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Notes
Practical notes, not a newsletter
Short pieces on the Russian-entity file: operating and quiet companies, what a dormant company still owes, how long liquidation actually takes, how to read applicable U.S. sanctions licenses, and what to send in week one.
Hold, mothball, or liquidate — write it down
Three residual paths. A sale to a local buyer is a fourth, and it is usually someone else’s process.
A dormant Russian company is not a closed company
If it is still on EGRUL, it still files. Nil is a filing. Silence is a violation.
Wind-down is a 6–24 month statute, not a board resolution
A New York decision to exit is the start of a Russian procedure. Publication, creditors, and the FTS set the clock.
How to read U.S. sanctions licenses for residual administration
Applicable general licenses under U.S. sanctions law are real, and narrower than a slogan. They are also wider than “we don’t touch Russia.”
HQ should not VPN into Moscow to read 1C
If the only copy of the books is on a Russian host, you do not have a continuity plan. You have a hope.
What to send in week one
A complimentary call is short. A real start is a defined pack. This is the pack.
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