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OFAC's enforcement framework distinguishes statutory listings (designating a person/entity to the SDN list, which is a perimeter-creating action) from enforcement-completion settlements, which price-discover the cost of willful violations of an existing perimeter. The GVA Capital action sits in the second category and resolves conduct under the Ukraine-/Russia- Related Sanctions Regulations (and the underlying IEEPA authority) plus violations of OFAC's Reporting, Procedures and Penalties Regulations (RPPR, 31 CFR Part 501).
designation, GVA Capital — an early-stage Silicon Valley VC firm — worked with Kerimov and his nephew to deploy $20 million of Kerimov's capital into a Delaware special-purpose vehicle that GVA established. The capital flowed via Prosperity Investments, L.P., a Guernsey- domiciled fund in which Kerimov held a property interest.
Capital received outside legal advice that any sale or transfer of the investment "could not directly or indirectly involve Kerimov." Notwithstanding that advice, GVA continued for approximately three years to provide management services and to pursue a liquidation of the investment, with knowledge of Kerimov's continuing property interest in Prosperity. Under OFAC's "any interest whatsoever" rule (Executive Order 13662 / IEEPA blocking regulations), Kerimov's retained interest causes the underlying property to be blocked, and any U.S. person dealing in that property without a licence violates the regulations.
in 2021. GVA initially certified its production complete after approximately 173 documents; following issuance of a Pre-Penalty Notice it ultimately produced approximately 1,300 additional documents — a delay of more than two years constituting the RPPR violation component.
| Component | Amount |
|---|---|
| Sanctions violations (IEEPA / RuHSR) | $214,000,000 |
| RPPR / subpoena non-compliance | $1,988,868 |
| Total | $215,988,868 |
OFAC determined the conduct egregious and not voluntarily self-disclosed, which under OFAC's Economic Sanctions Enforcement Guidelines drives the base penalty to the statutory maximum applicable to the underlying violations.
Severity is rated quantitatively because, like the November 2023 Binance settlement, the penalty itself contributes to the empirical ceiling for sanctions-violation civil penalties, and because the action establishes a new sectoral precedent:
Binance settlement, and the largest applied to a non-bank, non-fintech US registered investment-adviser-adjacent firm.
treat oligarch-linked asset management as egregious post-2018.
(taking office January 2025) — the case had been in pipeline under the prior administration but the maximum-penalty disposition under Trump 2.0 sets the early enforcement-priority signal.
investment-adviser firm — establishes that the VC sector is squarely within OFAC's perimeter and not afforded de facto leniency relative to banks or fintechs.
Severity is bounded at 4 (not 5) because the action does not create a new sanctions perimeter or designate new SDNs — it is enforcement-completion within existing programs. Severity 5 in this framework is reserved for perimeter-creating actions (statutory listings, sectoral blocking orders, new programs).
and other investment advisers will face elevated diligence expectations on LP / fund-of-funds beneficial ownership, particularly where pre-designation capital from sanctioned-jurisdiction-linked individuals has been deployed into US-domiciled SPVs. The "any interest whatsoever" rule is reinforced as the operative test.
2.0 a willingness to apply the per-violation statutory ceiling rather than negotiate to a fraction-of-base disposition; this changes the expected-value calculus in self-disclosure decisions for active matters.
component, while small relative to the headline figure, is the largest reporting-violation penalty in recent practice and signals that protracted subpoena production will draw a separate enforcement track rather than be subsumed into the underlying-violation analysis.
($968.6M) and the 2024 UK OFSI Apple Distribution penalty (£10.5M), the GVA action contributes a third anchor to the cross-jurisdictional enforcement-ceiling dataset used to calibrate compliance-cost expectations for financial intermediaries, fintechs, and now investment advisers.
theories, given the statutory-maximum and the firm's early-stage VC scale; an appeal would be the first contested OFAC penalty of this size to test OFAC's enforcement-guidelines methodology in court.
investment-adviser perimeter to private-equity or hedge-fund managers with similar pre-designation LP capital, or whether GVA proves to be an outlier driven by the specific Kerimov-Prosperity factual record.
— whether it remains blocked, is forfeited, or is licensed for divestment to a non-blocked counterparty.