Fed Workers Should Be Careful About Donating Directly to Ukraine’s Military
Donations to an overseas government or agent have to be reported, and federal employees are responsible for ensuring their donation goes where it should.
The social media savvy of the Ukrainian government in the wake of an invasion has been both impressive and inspiring. Both citizens and government officials have channeled every means available to petition for support. Elon Musk, co-founder and CEO of Tesla, provided Starlink satellite internet connectivity, and the country is even accepting dogecoin and cryptocurrency donations.
In addition to hundreds of individual GoFundMe campaigns linked to the state, the Ukrainian government created a web page dedicated to accepting donations directly for Ukraine’s military.
Many individuals across the government and national security community are empathetic to Ukraine’s plight. A sovereign nation has been attacked, and those who have committed themselves to public service may feel particularly invested in Ukraine’s tragedy.
But when it comes to a crowdsourced conflict, those who work in the government – and particularly anyone with an active federal security clearance – may want to think twice. With so many ways to give, or be involved, many people are also beginning to ask if making a donation is legal.
The Pitfalls of Overseas Donations
In almost all cases it’s better to provide a donation with an organization that has some U.S. affiliation or branch. In rare cases individuals have actually been prosecuted for funneling money to “charities” overseas that were later found to be illegitimate. If you work in the government and hold a federal clearance, the guidance gets even trickier: Foreign Influence and Foreign Preference are two of the 13 adjudicative guidelines used to make clearance eligibility determinations. Question 20A.5 of the SF-86 application for national security positions specifically asks about “financial support for any foreign national.” Question 20B.1 goes on to ask about "providing advice or support to a foreign government."
Any donation made directly to Ukraine’s military effort would easily fall into a reportable category. Whether it would cost you your clearance or a government job is one thing, but it would certainly be a conversation starter during your next security clearance interview or upgrade. The urge to support the country of Ukraine is strong, and the Ukrainian government has been savvy in its response and in providing methods of engagement – from the creation of the International Legion of Territorial Defense of Ukraine to the National Bank of Ukraine’s Armed Forces donation page.
But it’s worth noting that any donation made to an overseas government or agent would need to be reported. And then you become responsible for ensuring that your donation is going where it should. A blank check (or dogecoin, or cryptocurrency) investment made toward a foreign government or entity isn’t without risk.
Don’t Fight the Urge to Help
The desire to support Ukraine – or any international conflict or tragedy – is spot on. But if you work in the government or hold a security clearance, the safest path to providing support is through a U.S.-based charity. And while it may be tempting to hop on that crowdfunding effort to sponsor a tank or a granny with an AK-47, your best bet is to make sure donations are non-governmental in nature and geared toward relief and aid efforts.