Built around U.S. law, not around it

We do not facilitate prohibited transactions. We provide administrative continuity inside what applicable OFAC regulations and U.S. export controls still permit.

Applicable general licenses

U.S. sanctions law provides general licenses that can authorize certain administrative transactions connected with winding down or maintaining a Russian entity — typically taxes, maintenance, local salaries, and the costs of preserving or liquidating the company. We scope every file to the text then in force and will confirm the architecture in writing. We do not treat a general license as a specific license, or as permission to keep trading.

U.S. person exclusion

No U.S. person conducts the Russian transaction. Tax filings, regulator submissions, banking interfaces, and director services are performed by the affiliated non-U.S. entity under Russian law, with its own staff. That separation is not a slogan. It is the architecture of the engagement letter.

SDN screening

We screen the entity, directors, and known counterparties against the SDN and blocked-persons lists before work starts, and again during the mandate. If someone is listed mid-stream, we tell you immediately and stop or recast. We do not take sanctioned sectors.

Limits

What this firm will not do

Clarity here is part of the product. A GC should be able to send this page to sanctions counsel without footnotes.

Continue or disguise prohibited trade with Russia
Work for or with SDN, blocked, or 50-percent-owned listed parties
Put a U.S. person into a Russian payment, signature, or directorship
Advise you to ignore a license condition or a reporting duty
Pretend that a General License is a specific license, or that it lasts forever

Questions we are asked

For counsel, before the first call

Is this legal for a U.S. person?

Every engagement is scoped to sit inside applicable U.S. sanctions law and export-control rules. Where general licenses authorize residual administrative steps — taxes, maintenance, local salaries, preservation or liquidation costs — we work inside that perimeter. We do not facilitate prohibited commercial activity. A written confirmation of the architecture is available on request. This site is not legal advice; qualified U.S. counsel should review the structure against the client’s facts.

Why not hire a Russian firm directly?

Then the parent is the counterparty on a Russian contract, under Russian law. With Colibry, the parent’s engagement is with a New York resident, governed by New York law, paid in U.S. dollars, with disputes in New York County. In-country accounting, tax, director, payments, and representation are performed by our affiliated company. That operating responsibility in Russia is ours.

Do we send money to Russia?

No. You contract with Colibry LLC, a New York entity, and pay in USD to a U.S. bank account. Statutory amounts due in Russia — tax, fees, leftover payroll — are paid in rubles by the affiliated company, from the entity’s own balance or, where that is gone, from the affiliate’s in-country funds. You reimburse those advances to Colibry LLC in dollars, in the United States. The parent never originates a wire to Russia.

Are you a law firm?

No. Colibry LLC is an administrative and compliance advisory. We are not a law firm and do not create an attorney-client relationship. Engagements are governed by New York law. Disputes are heard in the courts of New York County.

Do you only work with dormant companies?

No. We administer companies that still operate and companies that do not. Accounting, tax, director, representation before the FTS, ruble payments, and the books sit in the same New York architecture. Mothball and liquidation are for boards that have chosen a quiet or exit path.

What if the Russian entity is dormant?

Dormant does not mean exempt. A company that remains on EGRUL still owes filings, a director, an address, and responses to the FTS. Inaction usually raises the cost of any later wind-down. We handle both “keep it current” and “take it off the register.”

OFAC updates licenses. We re-read them. Nothing on this page is legal advice or a representation that a particular license covers a particular client. U.S. sanctions counsel should be in the file. The full list is on the FAQ.

Confidential intake

Begin with a conversation, not a wire to Russia.

Complimentary initial consultation. We typically respond within one business day. Inquiries are handled with complete discretion.

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