Akrivis Advises on Acquisition of Miami Properties Seized by US Department of Justice KleptoCapture and tied to Sanctioned Russian Oligarch

Akrivis Law Group was recently involved in the successful transfer of two Miami Beach hotel condominiums subject to a U.S. Department of Justice (DOJ) forfeiture action as part of the Department’s KleptoCapture task force formed in 2022 in response to the invasion of Ukraine.  These two properties were tied to Viktor Perevalov, a Russian national sanctioned by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).

Federal officials last week formally took ownership of the two condominium located at the Ritz-Carlton Bal Harbour in Miami-Dade County following an order from a district judge, finding the properties to be connected to Viktor Perevalov, an individual designated by OFAC to its List of Specially Designated Nationals and Blocked Persons List (the SDN List) in 2018 under Executive Order (E.O.) 13662, and once again designated in December 2024, this time under E.O. 14024.  Perevalov and Valeri Abramov were joint founders of a construction company connected to work in Crimea following Russia’s occupation of this region in Ukraine in 2014.   Entities on the SDN List are blocked from virtually all trade in goods, services, and technologies with U.S. persons, a broadly defined term including but not limited to U.S. citizens, permanent residents, and legal entities formed under the laws of a U.S. jurisdiction. Any property subject to OFAC jurisdiction in which such parties have an interest must be blocked.

Perevalov had initially purchased the Ritz-Carlton properties in 2008.  Later, the individuals changed the title owner of the condos to “1616 Collins LLC” with a different listed beneficial owner, seemingly to continue to maintain and lease the properties, despite the legal requirement that they be blocked.  In so doing, the properties were maintained with the proceeds traceable to violations of the International Emergency Economic Powers Act (IEEPA).  In March 2024, one month after the forfeiture complaint for the properties was filed by the federal government, a third individual, Renata Perevalova, brought a claim asserting herself as the true owner of the two units, denying that the properties were derived from illegal proceeds. Perevalova eventually withdrew her claim in October 2024, and this past December the government brought a motion for forfeiture by default judgment.  The successful forfeiture reiterates that the attempt to hide assets behind nominees and/or shell companies can have significant real long-term costs.

After the DOJ seized properties from the blocked entity discussed here, Akrivis was able to navigate both OFAC regulations and the criminal asset forfeiture process to help our client, which owns the broader Ritz-Carlton Bal Harbour property, to purchase the two units quickly and at a favorable rate.  Typically, the DOJ sells seized properties at the conclusion of the court case though a public auction and a potential buyer must wait for the court matter to end and then bid against other potential purchasers.  In this case, Akrivis initiated negotiations with the government only months after the forfeiture complaint was filed and notably reached an agreement for the sale without undergoing the auction bidding process.  

We are pleased to be able to offer clients that kind of expertise, combining a deep knowledge of sanctions by partner Farhad Alavi (Washington) and criminal law by Walter Norkin (Miami/New York), a former Assistant U.S. Attorney in the Southern District of Florida (SDFL) and the Eastern District of New York (EDNY).

A boutique law firm with offices in Washington, New York, and Miami, Akrivis regularly represents clients around the world from public companies to high net worth individuals in a variety of matters, focusing particularly on U.S. trade laws such as sanctions and export controls, as well as federal criminal cases with an international component, including trade or drug enforcement-related cases.  This complements the firm’s other work in white collar investigations, dispute resolution, and international corporate issues.

The DOJ Press Release can be found here https://www.justice.gov/opa/pr/justice-department-secures-forfeiture-two-miami-condos-violations-russia-related-us.