Lobbyist employers and lobbyists face a huge number of restrictions under HLOGA.   What about non-lobbyists working for lobbyist employers?   In one House memorandum, the guidance provides:

. . . The new rule prohibits gifts “from” a private entity that retains or employs lobbyists. Certainly, a gift paid for with the private entity’s funds (such as by use of a corporate credit card) would be considered a gift “from” the private entity. The new prohibition may also apply, depending on the circumstances, even when a non-lobbyist employee of an entity that retains or employs a lobbyist pays for a gift using personal funds, such as where the Member or employee knows that that donor is using personal funds to evade the application of the new rule.

 Example 4:  A non-lobbyist employee of a constituent company that retains lobbyists offers to take the district director to a $40 lunch. The company’s employee says that he intends to use his personal funds instead of company funds to avoid the prohibition on gifts from entities that retain or employ lobbyists.  The district director may not accept the lunch.