asset exchanges and custodians within the covered perimeter
- Advisers selecting stablecoin transfer providers

## What is still open

- Final scope and adoption of the prohibition
- Federal Register publication and resulting comment deadline
- Identification of additional sub-agents and associated addresses

## What it means for an advisor

- Map client stablecoin transfer routes to potential sub-agent exposure
- Assess provider readiness for proposed notification and screening duties
- Distinguish proposed FinCEN requirements from current OFAC obligations

## Sources

1. [Proposal of Special Measure Prohibiting the Transmittal of Funds Regarding Transactions Involving the A7 Network’s Sub-Agents](https://www.fincen.gov/system/files/2026-10/9714-A7-NETWORK-NPRM.pdf) · Financial Crimes Enforcement Network · 2026-10-01


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Published by Ketju Research on RIADeFi (https://riadefi.com). Educational research for financial professionals; not investment, legal, tax, or compliance advice.