Today, the Office of Government Ethics (OGE) issued a Legal Advisory memo explicitly stating the OGE’s view anonymous contributions to legal defense funds of federal employees are prohibited.

Legal Advisory LA-17-10 specifically refers to OGE Informal Advisory Opinion 93×21 (1993), which found employees who received anonymous donations would “be unable to favor the anonymous donors.” The new Legal Advisory memo acknowledges that shortly after the Informal Advisory Opinion was issued, the agency began “advising, and is continuing to advise, that the instruments establishing legal defense funds include a clause stating that ‘contributions shall not be accepted from anonymous sources.’”

The new memo reiterates the OGE’s position given in an interview by the head of the OGE with Politico earlier this month. The interview was made in reaction to an OGE note on the 1993 opinion that had been changed earlier this year to say the opinion’s original applicability had not changed.

Critics of the note change had said it opened the door up to lobbyists and other prohibited sources funding legal defenses for employees currently working in the White House.

Hawaii’s Governor-Elect, David Ige, is scheduled to be inaugurated on December 1, 2014. There are several things to keep in mind if you are considering involvement in inaugural events.

In Hawaii neither lobbyists nor non-lobbyists are permitted to provide event tickets to state legislators or employees.

If you intend to make a contribution to defray inaugural expenses, keep in mind contributions made or accepted for that purpose are subject to ordinary contribution limits. Individuals, partnerships, noncandidate committees, parties, associations, corporations, business entities, organizations, and labor unions may contribute up to $6,000 per election period to a candidate for a four-year statewide office.

For the offices of governor and lieutenant governor, the four-year contribution period ended on election day. Contributions made to a candidate’s committee on or after November 5, 2014, will count towards the 2018 election period limits.

Utah Representative Kraig Powell has introduced a bill prohibiting anonymous cash contributions over $50 and requiring forfeiture of the contributions.

As written in HB 493, anonymous contributions over $50 to state and local candidates must be given to the governmental entity where the position the candidate is pursuing exists, such as to a school district’s general fund for a local school board candidate. Other beneficiaries of the anonymous political donations over $50 would be the state’s general fund, and county and municipality general funds.

Reporting by the candidates of the transferred anonymous contribution would not be required.