Fundraising activities and Ukraine

Many are outraged after witnessing the events in Ukraine. Understandably, there is a desire to want to reach out, assist, — to help out in some way. Often times fundraising activities or clothing drives are fashioned as a way to reach out, motivate, and provide a means for others contribute to a “good cause.”

Such activities are admirable, but they can also be problematic. Laws and regulations seek to provide a roadmap to guide Federal employees and Service Members through twists and turns associated with issues pertaining to ethics, conflicts, pressures, appearances, and official endorsements.

Before engaging in fundraising activities of any kind on a Federal or other military installation, or before seeking contributions from employees or other Service Members, make sure you coordinate through appropriate command channels, prior to the event.

In the Army, that usually means ensuring the Office of the Garrison Command has approved the event and has oversight — normally, through the installation MWR.

All fund-raising on Army installations must comply with Army Regulation 600-29 “Fundraising within the Department of the Army.”

The broad, general rule is that the Army may officially support fundraising authorized by the Combined Federal Campaign. Activities to raise funds in a Federal facility other than the CFC can be problematic because it tends to disrupt work, compete with the CFC for donations, promote an abuse of authority by superiors in relation to subordinates, and cause subordinates to contribute in order to seek favor with their supervisors. Thus, there is a legitimate need to regulate and oversee fundraising activities outside of the CFC.

Besides the CFC, there are generally four types of fundraising activities authorized within the Army. These activities are: 1) fundraising approved by the Office of Personnel Management for emergency or disaster appeals, 2) fundraising in support of Army Emergency Relief, 3) local fundraising that is scrutinized and approved IAW AR 600-29, and 4) religious fundraising conducted IAW AR 165-1.

The focus here is local fundraising drives. Army regulations permit fundraising by organizations composed primarily of Army personnel or their family members (including installation MWR activities as provided for in AR 215-1), among their own members (excluding contractor personnel) and only to benefit welfare funds for their own members. This includes informal funds such as cup and flower funds.

Fundraising for Army museums done in conjunction with private museum organizations are permitted and regulated by other specific Army regulations.

It is also permissible to occasionally fundraise in support of on-post private organizations and to conduct other limited fundraising activities to assist those in need as authorized by the Garrison Commander or heads of organizations.

Door-to-door solicitations are not permitted, normally, without an exception to policy approved through Command channels.

Most fundraising is admirable and intended to be virtuous. But, it can get complicated on Federal installations for reasons noted above. Be careful, and run fund raising events involving Federal employees or Service Members through the chain of command.

Finally, with regard to Ukraine, you should note that President Biden ordered Federal assistance to help ease the burdens on people in Europe and refugees around the world impacted by the war in Ukraine. He authorized a SPECIAL CFC SOLICITATION period that opens the CFC donation portal from April 18 through June 30, allowing you to support your favorite CFC-participating charity. Find the portal at https://cfcgiving.opm.org.

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