Sanctions-Evading China-Bound Billions Turn Untraceable In Moscow

On its launch in late 2024, A7 touted itself as a sanctions-proof payments system, and has come under increasing scrutiny for its role as one of the Kremlin's principal channels for laundering billions of dollars worth of payments out of Russia and into the global financial system, via a global network of shell companies, often with accounts at major international banks.

As part of its launch, A7 integrated into its business a hodgepodge of informal payment brokers at Moscow markets, including Sadovod, according to internal A7 records seen by ICIJ.

For A7,“Sadovod is simply a big client base – a big, aggregated pile of clients,” a person familiar with the matter, who requested anonymity due to security concerns, told ICIJ.“And that's exactly what they go there for: the money and the profit.”

For years, this ecosystem of market brokers converted importers' cash into conventional bank transfers or crypto, most often bound for China. This informal system was upended by Western sanctions, which barred Russian businesses from the SWIFT system, the international messaging network that allows banks to exchange transactions. The threat of US secondary sanctions – which target entities for doing business with sanctioned states or businesses – made Chinese banks more cautious when dealing with Russia.

The informal cash payment system at Moscow's wholesale markets“depends on trusted intermediaries, established relationships and confidence that money will arrive,” Ilia Shumanov, managing partner of Russia-focused due diligence firm Tri-Trace Investigations, told ICIJ.“Its international reach can be extensive, while outsiders have limited visibility into the underlying transactions.”

Under A7's new, supercharged system, a platoon of market brokers takes in the bags of cash brought by vendors and makes an initial count.

The brokers then stuff the rubles into numbered bags to be loaded, along with clients' payment orders, into vans bound for an A7 processing office elsewhere in the Russian capital, according to leaked internal payment and cash management records.

A review of cash deposit and internal payment records shows that a small army of 50 or so A7 cashiers feeds the cash into a counting system where the amounts are verified; A7 enters the bag number, ruble amount and the client's payment order into a bespoke payment management system, then trucks the cash on to Promsvyazbank, or PSB, the Russian state defense bank, a co-owner of the company. PSB puts it in a vault and credits A7 accounts.

PSB acknowledged ICIJ's request for comment, but did not provide a response.

Records show that A7 then orders one of a network of shell companies registered outside Russia to make a payment on behalf of an A7 client to a beneficiary's account, often a Chinese exporter, at another bank outside Russia – without any trace of the cash, or Russian origin, of the funds surfacing on the wire transfer or supporting documentation. The shell companies are advanced funds from A7 in Russia which pass through Kyrgyzstan on their way to the payee.

“The only bank that sees [where the funds come from] is Promsvyazbank,” Voloshin commented.“And the only company that sees everything is A7 itself.”

With A7's role in sanctions evasion increasingly in the spotlight of Western authorities, understanding the source of A7 payments will become a central challenge for Western sanctions enforcers and international banks charged with know-your-customer (KYC) and other anti-money-laundering obligations.

The scale of A7's cash intake is visible in a series of leaked documents reviewed by ICIJ, including a cash deposit ledger dated to shortly after the company's launch in late 2024. Over a six-week period between November and December 2024, that ledger and other documents provide a running total of A7's incoming cash at that time, some 126 billion rubles ($1.2 billion).

A leaked A7 promissory note register reviewed by ICIJ reveals that A7's cash intake at PSB only rose in 2025, reaching 195 billion rubles ($2.3 billion) in a single month by April 2025, and 250 billion rubles ($3.1 billion) in June 2025. At its peak, A7 was processing at least 58 tons of cash per month.

PSB, which serves as a bank for all payments routed through the company inside Russia, typically has to give approval to process market payments made by A7, likely because of the size of this channel, according to a leaked A7 document seen by reporters.

It is unclear what checks, if any, A7 or the brokers at Sadovod and other markets perform on these funds.

“Sadovod is quite a chaotic place, I can't imagine [the brokers] do all the checks required – KYC, source of wealth, source of funds,” Voloshin continued.“They may check your passport. But where the money comes from, that's the biggest question.”

The problem of undeclared cash circulating at Moscow's wholesale markets has also been flagged by Russian financial authorities, including its Central Bank.

“Where do [cash] funds of unknown origin come from?” a senior Central Bank official asked during remarks at a banking conference in Moscow on Sept. 23.“I won't be revealing anything new here,” he said,“but primarily they come from wholesale and retail markets, mostly in Moscow, and illegal crypto exchanges.”

Sadovod did not respond to ICIJ requests for comment. There is no allegation of wrongdoing by the market.

One A7 payment register, dated late 2024, as well as other payment records, suggests that A7's market payments are mostly bound for China. Chinese exports to Russia have surged since the Kremlin's full-scale invasion of Ukraine, as Russia's industrial and consumer economy has searched for new inputs to replace Western goods.

The payment register showed approximately 2,300 proposed and in many cases documented transfers for different Sadovod brokerage teams – numbered one to six and called“otdely,” or“departments” – destined for their clients' suppliers, or further intermediaries, in Hong Kong and mainland China.

The person familiar with the markets payment business told ICIJ that the brokerage teams typically operate from offices close to the market administration offices.

These payments, the register shows, were routed predominantly through the bank accounts of a Kyrgyz state-owned company, the Trading Company of the Kyrgyz Republic, as well as several trading companies in Turkey and Hong Kong. The Kyrgyz Ministry of Economy acknowledged ICIJ's request for comment, but did not respond.