Sanctions Evasion Reference

Gracetown: payments for a designated oligarch's former company

OFAC fined a New York property manager $7.1m in 2025 for taking 24 payments on behalf of a company owned by Oleg Deripaska after his designation, and for not reporting the blocked debt for over 45 months.

period

2013–2025

outcome

Civil penalty

parties

Gracetown, Inc.; Baufinanz

programmes

Russian Federation

reviewed

2026-09-20

Cite this page
APA 7
Sanctions Evasion Reference. (2026, September 20). Gracetown: payments for a designated oligarch's former company. https://sanctionsevasion.org/cases/gracetown-deripaska-2025/
Chicago
Sanctions Evasion Reference. “Gracetown: payments for a designated oligarch's former company.” Last reviewed September 20, 2026. https://sanctionsevasion.org/cases/gracetown-deripaska-2025/.
BibTeX
@misc{ser-cases-gracetown-deripaska-2025,
  author = {{Sanctions Evasion Reference}},
  title  = {Gracetown: payments for a designated oligarch's former company},
  year   = {2026},
  note   = {Last reviewed 2026-09-20},
  url    = {https://sanctionsevasion.org/cases/gracetown-deripaska-2025/}
}

The date is when this page was last reviewed, not when it was first published.

Penalties imposed

AuthorityDate AmountNote
OFAC 2025-12-04 $7,139,305 Penalty notice (not a settlement) for violations of the Ukraine-/Russia-related regulations and a reporting failure. Egregious; not voluntarily self-disclosed. Base and statutory maximum $8,906,358.

A case about ownership that changed hands a few weeks before a designation.

What happened

Gracetown was set up in 2006 to manage three luxury properties in New York and Washington, D.C. that Oleg Deripaska bought through various vehicles. OFAC says Deripaska was Gracetown’s ultimate beneficial owner from 2006 to 2018, and that shortly before his designation a relative and known associate of his became the ultimate beneficial owner. The company relied on funds and direction from Russia-based stakeholders, and a New York property manager ran its bank accounts on their instructions.

In 2013, a British Virgin Islands company also owned by Deripaska settled a loan dispute with a US person. The settlement had monthly payments go to Gracetown, which booked them as a loan from the BVI company and used them for property costs.

After the designation

OFAC designated Deripaska on 6 April 2018 and sent Gracetown a notification of blocking, received on 10 April 2018, that said dealings with him and his property were unlawful and that it had to block and report property in which he had an interest. Gracetown kept taking the monthly payments until May 2020: 24 more payments, totalling $31,250, on top of $72,500 already received and spent. It first reported the blocked debt of $103,750 on 11 January 2022, more than 45 months after the notice, and by then OFAC or another agency already knew of the conduct.

The penalty

OFAC found the violations egregious and not voluntarily self-disclosed, so the base was the statutory maximum, $8,906,358. The penalty was $7,139,305. It found Gracetown willfully or at least recklessly violated sanctions, and noted that the same property manager had handled every payment from 2013 to 2020 on the new owner’s instructions. It credited a tolling agreement and no earlier penalty, but said no further reduction was warranted.

What the record shows

  • A change of owner did not end the exposure. OFAC’s compliance point: entities formerly owned by a blocked person, or that continue to work closely within the network of one, “are taking substantial risk”.
  • An explicit notice changes the analysis. The release stresses that Gracetown had been told in writing.

See ownership threshold structuring, the same pattern in another case, and the 50 percent rule.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • Russia sanctions — Measures imposed from 2014 and greatly expanded from 2022, combining designations, sectoral restrictions, export controls and a price cap on seaborne oil.

Enforcement documents and sources

  1. Enforcement release: OFAC Imposes $7,139,305 Penalty on Gracetown, Inc.. U.S. Department of the Treasury, Office of Foreign Assets Control, 2025. Enforcement release, 2025-12-04, US$7,139,305.
  2. Economic Sanctions Enforcement Guidelines, Appendix A to 31 CFR Part 501. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026. Sections I (definitions), II (responses), III (general factors), V.B (penalty calculation).

All enforcement cases