The clearest published statement of what a proxy arrangement looks like from the outside, and one of the rare cases resolved by a Penalty Notice at the statutory maximum rather than by settlement.
What happened
OFAC’s enforcement release records that between April 2018 and May 2021, GVA Capital — a venture capital firm based in San Francisco — “knowingly managed an investment for sanctioned Russian oligarch Suleiman Kerimov while aware of his blocked status.”
The relationship predated the designation. In 2016, GVA Capital officials met Kerimov at his estate in France “to secure his personal approval for the investments.” OFAC designated Kerimov in April 2018.
GVA Capital “nonetheless continued managing these investments by working through Kerimov’s nephew, Nariman Gadzhiev, who GVA Capital knew served as Kerimov’s proxy.”
The proxy, stated plainly
That sentence is the whole nominee technique in one line, and it is worth noticing what it does and does not require.
It does not require a forged document, a shell company or a secrecy jurisdiction. It requires a person who is not designated, who is close enough to the designated person to be trusted, and who can be put between them and a counterparty. A nephew is a nominee with no paperwork attached.
It also does not defeat the prohibition. The interest being managed was still Kerimov’s, so the property was still blocked and dealing in it was still prohibited. Interposing the nephew changed who GVA Capital spoke to, not whose money it was — and OFAC’s finding is that GVA Capital knew that.
Heritage Trust
The release notes that the Penalty Notice follows OFAC’s 2022 issuance of a Notification of Blocked Property to Heritage Trust, “a Delaware-based vehicle then-valued at over $1 billion and in which Kerimov held an interest.”
A trust is the structure that does what a nominee does, formalised: legal title sits with a trustee, the benefit sits elsewhere, and the register of the underlying assets shows only the trustee. That it was a Delaware vehicle is worth registering — concealment structures are not exclusively an offshore phenomenon.
The gatekeeper framing
OFAC’s own summary is that the action “underscores the importance of gatekeepers in preventing sanctions evasion and highlights the risks of facilitating such efforts.”
An investment manager is precisely a gatekeeper in the sense the professional enabler literature uses. It holds the relationship, executes the transactions, and is the only party in a position to ask whose money this actually is.
Why the penalty is at the maximum
Two features. The conduct was knowing rather than negligent — OFAC uses the word “knowingly,” and places the meeting with Kerimov and the knowledge of the proxy arrangement in the narrative to establish it. And GVA Capital additionally failed to comply with an OFAC subpoena, which removes the cooperation mitigation that reduces most settlements.