Genesis Asset Managers, LLP OFAC Settlement: $112.5K

Last updated: July 20, 2026

Genesis Asset Managers, LLP agreed to remit $112,500 to settle potential civil liability for an apparent violation of the Iranian Transactions Regulations, 31 C.F.R. part 560, that occurred on or about August 1, 2007. OFAC determined the case was not egregious.

Penalty Amount

$112,500.00

Enforcement Date

May 21, 2012

Rank in Top Penalties

#234

Case Details

Type:: Entity
Name:: Genesis Asset Managers, LLP
Country:: 🇺🇸 United States
Industry:: Securities
Penalty amount:: $112,500.00
Egregious case:: No
Apparent violations:: 1
Voluntary self disclosure:: Yes
Case:: Settlement
Violation period:: From August 1, 2007
Program:: Iranian Transactions Regulations ("ITR"), 31 C.F.R. part 560
Enforcement date:: May 21, 2012

Nature of the Apparent Violations

GAM US is the investment manager of Genesis Emerging Markets Fund ("GEMF"), a Guernsey-organized investment fund. Pursuant to a Management Agreement between GAM US and GEMF, GAM US has the authority to act as GEMF's manager, investing and re-investing cash, securities, and other property comprising the assets of GEMF. GAM US contracts with its London-based subsidiary, Genesis Investment Management LLP ("GIM UK"), through an Investment Advisory Agreement, pursuant to which GIM UK provides investment advice and recommendations to GAM US relating to GEMF in return for a fee. The Investment Advisory Agreement authorizes GIM UK to carry out transactions as an agent of GAM US in accordance with the investment policies and strategies adopted from time to time by GEMF. In 2007, pursuant to this delegated authority, GIM UK purchased approximately $3 million of shares for GEMF in the First Persian Equity Fund ("FPEF"), a Cayman Islands company that invests exclusively in Iranian securities, constituting one apparent violation of the ITR on or about August 1, 2007.

How OFAC Determined the Penalty

OFAC determined the apparent violation was not egregious. GAM US voluntarily self-disclosed the apparent violation and substantially cooperated with OFAC's investigation by responding promptly and completely to OFAC's requests for information and by agreeing to settle this matter without the issuance of a Prepenalty Notice. GAM US agreed to remit $112,500 to settle potential civil liability.

Aggravating Factors

GAM US failed to exercise a minimal degree of caution or care in the conduct that led to the apparent violation of the ITR.
Officers of GAM US were aware of the conduct giving rise to the apparent violation.
Substantial economic benefit was conferred to Iran, thereby undermining the objectives of the ITR.
GAM US did not have an OFAC compliance program in place at the time of the apparent violation.

Mitigating Factors

GAM US has not received a penalty notice or Finding of Violation from OFAC for substantially similar violations.
GAM US substantially cooperated with OFAC's investigation by responding promptly and completely to OFAC's requests for information, by voluntarily self-disclosing the apparent violation in question, and by agreeing to settle this matter without the issuance of a Prepenalty Notice.
GAM US took appropriate remedial action.
GAM US may not have fully understood its OFAC obligations under U.S. law.

Official Source Documents

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Archived on June 13, 2026

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