(2) Self-aggrandizement:
As noted above, the broadest form of the publicity and propaganda
restriction prohibits the use of appropriated funds "for publicity or
propaganda purposes not authorized by the Congress." A fiscal year 2003
governmentwide variation limits the restriction to activities "within
the United States."[Footnote 331]...
In a 1973 [Nixon] case, B-178528, July 27, 1973, the Republican National
Committee financed a mass mailing of copies of editorials from British
newspapers in praise of the President. The editorials were transmitted
with a letter prepared by a member of the White House staff, on State
Department letterhead stationery, and signed by the Ambassador to Great
Britain. GAO again noted the extreme difficulty in distinguishing
between disseminating information to explain or defend administration
policies, which is permissible, and similar activities designed for
purely political or partisan purposes. (See also B-194776, June 4,
1979.) In addition, a legitimate function of a foreign legation is to
communicate information on press reaction in the host country to
policies of the United States. Thus, GAO was unable to conclude that
there was any violation of the publicity and propaganda law...
Some agencies have authority to disseminate material that is
promotional rather than purely informational. For example, the Commerce
Department is charged with promoting commerce. In so doing, it entered
into a contract with the Advertising Council to undertake a national
multimedia campaign to enhance public understanding of the American
economic system. Finding that this was a reasonable means of
implementing its function and that the campaign did not "aggrandize"
the Commerce Department, GAO found nothing illegal. B-184648, Dec. 3,
1975. [Ford]
If an agency does not have promotional authority, the scope of its
permissible activities is correspondingly more restricted. For example,
GAO found the publicity and propaganda law violated when a presidential
advisory committee, whose sole function was to advise the President and
which had no promotional role, set up and implemented a public affairs
program that included the hiring of a "publicity expert." B-222758,
June 25, 1986. [Reagan]
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