A historic $215.9 million penalty on GVA Capital, a San Francisco-based venture capital firm specializing in AI, exposes how Russian oligarch Suleiman Kerimov’s wealth slipped through the cracks of US sanctions. Despite being blacklisted in 2018, his investments, funneled through offshore networks, continued to grow—until the US stepped in.
Jun 16, 2025 15:57
6 min read
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Seen as a wake-up call for American firms, the Office of Foreign Assets Control (OFAC) imposed on June 12 a $215.9 million penalty on GVA Capital, founded in 2011 by Russian entrepreneurs Magomed Musaev and Pavel Cherkashin and specializing in artificial intelligence, robotics, and space technology.
The firm violated Ukraine-Russia-related sanctions by continuing to manage the investment years after the Russian oligarch Suleiman Kerimov was added to the sanctions list and confirmed as ignoring a US federal subpoena for more than 28 months.
How sanctioned billions kept growing
Kerimov is an elusive figure in Russia’s oligarchic class, close to the Kremlin. Forbes estimates the Dagestani native’s net worth at $16.4 billion, ranking him #145 globally. Since 2008, Kerimov has served as a member of Russia’s Federation Council, representing Dagestan. He built his $17.5 billion fortune through investments in major companies like Gazprom (Russia’s state-owned gas producer and exporter) and Sberbank (Russia’s largest state-owned bank) and, later, Wall Street giants such as Goldman Sachs and Morgan Stanley (major American investment banks).
Russian leader Vladimir Putin, Turkish President Tayyip Erdogan, Russian oligarch Suleiman Kerimov, and Grand Mufti Ravil Gainutdin attend the opening ceremony of the restored Moscow Cathedral Mosque on 23 September 2015 in Moscow. (Source: Getty Images).
The US Treasury Department sanctioned him in 2018, cutting off his access to American financial assets, including investments managed by US-based firms, funds held in US financial institutions, and equity in American tech companies. Yet behind the layers of offshore entities and trust structures, his money has quietly remained in play.
Through the Delaware-based entity Heritage Trust, Suleiman Kerimov maintained interest in the major US tech company, believed to be Luminar Technologies, an investment routed originally through Prosperity Investments, L.P., and managed by GVA Capital, a San Francisco-based venture capital firm.
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Shares in a US tech company—believed to be Luminar Technologies—were still being managed for sanctioned Russian oligarch Suleiman Kerimov through a Delaware-based entity, Heritage Trust, OFAC discovered in April 2021. Kerimov’s $20 million investment, made in 2016 via his nephew Nariman Gadzhiev and routed through GVA Auto LLC, had grown to approximately $1.3 billion.
“This enforcement action underscores the importance of gatekeepers in preventing sanctions evasion and highlights the risks of facilitating such efforts,” cites the report.
The OFAC enforcement reveals that GVA Capital met with Kerimov at his estate in France in 2016 to secure his personal approval for the deal. Later, several high-level meetings, one of which took place on Kerimov’s private aircraft, were involved. The investment was coordinated through his nephew and known proxy, Nariman Gadzhiev. GVA Capital continued managing the investments through Gadzhiev even after OFAC sanctioned Kerimov.
The global trail of the Russian oligarch’s wealth
During the 2008 financial crisis, US Treasury officials personally called to ask Kerimov not to sell his stakes. But Kerimov’s taste for high finance came with high drama: he bought FC Anzhi Makhachkala, flew in Christina Aguilera and Shakira for parties, and crashed a $650,000 Ferrari in Nice, suffering severe burns.
Kerimov’s legal troubles began in 2017, when French police arrested him in Nice over alleged tax fraud tied to a string of €127 million villas in Cap d’Antibes.
Though he cut a €64 million deal to avoid formal charges, Russia’s war in Ukraine reignited scrutiny. In 2024, France froze the villas again and opened a new money-laundering probe involving his daughter, Gulnara, and son, Said.
Known for a public feud with Chechen leader Ramzan Kadyrov, who accused him of plotting an assassination, Kerimov still serves in Russia’s Federation Council and controls vast assets through offshore networks running a Swiss-based foundation funding mosques, Hajj trips, and elite education.
What the fine means for US sanctions enforcement
“The penalty is the maximum civil fine the agency could have imposed, and it’s the largest civil fine by OFAC since it fined virtual currency exchange Binance over $968 million in 2023,” Export Compliance Daily stated after the OFAC enforcement release.
A journalist films the wreck of a black Ferrari that crashed into a tree and burst into flames in Nice on 26 November 2006, injuring Russian oligarch Suleiman Kerimov and a female passenger. (Source: Getty Images)
The $215,988,868 penalty against GVA Capital is one of the largest penalties ever imposed by OFAC. The penalty reminds financial intermediaries or “gatekeepers” of the risks they face when working with individuals or entities under US sanctions.
This case is particularly significant because it illustrates how intermediaries, whether through carelessness or complicity, undermine sanctions meant to block funds from sanctioned individuals.
Financial institutions such as OPEC serve a critical role in upholding sanctions, with gatekeepers like investment firms, accountants, and lawyers playing a key role in preventing illicit actors from exploiting the financial system.
Beyond financial damage, GVA Capital now faces reputational damage, though no direct comment from GVA Capital regarding the penalty imposed by OFAC has been released.
In light of the full-scale invasion of Ukraine, the OFAC decision directly impacts the ability of sanctioned individuals like Suleiman Kerimov to circumvent international restrictions, empowering the frameworks designed to weaken Russia’s financial reach and curb Russian influence in the US and beyond.
This penalty can be seen as a victory in the ongoing effort to cut off the financial resources of Russian oligarchs, whose wealth has historically been used to fuel the Kremlin’s military ambitions.
Following this case, other financial institutions and investment firms (such as venture capital firms) will likely face greater scrutiny from OFAC.
Other countries aligned with US sanctions may take similar enforcement actions against GVA Capital or related entities, further increasing pressure on the firm and its leadership while reinforcing the crucial financial pressure on Russia.
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The $215.9 million penalty against GVA Capital is one of the largest ever imposed by OFAC, marking a significant moment in the agency’s history. While OFAC has issued substantial fines before, such as the $968 million penalty against Binance in 2023, the GVA Capital fine is particularly notable for its focus on sanctions evasion related to Russia.
“US persons operating in these industries should have a clear understanding of their US sanctions compliance obligations, as well as the risks posed by dealing with counterparties who are themselves sanctioned or who reside in sanctioned jurisdictions,” OFAC stated.
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