Enforcement Release: GVA Capital Ltd.

Date issued: Jun. 12 2025

Last substantive commentary amendment:
Apr. 03 2026

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TURBOFAC Commentary (1343 words)

Notes:

[2026-04-04 update - read in light of OFAC's 2026 Sham Transactions Guidance. The below has not yet been updated to reflect the issuance of the Sham Transactions Guidance].

1) This enforcement action, one of the most substantial in terms of the size of the fine and the first issued to an investment management firm based on there being a sanctioned investor, arises out of facts partially described in U.S. Treasury Blocks Over Billion in Suleiman Kerimov Trust (Press Release) (a press release describing a blocking action but filed to OFAC’s “Enforcement” landing page). See comments thereto, and note that this is one of a small handful of enforcement actions described as targeting “gatekeepers” (compare Enforcement Release: Family International Realty LLC).

2.1) Note in addition that this is an extremely rare example of Enforcement Release that describes...