The Office of Government Ethics has issued an annual report that serves as a reminder that among the ethical conduct policies applying to federal employees, those dealing with conflicts of interest can implicate criminal penalties as well as workplace discipline.
An annual report on prosecutions by the Justice Department under those laws, covering calendar year 2018, recites the details of 12 such cases, about the same number as in prior recent years. While the number of cases is small relative to the size of the federal workforce, the penalties assessed in those cases included probation, community service, criminal fines and penalties, restitution orders–one in the hundreds of thousands of dollars–and in several cases, imprisonment–which ranged from one day to eight years.
Meanwhile, the OGE posted a reminder to agencies that political appointees must file financial disclosure reports and then enter into ethics agreements that require them to take specific steps to avoid potential conflicts of interest related to their financial and business interests. If they fail to take the specified actions within 90 days of confirmation, the OGE can decline to certify the appointee’s annual financial report and/or notify the head of the agency and the White House.
It also issued a separate notice to agencies that any substantive changes to such agreements must have OGE approval.