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B-212235(2) 1 (1983-11-17)

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                COMPTROLLER GENERAL OF THE UNITED STATES
                            WASHINGTON D.C. 20648      


 B-212235(')                               November 17, 19.83


 The Honorable Don Bonker
 Chairman, Subcommittee on International
   Economic Policy and Trade
 Committee on Foreign Affairs
 House of Representatives

 Dear Mr. Chairman:

      This is in response to your June 29, 1983, letter
 requesting this Office to rule on the propriety of an
 article entitled Renewal of the Export Administration Act:
 The Legislative Picture that was published in the May 30,
 1983, issue of Business America, a biweekly magazine-type
 trade publication of the Department of Commerce. -You have
 requested us to determine whether the publication of the
 article violated statutory restrictions against lobbying
 with Federal funds or any other statutory restriction. You
 have also asked us to determine who was responsible for
,publishing the article. Our view of this matter led us to
conclude that the article violated an appropriation restric-
tion against lobbying activities.

      Senator Jake Garn, Chairman, Committee on Banking,
 Housing and Urban Affairs, has asked us the same question.
.A similar report is also being sent to Senator Garn as of
this date.

                          BACKGROUND

      The International Trade Administration of the Depart-
 ment of Commerce publishes a biweekly periodical called
 Business America which usually contains a series of articles
 dealing with international trade. Individuals and busines-
 ses engaged in international commerce subscribe to this
 magazine. The index page of the May 30, 1983, issue des-
 cribed the section entitled'A Guide to Export Administra-
 tion, of which the article in question was a part, as
 follows:

      The current debate over extension of the Export
      Administration Act of 1979 has put the spotlight
      on U.S. export control policy, once of interest
      only to the exporting community. The ongoing
      review of this legislation govern ing our export
      control system provides government, U.S. exporters
      and the Congress an opportunity to balance secu-
      rity, foreign policy and commercial goals for the
      nation. In this issue.Business America tries to
      take some of the mystery out of the export control


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