In the Feb. 28 letter to OGE Director Walter Shaub, White House deputy counsel Stefan Passantino said he met with Conway about the incident and briefed her on federal employee ethics laws.
"We concluded that Ms. Conway acted inadvertently and is highly unlikely to do so again," he wrote. "Ms. Conway has acknowledged her understanding of the standards and has reiterated her commitment to abiding by them in the future."
"Go buy Ivanka's stuff," Conway said in a Fox News interview last month. "I'm going to give a free commercial here. Go buy it today, everybody."
After the incident last month, the OGE sent a letter to the White House calling for an investigation and review of Conway's actions -- which Shaub described as a "clear violation of the prohibition against misuse of position" -- and recommended disciplinary action.
"Other federal employees would likely be suspended for engaging in this conduct, and White House officials should not be held to a different standard," he said in a statement. "I hope that the president reconsiders his decision and that he and his staff will take their ethical obligations more seriously.”
While the OGE can still recommend a specific penalty for Conway to the White House, that recommendation would be non-binding.
Conway said last month that the president still supported her after the episode.