Leaked documents reportedly show that US-designated network A7 listed FCA-registered UK fintech Wooshpay as a route for making payments.
Documents from a leak of A7 records show that the Kremlin-backed money laundering network named Wooshpay, a UK fintech registered with the Financial Conduct Authority (FCA) as a small payment institution and incorporated as Swooshtransfer, on a list of entities it could use to make payments. One document indicates that A7 sought to create a cover story for the relationship by forging an invoice suggesting Wooshpay supplied it with ‘cashmere sewing fabric’. The US Treasury recently designated A7 as a transnational criminal organisation, following reports that it had moved USD 6.9 billion through conventional banks using hundreds of front companies and a large-scale document forgery operation. The network’s core purpose is to allow Russian importers to make payments abroad despite the financial sanctions imposed on Russia after the full-scale invasion of Ukraine.
The payment route
An internal A7 note prepared for staff 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. While many of A7’s front companies were controlled by the network, the note referred to Wooshpay as a ‘rented’ treasury, implying it was an independent business that carried out work for the network alongside other activities. The document set conditions for this route, including a limit of USD 50,000 in payments per day and a requirement for a customs declaration containing no Russian-language text.
The one payment identified on this route, a transfer of about USD 26,000, was recorded by A7 with a reference number indicating that Wooshpay was making onward payments for the network rather than simply receiving funds. 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. Wooshpay’s website presents the company as a provider of payment products and subscription billing tools for AI companies.
Compliance obligations and the Chinese bank link
FCA registration requires Wooshpay not only to identify and verify customers and their beneficial owners, but also to understand the purpose of each relationship and monitor transactions. The case draws attention to the due diligence obligations that apply to small payment institutions, and to how such firms may be used as payment routes by sanctions evasion networks.
The recorded payment was sent to an account at Zhejiang Chouzhou Commercial Bank. According to banking counterparty intelligence company BankCheck, the lender ranks 98th among Chinese banks by balance sheet, yet ranks fourth among Chinese banks by volume in the A7 data, with its customers receiving about USD 170 million from A7 between late 2024 and August 2025. In total, 268 entities in the leaked documents held accounts at the bank, 120 of them non-resident accounts. Wooshpay was one of four UK-domiciled entities with accounts there, 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.
