U.S. sanctions have made it nearly impossible for American companies to manage their remaining Russian legal entities. Colibry LLC provides a fully U.S.-structured solution — all contracts and payments remain on American soil, while your Russian compliance obligations are handled on the ground.
When American companies announced their departure from Russia in 2022, they focused on the operational exit. What many did not fully anticipate was the legal entity problem that remains years later.
Russian-registered subsidiaries, representative offices, and joint ventures require ongoing tax filings, regulatory reporting, statutory director maintenance, and ultimately a formal liquidation process — regardless of whether any business is being conducted.
Direct financial transfers from the United States to Russia are restricted under OFAC sanctions. Hiring Russian firms directly raises further compliance questions. The result: hundreds of American companies are accumulating silent legal risk.
Colibry LLC was established to solve exactly this problem — from New York, within the full framework of U.S. law.
Over 300 U.S. companies retain Russian legal entities following operational withdrawal. Many are accumulating unpaid tax penalties and reporting violations.
OFAC sanctions make direct USD transfers to Russia effectively impossible for most U.S. companies, blocking routine tax payments and compliance fees.
U.S. persons are prohibited from providing management consulting and accounting services to Russian entities — unless those entities are owned by U.S. persons.
Voluntary liquidation of a Russian LLC takes 12–18 months and requires continuous in-country legal presence. Most U.S. companies have no one to manage it.
All engagements are structured as U.S.-to-U.S. contracts. Colibry LLC engages your company in New York. All fees are invoiced and paid in USD to a U.S. bank account. Our operational infrastructure in Russia handles the administrative requirements, eliminating the need for any direct financial transfer to Russia.
Ongoing administration of your Russian entity's statutory obligations with the Federal Tax Service and regulatory authorities.
Keeping your Russian legal entity in good standing for as long as required, with full administrative support.
Full management of voluntary liquidation from initiation through final de-registration — handled end-to-end.
Representation before Russian regulatory bodies and tax authorities in connection with your entity's compliance history.
Sanctions compliance assessment ensuring your engagement with us — and your remaining Russian obligations — are fully authorized.
Ongoing transparency into the status of your Russian entity, delivered to your legal team in the United States.
Four steps. All within U.S. legal boundaries. No direct transfers to Russia required.
Your company engages Colibry LLC under a New York-law services agreement. All terms, fees, and obligations are U.S.-to-U.S. OFAC compliance is confirmed at onboarding.
Fees are invoiced in USD and paid to Colibry's New York bank account. Tax fund advances are also held in the U.S. No wire transfers to Russia.
Colibry's Russia-based operational infrastructure handles all filings, regulatory interactions, and statutory obligations on behalf of your Russian entity.
Your U.S. legal team receives copies of all filed documents, compliance status reports, and immediate notification of any regulatory developments.
We do not advise clients to operate in legal gray areas. Every aspect of Colibry's service model has been designed around the explicit authorizations provided by OFAC for U.S. persons with Russian entities.
General License 13P (effective January 2026) expressly authorizes U.S. persons to pay taxes, fees, duties, and to obtain permits, registrations, and certifications in Russia — to the extent such transactions are ordinarily incident and necessary to day-to-day operations of a U.S.-owned entity.
The U.S. Person Exclusion under the IT and Software Services Determination confirms that services provided to Russian entities owned or controlled by U.S. persons are not prohibited — even where those same services to other Russian entities would be.
We recommend that clients involve their own outside counsel in reviewing the structure prior to engagement.
Authorizes payment of Russian taxes, fees, and statutory charges by U.S. persons for their Russian operations.
Services to Russian entities owned/controlled by U.S. persons are excluded from the management consulting prohibition.
No direct financial transfers to Russia. All fees paid in USD to Colibry's New York account.
All counterparties and client entities are screened against the OFAC SDN List prior to engagement.
Colibry does not provide management consulting, corporate formation, or accounting to non-U.S.-controlled Russian persons.
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.
Colibry is a New York-registered LLC. All contracts are governed by New York law. Your engagement never leaves U.S. legal jurisdiction, and your payments stay in the American banking system.
Deep understanding of Russian civil, tax, and corporate law — including the Federal Tax Service procedures, arbitrazh court processes, and the specific regulatory frameworks governing foreign-owned entities.
We understand U.S. sanctions not as an obstacle but as a framework. Our service model was structured from the ground up around OFAC's authorizations, not in spite of them.
Unlike legal advisory firms that can only advise, Colibry has the on-the-ground operational capacity to actually execute filings, manage communications with Russian authorities, and represent your entity in administrative proceedings.
All client engagements are treated with strict confidentiality. We understand the sensitivity of maintaining a Russian legal presence in the current environment and operate accordingly.
Based in New York City, we work in the same time zone and legal environment as your General Counsel, outside advisors at major law firms, and your compliance team.
We typically respond within one business day. Initial consultations are confidential and without obligation.
All inquiries are treated as confidential. Submission of this form does not constitute legal advice or create an attorney-client relationship.