OFAC has assessed a $215,988,868 civil monetary penalty against venture capital firm GVA Capital Ltd. for violations of OFAC's sanctions against Russia and for related reporting obligations. Between April 2018 and May 2021, GVA Capital knowingly managed an investment for sanctioned Russian oligarch Suleiman Kerimov while aware of his blocked status. GVA Capital also failed to comply with an OFAC subpoena during OFAC's investigation into this matter. The penalty amount reflects OFAC's determination that GVA Capital knowingly violated U.S. sanctions against Russia, as well as OFAC’s Reporting, Procedures, and Penalties Regulations conduct, and that the entity’s conduct was egregious and not voluntarily self-disclosed. This enforcement action highlights the Treasury Department’s increasing focus on venture firms and registered investment advisers, which will also be subject to full anti-money laundering (AML) controls under the Bank Secrecy Act (BSA) as of January 1, 2026.