OFAC Fines IPI Partners $11.485M for Sanctioned Russian Oligarch Kerimov's Four-Year Concealed Investment in US Data Center Fund

On December 2, 2025, OFAC announced a $11,485,352 civil settlement with IPI Partners, LLC, a Chicago-based private equity firm specializing in buying, developing, and operating US data centers, for 51 apparent violations of Ukraine-/Russia-related sanctions (31 C.F.R. part 589).

The mechanism: In 2016, IPI established IPI Data Center Partners Fund I, L.P. to buy, build, and operate data centers leased to tenant companies. In 2017, an IPI investment-committee member was introduced — via a former investment banker acting as intermediary — to Nariman Gadzhiev, identified as the nephew and investment representative of Suleiman Kerimov, a Russian oligarch and (from April 6, 2018) OFAC-designated SDN individual (Executive Order 13661, for being an official of the Government of the Russian Federation). The IPI executive met Gadzhiev in person in San Francisco (August 14, 2017) and later met Kerimov himself in person at his estate in Nice, France (November 5, 2017).

The actual investor of record was Definition Services, Inc., a British Virgin Islands entity, which signed two subscription agreements (September 28, 2017 and March 29, 2018) committing a total of $50 million to the IPI Fund. Definition is “ultimately owned by” Heritage Trust, a Delaware-based Kerimov family trust formed in July 2017 specifically to hold and manage Kerimov’s US-based assets — the same Heritage Trust that separately held a 1% SpaceX stake (see musk-elon.md) and that OFAC subsequently found to hold ~$1.3 billion in assets when it issued a Notification of Blocked Property against the trust on June 23, 2022.

The violation: After Kerimov’s April 6, 2018 SDN designation, IPI’s outside counsel — working from an incomplete factual picture IPI itself withheld (it did not disclose that the intermediary banker had been described as Kerimov’s “gatekeeper,” or that its own executive had met Gadzhiev and Kerimov in person) — advised that Definition’s account did not need to be blocked because Kerimov did not formally own 50%+ of Definition. IPI continued dealing with Definition for four more years: 18 capital calls, 20 profit distributions, and 13 management-fee collections between April 2018 and June 2022, all in apparent violation of US sanctions.

OFAC found the violations non-egregious and not voluntarily self-disclosed; aggravating factors included that IPI “acted contrary to U.S. foreign policy interests… by facilitating a sanctioned Russian oligarch’s access to, and use of, the U.S. financial system in precisely the way that U.S. sanctions seek to prevent,” allowing Kerimov “to participate in a lucrative investment and grow his wealth after he was designated.”

Corpus connection — not identical to the Beale Infrastructure chain, but adjacent: IPI Partners was acquired by Blue Owl Capital in a deal announced October 7, 2024 and closed January 6, 2025 — after the sanctioned-investment conduct in this settlement (2017–2022) but the same corporate lineage that later produced Beale Infrastructure, Blue Owl’s AI-datacenter development platform (De Soto, KS campus; see beale-infrastructure.md). The settlement does not establish that Kerimov’s capital touched any specific named property later folded into Beale or any other post-acquisition Blue Owl datacenter asset — IPI Fund I (the vehicle Kerimov/Definition invested in) is not shown in available sources to be the same vehicle behind Beale’s De Soto project. This is a real, primary-source-confirmed instance of sanctioned Russian oligarch capital sitting inside a US datacenter private-equity fund for four years past designation — the first such instance found in this investigation beyond the PNK/Sharkov thread — but it predates and is corporately distinct from the Blue Owl/Beale AI-buildout entity that inherited IPI’s brand and platform.

See also: task-inv6-russian-capital-us-datacenter-realestate-hunt (the research ticket that surfaced this), sharkov-andrey.md (the PNK/Sharkov anchor case this ticket radiated from), beale-infrastructure.md (the Blue Owl/IPI-descended AI-datacenter developer), musk-elon.md (Heritage Trust’s separate SpaceX stake).

Conductor verification, 2026-08-31 — the OFAC release was pulled and read directly. Every element of this entry checks out against Treasury’s own enforcement release (ofac.treasury.gov/media/934786, HTTP 200, PDF read in full):

• $11,485,352 settlement · December 2, 2025 · IPI Partners, LLC, “a Chicago-based private equity firm that specializes in buying, developing, and operating data centers.”
• Suleiman Kerimov, designated April 6, 2018; IPI “continued to maintain those investments for four years after” designation.
• Definition Services, Inc. (BVI) signed a subscription 2017-09-28 for $25 million, then a second $25 million commitment — the release’s own words: “For the entire investment commitment in the IPI Fund, totaling $50 million.” The $50M figure is correct, and it is a commitment, not a capital call or an outlay.
• Heritage Trust — the release calls it “a Delaware-based Kerimov family trust” holding ~$1.3 billion when OFAC issued a Notification of Blocked Property.

Two figure types worth keeping distinct (added by the conductor): the base civil monetary penalty was $14,356,690; the settlement of $11,485,352 reflects OFAC’s General Factors mitigation. A settlement is not a penalty schedule amount, and neither is a measure of the money involved — which was the $50M commitment.

The Blue Owl / Beale caveat above is correctly constructed and should not be softened. It names the corporate lineage and then explicitly refuses the inference — twice — that Kerimov capital touched De Soto. The acquisition (announced 2024-10-07, closed 2025-01-06) postdates the sanctioned conduct (2017-2022), and no source ties IPI Fund I to the Beale vehicle. Adjacency is not identity.