The sanctions regime administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) can pose significant risks for private fund managers, such as private equity (PE) firms, including when sanctions are imposed on an existing investor. In 2018, IPI Partners, LLC (IPI), secured a $50‑million capital commitment from an entity affiliated with Russian billionaire Suleiman Kerimov, whom OFAC subsequently placed on its Specially Designated Nationals and Blocked Persons list. After conducting due diligence and seeking the advice of counsel, IPI determined that Kerimov did not have an interest in the investor entity. Subsequently, OFAC alleged that Kerimov indirectly controlled the entity and that, as a result, IPI had dealt in Kerimov’s property interests in violation of U.S. sanctions. IPI ultimately agreed to pay nearly $11.5 million to settle the matter, according to OFAC’s enforcement release (Release). This article parses the Release, with commentary from Lowenstein Sandler counsel Abbey E. Baker and MoloLamken partner Walter H. Hawes IV. See our three-part series on sanctions compliance: “How Sanctions Regimes Work” (Jun. 16, 2022); “Their Impact on Private Fund Investors and Investments” (Jun. 23, 2022); and “How to Comply With Them” (Jul. 7, 2022).