Editor’s Note: RDIF informed The Daily Beast subsequent to publication that it does not currently employ Americans and that Dimitriev denied seeking to lift sanctions. Furthermore, former deputy CEO Sean Glodek was not the number two person at the fund. We regret the errors.

A multibillion-dollar Russian sovereign wealth fund has a long history of employing Americans despite being sanctioned by the United States.

The Russian Direct Investment Fund drew renewed interest in recent weeks after news surfaced that unofficial Trump envoy Erik Prince met with RDIF’s CEO, Kirill Dmitriev, days before President Trump’s inauguration. And an individual close to the bank says Dmitriev is focused on removing sanctions on the fund, as it tries to attract investments into Putin’s Russia.

RDIF denies that it has ever taken any actions with respect to the removal of sanctions on it.

“It’s an interesting organization, a little bit more open to outsiders than other state-run organizations,” an individual close to RDIF told The Daily Beast. “I think now their proportion [foreigners] is smaller, and that probably represents the overall trend in Russia.”

“Now it’s a little bit like one of those ministries, you can say, the ministry of foreign investment,” the individual added.

Americans and people with ties to the U.S. have held some of the top spots at RDIF. For years, a deputy CEO at the fund was Sean Glodek, a Stanford alum and Wharton MBA graduate who previously worked at Deutsche Bank and Lehman Brothers. The current deputy co-director for RDIF’s Russia-China investment fund is Oleg Chizh, a Brandeis and Columbia graduate. Other Americans have served in top investor relations and advisory roles.

RDIF is a sovereign wealth fund, which oil-rich nations like Russia use to invest for profit, and has more than $10 billion in assets under management, according to its website.

RDIF “has always attracted top talent from the global investment community and continues to hire professionals from many countries,” Arseniy Palagin, a spokesman for the fund, told The Daily Beast. “As you should know there are no restrictions for U.S. citizens to be employed by the Fund, to work in the Fund, no restrictions to meeting Fund’s employees.”

Dmitriev, the RDIF director who met Prince, also has strong ties to the United States. Born in Ukraine, he came to the U.S. in the early 1990s and graduated from Stanford in 1996. Like many graduates of elite universities, Dmitriev went on to work in consulting and, a few years later, to Harvard Business School, which he graduated as a Baker scholar—a distinction reserved for the top five percent of any graduating class. Though Dmitriev lives in Russia, his immediate family lives in America, where they’d vacationed together and enjoyed water sports, as evidenced in a 2005 civil case about a boat injury his mother suffered the previous year. (The family did not return requests for comment.)

The United States Citizenship and Immigration Services declined to comment on Dmitriev’s citizenship status, citing privacy concerns, but the RDIF said Dmitriev holds Russian citizenship and has never held American citizenship.

When the RDIF was created in 2011, Dmitriev got its top job.

“He was no Warren Buffett when it came to actually came to making investments [...] but Kirill is more like a builder of organizations,” the insider explained. “He’s good at being out there, making friends in positions of power, doing PR—which he personally tries to control as much [as possible].”

A few years later, the fund was spun off from Russia’s owned Vnesheconombank—the so-called “bank of spies” whose leader met with Jared Kushner in December 2016.

“[Dmitriev] built a pretty autocratic organization,” the man said. “It’s like a analogy for the Russian state, in a way, where you have a CEO who oversees everything, micromanages everything, and everyone else is expendable.”

And it wields tremendous power inside the country.

An employee “could call up anyone in Russia, a big CEO would take [their] call,” the individual close to RDIF explained, likening to “calling from the prime minister’s office."

Part of its mission is to make outsiders more comfortable investing in Russia by pairing their capital with RDIF funds. It was formerly part of VEB, the bank that doubles as Russian President Vladimir Putin’s “private slush fund,” according to Atlantic Council fellow Anders Aslund.

“The Russian Direct Investment Fund is deeply involved in Putin’s hanky panky,” Aslund told The Daily Beast. “[Dmitriev] is very comfortable with Putin. He’s one one of these young, well educated technocrats Putin’s comfortable with.”

Dmitriev did not respond to requests for comment, but explained his mission in a 2013 interview.

“Many people have misperceptions about Russia, and they feel the risk is greater than it really is,” Dmitriev explained to CNBC in 2013. “So we put the [Russian] government’s money alongside other investors’ to make sure they are comfortable and understand that Russia can be an attractive investment destination.”

It’s meant to counter the notion that “Russia is not always a very attractive destination for foreign capital, because there's a lack of rule of law,” the individual close to RDIF added. “It’s a kind of state-sponsored solution for the question of, how do we bring foreign direct investment to Russia.”

That plan hit a snag when RDIF, along with its former parent company, VEB, was sanctioned by the U.S. government in 2014 after Russia’s annexation of Crimea.

“It really made life more complicated for the institution,” the insider added.

The unique nature of sanctions against RDIF and Russian entities like it make it possible for Americans to work for them without breaking the law, experts say. While sanctions ordinarily mean that an entity’s assets are frozen and it is prohibited for U.S. persons and entities to deal with them, American sanctions took a different approach, according to Zachary Goldman, a former Treasury Department official.

“In 2014, however, the U.S. and E.U. created a new type of sanction for the Russia issue,” Goldman said.

These sanctions were designed to crack down on individuals close to Putin, and to target four sectors of the Russian economy by limiting their access to long-term growth capital.

“What it means is that there are restrictions on dealing in debt and equity with VEB,” Goldman explained.

Working for the fund would not necessarily be problematic for U.S. citizens, then, because of the scope of the limitations. Employees at the bank would just have to be careful to stay within the the lines, Goldman said.

“Co-investments and meetings with RDIF are not restricted and are not subject to US sanctions or any other restrictions. RDIF always operates in full compliance with relevant regulations and legislation and its operations do not violate sanctions,” the fund said after revelations of Dmitriev’s meeting with Prince. “RDIF is not engaged in any political activities. The fund operates purely on a commercial basis, providing our co-investors with attractive and stable returns.”

Dmitriev is not subject to sanctions. He is simply a fund manager, albeit one unusually close to Putin, and one who the individual close to RDIF said is keen on having sanctions removed.

And even before meeting with Prince, he was optimistic about the Trump White House.

“We believe having a businessman in the White House who makes pragmatic decisions is very important,” Dmitriev told the Financial Times in November 2016. “We believe what is great about president-elect Trump is that he is open-minded about Russia.”