Enforcement Release: Gracetown, Inc.

Date issued: Dec. 04 2025

Last substantive commentary amendment:
Apr. 03 2026

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TURBOFAC Commentary (374 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) Read in conjunction with ENF 51231 (1) (Notable Notification of Third Party Blocking) (notification of third-party blocking served on Gracetown) and U.S. v. Graham Bonham Carter (Criminal Indictment, 2022 - SDNY) (2022 criminal indictment against an individual in connection with illegal payments through Gracetown).

2) Gracetown is a U.S. person holding company alleged to have owned by the SDN Oleg Deripaska up through a point prior to his designation, and afterward, “a relative and known associate of Deripaska”. OFAC alleges that “Gracetown received 24 payments on behalf of a company ultimately owned by a sanctioned Russian oligarch, Oleg...