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ARTICLE · 22 JULY 2022

Russian Sanctions Impact Delaware Entities

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The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is prohibiting the provision of accounting, trust and corporate formation, and management services to any person in the Russian Federation.

United StatesInternational Law
Teresa M. Goody
Teresa M. Goody
Asim Grabowski-Shaikh
Asim Grabowski-Shaikh
Melissa B. Mannino
Melissa B. Mannino
Lana Muranovic
Lana Muranovic
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Key Takeaways

  • The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is prohibiting the provision of accounting, trust and corporate formation, and management services to any person in the Russian Federation.
  • The Delaware Secretary of State is currently blocking entities formed in Delaware that have a director and/or officer with an address in the Russian Federation, which precludes entities from making any filings with the Delaware Division of Corporations, to include paying their franchise tax and filing annual reports.

OFAC's Service Prohibition

On May 8, 2022, OFAC issued a Determination (May 8 Determination) pursuant to Executive Order (E.O.) 14071 of April 6, 2022 (Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression) and 31 CFR § 587.802 that certain accounting, trust and corporate formation, and management consulting services are prohibited to

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