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Enforcement Release: December 2, 2025
IPI Partners, LLC Settles with OFAC for $11,485,352 Related to Apparent Violations of Ukraine-/Russia-Related Sanctions
IPI Partners, LLC (“IPI”), a Chicago-based private equity firm that specializes in buying, developing, and operating data centers, has agreed to pay $11,485,352 to OFAC to settle its potential civil liability for apparent violations of Ukraine-/Russia-related sanctions. In 2017 and 2018, IPI solicited and received investments from Russian oligarch Suleiman Kerimov through a series of legal structures, and continued to maintain those investments for four years after OFAC designated Kerimov on April 6, 2018.
This settlement amount reflects OFAC’s determination that IPI’s apparent violations were non-egregious and not voluntarily self-disclosed. More broadly, this enforcement action highlights the sanctions risks that U.S. capital markets participants, including those in the private equity industry, can face. It is critical for such actors to understand and manage...
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1) Read in conjunction with U.S. Treasury Blocks Over Billion in Suleiman Kerimov Trust (Press Release) (blocking of Heritage Trust and all entities owned by Heritage Trust) and Enforcement Release: GVA Capital (related civil penalty). The GVA Capital case and this case arise out of similar facts. In GVA Capital, the entity fined was an investment fund that “knowingly” accepted investments in which an SDN had an interest. IPI (a U.S. person) did likewise. As with GVA Capital, here there was a relationship established with the SDN-linked investor entities prior to the relevant designation, and a continued relationship and failure to block investments after the designation, where there was arguably some degree of “plausible deniability” concerning the blocked person’s ongoing interest in the investment, but not enough to satisfy OFAC. More specifically, in this case, which...