Prompted by Congressional and media scrutiny on federal
employees working with prospective employers, the Office of
Government Ethics has reissued a summary of the
post-employment restrictions in 18 U.S.C 207 emphasizing
their applicability to employees seeking new jobs.
The provisions covering job seeking are in subpart F,
Standards of Ethical Conduct, which state that an employee
“shall not participate personally and substantially in any
particular matter that, to his knowledge, has a direct and
predictable effect on the financial interests of a
prospective employer with whom the employee is seeking
employment.”
In this case seeking employment includes expressing interest,
“unsolicited communications by the employee, and any
response by the employee, other than rejection, to an
unsolicited overture from a prospective employer,” even if
it is through a headhunter or other intermediary, according
to OGE