Despite this designation, GVA Capital continued to manage Kerimov's U.S. investments, taking instructions from individuals it had reason to believe were acting on Kerimov's behalf, including attempts to sell or distribute shares in a U.S. company for his benefit. Importantly, Kerimov held shares in a U.S. company through intermediary entities, including a Delaware trust formed in July 2017 to hold and maintain Kerimov's U.S. assets, a fact that GVA Capital was well aware of on the basis of extensive pre-designation interactions with Kerimov. This led OFAC to find that GVA Capital's violations were willful as its "senior management had actual knowledge" that the relevant funds and investments ultimately came from Kerimov and that Kerimov retained a property interest in the investments through the trust. Moreover, OFAC noted a legal opinion that GVA Capital obtained regarding the applicability of U.S. sanctions to GVA Capital's investments.