United States Office of Government Ethics, Preventing Conflicts of Interest in the Executive Branch

All Advisories for 1997

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11/24/1997

(Legal) 97x16: Post-Employment Restrictions; Senior Employees; 18 U.S.C. § 207(c)pdf
OGE did not create an exception to 18 U.S.C. § 207(c) for a new director position within an agency because that agency did not provide sufficient evidence to show that the imposition of section 207(c) would cause undue hardship within the meaning of section 207(c)(2)(C)(i).

11/19/1997

(Legal) 97x15: Free Attendance at Gatheringspdf
Discusses whether a board of presidentially appointed federal employees who approve free attendance for the board at gatherings, satisfied the procedural requirements when determining that the agency's interest in attending is outweighed by the risk of impropriety.

10/16/1997

(Legal) 97x13: Fundraising for a Professional Societypdf
Employees may fundraise for a professional society or other nonprofit organization, but they may not personally solicit funds from subordinates or from person known to be "prohibited sources."

09/12/1997

(Legal) 97x14: Waiver of One-Year "Cooling-Off Period"pdf
An agency's proposed waiver of the one-year "cooling-off" period in 18 U.S.C. § 207(c) under 18 U.S.C. § 207(j)(5) was appropriate. [cites former 5 C.F.R. Part 2637]

09/08/1997

(Legal) 97x12: Discussion of 14 Fundamental Principles of E.O. 12674; Development of E-Filing System for Confidential Financial Disclosurepdf
OGE does not have the authority to waive the application of the 14 fundamental principles established by Executive Order 12674 or the implementing regulation at 5 C.F.R. § Part 2635. OGE authorizes a pilot test of electronic filing for confidential financial disclosure system.

08/12/1997

(Legal) DO-97-029: 1996 Conflict of Interest Prosecution Surveypdf
1996 Conflict of Interest Prosecution Survey

06/26/1997

(Legal) 97x11: Application of Lifetime Representation Barpdf
Personal and substantial participation by a former employee in preparing damage survey reports barred her from communicating with or appearing before her former agency on behalf of her new employer.

06/25/1997

(Legal) DO-97-028: Using New OGE Form 450-Apdf
Executive branch departments and agencies are authorized to adopt a standardized certificate of no new interests (OGE Optional Form 450-A) in lieu of an annual OGE Form 450, for regular employee annual confidential disclosure filers who can make the required certifications.

06/11/1997

(Legal) DO-97-027: Waiver Consultations under 18 U.S.C. § 208(b)pdf
In situations where a waiver is sought with respect to service in an official capacity as an officer or director of a private organization, the Office of Government Ethics will provide consultation only with respect to whether the procedures set forth under paragraph (a) of 5 C.F.R. § 2640.301 have been followed, and whether the factors set forth under paragraph (b) of that section have been adequately considered.

06/02/1997

(Program) DO-97-026: Results of the Office of Government Ethics' (OGE) Agency Ethics Training Program Surveypdf
"In February 1997, OGE conducted a survey to learn more about the experiences, opinions, and needs of agency ethics officials regarding various facets of their agency ethics training programs. Ninety-four ethics officials responded to our survey questionnaire, with many adding valuable written comments. The report on the survey results is attached.

05/21/1997

(Legal) 97x10: Travel Expenses in Connection with Certain Unofficial Teaching, Speaking, and Writing Activitiespdf
Pending the final court order clarifying the reach of the appellate decision in Sanjour v. U.S., OGE issued an interim policy about the prohibition on accepting travel expenses connected with certain unofficial speech.

05/21/1997

(Legal) 97x9: Application of 18 U.S.C. § 207 Provisions to Employees of District of Columbiapdf
OGE discusses the changes made to 18 U.S.C. § 207 by the Ethics Reform Act of 1989 and the related technical amendments enacted in 1990. Certain provisions of section 207 apply to District of Columbia employees. [cites former 5 C.F.R. part 2637]

05/21/1997

(Legal) DO-97-025: Travel Expenses in Connection with Certain Unofficial Teaching, Speaking, and Writing Activitiespdf
Pending the final court order clarifying the reach of the appellate decision in Sanjour v. U.S., OGE issued an interim policy about the prohibition on accepting travel expenses connected with certain unofficial speech.

04/22/1997

(Legal) 97x8: Appearance of Impartiality and Disqualification Processpdf
5 C.F.R. § 2635.502 establishes a mechanism for an employee to determine whether "appearances" require his disqualification from an assignment and to seek authorization from an agency designee before he does participate.

04/02/1997

(Legal) 97x7: Application of 18 U.S.C. § 208 to Employee Service on Boards of Directors of Non-Federal Entitiespdf
The Office of Legal Counsel, Department of Justice, issued a memorandum addressing whether 18 U.S.C. § 208 would prohibit Federal Bureau of Investigation personnel from serving on the boards of directors of non-Federal nonprofit entities in their official capacities.

04/02/1997

(Legal) DO-97-015: Application of 18 U.S.C. § 208 to Employee Service on Boards of Directors of Non-Federal Entitiespdf
The Office of Legal Counsel, Department of Justice, issued a memorandum addressing whether 18 U.S.C. § 208 would prohibit Federal Bureau of Investigation personnel from serving on the boards of directors of non-Federal nonprofit entities in their official capacities.

03/27/1997

(Legal) 97x6: Agency Restrictions on Former Agency Employees Practicing Before the Agencypdf
18 U.S.C. § 207 cannot not be the authority upon which broader agency regulatory restrictions on former agency employees practicing before the agency in connection with certain cases are based.

03/25/1997

(Legal) 97x5: Restrictions Affecting Spouses Who Work for the Same Agencypdf
While there is no rule barring spouses from working for the same agency, there are statutory and regulatory restrictions that prevent conflicts of interest from arising in these situations.

03/21/1997

(Legal) 97x3: Use of Official Time and Government Equipment for Unofficial Purposespdf
Whether military Reservists and National Guard members may use official time and Government equipment at their civilian Federal positions depends upon whether the agency has authorized such use.

03/21/1997

(Legal) 97x4: Referring to Official Title and Position in Connection with Outside Writingpdf
An employee may not give more prominence to his Government title and position than to other biographical information that he provides in connection with outside writing.

03/05/1997

(Legal) 97x2: Disqualification during Subordinate's Job Searchpdf
OGE comments on whether 5 C.F.R. § 2635.502 should preclude a Board member at an agency from participating in a meeting, about a rulemaking, if the Board member's subordinate is discussing employment with a trade association for the industry affected by that rulemaking. [The guidance in this letter was modified by OGE Informal Advisory Letter 06 x 1 and DAEOgram DO-06-002.]

01/31/1997

(Legal) DO-97-009: 1995 Conflict of Interest Prosecution Surveypdf
1995 Conflict of Interest Prosecution Survey

01/21/1997

(Program) DO-97-007: Changes in the Ethics Agreement Compliance System for Presidential Appointees Confirmed by the Senatepdf
In the Spring 1996 edition of the Ethics Newsgram, the Office of Government Ethics (OGE) announced future changes to improve the administration of the ethics agreement compliance system for Presidential appointees confirmed by the Senate. This DAEOgram provides more details on those changes and how they will affect the system at executive branch agencies.

01/13/1997

(Legal) 97x1: Proposed Gift of Cash to Letter Carrierpdf
The Standards of Conduct prohibit an employee of the U.S. Postal Service from accepting a Christmas gift of $10 in cash from a customer on his route.