Multinational Companies Operating in Russia Must Be Aware of Recent Restrictions on Disseminating Certain Information

Following Russia’s invasion of Ukraine on February 24, 2022, the Russian government has imposed several restrictions that may affect employers with operations in Russia. The restrictions prohibit:

  • Public dissemination of knowingly false information about the use of the Russian Federation’s armed forces;
  • Public actions aimed at discrediting the use of the Russian Federation’s armed forces, including calls to obstruct the use of the armed forces; and
  • Calls for foreign states to impose restrictive measures, such as political or economic sanctions against the Russian Federation, its citizens, or its legal entities.

Individuals who violate these restrictions may face administrative and criminal liability, including fines and imprisonment, including up to 15 years imprisonment for dissemination of “fake” information about the use of the Russian Federation’s armed forces.

Employers with operations in Russia should use caution when making comments about the conflict in Ukraine on social media and during public events or meetings. Employers should also notify employees about the potential consequences of making public comments about the conflict, including in their reactions to posts of others (such as “liking” or reposting someone else’s post). In addition, employers should keep in mind that providing financial, logistical, or consulting assistance to organizations and individuals may result in administrative and criminal liability if that assistance may be used against Russia’s armed forces.