On October 23, Russia's deputy prime minister said three tankers were at sea, that supply contracts were being finalized, and that volumes would rise to 1 million tons in December and could reach 3 million a month. A week earlier, the United States had waived, by executive order, the duties Congress had required to punish Russia's energy customers. Within a week, the waiver became a contract.

Azura's cargo is about 40 minutes of American diesel demand; 3 million tons a month would be a fifth of it, and roughly four times what Russia exported in the third quarter. To deliver that, Russia must repair the refineries Ukraine has spent a year destroying, which Rosneft now says it cannot afford. The contract's first effect is to give Washington an interest in Russian refineries running, even as Ukraine's president says the interceptors it has already paid for "are still not coming."

Diesel is one of four things the arsenal took this autumn from parties it does not control. The second is magnets: China exported 6,165 tons in September, its largest month this year, and they are the magnets in the motors of the drones the new Autonomous Warfare Command is to buy by the hundreds of thousands; Beijing's pause on its licensing rules lapses on November 10, with no notice published. The third is a room: the President said on October 19 that he would meet Vladimir Putin and Xi Jinping in China next month, after the Wall Street Journal reported that Putin had proposed a three-way meeting in Shenzhen to settle the war in Ukraine, without Ukraine. The fourth is money: on October 21, the Treasury sold 20-year bonds at a record 5.469 percent with foreign demand well below its average, and the 10-year fell below 5 percent the next day only because investors fled artificial-intelligence debt for the government's.

The one adversary with nothing to sell was squeezed: a third carrier group was ordered toward Iran on October 21, and Brent settled Friday at $116.72, its highest since April, which raised the price of everything the arsenal buys from the adversaries that do sell.

A sanction is the instrument of the party that sells. This autumn, the United States is the party that needs, and each supplier holds a date on which it can change the terms: October 31, when Russia's own fuel-export ban lapses; November 10 for Beijing's licenses; early November for the Treasury's refunding; November 18 for the summit. In economic warfare, the buyer takes the terms.

I write this from the Cipher Brief's Threat Conference at Sea Island, where General Bryan Fenton and I addressed the question of what the Department of War has to do with economic warfare. The week answered it before we spoke: the Department is now, by available reports, a customer of one adversary's refineries, a buyer of another's magnets, the holder of an ally's interceptors, and the owner of the carriers that set the price of oil. No office weighed those instruments against one another; the suppliers did.

For nine weeks in these pages, I have written about what the United States cannot do, from the army it cannot command to the day it cannot choose, and each piece ended at the same place: a decision no one was assigned to make. The diagnosis is complete, and the series turns here from what we cannot do to what we must. The place to start is the Autonomous Warfare Command: its plan is due on October 30, and it will be the government's largest buyer of the parts this piece is about.

Three things must be in that plan, and none of them is money.

First, the authority to decide. The Secretary's memorandum settles who buys. It has not settled who decides: one command-and-control architecture across every Service and domain, including space; who allocates among theaters when two ask for the same drones on the same day; who overrides at tempo; and whether the answer binds the Services. Congress granted those authorities to Special Operations Command in 1986, with its own budget line and acquisition power. The plan should name the same for this command, and add the paragraph Congress left out in 1986: command and control.

Second, the edge. Ukraine computes on the aircraft; we compute in Virginia and wait, and the Pacific cannot fight on a round trip. The plan must put the computing on the platform and the communications on a layer the force controls, so that no one else sets its speed.

Third, supply before the ban. The command's motors turn on Chinese magnets until American plants deliver, and the Pentagon's own ban takes effect on January 1. A Defense Production Act priority rating and a drawdown from the National Defense Stockpile, issued before November 10, stock what we need before we forbid what we depend on. The same plan is the demand signal industry has asked for: an architecture and a date.

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The Cipher Brief is committed to publishing a range of perspectives on national security issues submitted by deeply experienced national security professionals. Opinions expressed are those of the author and do not represent the views or opinions of The Cipher Brief.

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On the morning of October 23, the cargo ship Khoryv sent a distress call 13 nautical miles off Constanța, Romania. Territorial waters end at twelve. Whoever flew the drone that sank her knew where the line was, and chose to stand one mile outside it.

That mile is the story. It is the difference between an attack on a NATO member and an incident in a NATO member's exclusive economic zone. It is the difference between Article 5 and a press release. The London insurance market understood this before most capitals did. When the Joint War Committee extended its Black Sea listed area on September 16, it covered the entire sea except the territorial waters of Bulgaria, Georgia, Romania and Turkey. The underwriters drew the same line the drone operators did. Nobody should find that comforting.

This is what gray zone conflict looks like. Freighters burning off the coasts of two NATO allies, sailors lost in cold water, and attacks clustered around the Sulina Channel, which became the main outlet for Ukrainian grain after Russia hammered Ukraine's own ports. It is war at a time and place of the attacker's choosing, priced just below the point where anyone is obliged to do anything about it.

"The problem is that we cannot prove it"

Bulgaria's prime minister, Rumen Radev, is nobody's idea of a Russia hawk. He told his parliament the logic of the attacks points to Moscow, and then said the quiet part out loud: "The problem is that we cannot prove it."

NATO's response has been built to solve Radev's problem. After the North Atlantic Council met on October 20, the Alliance announced it would send maritime patrol aircraft, radar, drones, intelligence personnel and forensic teams to examine the explosives. A U.S. Navy P-8 Poseidon is already flying the Black Sea. These are sensible deployments. They are also answers to the wrong question.

Play the scenario out. Grant NATO perfect attribution. The forensic teams recover a guidance board with Russian markings. The P-8 tracks a launch back to a known site. The Alliance announces, with high confidence, that the Russian Federation sank the ship. Now make it worse: the next drone hits a tanker alongside the pier at Constanța, the fire spreads, and thousands of civilians are dead.

The Kremlin denies it. Within the hour, Russian state media points at Kyiv, and it doesn't have to work hard to sell the story. Ukraine has been running its own maritime drone campaign since July, so the Black Sea is full of Ukrainian drones, and everyone knows it. A few Western commentators find the denial "plausible enough to warrant caution." Allies invoke Article 4 and consult. Statements are issued. Sanctions, already near their ceiling, are tightened at the margins. Then nothing happens, because every capital in the room is doing the same arithmetic: Russia has nuclear weapons, the Black Sea is not worth a war, and the dead are already dead.

You don't have to imagine that sequence. We ran it on July 17, 2014, when a Buk missile destroyed Malaysia Airlines Flight 17 over eastern Ukraine and killed everyone aboard. A Dutch-led investigation established in 2016 that the launcher had been delivered from Russia, and by 2018 that it came from a Russian army unit. The ICAO Council found Russia responsible in May 2025. The European Court of Human Rights did the same that July. Moscow denied all of it, spent years promoting theories that blamed Ukraine, and in 2022 invaded the country the missile had been fired over. Attribution was as good as attribution gets. The consequence, eleven years later, was an order to enter into good-faith negotiations on reparations.

That is the lesson Moscow took from MH17, and it is the one we refuse to learn. Deniability is not a shield for the attacker. It is a gift to the defender who would rather not act. Russia doesn't need us to believe its denials. It only needs us to want to.

Operational freedom is the target

The point of these strikes isn't the ships. It's the water around them. Every hull that burns off Sulina raises the premium on the next one, pushes a charterer toward a different route, and teaches a shipowner that a NATO coastline offers no protection. The attacker never has to declare a blockade. The market imposes it for him. Freedom of action shrinks by increments, each too small to justify a response, until the defender wakes up to find that the sea he was sure he controlled has a new landlord.

This is how Russia and China will impose costs on the West for the foreseeable future. Not with the decisive battle our doctrine, our budgets, and our military exercises are built around, but with a steady accumulation of incidents chosen for their deniability, timed to our distractions, and calibrated to our fear of escalation. Salami slicing is not a new idea; Beijing has practiced it in the South China Sea for more than a decade. What's new is the drone, which makes the slicing cheap, precise and anonymous.

The honest complication

The Black Sea gray zone is not one-sided, and pretending otherwise hands Moscow its talking points. Ukraine's Operation Molochka, launched in July, claims to have disabled 300 Russian-linked vessels in the Black and Azov Seas. Turkey's foreign minister says both sides are mounting heavy attacks to establish superiority before winter.

The distinction holds. Ukraine is striking the logistics of the country that invaded it, mostly sanctioned tankers serving Russian ports and occupied Crimea. Russia is striking grain ships in the economic zones of two NATO members that are not party to the war, with the apparent aim of making Ukraine's last reliable export route uninsurable. One is a belligerent waging war at sea. The other is exporting that war to the Alliance's doorstep and daring it to notice.

Taiwan won't look like Hellscape

If you want to know what a Taiwan conflict will look like, watch the Black Sea.

In 2024, Adm. Samuel Paparo said he wanted to "turn the Taiwan Strait into an unmanned hellscape" to defeat what he described as Beijing's likely plan: a massive attack with little warning. It's a sound concept, and the CNAS work that fleshed it out this year is serious. Hellscape is built to break an amphibious assault at the water's edge.

Beijing is rehearsing something else. The PLA's Justice Mission 2025 drills in December, run alongside the China Coast Guard, simulated a blockade of Taiwan's main ports and control of the waterways that carry its energy imports. This year the China Coast Guard and Maritime Safety Administration have run what the Jamestown Foundation calls a "quasi-quarantine" east of the island, creating the appearance of administrative control without declaring a blockade. Taiwan has already prosecuted a Chinese captain for severing an undersea cable. Each step is a law enforcement action, an inspection, an accident. None of them is an invasion.

A drone swarm waiting in the Strait for a landing force has nothing to shoot at when the adversary is a coast guard cutter boarding a container ship for a "safety inspection." The first Taiwanese or American drone to fire makes Taipei the aggressor. So Beijing won't cross the Strait. It will tighten the noose: a quarantine, a severed cable, an insurance listing, a shipping line that quietly decides Kaohsiung isn't worth the premium. It will bank on the world's risk aversion. It’s already working. After the May summit in Beijing, Washington paused a record $14 billion arms package for Taiwan, and the President described those sales as a "very good negotiating chip". Taiwan will not be conquered. It will be persuaded, one closed option at a time, that there is nothing left to defend.

Answering below the threshold

You cannot deter gray zone coercion with a capability designed for the war the adversary is careful never to start. The answer has to live in the same band the attacker does: below the threshold of general war, above the threshold of pain. Three steps would help in the Black Sea, and each has a Pacific twin.

Presence that denies, not presence that watches. Turkey, Romania and Bulgaria already run a Mine Countermeasures Task Group whose mandate was widened in July to cover undersea infrastructure. Montreux restricts warships of non-Black Sea states, not the littoral navies. Widen the mandate once more, to counter-drone escort of merchant traffic through allied economic zones, and buy the equipment from the Ukrainians who have kept their own grain corridor open under fire. In the Pacific, the equivalent is a convoy and escort plan for a quarantine, not only a kill chain for an invasion.

Decide the response before the incident. The moment of decision is where risk aversion wins, because it is always easier to wait for one more forensic report. Allies should agree in advance, and say publicly, what a verified strike on shipping in their waters will cost Moscow: a pre-approved tranche of capability released to Ukraine, a pre-agreed number of shadow fleet hulls detained. Attribution should trigger an equivalent consequence, not another discussion. Taipei and Washington need the same menu for a quarantine, written now, while no one is under pressure.

Take the market off the adversary's side. When insurers and charterers do the attacker's work, governments need a sovereign war-risk backstop for vessels trading to allied ports, so the next listed-area extension doesn't function as a blockade by spreadsheet. Taiwan will need that backstop on the first day of a quarantine, not the ninetieth.

None of this is escalation. It is the minimum required to make the gray zone cost something.

The Thirteenth Mile

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The Cipher Brief is committed to publishing a range of perspectives on national security issues submitted by deeply experienced national security professionals. Opinions expressed are those of the author and do not represent the views or opinions of The Cipher Brief.

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Economic statecraft has become a primary instrument of US national security, deployed with a frequency and ambition that outpaces the intelligence architecture built to support it. For sanctions, tariffs, investment screening, export controls, and development finance to succeed, the United States must fully leverage the data and intelligence available to it. Now is the time for the IC to organize itself around the discipline of economic and financial intelligence.

The IC has long struggled to prove its value to economic customers: the Secretaries of Treasury, Commerce, Defense, and State, as well as the US Trade Representative and financial regulators. One frequent explanation is the IC’s historic orientation toward military and diplomatic support. Another is the perception that classified economic analysis lacks distinctive value. I spent most of a twenty-three-year intelligence career inside the economic discipline, ultimately leading Treasury’s Office of Intelligence and Analysis (OIA). While this may once have been true, the IC is doing better than ever to meet growing demand.

The problem is no longer the quality of the analysis—which has matured immensely—but the IC’s decentralized approach to serving its economic customers. No IC agency is specifically responsible for the discipline of economic and financial intelligence. The closest is OIA.

Congress created OIA in statute in 2004 with an eye toward sanctions support and countering terrorism finance. Its role has since expanded across economic, financial, and cyber issues for customers across government and industry. However, OIA is not the designated IC lead for US economic statecraft—no IC agency is. One consequence is that the Office of the Director of National Intelligence (ODNI) remains the statutory lead for analytic support to the Treasury-led Committee on Foreign Investment in the United States (CFIUS). That made sense in 2007, when the Foreign Investment and National Security Act codified CFIUS and assigned the Director of National Intelligence that role. At the time, OIA was in its infancy and consumed by counterterrorism. That is no longer the case.

The instinct in Washington is to solve a challenge like this by first creating a new organization, then fixing the functions. Congress should start with the functions instead, then address where the discipline sits. To improve IC support to economic statecraft, Congress must first act on six fronts.

Designate a functional manager. One IC element must own economic and financial intelligence as a discipline: collection priorities, analytic standards, a hiring and training pipeline, and a framework for systematic engagement with allies and industry. Nothing about that role requires a new agency.

Clarify authorities. Explicitly authorize collaboration between the designated lead and both its government customers and the private sector, including exchange of expertise and data.

Supercharge private sector engagement. Many of the best national security solutions in economics and finance will come from industry. Create a permanent path for its ideas, expertise, and capabilities.

Work with what exists. Use OIA as the foundation and keep the number of IC agencies flat, but cap its size so it stays nimble as economic statecraft evolves.

Revisit ODNI’s CFIUS role. IC support to CFIUS sits with ODNI because in 2007 no one else could carry it. Whether it should move depends on where the discipline lands, but Congress should not view the 2007 answer as permanent.

Fund it as a national mission. Economic intelligence should not have to compete for a share of a domestic department’s topline. Give the discipline a dedicated budget line, with the investment in people and AI that exploiting economic data at scale requires.

That leaves where the discipline sits—and there are three answers, not one.

The easiest first step is a designation: name OIA the functional manager, leave it in Treasury, and make clear in statute and to policy customers that OIA is the center of gravity for economic and financial intelligence. That is available now and beats the status quo. Nevertheless, an IC office answering to the Secretary of the Treasury will always be seen—correctly—as Treasury’s first. This is why Commerce and others periodically press for shops of their own, an outcome that grows the IC rather than optimizing it.

The achievable reform is bureau status. Treasury did this with FinCEN in 2002, and FinCEN is now treated as a government-wide and international resource rather than Treasury’s alone. Done properly it means a separate appropriation, a director accountable to both the Secretary and the DNI, and a statutory mission naming service to the whole government, the private sector, and our allies.

The stretch option is to elevate OIA to become an independent National Geo-Economic Intelligence Agency—still my own preference, because only independence settles the question of whose intelligence office it is. But where the discipline sits is the last decision, not the first. Under any of the three, the proximity OIA has built with Treasury policymakers is a design problem with a known solution: dedicated, co-located teams at each major customer department.

Economic intelligence is a core national security capability and should be organized and resourced like one: purpose-built to track, anticipate, and disrupt adversary financial and commercial threats in real time. The playbook has changed. Our competitors are more agile, emboldened, and shaping markets and supply chains to their advantage while we debate whether the threat qualifies as strategic.

All statements of fact, opinion, or analysis expressed are those of the author and do not reflect the official positions or views of the U.S. Government. Nothing in the contents should be construed as asserting or implying U.S. Government authentication of information or endorsement of the author's views.

The Cipher Brief is committed to publishing a range of perspectives on national security issues submitted by deeply experienced national security professionals. Opinions expressed are those of the author and do not represent the views or opinions of The Cipher Brief.

Have a perspective to share based on your experience in the national security field? Send it to Editor@thecipherbrief.com for publication consideration.

Read more expert-driven national security insights, perspective and analysis in The Cipher Brief

Over the last century, modern medicine achieved a historic feat. We increased the human lifespan by 33%. But at the same time, we completely failed to defend our brain healthspan. Today, a silent gap of 15 to 30 years exists between the time our bodies survive and the time our brains remain vibrant, innovative, and fully functional. It is a terrifying paradox. Medical science has advanced so much that a newborn today can realistically expect to live to 100, if not 120 years old. Yet, we passively accept that their cognitive engine will begin an irreversible, downhill slide in their thirties with the likelihood of dementia reaching almost 100% by the age of 110. What good is an extra three decades of biological existence if our brains lack the strength and resilience to enjoy it? This is no longer just a localized healthcare crisis; it is an imminent national security threat to our competitive edge.

Look at where our national focus and funding are directed. America is focused on investing billions of dollars into artificial intelligence and hypersonic defense systems. However, we are systematically ignoring the ultimate computing engine that builds the technology, commands our military, drives our economy, and stabilizes our communities: the human brain.

Our global competitors are not making this mistake. Most notably, China understands that future geopolitical dominance will not be won simply by hoarding raw technology. It will be won by the cognitive longevity, relentless innovation, and emotional resilience of their population. They are playing the long game and investing in their brain economy; We are falling behind.

In the military, we use a concept called staying "left of boom." It means executing proactive, aggressive conditioning and preventative strategies to stop a catastrophe before it happens, rather than digging through the wreckage after an explosion.

Right now, America’s approach to brain health is reactive. Our public policy treats brain aging as an inevitable, downhill slide into deficit. We pour billions of dollars into solving brain health collapse, like dementia and visible cognitive breakdown, before we actively intervene. But that approach is a losing strategy. We must shift from a reactive, disease-focused model to a proactive era of precision brain health in order to finally maximize American brainpower. If we do not actively optimize our collective intelligence and mental endurance, we will fall behind not only in defense readiness but also in scientific advancement and workforce productivity.

Fortunately, building a sharper, more resilient nation has never been easier or more measurable.

A landmark, three-year longitudinal study of 4,000 adults recently published in Nature Portfolio’s Scientific Reports completely dismantles the myth of inevitable cognitive decline. The data proves that the human brain possesses a no-ceiling capability. From ages 19 to 94, the brain retains a profound capacity to continually rewire, adapt, and improve its performance over time.

The key to unlocking this potential is a newly validated, multidimensional metric called the BrainHealth Index. For the first time, we can treat the brain exactly like physical fitness. We don't guess if our hearts are healthy; we measure blood pressure. The BrainHealth Index finally gives us a credible benchmark to track and measure holistic brain improvement across three critical pillars:

• Clarity: Our raw capacity to solve complex, novel problems and drive deep technological innovation.
• Connectedness: Our capacity for social purpose and communication, which serves as the bedrock for stable families and strong communities.
• Emotional Balance: The mental resilience required to perform under extreme pressure, from corporate boardrooms to tactical defense environments.

When we actively invest in and train our cognitive micro-skills, the positive implications ripple across society. Every day, citizens become better in their personal relationships, more productive at their jobs, and significantly more resilient against modern burnout and life stressors. Scaled nationally, this collective mental fitness becomes the invisible armor required for our national defense and technological endurance.

As a neurologist, a retired U.S. Army Colonel, and the former founding director of DARPA’s Biological Technologies Office, I have spent my entire career protecting and restoring the brains of our service members. I know what the human mind is capable of achieving when it is pushed to optimize, rather than just manage decline.

Our federal agencies, including the Department of Health and Human Services, the NIH, and the Department of Veterans Affairs, must immediately work to adopt scalable, digital health initiatives that democratize these brain optimization tools nationwide. But executive action is only half the battle. Congress must step up and introduce a unified, bipartisan National Brain Capital Act. Just as lawmakers realized we could not secure our future without a CHIPS and Science Act to defend our artificial intelligence hardware, they must recognize that we cannot protect our nation without a legislative framework to maximize our human brainpower. We must empower every single citizen with the self-agency to improve their own cognitive capacity. It is time for Congress to stop treating brain performance as a passive medical luxury for the few. It is a national imperative to keep America leading the world.

The Cipher Brief is committed to publishing a range of perspectives on national security issues submitted by deeply experienced national security professionals. Opinions expressed are those of the author and do not represent the views or opinions of The Cipher Brief.

Have a perspective to share based on your experience in the national security field? Send it to Editor@thecipherbrief.com for publication consideration.

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A7’s OpenAI prompt was six words long: "Translate [name] to [language]. Answer only translated text."

Developer code leaked in 2025 from A7—the Kremlin-linked payment network designated by Treasury on October 1 as “a significant transnational criminal organization”—shows A7 used this prompt with OpenAI's API to create fake invoices, fake stamps, and a complex ledger that made Russian procurement look like ordinary trade.

Our investigative work, as featured originally in the “Big Shor” investigation and in subsequently featured in the New York Times and Financial Times, reveals that between January 2025 and June 2026, A7 laundered over $80 billion through the international financial system and continues to do so today. Zach was the principal researcher and Dawson peer reviewed the report and mentored the research team.

The common story is that sanctions cut Russia off from SWIFT and dollar clearing. In reality, Russia never left the Western financial system; A7 is how it re-entered at state scale. It still needs dollars and euros to buy components, sell oil, and pay intermediaries; China’s CIPS, yuan, crypto, and barter cannot replace them.

How the scheme works

A7 acts for Promsvyazbank, the state bank serving Russia's defense sector. A7 has laundered over $80 billion through roughly 435 financial institutions in at least 83 countries, funding Russia’s war in Ukraine, intelligence operations, election interference, and trade. Its clients have included Iranian oil sellers, which is why Treasury rolled the designation into Operation Economic Outcast.

A7’s shell companies, often run from Russia over VPNs, open accounts at local banks in Bishkek or Dubai’s free trade zones. Those banks rely on larger regional banks, which clear dollars through correspondents in New York or Hong Kong. Each sees only the customer in front of it. Card programs issued under sponsor banks give front companies and Russians access to payment rails without a direct banking relationship.

Fundamental to the scheme were fake invoices, produced at scale using OpenAI’s ChatGPT. A7 also used ChatGPT to forge stamps and automate intake of SWIFT payment confirmations from scanned receipts. Because A7 broke the operation into steps that each looked legitimate, OpenAI’s screening was unlikely to flag it—a gap AI companies must close.

This is where the burden falls on banks, and where the anti-money laundering (AML) framework fails. It was built to catch criminals hiding proceeds, not a state-backed service with intelligence-grade tradecraft. A7’s disposable shell companies are replaced faster than any sanctions list can be updated. To Western correspondent banks, its flows look like normal bilateral trade.

Banks can catch A7 only by tracking behavior over time: new free-zone trading companies moving outsized volumes, product descriptions that do not match the counterparty, and payment routes with no commercial logic. However, banks can only go so far on their own.

The deeper problem is permissive jurisdictions—UAE free zones, Hong Kong, Kyrgyzstan, and Türkiye—that offer fast incorporation, light ownership checks, and access to dollars and euros. Intermediating Russian trade is profitable, and many of these governments frame it as “neutrality” rather than evasion. In Kyrgyzstan, A7 relied on relationships reaching the highest levels of government and the banking sector.

The Macro Threat: Sanctions, SWIFT, and China

As former U.S. Treasury and intelligence officials, we see A7 as a sobering reminder that the first wave of financial sanctions on Russia fell short. The international banking system remains the indispensable engine of Russia’s war effort.

This exposes a broader geopolitical failure: adversary coordination. Russia, Iran, the DPRK, and China increasingly share intermediaries and methods to exploit Western finance rather than build their own. Yet the allied response remains fragmented, targeting networks like A7 one at a time.

This forces hard choices about dollar access. Washington could strip correspondent access from the Chinese and regional banks moving billions for U.S. adversaries. That might disrupt A7, but it raises the question of whether weaponizing dollar access compels compliance or accelerates Beijing and Moscow's push for a closed-loop financial system.

Changing the Equation: Government Actions

Allied governments must close systemic loopholes. Diplomacy with third countries has largely run its course; the leverage now lies in their banks’ access to Western finance. Tools like FinCEN’s Section 311 can force regional banks to choose between servicing networks like A7 and keeping their Western correspondent accounts. Regulators must treat nested correspondent relationships (banks clearing payments for other banks’ customers) and sponsored credit card programs (cards issued by smaller banks and fintechs under a bank’s license) as direct compliance liabilities.

Exams that test only static list-screening teach banks to build to that baseline. Exams should require network analysis, and governments should help scale these costly tools for vulnerable institutions in developing countries. This must be paired with mandatory information sharing: secure channels for client exit data and real-time international exchange of typologies.

Finally, authorities must treat AI and cloud infrastructure with the same scrutiny as traditional finance. Finalizing know-your-customer rules for cloud providers and requiring AI companies to flag behavioral anomalies would deny illicit actors the cheap infrastructure they need to scale.

A7 still moves billions every month. A week after Treasury acted, A7 announced a stablecoin USDT-SWIFT product; the timing was not a coincidence. Even if A7 is degraded, its model is highly portable, and Iran and North Korea are watching. The question for Washington, London, and Brussels is whether they can help industry disrupt these networks through a compliance culture that prioritizes real impact over list-based box-checking.

The Cipher Brief is committed to publishing a range of perspectives on national security issues submitted by deeply experienced national security professionals. Opinions expressed are those of the author and do not represent the views or opinions of The Cipher Brief.

Have a perspective to share based on your experience in the national security field? Send it to Editor@thecipherbrief.com for publication consideration.

Read more expert-driven national security insights, perspective and analysis in The Cipher Brief