U.S. Treasury Blocks Over $1 Billion in Suleiman Kerimov Trust (Press Release)

Date issued: Jun. 30 2022

Last substantive commentary amendment:
Apr. 03 2026

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TURBOFAC Commentary (643 words)

Notes:

[6-12-25 update - see Enforcement Release: GVA Capital, and comments thereto (enforcement action arising out of the facts described in this Press Release)]

[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].

[2026 update - reporting by Bloomberg indicates that Kerimov's continued interest in the Trust was the product of a setup whereby "Kerimov’s mother was the grantor and could distribute the trust’s funds to any of her descendants unless they were explicitly barred from receiving them" (and Kerimov was not barred from receiving the trust's funds). See https://www.bloomberg.com/news/articles/2025-08-11/citi-oversaw-1-billion-for-trust-us-tied-to-sanctioned-oligarch?embedded-checkout=true].

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1) OFAC rarely issues press releases that break ground as it relates to the scope of prohibitions, but the following sentence appears to confirm that the entirety of a...