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 (568 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].

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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 trust if blocked if a single beneficiary thereof is blocked. Note that it is not clear whether the share to whcih the blocked nephew was entitled was equal to or exceeded 50%. It appears that the answer is "no".

Additionally, Kerimov’s nephew, Ruslan Gadzhiyevich Gadzhiyev, is a member of the designated State Duma of the Federal Assembly of the...