The U.S. Treasury Department’s Office of Foreign Assets Control has levied a nearly $216 million penalty against a Silicon Valley venture capital firm that managed an investment on behalf of a sanctioned Russian billionaire with alleged financial ties to President Vladimir Putin.

OFAC called the case “egregious” and said it had imposed the historic penalty after finding the firm, GVA Capital Ltd., “willfully violated U.S. sanctions” through its involvement with Suleiman Kerimov, a gold magnate and Russian politician who has repeatedly appeared in ICIJ’s investigations.

The U.S. sanctioned Kerimov in April 2018 for being a Russian government official. At the time, OFAC accused him of smuggling hundreds of millions of euros into France — including as much as 20 million euros at a time in suitcases — and laundering the funds by purchasing property. Kerimov has not publicly commented on OFAC’s allegations, but Russia’s foreign ministry said when the sanctions were announced that Moscow would not respond to any “anti-Russian attack without a harsh answer.”

Kerimov, who is worth $16.4 billion according to Forbes’ billionaire index, made a fortune buying up energy assets and major stakes in Russian banks after the Soviet Union collapsed. He has represented the Republic of Dagestan in the upper house of the Russian parliament since 2008 and was one of the few oligarchs summoned to a meeting in Moscow the day Russia invaded Ukraine in 2022.

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According to OFAC, GVA Capital’s co-founders, Magomed Musaev and Pavel Cherkashin, traveled to France on two separate occasions in 2016 to meet Kerimov at his estate and secure his investment in Luminar, a U.S.-based LiDAR technology company that manufactures equipment for self-driving cars. The firm was then reportedly instructed to coordinate the deal with Kerimov’s nephew, Nariman Gadzhiev, who was acting as a proxy through a now-dissolved Guernsey company called Prosperity Investments, LP.

GVA Capital invested $20 million on behalf of Kerimov into Luminar in 2016, OFAC said. According to the company’s website, Luminar partners with leading car manufacturers like Volvo, Polestar and Mercedes-Benz.

OFAC said in its statement that GVA Capital received legal advice shortly after Kerimov was sanctioned in 2018, warning the investment firm that any sale or transfer of the shares could not directly or indirectly involve Kerimov. Despite the legal advice, OFAC said, the firm ignored the warning and engaged in one prohibited transaction and attempted three others in coordination with Gadzhiev, Kerimov’s proxy.

Musaev and Cherkashin did not respond to ICIJ’s requests for comment. In an interview with local news outlet San Francisco Standard for a 2022 story about Kerimov’s investments in the city, Cherkashin, one of the GVA Capital co-founders and a former director of the firm, said that investing in Silicon Valley is “the sacred right of every human being on Earth.”

Founded in 2011, GVA Capital is headquartered in Silicon Valley and registered in the Cayman Islands. Its investment portfolio focuses on emerging tech like artificial intelligence, robotics and self-driving cars.

One of its two directors is Leonard Grayver, a Silicon Valley attorney, according to Cayman Islands corporate records. Grayver told ICIJ he had only been a director since April 2021. He told ICIJ he had served as the firm’s legal counsel since becoming a director, which “significantly limited” his ability to talk about its business dealings.

“The sanctions regime implemented by OFAC is a very important, even critical, tool in limiting Russia’s access to international financial systems and technologies and hindering its ability to finance further military actions and economic development,” Grayver said in an email to ICIJ. “It’s incumbent for U.S. financial institutions, and especially for U.S. based services providers to increase their vigilance in ensuring full compliance with OFAC’s sanctions and export controls.”

GVA Capital’s second director, Cayman Islands corporate records show, is Odrison Investments Limited, registered in Cyprus. That company was previously controlled by another company controlled by two Cypriot lawyers, Andreas Th. Sofocleous and Georgios Angeli. In 2020, investigative outlet OCCRP found the pair may have acted as proxy owners for a Cyprus-based insurance company with alleged links to Bulgarian organized crime. The pair declined to comment on the allegations in OCCRP’s story, but Sofocleous told OCCRP the company followed all legal requirements related to forming and administering companies.

In response to a comment request from ICIJ, Sofocleous wrote in an email that “all services provided” by the second company to Odrison Investments ended in August 2021, and that he did not know Kerimov, “nor the persons who represented him, nor his relationship with GVA.”

According to the corporate records, Odrison Investments’ directors are Dimosthenis Georgiou, a Cypriot corporate services provider linked to a string of Cyprus-registered companies, and Soloserve Limited, another Cypriot company with Georgiou listed as its director.

Cyprus’ financial services industry has long helped Russian nationals shift assets overseas. In 2023, ICIJ’s Cyprus Confidential investigation revealed how the Mediterranean island’s financial services providers had helped Russia’s elite hide their wealth as war sanctions loomed.

In its statement announcing the penalty against GVA Capital, OFAC said the Silicon Valley firm had undermined U.S. foreign policy interests by “facilitating a sanctioned Russian national’s access to, and use of, the U.S. financial system in precisely the way that his designation sought to prevent.”

“This enforcement action underscores the importance of gatekeepers in preventing sanctions evasion and highlights the risks of facilitating such efforts,” OFAC said in its release.