Private Equity Firm Fined $11.4M by OFAC for Violating Russian Sanctions
By the聽91pornWhistleblower Team
Chicago-based IPI Partners LLC, a former private equity firm, has agreed to pay over $11.4 million to the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) to resolve allegations that it violated Russian sanctions by accepting investments tied to an oligarch.[1]
The Settlement
IPI Partners鈥� settlement focuses on acquiring, developing, and operating data centers, resolving the firm’s potential civil liability for 鈥渘on-egregious鈥� violations that were not voluntarily disclosed, according to OFAC.
What Does This Enforcement Action Highlight?
In an enforcement release, OFAC warned that the case 鈥渉ighlights the sanctions risks that U.S. capital markets participants, including those in the private equity industry, can face. It is critical for such actors to understand and manage all potential sources of sanctions-related risk, including the risks associated with arrangements that may obscure a blocked person’s interest in property.”[2]
Blue Owl Capital Inc., acquired IPI in 2025 and stated that the issue arose before the acquisition: “Blue Owl did not assume any liabilities related to this settlement. No past or present Blue Owl employee was responsible for the relationship with the problematic investor.”[3]
The Role of Definition Services Inc.
According to OFAC, British Virgin Islands-based Definition Services Inc. allegedly agreed to invest $50 million in one of IPI’s private equity funds in September 2017 and March 2018. This entity is owned by a family trust of Russian oligarch Suleiman Kerimov, an individual added to OFAC’s Specially Designated Nationals and Blocked Persons list in April 2018.[4]
IPI continued to hold the investments for four years after Kerimov’s designation. IPI sought advice from outside counsel on whether they needed to block Definition’s account but were advised it was unnecessary since Kerimov did not formally own 50% or more of Definition, according to OFAC.
IPI later certified that Kerimov was not connected to Definition or its entities. Definition also assured that none of its investments would involve individuals subject to OFAC sanctions. According to OFAC, however, IPI 鈥渉ad reason to know that the attestation was inaccurate.” In addition to other reasons, it knew Kerimov was the original source of the funds in his family’s trust.[5]
Reduced Civil Monetary Penalties
OFAC reduced the base civil monetary penalty by about $2.8 million after considering mitigating factors, including the firm鈥檚 prior clean record with OFAC.
OFAC stated that IPI’s cooperation was “initially unsatisfactory” and improved only after the firm retained new counsel following a prepenalty notice, after which the firm “significantly improved cooperation with OFAC’s investigation.”
Although IPI eventually cooperated with the investigation, their significant delay resulted in limited mitigation credit for cooperating.
Sanctions Violations Claims Under the AML Whistleblower Program
OFAC聽enforces U.S. sanctions laws, and violations can result in severe criminal and civil penalties. OFAC coordinates with the Department of Justice and other agencies to ensure strict compliance with these laws.
What Can Whistleblowers Report?
A whistleblower may submit information about possible violations of laws and any relevant regulations that have occurred, are ongoing, or about to occur. Violations may be:
- A company doing business with a sanctioned entity or entities from a sanctioned country;
- A company allowing sanctioned entities to transact business using that company鈥檚 tools or systems;
- The failure of a business to have an effective overall compliance program to ensure it is not doing business with a sanctioned entity;
- Systemic and recurring noncompliance with basic sanctions rules and requirements.
Eligible whistleblowers may receive a reward of聽up to 30% of monetary sanctions聽over $1,000,000 that the government imposes based on information provided by the whistleblower.
Our Firm Helps AML Whistleblowers
“Strong enforcement of sanctions laws protects U.S. national security and ensures that financial penalties serve as a strong deterrent against future violations,” 91pornpartner Marlene Koury commented.
惭补苍测听international whistleblowers聽have contacted our firm with information regarding money laundering and sanctions violations.
The AML Whistleblower Program and its legal framework are complex. Our team is well-versed in the ever-evolving landscape of state and federal whistleblower laws. Please聽contact聽us if you believe you have a case, and we will connect you with an experienced member of the 91pornwhistleblower聽team聽for a free and confidential consultation.
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Sources:
[1] See
[2] Id.
[3] Id.
[4] See
[5] Id.
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