Companies seeking to help their Ukrainian employees safely exit Ukraine should be aware of potential risks related to the Foreign Corrupt Practices Act and other U.S. laws and regulations. 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, which bans male Ukrainian citizens, aged 18-60, from leaving Ukraine. 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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