In the United States, the private equity fund IPI Partners was fined $11.5 million for continuing to accept and manage investments from Russian oligarch Suleyman Kerimov after he was sanctioned by the U.S. Treasury Department, from the report by Office of Foreign Assets Control.
IPI Partners, which specializes in acquiring, developing, and operating data centers, agreed to a voluntary settlement of potential civil liability. The nominal investor in the fund was Definition Services, Inc. from the British Virgin Islands, which committed to investing $50 million. The company is owned by a family trust of Kerimov, established in 2017 in Delaware.
OFAC’s investigation showed that Kerimov retained a beneficial interest in the trust after being added to the sanctions list. The agency emphasized that IPI could not have been unaware that the investments came from a sanctioned individual: intermediaries involved in negotiations explicitly represented Kerimov’s interests, and a senior fund manager even met the oligarch in person at his estate in Nice.
"OFAC determined that IPI did not voluntarily self-disclose the Apparent Violations and that the Apparent Violations constitute a non-egregious case. Accordingly, under OFAC’s Economic Sanctions Enforcement Guidelines (“Enforcement Guidelines”), 31 C.F.R. Part 501, app. A., the base civil monetary penalty applicable in this matter equals the applicable schedule amount, which is $14,356,690"
The company, after consulting with lawyers, relied on the formal criterion that it did not have 50% ownership in the investor structure and continued accepting the investments. Between July 2018 and June 2022, IPI executed 51 transactions related to Kerimov’s property or beneficial interests.
