The Office of Government Ethics, in response to what it said were growing numbers of questions about whether virtual currencies, “coins” and the like are subject to financial reporting and conflict of interest laws, has answered in the affirmative.
The reason, it says, is that virtual currency and other “digital assets” have “largely been held for investment purposes” and the laws governing both confidential and public financial disclosures by federal employees require reporting of any interest in property held for investment.
“Executive branch employees are therefore required to report their holdings of virtual currency on their public or confidential financial disclosure report, subject to applicable reporting thresholds for property held for investment or the production of income,” newly issued guidance says.
Further, virtual currency “may create a conflict of interest for employees who own it” and agencies should “analyze whether their employees’ official duties would have an effect on the value of their virtual currency, just as they would any other property held for investment or the production of income. They should also alert their employees to the potential conflict of interest risk posed by ownership of virtual currency,” it says.
