LA-14-04: Annual Update of 18 U.S.C. § 207(c) Component Designations

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June 11, 2014
LA-14-04

LEGAL ADVISORY

TO:

Designated Agency Ethics Officials

FROM:

Walter M. Shaub, Jr.
Director

SUBJECT:

Annual Update of 18 U.S.C. § 207(c) Component Designations

The Director of the Office of Government Ethics (OGE) is authorized by 18 U.S.C. § 207(h) to designate separate departmental and agency components for purposes of 18 U.S.C. § 207(c), the one-year post-employment restriction applicable to former "senior" employees. Procedures for the designation of components are prescribed in 5 C.F.R. § 2641.302(e). Current component designations are set forth in Appendix B of part 2641, as amended by Post-Employment Conflict of Interest Restrictions; Revision of Departmental Component Designations, 76 Fed. Reg. 30245 (May 25, 2011). Proposed component designations are set forth in 79 Fed. Reg. 33138 (June 10, 2014). Agencies do not need to resubmit component designations set forth in the proposed rule.

Designated Agency Ethics Officials are required by section 2641.302(e)(2) to forward to OGE by July 1 of each year "a letter stating whether components currently designated should remain designated . . . ." If your department or agency currently has components that are designated for purposes of 18 U.S.C. § 207(c) and no changes are needed, please confirm in writing by July 1, 2014 that the current list of designations in Appendix B and the proposed list at 79 Fed. Reg. 33138 do not require revision. Any request to modify the existing or proposed list of components should be submitted in accordance with the procedures set forth in section 2641.302(e) by July 1, 2014. We ask that each "parent" department or agency submit a consolidated response on behalf of all of its components. You need not reply if your department or agency currently has no designated components and you do not wish to request the designation of any component.

We very much appreciate your cooperation in this matter. If you have any questions, please contact Amy Braud, Associate Counsel, at 202-482-9215 or aebraud@oge.gov.