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LA-20-03: Conflict of Interest Analysis for Stocks under 18 U.S.C. § 208
This Legal Advisory reminds agency ethics officials that under 18 U.S.C. § 208, an employee may not participate in any particular matter that would have a direct and predictable effect on the financial interests of a company in which the employee (or any imputed person) owns stock, not merely those particular matters that would affect the stock price.