Regulating private military companies: a comparative study of national approaches in the United States, Turkey, and Russia

Abstract The increasing proliferation of private military companies (PMCs) has notably transformed the landscape of modern conflicts, exposing critical flaws in both International Humanitarian Law (IHL) and national regulatory frameworks. While international legal frameworks have historically sought to curtail mercenarism, they have largely failed to address the rise of PMCs, leading to legal loopholes vulnerable to state exploitation. This article conducts a comparative analysis of the regulatory approaches of the USA, Turkey, and Russia to examine whether domestic regulations in these states serve as reactive responses to international legal deficiencies or are strategically designed to exploit these deficiencies to exert control over foreign policy objectives. By categorizing these models as explicit regulation (USA), implicit regulation (Turkey), and non-regulation (Russia), the study demonstrates in three distinct models how legal deficiencies at the international level actively enable states to instrumentalize PMCs while evading responsibility for potential violations of IHL and human rights.