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Russia & CIS Compliance Advisory

Your Russian entity.Managed from New York.Fully compliant.

Colibry LLC provides U.S.-based administrative and compliance services for American companies with Russian subsidiaries — without direct transactions with Russia.

Colibry — Russia & CIS Compliance Advisory
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The Problem

A compliance gap no one anticipated

When Western companies exited Russia in 2022, most left behind active legal entities — still required to file taxes, maintain directors, and respond to regulators. The gap between U.S. legal restrictions and Russian administrative requirements created a compliance vacuum that few firms are equipped to fill.

300+
U.S. companies

American corporations left active Russian subsidiaries behind when they suspended or terminated operations following the 2022 sanctions.

The payment gap
 

U.S. sanctions restrict direct financial transfers to Russia. Yet Russian law requires timely payment of taxes, salaries, and administrative fees. Most companies have no compliant mechanism to bridge this gap.

The compliance gap
 

Without active management, Russian entities accumulate tax penalties, lose good-standing status, and become significantly harder and more expensive to wind down. Every month of inaction increases exposure.

Services

Seven specialised services

End-to-end management of your Russian legal entity — structured entirely within U.S. law, without direct transactions with Russia.

01

Tax & Regulatory Compliance

Full tax filing cycle — CIT, VAT, insurance premiums — FTS interactions and deadline management. Conducted through our affiliated Russian entity without any direct U.S. involvement.

02

Corporate Maintenance

Nominee General Director, registered legal address, active EGRUL status, and full corporate secretariat — ensuring your entity remains legally operational at all times.

03

Entity Liquidation (Wind-Down)

End-to-end voluntary liquidation: preliminary due diligence, liquidation resolution, FTS audit support, creditor settlement, and final EGRUL deletion.

04

Audit & Regulatory Dispute Defense

Professional representation in FTS desk and field audits. Preparation of objections, document collection, appeals to regional authorities, and arbitration support.

05

OFAC Compliance Review

Assessment of your activities against current OFAC regulations. Analysis of applicable General Licenses (GL 13P, GL 4, GL 25). Written compliance confirmation for each client.

06

Regulatory Reporting & Monitoring

Continuous monitoring of Russian legislative changes. Filing of Rosstat reports, controlled transaction notifications, and mandatory permits. Monthly compliance reporting in English.

Unique to Colibry 07

IT Infrastructure & Data Continuity

Own server infrastructure in Russia linked to a U.S. mirror server — ensuring uninterrupted access to your Russian accounting systems regardless of internet conditions, VPN restrictions, or sanctions-related IP blocks.

Clients host their 1C or other accounting systems with us and access data securely through our U.S.-based infrastructure. The only solution of its kind on the market.


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Sanctions Framework

Built around U.S. law, not around it

Every Colibry engagement is structured to comply with applicable OFAC regulations and U.S. export controls. We do not facilitate prohibited transactions — we provide administrative continuity within the bounds of what U.S. law permits.

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General License 13P

Administrative transactions for U.S. persons winding down operations in Russia are authorized under OFAC General License 13P and successor licenses — including taxes, maintenance fees, salaries, and costs of preserving or liquidating a Russian entity. Colibry structures every engagement within the scope of applicable General Licenses. Written confirmation provided on request.

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U.S. Person Exclusion

Our structure ensures that no U.S. person directly conducts transactions in Russia. All in-country activities — tax filings, regulatory submissions, banking interactions, and director services — are performed exclusively by our affiliated non-U.S. entity under Russian law with its own dedicated staff. This separation is central to the compliance architecture of every Colibry engagement.

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SDN Screening

All engagements are subject to OFAC SDN and blocked persons screening prior to commencement. We do not work with sanctioned entities, individuals, or sectors. Screening is repeated periodically. If an entity or counterparty becomes sanctioned during an engagement, we immediately notify the client and assess implications for ongoing services.

How It Works

The client's legal and financial perimeter remains entirely American

Neither the client nor Colibry LLC engages in direct transactions with Russia. You never have to explain a wire transfer to Russia to your compliance team.

01

U.S. Contract

You sign a service agreement with Colibry LLC — a U.S. legal entity incorporated in the State of New York. Governed by New York law. All disputes resolved in the courts of New York County. No foreign jurisdictions, no Russian counterparties on the client side. Colibry assumes full responsibility for organizing all work in Russia.

02

USD Payment

You pay in U.S. dollars to a U.S. bank account held by Colibry LLC. No wire transfers to Russia. No currency conversion. The transaction remains entirely within the U.S. financial system and does not touch OFAC-restricted channels. All invoices are issued in English with itemized service descriptions.

03

In-Country Administration

Colibry executes all in-Russia operations through its own affiliated company — staffed with dedicated in-house specialists. Our team files tax returns, interacts with the FTS, manages the nominee director, and receives correspondence. The affiliated entity is not a U.S. Person — central to the sanctions compliance architecture.

04

Reporting to You

Regular English-language reports: status of filed returns, scanned document copies, and notifications of any regulatory changes or authority actions. Upcoming deadlines flagged four weeks in advance. Immediate notification with risk assessment for unusual situations.

Why Colibry

A singular combination of expertise

Colibry LLC was founded in New York by professionals with direct experience in both U.S. and Russian legal systems — a combination that is exceptionally rare in the current environment.

New York–Based

U.S. legal entity, U.S. bank account, U.S. jurisdiction. Your contracts stay domestic. Your payments stay in the U.S. financial system. You never have to explain a wire transfer to Russia to your compliance team.

Sanctions-Compliant Structure

Every engagement is designed around OFAC General Licenses and U.S. legal guidance — not despite it. Written confirmation of the compliance framework provided to each client. Our model has been reviewed by U.S. sanctions counsel.

Russian Legal Expertise

Direct, first-hand experience with Russian corporate law, tax administration, and regulatory systems through our own affiliated Russian entity with a dedicated in-house team that has operated through multiple cycles of regulatory change.

Confidential by Design

Client relationships are never disclosed. All communications are attorney-work-product adjacent. We do not market client names or case studies without explicit written consent.

Fixed-Scope Engagements

Clear scope, defined deliverables, and transparent pricing agreed in advance. No open-ended retainers unless you want them. No surprise invoices. Every engagement letter specifies exactly what we will and will not do.

Reporting You Can Trust

All compliance work is documented and reported in plain English with full audit trails. You always know what has been filed, when, and what response was received. Documentation is structured for potential regulatory review.

Own IT Infrastructure in Russia

We operate our own server infrastructure in Russia, enabling clients to host their accounting systems with us and access their data securely through our U.S. mirror server — uninterrupted even if Russian internet access is restricted.

IT Infrastructure & Data Continuity

Uninterrupted access to your Russian accounting systems

Sanctions restrictions and the instability of Russia's internet environment create a real risk of losing access to corporate accounting systems hosted in Russia. VPN blocks, cross-border data restrictions, and potential IP closures can cut off your head office at any moment.

Colibry LLC offers a concrete technical solution: our own server infrastructure in Russia, linked to a mirror server in the United States — ensuring continuous access to your data regardless of conditions on the ground.

  • Hosting of 1C and other Russian accounting systems on our Russia-based server
  • Real-time data mirroring to a U.S.-based server
  • Secure remote access from any location — no VPN or Russian IP required
  • Daily automated backups with retention policy
  • Encrypted data transfer between Russia and U.S. infrastructure
  • Incident monitoring and 24-hour emergency response
Inquire About IT Services
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Your U.S. Headquarters
Secure remote access — no VPN required
Encrypted connection
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U.S. Mirror Server
Colibry infrastructure — United States
Real-time sync
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Russia-Based Server
1C / accounting systems — Colibry Russia
Unique to Colibry
Contact

Begin a confidential conversation

All inquiries are handled with complete discretion. Initial consultations are complimentary. We typically respond within one business day.

Contact Information
Address
20 West 64th Street, Suite 39F
New York, NY 10023
General Inquiries
Rinat McLaren — Managing Partner
Roman McLaren — Partner
Entity
Colibry LLC
Registered in the State of New York
Website

All inquiries are treated as confidential. Submission of this form does not constitute legal advice or create an attorney-client relationship.

Thank you. We will be in touch within 24 hours.