The Criminal Division has interpreted Section 602 as not prohibiting a federal employee’s solicitation of voluntary political contributions from other non-subordinate federal employees. However, because of the potential for coercion, express or implied, that inheres in the supervisor-subordinate relationship, contributions solicited from a subordinate are not considered “voluntary.” The 1993 Hatch Act amendments reflect this interpretation; both the criminal and civil codes, as amended, expressly prohibit the solicitation of subordinates, while allowing certain solicitations of colleagues. The 1993 law further amended Sections 602 to exempt the soliciting activities authorized by the civil Hatch Act provisions, 5 U.S.C. §§ 7323 and 7324. All officers and employees of the executive, judicial, or legislative branches of the federal government are within the class reached by Section 602. The statute does not reach persons who are paid with federal funds that have lost their “federal” character, such as state or local government employees or persons paid under federal grants. However, 18 U.S.C. §§ 600 and 601 may cover such persons. The Federal Election Campaign Act Amendments of 1979 limited Section 602 in two respects. First, the word “knowingly” was added to clarify that the solicitor must have been aware of the federal status of the person solicited. Second, the critical term “contribution” in Section 602 was linked to the definition of this term in FECA, at 5 2 U.S.C. § 30101(8), which restricts “contributions” to financial activities intended to influence a federal election. 102

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