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The Fourth Circuit Court of Appeals held that 18 U.S.C. § 208(a) applied to a federal employee's participation, on behalf of the government, in any application or contract in which he has a conflict of interest, not just those that involved outside suppliers of goods and services to the government.
https://scholar.google.com/scholar_case?case=10783725482547685803&q=U.S.+v.+Lund,+853+F.2d+242&hl=en&as_sdt=20006&as_vis=1