British payments specialist Michael Donald, who previously served on the board of Visa UK and worked at a number of major Western financial companies, has emerged at the center of an investigation into the Kyrgyz payment platform VexPay. According to documents obtained by the Financial Times, the platform was developed with the active involvement of representatives of the A7 network — a financial infrastructure created with the participation of Russia’s Promsvyazbank and fugitive Moldovan oligarch Ilan Shor, which the United States has linked to large-scale sanctions evasion.
At an August 12, 2025 meeting in Moscow, Shor introduced VexPay’s new management and named Donald as one of the platform’s executives. Donald confirmed to the Financial Times that he attended the meeting, but categorically denied that he had been an employee or director of VexPay or had agreed to head the company. According to Donald, he was advising Kyrgyz state-owned Processing KG on international payments, card acceptance, Apple Pay and engagement with Visa.
This discrepancy is central to assessing Donald’s role. The appearance of his name in A7 meeting records does not prove that he agreed to work for VexPay or that he was aware of any potential use of the platform to circumvent sanctions. At the same time, the confirmed presence of a British payments specialist at the Moscow meeting, and the nature of the consulting work he acknowledges, illustrate how the creation of alternative financial infrastructure depends not only on technology but also on Western expertise in Visa, international acquiring and digital payments.
VexPay May Be Part of A7’s Evolution Rather Than a Standalone Fintech Project
Formally, VexPay is linked to Kyrgyz state-owned Processing KG rather than A7. The Kyrgyz side denies any external control over the project. However, minutes, correspondence and other documents obtained by the Financial Times covering the period from March to August 2025 indicate substantially deeper involvement by A7 representatives.
According to those materials, Shor and A7 employees participated in discussions concerning VexPay’s structure, the opening of bank accounts, staffing, the location of call centers, legal arrangements and technical architecture. The project itself was presented to Kyrgyz officials as an alternative international payment channel capable of operating outside the traditional SWIFT infrastructure.
This makes it possible to view VexPay within the broader evolution of Russia’s adaptation to sanctions.
After Russian banks’ access to Western financial infrastructure was restricted, Moscow began building not a single alternative to SWIFT but a multilayered ecosystem combining banks, payment companies, crypto-assets, intermediary firms and third-country jurisdictions.
In such a system, shutting down or sanctioning one operator does not dismantle the entire network. Transactions can be rerouted through another company, bank, token or jurisdiction.
A7 Is Evolving into a Transnational Shadow Payment Infrastructure
On October 1, 2026, the U.S. Department of the Treasury took a significant step by designating the A7 Network as a significant transnational criminal organization.
According to the U.S. Treasury, A7 uses a network of intermediary companies in third countries that disguise transactions as ordinary trade payments. The bank accounts and web resources of such companies may in practice be controlled by A7 personnel, while access to financial accounts can be conducted through specially created VPN infrastructure that conceals the operators’ actual locations.
Of particular importance, the U.S. assessment extends well beyond Russian sanctions evasion. Washington has linked A7 to financial operations benefiting Iran, the Islamic Revolutionary Guard Corps and other sanctioned entities.
A7 therefore increasingly resembles not simply a Russian sanctions-evasion mechanism but an exportable financial infrastructure that could potentially be used by a range of sanctioned actors.
It is in this context that VexPay becomes particularly significant.
Kyrgyzstan Provides A7 with a Necessary Gateway
For Russia’s sanctions-evasion system, Kyrgyzstan offers several advantages: geographic proximity, substantial trade with Russia, the integration of post-Soviet financial systems and, at the same time, the ability of local banks and payment companies to interact with external financial infrastructure.
This makes it possible to construct a fundamentally different model from a direct payment originating from a sanctioned Russian bank.
A Russian client or entity can be separated from the international financial system by several layers of intermediaries: Russia → A7/affiliated operator → intermediary company → Kyrgyz payment infrastructure → local or foreign bank → international payment system → final counterparty.
The greater the number of layers, the more difficult it becomes for a correspondent bank to establish the original source of funds, the real party ordering the transaction and its underlying economic purpose.
This is why U.S. regulators are increasingly focusing not only on A7 itself but also on its sub-agents — companies that may formally appear independent of the Russian network.
Michael Donald’s Significance Lies Primarily in His Expertise
The available evidence does not support a conclusion that Donald knowingly helped A7 circumvent sanctions. His professional profile does, however, explain why the involvement of a specialist with his background could have been valuable to the project.
Donald has more than 30 years of experience in the payments industry, having worked at MBNA, Bank of America and other financial institutions, and served on the board of Visa UK. His own company, ImageNPay, specializes in digital payment products and virtual cards.
According to Donald, his consulting work for Processing KG concerned precisely the components that are critical to integrating a new payment operator into the international system: card acceptance, Visa, Apple Pay and international payments.
The principal value of a Western consultant to such a project therefore does not necessarily lie in formally managing the company. Potentially more important are knowledge of international payment-system rules, technical requirements, compliance procedures, acquiring, and the mechanisms for integrating a local fintech platform with global financial infrastructure.
ImageNPay’s Russia Links Predate VexPay
The fact that Donald and ImageNPay’s contacts with the Russian market did not begin in 2025 adds further significance to the case.
As early as 2020, ImageNPay participated in the Soft-Landing Programme of Russia’s Skolkovo innovation center. Donald publicly described Russia and the CIS countries as important future markets for the company and said it was using a team of Russian programmers.
Corporate records for the British company ImageNPay UK Limited also show that Dmitry Kuptsov owned 27.2% of the company in 2020. At the same time, the Russian origin or business connections of an individual shareholder do not in themselves constitute evidence that ImageNPay was controlled by Russian entities or participated in sanctions evasion.
The claim that ImageNPay served as a “cover for Russian capital” therefore requires a substantially stronger evidentiary basis.
The West’s Main Vulnerability Is Not SWIFT, but Access Points to the Global Financial System
The VexPay case indicates that the sanctions confrontation is gradually shifting.
Initially, the Western strategy focused on disconnecting Russian banks from SWIFT, blocking correspondent accounts and freezing assets.
Russia’s response has been to create alternative routes in which a sanctioned entity may not appear at all at the first layer of a transaction visible to a Western bank.
Instead of a direct route — Russian bank → SWIFT → Western bank — a more complex chain emerges: Russian client → shadow payment network → intermediary company → financial institution in a third country → fintech → international payment infrastructure.
The critical resource is therefore no longer SWIFT itself, but the ability to gain access to international acquiring, correspondent banks, Visa/Mastercard, digital wallets and other global payment interfaces.
Western Expertise May Be a Distinct Vulnerability in the Sanctions Regime
The VexPay case highlights another potential problem: Russia’s technological isolation can be partly offset by recruiting specialists who have spent years working inside Western financial infrastructure.
Their value lies not only in personal contacts.
They understand how payment systems are structured, which technical and compliance requirements must be met, how financial institutions are onboarded, how international acquiring works and which criteria banks and payment systems use to assess risk.
Regulators should therefore focus not on a consultant’s nationality or the mere fact of working in a third country, but on the nature of the services provided, the project’s ultimate beneficiary, its source of financing, and whether the expertise supplied enables sanctioned entities to regain access to prohibited financial services.
The Risk to Visa, Apple Pay and Western Banks Is Different in Nature
The argument concerning a direct risk of secondary sanctions also requires qualification.
The mere use of Visa, Mastercard or Apple Pay technologies does not mean that those companies are participating in a sanctions-evasion scheme. The risk arises when a payment operator, bank or fintech company fails to identify a concealed sanctioned participant or continues to service transactions after such a connection has been established.
A7 therefore creates, above all, an attribution problem.
When several formally independent companies are positioned between the Russian originator of a payment and a Western financial institution, identifying the transaction’s ultimate beneficiary becomes substantially more difficult.
The new U.S. pressure model is directed precisely at this problem: targeting not only A7’s core structure but also its international sub-agents.
Key Judgment
The VexPay case points to a qualitative evolution in Russia’s sanctions-evasion system. Moscow is no longer merely attempting to build its own isolated alternative to SWIFT. A more effective model is the construction of a distributed network that uses public and private entities in third countries as gateways to the global financial system.
In this model, A7 provides the financial flows and network of intermediaries; third-country jurisdictions provide the legal and banking shell; fintech platforms create the technological interface; and Western payments expertise can potentially help integrate this infrastructure with international services.
VexPay is an important case because it illustrates a possible transformation of sanctions evasion from a Russian “shadow banking system” into an international fintech architecture.
Michael Donald’s role, however, must be assessed separately from A7’s. The available documents confirm his presence at the Moscow meeting and his consulting work for Processing KG, but do not establish that he agreed to lead VexPay, controlled the platform or knowingly facilitated unlawful sanctions evasion.The distinction between confirmed professional involvement and unproven knowing participation in sanctions evasion is therefore critical to any legally robust assessment of the case.
