A private equity fund in Chicago entered into an $11.48 million Settlement for managing $50 million in investments tied to Russian oligarch Suleiman Kerimov long after he was sanctioned.
The firm did what many funds do: it vetted the entities, relied on clean records, and took into account the opinion of an outside adviser that there was no 50% ownership. In fact, the facts were impossible to ignore:
- The company from the British Virgin Islands, which invested 25 million in the fund, was ultimately connected with a Delaware trust created to hold the American assets of Suleiman Kerimov.
- Representatives openly introduced themselves as Kerimov's people.
- There was even a personal meeting with Kerimov himself at his estate in Nice, France.
Despite everything that is, the fund continued to issue capital calls, make distributions, and pay management fees long AFTER Kerimov became SDN.
OFAC's conclusion was simple: if you are dealing with proxies, intermediaries, or entities that hide the true owner, you are on the hook. Advice won't save you. Confirmations won't save you. A clean check will definitely not save you.
