On June 30, 2022, the US Department of the Treasury’s Office of Foreign Assets Control blocked Heritage Trust, a Delaware-based trust in which OFAC-designated Russian oligarch Suleiman Abusaidovich Kerimov and his nephew Ruslan Gadzhiyevich Gadzhiyev hold a property interest. OFAC issued a Notification of Blocked Property against Heritage Trust in order to prevent Kerimov from accessing its assets, which were valued at more than $1 billion on June 30, 2022. According to OFAC, the trust was formed in 2017 to hold and manage Kerimov’s US-based assets, and Gazhiyev is a beneficiary of the trust. OFAC reports that the trust was recently discovered after an extensive enforcement investigation revealed that Kerimov used a network of relatives, advisers, and a complex series of legal structures to hide his interest in the trust.
Kerimov is a member of the Federation Council of the Federal Assembly of the Russian Federation and was designated by OFAC in 2018 pursuant to Executive Order 13661 for being an official in the Government of the Russian Federation. OFAC recently designated Gadzhiyev, a member of Russia’s State Duma, on March 24, 2022 pursuant to EO 14024.
Under the Notification of Blocked Property, Heritage Trust is subject to the same prohibitions that are applicable to Kerimov. As a result, all transactions by US persons or within the US that involve the property or interests in property of a designated person are prohibited, unless they are exempt or authorized by an OFAC-issued general or specific license.