How Intermarium Assisted a Swiss Humanitarian Foundation in Establishing Its Representative Office in Ukraine

Background: Humanitarian Mission Meets Legal Complexity

In early 2025, Fondation Hirondelle, a well-known Swiss humanitarian organization involved in media initiatives in conflict and post-conflict zones, decided to expand its boundaries and launch several humanitarian projects in Ukraine with the aim of helping to cover the war in Ukraine and train Ukrainian media.

Therefore, they decided to open their own office in Kyiv and register it as a foreign representative office in Ukraine with the aim of fully controlling it from Switzerland. A foreign non-profit representative office is an ideal way to allow them to operate on the territory of Ukraine, hire local staff and manage resources.

At first glance, this may seem simple, but the practical and regulatory realities of registering a foreign representative office in Ukraine in 2025 turned out to be much more complicated than expected.

Challenge: Navigating New Legal Waters

A Shifting Legal Landscape

Until amendments were made to a number of Laws in September 2024, registration of foreign representative offices was carried out through the Ministry of Economy of Ukraine. However, as of September 2024, the responsibility was formally transferred to the Ministry of Justice — a shift meant to streamline the process. In practice, however, the transition created a legal grey zone. Procedures were undefined. No designated officers were authorized. There was no tested pathway.

HIRONDELLE found itself in uncharted territory — and with no precedent to follow, the risks of delay or failure loomed large.

A Team Without Expats

A unique facet of the project was that the foundation’s entire Ukrainian operation would be staffed by local employees. There would be no Swiss or other foreign nationals stationed in Ukraine — at least not permanently. While this decision greatly simplified matters from a resource perspective, it also posed a legal hurdle: how to issue a temporary residence permit for a Swiss representative arriving to initiate operations?

Since this required an official card - and after legislative changes, it can only be issued by the Ministry of Justice and signed by an authorized person of the newly registered office, who had not been appointed at that time because there was no order for her appointment - the situation was not going well.

Related: Applying for a Temporary Residence Permit in Ukraine

Bank Account Woes

Ukrainian banks have long been wary of foreign representative offices due to compliance and financial monitoring risks. Unlike commercial enterprises or NGOs, representative offices face stricter due diligence. HIRONDELLE encountered obstacles in explaining the nature of their activities, documenting the Swiss headquarters’ status, and satisfying KYC requirements — all without any prior financial footprint in Ukraine.

Our Solution: Legal Foresight and Practical Execution

Step 1: Legal Strategy and Pre-registration Audit

Our team at Intermarium Law Firm began with a complete compliance review and feasibility analysis. We leveraged our experience in opening foreign representative offices in Ukraine to design a legal roadmap that could accommodate the lack of precedent at the Ministry of Justice.

We reached out directly to officials in both the Ministry of Justice and related agencies, offering model documents and requesting clarification where no formal procedures existed. In essence, we became legal pioneers — establishing not only a solution for HIRONDELLE, but also contributing to the shaping of practice for future registrations.

Step 2: Structured Documentation and Legal Translation

All documents required for the registration were carefully prepared in accordance with both Swiss legal standards and Ukrainian administrative requirements. This included:

• The parent organization’s founding documents
• Board resolutions confirming the decision to open a representative office
• Powers of attorney for our Ukrainian lawyers
• Employment agreements for Ukrainian staff
• Internal regulations adapted for Ukrainian law

Every document was notarized, apostilled, and officially translated with legal precision.

Step 3: Securing the Temporary Residence Permit

To resolve the paradox of needing a service card for a foreign representative without an authorized signer, we devised an interim legal workaround. Through careful coordination with the migration authorities and the client’s Swiss leadership, we secured a temporary authorization allowing the initial applicant to complete the residence permit process.

Learn more: Applying for a Temporary Residence Permit in Ukraine

Step 4: Banking and Compliance Mediation

We guided a Swiss fund through the complex process of opening a bank account in Ukraine. This included:

• Consulting with a number of banks to determine the optimal and most acceptable terms for the fund.
• Pre-negotiating document templates and approvals
• Offering legal opinions to confirm the non-profit and non-commercial nature of the office
• Assisting in the compliance interview process

By acting as intermediaries and legal interpreters between the Swiss client and the Ukrainian bank, we ensured the account was opened without delay.

The Outcome: Fully Operational Within Weeks

Thanks to our structured and proactive approach, Fondation Hirondelle succeeded in officially opening its representative office in Ukraine — becoming one of the first international organizations to navigate the new Ministry of Justice regime.

Their office is now fully compliant, locally staffed, and operationally efficient — all while being legally and administratively tethered to Switzerland.

Why This Case Matters

HIRONDELLE’s success represents more than just another registration — it’s a testament to how legal innovation and international cooperation can empower humanitarian work in complex environments. It shows that, even in the face of bureaucratic uncertainty, it is possible to launch meaningful initiatives with the right legal guidance.

At Intermarium, we take pride in transforming regulatory chaos into functional frameworks — not only helping clients succeed, but also shaping national legal practice in the process.

Interested in setting up your own office in Ukraine? Read more: Registration of Branches and Representative Offices in Ukraine