Dear Ambassadors — About That ALS #IceBucketChallenge. Just. Don’t. Do. It.

— Domani Spero
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On August 17, we posted about Ambassador Heyman who took the ALS ice bucket challenge in Ottawa. (see Tweet of the Day: Ambassador to Ottawa Bruce Heyman Takes the ALS #IceBucketChallenge. Ambassador to Israel Dan Shapiro also did the ALS challenge. Today, Ambassador Kenney did the ice dunk in Bangkok without a specific mention of ALS.  There’s a reason for that.



The State Department reportedly sent out an unclassified cable (14 STATE 101474) to all missions saying that State totally supports the ALS ice water thing but there are regulations to follow. The cable basically informed the ambassadors that they shouldn’t join in the craze since regulations state that they cannot use their position for any sort of fundraising.

I suppose, if you must join the craze,you need to write an action memorandum and first get permission from the State Department. Clearances from L/Ethics and Office of Emergencies in the Diplomatic and Consular Service (M/EDCS) are required before seeking approval from the Under Secretary for Management.

Y’all, welcome to the bureaucracy!

The relevant section appears to be in 2 FAM 960 (pdf) SOLICITATION AND/OR ACCEPTANCE OF GIFTS BY THE DEPARTMENT OF STATE, excerpted below:

No Department employee may engage in solicitation or other fundraising activities for U.S. Government use or for the use of an outside organization, without prior authorization, in writing, from the Under Secretary for Management, except as specifically authorized in 2 FAM 962.1-1 through 2 FAM 962.1-11 or 3 FAM 4123.4.

In order to obtain approval from the Under Secretary for Management for a solicitation or other fundraising request, the requesting office shall prepare an action memorandum and obtain clearances from L/Ethics and the Office of Emergencies in the Diplomatic and Consular Service (M/EDCS), as well as any other relevant offices. The memorandum must include the following:

(1) As much information as possible on the project for which funds will be raised;

(2) The amount of money to be raised;

(3) The potential donors to be approached;

(4) The method of raising money, including the proposed texts for any communications to be used in the solicitation;

(5) The availability of appropriated funds or alternative sources of funding; and

(6) The importance to the U.S. Government of the proposed project.

In addition, M/EDCS will incorporate into the memorandum information concerning any prior Departmental solicitations of the targeted donors.

Approval of solicitation or other fundraising proposals requires balancing the U.S. Governmental policy interests in favor of fundraising against the potential risks of Department involvement in raising money from the private sector. This process inherently requires making judgment calls about issues, such as the importance of the project and the risks that the Department will be subjected to criticism for its activities. In deciding whether to approve a solicitation, the Under Secretary for Management should consider:

(1) The amount of money to be raised;

(2) The degree to which the Department will be directly involved in the fundraising;

(3) Whether the money is being raised for unusual or exceptional expenses (such as capital improvements), which have more frequently been approved, or for ordinary operating expenses of the Department; or

(4) Whether the involvement of the private sector adds value to the project apart from financial assistance. (For example, the financial participation of a nongovernmental group in a public-private partnership may help to establish private sector linkages with the local country.)

The requesting office shall be responsible for providing the necessary information to M/EDCS, and L/Ethics to allow a determination about whether any of these factors exist with respect to a particular proposal.

Nothing quick or easy. But one other thing to think about — if ambassadors do this for ALS, they may get nudged or challenged to do it for others.  Where do they draw the line of what they will/will not support publicly? That’s why the regs.