On December 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced an $11,485,352 settlement with a Chicago-based private equity firm (the “Company”) to resolve alleged violations of Ukraine- and Russia-related sanctions due to continued indirect investment by the Company on behalf of a Russian oligarch, Suleiman Kerimov, designated by OFAC as a Specially Designated National (“SDN”) in 2018.

On November 26, 2024, the Fifth Circuit Court of Appeals held that the United States Office of Foreign Assets Control (“OFAC”) exceeded its authority by adding an entity that pools and anonymizes crypto transactions to OFAC’s Specially Designated Nationals and Blocked Persons list (“SDN list”).  Van Loon, et al. v. Dep’t of Treasury, et al., No. 23-50669, — F.4th — (5th Cir. Nov. 26, 2024).