The U.S. Treasury has delivered a sharp warning to financial firms facilitating sanctions evasion.
A $215,988,868 civil penalty has been levied against GVA Capital Ltd., a San Francisco-based venture capital firm, for violating U.S. sanctions tied to Russia and obstructing a federal investigation.
OFAC Targets GVA Capital in Landmark Sanctions Case
The Office of Foreign Assets Control (OFAC), part of the U.S. Department of the Treasury, announced on June 11, 2025, that it has imposed the maximum civil monetary penalty allowed under statute against GVA Capital Ltd.
The firm knowingly managed U.S.-based investments for Suleiman Kerimov, a Russian oligarch sanctioned in 2018, while being fully aware of his blocked status.
This action underscores the U.S. government’s heightened scrutiny of financial intermediaries that enable sanctioned individuals to access U.S. markets.
According to OFAC, GVA’s conduct was “egregious” and not voluntarily self-disclosed — two factors that significantly elevated the penalty.
Who Is Suleiman Kerimov?
Suleiman Kerimov, a Russian billionaire and former government official, was designated by OFAC in 2018 for his role in the Russian Federation.
Despite this designation, GVA Capital continued managing U.S. investments for him between 2018 and 2021 by working through his nephew, Nariman Gadzhiev, who served as a proxy.
OFAC’s investigation revealed that GVA’s executives even met Kerimov at his estate in France in 2016 to secure his approval for certain U.S. investments — well before formal sanctions were in place but indicating a long-standing financial relationship.
Breakdown of OFAC’s Findings
The U.S. Treasury’s enforcement division detailed multiple breaches during its investigation:
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GVA Capital continued handling shares in a U.S. company for Kerimov post-sanction, effectively dealing in blocked property.
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The firm failed to fully comply with an OFAC subpoena, delaying the investigation.
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Kerimov’s assets were held in Heritage Trust, a Delaware-based entity valued at over $1.3 billion in 2022.
Penalty Overview and Relevant Dates
| Detail | Information |
|---|---|
| Penalized Entity | GVA Capital Ltd. |
| Location | San Francisco, California |
| Sanction Violation Period | April 2018 – May 2021 |
| Individual Involved | Suleiman Kerimov |
| Proxy Used | Nariman Gadzhiev |
| Penalty Amount | $215,988,868 |
| Subpoena Compliance | Failed |
| Property Blocked by OFAC | Heritage Trust ($1.3 billion) |
This is one of the largest penalties ever issued under Russia-related sanctions.
The case serves as a warning to venture capital and private equity firms that their due diligence procedures must be thorough, ongoing, and responsive to changes in U.S. sanctions lists.
Enforcement and Industry Reactions
OFAC’s penalty notice emphasizes that gatekeepers to the U.S. financial system, including venture capital firms, bear the responsibility of preventing sanctions evasion.
GVA’s case illustrates how indirect financial dealings — including the use of proxies and trusts — still fall under OFAC’s jurisdiction.
“This enforcement action highlights the Treasury’s commitment to holding financial facilitators accountable,” the agency noted.
While no criminal charges have been publicly disclosed, OFAC’s decision has already drawn attention across the financial compliance sector, with experts calling it a “compliance wake-up call” for tech-focused investment managers.
Sanctions Compliance: Two Reminders for Firms
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Know Your Client (KYC): Relying on proxies does not eliminate responsibility under sanctions law.
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Respond Promptly to Subpoenas: Noncompliance adds severity to enforcement outcomes.
Bottom Line
The GVA Capital case sends a clear message: U.S. sanctions compliance is non-negotiable, and enforcement will extend to all corners of the financial ecosystem.
As the Treasury tightens regulatory controls, firms must stay vigilant, transparent, and responsive.
For more insights on financial compliance and sanctions enforcement trends, explore our ongoing coverage in the U.S. finance and regulatory section.
Sources: US Department of the Treasury and US Treasury Enforcement Release.
Prepared by Ivan Alexander Golden, Founder of THX News™, an independent news organization delivering timely insights from global official sources. Combines AI-analyzed research with human-edited accuracy and context.
