April 18, 2017
On April 18, 2017, the U.S. Office of Government Ethics (OGE) issued a Legal Advisory to assist agencies in identifying a “sponsor” of an event for purposes of the Free Attendance Exclusion and the Widely Attended Gatherings (WAG) Exception to the gift rules in the Standards of Ethical Conduct at 5 C.F.R. 2635.203(b)(8) and 5 C.F.R. 2635.204(g).
The Legal Advisory provides the standard for identifying a “sponsor;” lists certain activities that increase the likelihood that an individual or organization could reasonably be construed as the “sponsor” of an event; contrasts a “sponsor” from a financial contributor; and provides several examples illustrating how an agency might apply the standard discussed in the Legal Advisory to determine the identity of the “sponsor” of an event.
A copy of OGE’s Legal Advisory can be found here: https://www.oge.gov/web/OGE.nsf/All+Advisories/724E0F9C0B9054018525810600469173/$FILE/LA-17-04.pdf?open.