Leaked A7 records list an FCA-registered UK fintech as a $50,000-a-day route to China
Leaked records show the Kremlin-backed A7 network listing UK fintech Wooshpay as a payment route to China and Hong Kong, capped at $50,000 a day. The published documents do not settle whether Wooshpay knew, so its partners have only the listing to assess.
The Investor · Invest desk
Key figures for Zhejiang Chouzhou Commercial Bank: its customers received about $170 million from A7 between late 2024 and August 2025, per BankCheck; 268 entities in the leaked documents held accounts there; 120 of them were non-resident account holders.
| Figure | Value | Note | Claim |
|---|---|---|---|
| Received from A7 by the bank's customers, per BankCheck | $170,000,000 about | late 2024 to August 2025 | 14 |
| Entities with accounts | 268 entities | 15 | |
| Non-resident holders | 120 account holders | 21 |
What happened
- One document shows A7 staff forging an invoice that cast Wooshpay as a supplier of 'cashmere sewing fabric' to the network, a cover story for the relationship.
- The FT found one payment on the route, 189,000 renminbi or about $26,000, with a reference number indicating Wooshpay was sending money onward for A7.
- Wooshpay is UK-registered but listed as ultimately controlled by a Chinese national living in China, and a second director is recorded at Companies House as UK-resident.
- The US Treasury sanctioned A7 as a significant transnational criminal organisation on 1 October under an operation it called Economic Outcast.
- The FT had earlier reported that A7 pushed about $6.9 billion through conventional banks using hundreds of front companies and an industrial forgery operation.
Why it matters
- Who's exposed exposure A small payment institution must know its customers, understand why each relationship exists and monitor transactions, so a listing by A7 invites the question of what that monitoring caught.
- Who has to decide decision Banks and payment partners that deal with the Chinese lender must decide whether its mix of non-resident account holders and A7 volume calls for enhanced review.
- What it limits constraint A FinCEN rule built around A7-controlled sub-agents may not reach a firm A7 calls rented, which leaves screening of that firm's payments to the banks that process them.
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The cap is the figure to start from. At $50,000 a day [4], a route used on every day of the year would carry at most $18.25m [19]. According to the bank-intelligence firm BankCheck, customers of Zhejiang Chouzhou Commercial Bank received about $170m from A7 between late 2024 and August 2025 [14], so a fully used Wooshpay route would be roughly 11% of that [20], though the periods do not match exactly. The one transfer on record, sent to an account at that bank [7], used 52% of a single day's allowance [18].
We think the listing costs A7 little and costs Wooshpay more, or rather it costs whoever banks Wooshpay, since a payment firm's partners inherit any gap in its monitoring. A7 was not building another front company here. Its note called Wooshpay a "rented" treasury, which The Paypers said implies an independent business doing work for the network alongside its other activities [13], and the cover story was a forged invoice [2].
The counter-thesis is that Wooshpay is a bystander. The invoice is A7's own paperwork, and the documents the FT has published so far do not settle whether the firm knew how the network described it [17]. Against that, the reference number on the one payment indicated Wooshpay was sending money onward for the network [5], and a firm that sends money onward has its own record of who asked and why.
The bank end gives a cleaner signal than the firm does. Zhejiang Chouzhou ranks 98th among Chinese banks by balance sheet and fourth by volume in the A7 data [14]. Of the 268 entities in the leaked documents with accounts there, 120 are non-resident, or 45% [15][21]. Four are UK-domiciled, 1.5% of the total [16][22]. Wooshpay is one of them, and Albi International, which A7 also offered to a customer as a potential paying front and which is registered at a mailbox rental service in London, is another [16].
FinCEN has proposed a rule that would bar US institutions from transmitting funds involving A7-controlled foreign "sub-agents" [10], a category it says processed more than $17bn between January 2025 and June 2026 [11]. The reporting on the proposal does not say how it would treat a firm A7 does not control. If "rented" means what The Paypers takes it to mean, a rule drawn around control may not reach Wooshpay, and the screening falls to the banks that process its payments.
Two findings would prove this view wrong. A record showing the route never carried more than the single transfer would shrink the exposure to a roster entry. A finding that Wooshpay's own monitoring stopped or reported A7-linked payments would move the burden off its partners.
What to watch
- Further FT or regulator disclosures showing whether the Wooshpay route carried any payment beyond the single $26,000 transfer.
- Any FCA or Wooshpay statement on whether the firm's monitoring flagged A7-linked flows.
- The text of FinCEN's proposed rule, and whether its definition of A7-controlled sub-agents reaches independent firms the network rents.
Information, not investment advice. This story is general information about companies and markets, drawn from cited reporting. It is not a recommendation to buy, sell or hold any security; check the cited sources before acting.
Clarity's read
What the record supports and how the coverage leans. The claims behind it follow.
Reality
- Evidence62
- Adoption8
- Hype gap+15
- Incentives
- Not scored
- Confidence60
Claim ledger
Ranked by verification strength, evidence, and original report placement.
- [1]
Documents from a leak of A7 records show the Kremlin-backed money laundering network named Wooshpay, a UK fintech registered with the FCA as a small payment institution and incorporated as Swooshtransfer, on a list of entities it could use to make payments.
- [2]
One document indicates A7 sought to create a cover story for the relationship by forging an invoice suggesting Wooshpay supplied it with 'cashmere sewing fabric'.
- [3]
An internal A7 note described Wooshpay as holding an 'extensive licence' and listed it as a possible payment route to mainland China and Hong Kong in both renminbi and US dollars.
- [4]
The document set conditions for the route, including a limit of USD 50,000 in payments per day and a requirement for a customs declaration containing no Russian-language text.
- [5]
The FT identified a single payment on this route, a transfer of 189,000 renminbi, about $26,000, whose reference number in A7's records indicated that Wooshpay was sending money onward for the network.
- [6]
Wooshpay is registered in the UK but is listed as ultimately controlled by a Chinese national living in China, while another director is listed on Companies House as resident in the UK.
- [7]
The recorded payment was sent to an account at Zhejiang Chouzhou Commercial Bank.
- [8]
On 1 October the US Treasury, under an operation it called Economic Outcast, sanctioned A7 as a significant transnational criminal organisation and accused the network of also serving Iranian actors and their proxies.
- [9]
The FT reported that A7 had pushed about $6.9 billion through conventional banks using hundreds of front companies and an industrial forgery operation that manufactured supporting paperwork.
- [10]
The Treasury's Financial Crimes Enforcement Network proposed a rule that would bar US institutions from transmitting funds involving A7-controlled foreign 'sub-agents', the third-country companies that sign the paperwork and appear as the paying party.
- [11]
FinCEN has said those sub-agents processed more than $17 billion between January 2025 and June 2026.
- [12]
FCA registration requires Wooshpay to identify and verify customers and their beneficial owners, understand the purpose of each relationship and monitor transactions.
- [13]
The A7 note referred to Wooshpay as a 'rented' treasury, which The Paypers said implies it was an independent business that carried out work for the network alongside other activities, while many of A7's front companies were controlled by the network.
- [14]
According to banking counterparty intelligence company BankCheck, Zhejiang Chouzhou Commercial Bank ranks 98th among Chinese banks by balance sheet, yet fourth by volume in the A7 data, with its customers receiving about USD 170 million from A7 between late 2024 and August 2025.
- [15]
In total, 268 entities in the leaked documents held accounts at Zhejiang Chouzhou Commercial Bank, 120 of them non-resident accounts.
- [16]
Wooshpay was one of four UK-domiciled entities with accounts at the bank, alongside Albi International, which was also offered to an A7 customer as a potential paying front and is registered at a mailbox rental service in London.
- [17]
Whether the FCA-authorised firm knew how it was being described inside the network is not settled by the documents the FT has published so far.
- [18]
The single identified transfer of about $26,000 equals roughly 52% of the $50,000 daily limit.
- [19]
A route used every day of the year at the $50,000 daily limit would carry at most about $18.25 million.
- [20]
A fully used route at the cap would be roughly 11% of the about $170 million BankCheck says customers of Zhejiang Chouzhou received from A7, though the periods do not match exactly.
- [21]
The 120 non-resident account holders are about 45% of the 268 entities with accounts at the bank.
- [22]
The four UK-domiciled entities are about 1.5% of the 268 entities with accounts at the bank.
Sources
2 independent publishers whose own reporting we read for this story.
- crowdfundinsider.comKremlin Linked Money Laundering Operation A7 Turns to London Fintech for Transfers
1 article · October 12, 2026
- thepaypers.comKremlin-backed A7 network listed UK fintech Wooshpay as payment route
1 article · October 14, 2026
Topics and entities
Topics
- Sanctions Evasion
- Russia Sanctions Regimes
- Payments compliance and liability shift
Entities
- A7
- Financial Conduct Authority
- Zhejiang Chouzhou Commercial Bank
- Financial Crimes Enforcement Network
- Financial Times
- US Department of the Treasury