Policy by rumor
U.S. sanctions rules are amended on a short cycle. An internal memo from 2022 is not a file for this year. Over-restriction often blocks tax payments and director appointments that applicable general licenses still allow — and it does not stop a clever counterparty from creating a real violation.
- Over-restriction that leaves the subsidiary unfiled and unauditable
- Under-restriction that treats residual sales as “just admin”
- No SDN refresh after a director or bank change
- No written basis for the board when a bank asks
What it is
U.S. companies freeze more residual administration than the licenses require, and a smaller number wander over the line because nobody mapped the entity’s actual leftover operations to the text. Both errors are expensive. One is a missed wind-down; the other is an enforcement file.
Separately, U.S. sanctions rules restrict certain professional services — including accounting, corporate-formation, and management consulting — when they are supplied to persons in Russia. That is why the parent does not file, does not sit as a paid nominee, and does not “just have HQ accounting do 1C.” The affiliate — not a U.S. person — does the in-country acts. Applicable general licenses under U.S. sanctions law may allow residual administrative steps for winding down or maintaining an entity. They are not permission to keep trading.
Colibry produces a written English memo for this entity: the sanctions rules that apply, SDN and 50-percent screening, sectoral overlay, and a three-column result — permitted, prohibited, needs further review. It is not a substitute for a law-firm opinion. It is the factual map your counsel can adopt or challenge.
What is in scope — and what is not
We do
- Mapping of applicable U.S. sanctions rules and general licenses then in force
- Review of the client’s remaining operations — not a generic Russia deck
- SDN and blocked-person screening of the entity, directors, known counterparties, and banks
- Sectoral sanctions analysis as applied to this profile
- Export-controls (EAR / ITAR) flag if goods or technology still move
- Written memo: permitted / prohibited / further review, plus a recommended admin structure
We do not
- A formal attorney opinion (we work with your counsel, or you take the memo to them)
- A specific OFAC license application as a standalone lobbying project
- Clearance of new commercial activity in Russia
How the work runs
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01
Facts
Entity chart, leftover contracts, banks, directors, any goods or IP.
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02
Screen
SDN, 50 percent, sectoral. Hits stop the file.
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03
License map
Which sanctions rules apply, which conditions, what has changed.
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04
Memo
Three columns and a recommended Colibry (or decline) structure.
Calendar
| When | What |
|---|---|
| Week 1 | Document request and screening |
| Week 2 | Draft map to your counsel if they are copied |
| Week 2–3 | Final memo |
What we need to start
Missing items are a workstream, not a reason to wait. A signed note that a year of filings does not exist is more useful than another month of silence.
- Structure chart down to the Russian entity
- Current directors, banks, and material counterparties
- Description of leftover activity (even “none — dormant”)
- Any prior OFAC memo or bank questionnaire
Reporting
One written English memo. Optional short oral walkthrough with GC. Update if a license is amended during a live engagement.
Who it is for
General counsel, sanctions counsel, and boards that need a written basis before authorizing remaining Russia-related administration.
We will not take
- A request to bless new Russia sales
- A request to work around a listing
Fees and start
Fixed-scope engagements with fees agreed in advance. Pricing is set after an initial consultation at no charge. Standard report: 2–3 weeks from receipt of the document set. See how the New York contract works and the week-one document pack.