Foreign companies in Russia live under two rulebooks at once — their home sanctions and Russian countersanctions. We handle the Russian side: who your counterparties really are, the permits Russia requires, and getting lawful payments to clear — coordinating with your OFAC or EU counsel on their regimes.
Your home regime restricts what you can do with Russia. Russian countersanctions restrict what you can do inside Russia as an ‘unfriendly’-linked party. They are not mirror images, they sometimes conflict, and satisfying one does not mean you have satisfied the other. Most costly mistakes come from checking one and assuming the other.
We do the whole Russian side of sanctions compliance. What we do not do is opine on US or EU law — that is your sanctions counsel’s role, and we coordinate with them.
We look at where your sanctions exposure actually sits — counterparties, payments, supply chain, intragroup dealings — and tell you the points worth addressing first.
For the counterparties that matter, we establish real ownership to the 50% level, bridging the gap the Russian register leaves.
We structure payments and transactions to clear on their merits, and handle the Government Commission permits the Russian side requires.
Recurring re-screening and documentation, so a clean position stays clean and evidenced rather than assumed.
The two-system problem, and what it requires of you.
Read →The 50% rule and the traps that catch practitioners.
Read →Telling a legal block from a bank's own caution.
Read →No. We handle the Russian side — real ownership, permits, payment structure — and coordinate with your OFAC or EU counsel on whether something is permissible under their law. The Russian-side facts we establish are what your sanctions adviser needs to conclude, so the two roles fit together rather than overlap.
If the payment is lawful, we work on the route and the documentation so it clears on its merits — not by pressing the bank. If a payment is genuinely prohibited, there is no route to find, and we will tell you so: the honest answer there is to change the counterparty or not proceed.
Possibly, yes — a company with a clean name can still be blocked if a listed person owns 50% or more of it, directly or through layers, and the Russian public register will not reliably show that. Establishing real ownership is exactly where a name-only check misses the exposure that matters.
That is the point of ongoing cover rather than a one-off review. Lists change in both directions and ownership structures shift, so a screen is only good for the day it is run. We keep the position current, which is what makes it something you can rely on rather than a snapshot that is already out of date.
A senior adviser will review your setup and tell you the points worth addressing first — and coordinate with your sanctions counsel from there.
ex-Big Four team · Moscow · since 2018 · © TaxWell & Partners
Practical support for international business in Russia.