National Aeronautics and 

Space Administration

Mary W. Jackson Building NASA Headquarters 

Washington, DC 20546-0001

April 17, 2024 

Reply to Attn of: General Law Practice Group

TO: Distribution

FROM: Agency Counsel for Ethics 

SUBJECT: Determination Regarding Attendance by NASA employees at the Middle East 

Institute (MEI) 77th Annual Gala Dinner on April 17, 2024 

On April 17, 2024, the Middle East Institute, a nonprofit organization under 501(c)(3) of the 

Internal Revenue Code, will host a reception and dinner at the Smithsonian American Art 

Museum (National Portrait Gallery), G & 8th Streets, NW, Washington, DC. The reception 

starts at 6:00 p.m. and the dinner is at 7:00 p.m. The event is to celebrate MEI’s mission and 

the achievements of their awardees. The MEI Visionary Award, Chairmans Award, and the 

Issam M. Fares Award for Excellence will be presented to the awardees. 

Approximately 375 people have been invited to attend. Attendees will have a diversity of 

views or interests and will include representatives from the legislative branch, state and local 

government officials, representatives from industry, employees of Federal agencies, and 

members from the foreign government space agencies. The estimated cost of the event, 

including all food and beverages, is $240 per person. The Middle East Institute is in control 

of the organizing, planning and invitations for this event. Attendance at this event will allow 

NASA attendees to exchange information regarding various NASA programs. I find that the 

event meets the requirements of a “widely attended gathering” as defined in 5 C.F.R. § 

2635.204(g)(2). 

I further determine that there is an Agency interest in having NASA personnel attend the 

event because it will provide an opportunity for the invited persons to exchange ideas and 

views pertaining to NASA’s policies, programs, and operations. NASA employees, including 

NASA employees in non-career positions who are required to sign the ethics pledge under 

Executive Order 13989, who do not have a significant role in a matter affecting the interests 

of the sponsor may accept an invitation for free attendance to the event. In those 

circumstances, I find that the Agency’s interest in attendance outweighs any concern that the 

individual may be, or may appear to be, improperly influenced in the performance of their 

duties. 

However, NASA employees who have a significant role in any pending matter affecting the 

interests of the MEI, such as procurement duties, program management, or 

negotiating or administering a Space Act Agreement, should seek a separate determination

from their local ethics counselor as to whether they may accept the invitation. 
2

You are reminded of the $20 gift exception at 5 C.F.R. § 2635.204(a), which provides that 

you may accept gifts valued at no more than $20 per occasion (and no more than $50 from 

one source in a calendar year). We understand that MEI will be providing a “gift bag” upon 

departure the retail value of these items is $25.00. NASA employees may only accept the gift 

bag and its contents if they reimburse the sponsor the market value of the gift. 

Adam F. Greenstone