Enforcement Release: GVA Capital Ltd.

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (1223 words)

Notes:

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) Note in addition that this is an extremely rare example of Enforcement Release that describes the issuance of a “Penalty Notice,” rather than a settlement agreement. The lack of a settlement agreement, the size of the penalty and the fact that is for the “statutory maximum”...

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Enforcement Release: GVA Capital Ltd.

TURBOFAC Commentary (1223 words)