United States Office of Government Ethics, Preventing Conflicts of Interest in the Executive Branch

Invitations from Outside Sources
April 11, 2017

Generally, a Government employee may not accept, in his or her personal capacity, invitations from outside sources for free attendance at events, such as conferences, unless certain requirements are met. The payment by an outside source of fees charged for an event is considered to be a gift under the ethics regulations. In order for a Federal employee to be able to accept any gift from an outside source, one of the exceptions to the gift rules must apply.

Even if an employee may accept a gift, employees should consider declining gifts when they believe that their integrity or impartiality would be questioned if they were to accept the gift. In making this judgment, employees may consider, for example, whether accepting the gift would provide the donor with significantly disproportionate access.
 

Exceptions to the Gift Rules

An employee may generally accept:

  • a gift valued at $20 or less, provided that the total value of gifts from the same person is not more than $50 in a calendar year;
  • a gift motivated solely by a family relationship or personal friendship; and
  • a gift based on an employee's or his or her spouse's outside business or employment.
     

Widely Attended Gathering Exception

Another exception that may apply is the "widely attended gathering" exception. If an event qualifies as a widely attended gathering, and attendance at the event has been authorized under the gift rules by the agency, the employee may accept the offer of free attendance. An agency ethics official considers several factors in order to determine whether an event qualifies as a widely attended gathering. A few of those factors are listed below:

  • Is the employee's attendance in the interest of the agency?
  • Does the agency's interest outweigh the concern that the employee may be or may appear to be improperly influenced in the performance of the employee's official duties?
  • Does the donor have interests that may be substantially affected by the employee's official duties?
  • Is someone other than the sponsor of the event paying for the cost of the employee's attendance?

The widely attended gathering exception is a complex provision of the regulations, and the list above is not a comprehensive list of all of the factors that an ethics official must consider. This page is not intended to provide a comprehensive discussion of this exception. A more detailed discussion can be found in the legal advisory, DO-07-047, issued by the U.S. Office of Government Ethics in 2007.

 

Note: Full-time political appointees are further limited with respect to gifts from outside sources. Because these appointees sign the Ethics Pledge pursuant to Executive Order 13770, they are prohibited from accepting gifts or gratuities from registered lobbyists or lobbying organizations (subject to certain exceptions).

The information on this page is not a substitute for individual advice. Agency ethics officials should be consulted about specific situations.