Companies seeking to help their Ukrainian employees safely exit Ukraine should be aware of potential risks related to the Foreign Corrupt Practices Act (FCPA) and other U.S. laws and regulations. Following Russia’s invasion of Ukraine, Ukraine’s President Volodymyr Zelensky ordered a general military mobilization and declared martial law to ban male Ukrainian citizens, aged 18-60, from leaving Ukraine.
Many companies spanning a wide variety of sectors—from banks to law firms to tech companies and non-profits—employ Ukrainians subject to this ban. Over the past few weeks, several of these companies have hired expert security firms and mercenaries to help their employees and contractors exit Ukraine safely, including by providing visa assistance and cash. Reportedly, these “evacuation efforts have been complicated by Ukraine’s decree that most men ages 18 to 60 must remain in the country.”
Considering the turmoil in Ukraine, the employers’ desire to help employees leave Ukraine safely is understandable. But in any such efforts, companies need to be mindful of the potential legal risks involved, should their assistance result in the employees’ defiance of Ukraine’s martial law decree. Besides the risk of violating Ukraine’s law, risks may arise under the FCPA, money laundering laws, the False Claims Act, 18. U.S.C. Section 1001 (False Statements to Government Officials), immigration laws, and sanctions regulations, not to mention internal corporate compliance policies.
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