Enforcement Release: IPI Partners, LLC

Date issued: Dec. 03 2025

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TURBOFAC Commentary (1015 words)

Notes:

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...