Summary of the Seeking Employment and Post-Employment Restrictions
SEEKING NON-FEDERAL EMPLOYMENT
18 U.S.C. § 208; 5 C.F.R. §§ 2635.601 to 2635.606
The “seeking employment” rules are more restrictive than most Federal employees realize. The financial interests of any entity with which an employee is negotiating or has an arrangement concerning future employment are deemed to be the same as the employee’s own interests for purposes of the conflict of interest rules.
There are criminal penalties if an employee participates in any DOI matters that affect the financial interests of a prospective employer. Furthermore, the Office of Government Ethics interprets any form of communication regarding prospective employment with a non-Federal source (other than requesting a job application) to be seeking employment.
An employee must receive a written waiver from an ethics counselor before the employee participates in any particular matter at DOI that affects the financial interests of a prospective employer. Such waivers are only granted in limited circumstances.
Absent a waiver, the employee is disqualified from participating in any particular matter that affects the prospective employer’s financial interests.
An employee is no longer seeking employment if:
1. Either the employee or the prospective employer unconditionally rejects the possibility of employment; or
2. Two months pass after the employee sends an unsolicited resume and the employee receives no indication of interest.
Any response to a prospective employer that defers discussions until the foreseeable future does not terminate employment discussions.
Additionally, recent cases have come to light in which employees have been officially involved, prior to leaving Government service, in defining requirements or preparing the statement of work for a contract that they anticipated being involved in after leaving Government service. One such case resulted in the employee’s felony conviction under 18 U.S.C. § 208, on the theory that the employee had taken official actions that affected his own financial interest. Employees should be careful to avoid any such situations.
Procurement Integrity Act Contact Reporting Requirement
41 U.S.C. § 423; 48 C.F.R. §§ 3.104-1 to 3.104-9
An employee may not disclose “contractor bid or proposal information” or “source selection information” other than as provided for by law.
Under the Procurement Integrity Act, if an employee, participating personally and substantially in a procurement for a contract in excess of $100,000, contacts or is contacted by an offeror in that procurement regarding possible non-Federal employment, the employee must promptly report the contact in writing to his or her supervisor and to the agency ethics official.
Post-Government Employment Restrictions
18 U.S.C. § 207
NONE OF THE PROVISIONS OF 18 U.S.C. § 207 BAR ANY FEDERAL EMPLOYEE, REGARDLESS OF RANK OR POSITION, FROM ACCEPTING EMPLOYMENT WITH ANY PRIVATE OR PUBLIC SECTOR EMPLOYER. THEY MAY, HOWEVER, RESTRICT CERTAIN COMMUNICATIONS THAT FORMER EMPLOYEES MAY MAKE AS A REPRESENTATIVE OF A THIRD PARTY BACK TO THE FEDERAL GOVERNMENT AND ON CERTAIN ASSISTANCE THEY MAY PROVIDE TO THIRD PARTIES. Your rate of pay, your pay schedule, and whether or not you were assigned to DOI from a private sector organization under the Information Technology Exchange Program (5 U.S.C., chapter 37) determine exactly which of the statute’s provisions will apply to you. Specifically, when you leave Federal service:
If you are being paid at an annual rate which is less than 86.5% of the rate of basic pay for Executive Schedule Level II (which is $153,105 for CY 2009), you will be subject to three prohibitions -- 18 U.S.C. §§ 207(a)(1), (a)(2), and (b).
If you are in a position included in Levels II through V of the Executive Schedule, or your rate of basic pay is at or above 86.5% of the rate for Executive Schedule Level II (which is $148,953 for CY 2008), you will be subject to five prohibitions -- 18 U.S.C. §§ 207(a)(1), (a)(2), (b), (c), and (f).
Executive Level I employees (very senior employees) who terminate from Federal service will be subject to the five following post-employment prohibitions -- 18 U.S.C. §§ 207(a)(1), (a)(2), (b), (d), and (f).
Finally, if you are assigned from a private sector organization to DOI under the Information Technology Exchange Program (5 U.S.C., chapter 37), you will also be subject to the prohibition contained in 18 U.S.C. § 207(l).
The post employment prohibitions are explained as follows:
18 U.S.C. § 207(a)(1). Lifetime ban on making a communication or appearance involving particular matters involving a specific party or parties.
Prohibits all former Government employees from knowingly making, with the intent to influence, any communication to or appearance before an employee of any department, agency, or court of the United States on behalf of any other person (except the United States) in connection with a particular matter involving a specific party or parties when (1) the employee was personally and substantially involved in the matter as a Government employee and when (2) the United States is a party or has a direct and substantial interest in the matter. This restriction also applies to former special Government employees. This provision does not prohibit behind-the-scenes assistance.
IMPORTANT DEFINITIONS:
"Communication to or appearance before" means representational appearances and communications before a Federal Government department, agency or court, made in an attempt to influence the federal Government concerning a particular matter in which the former employee was personally and substantially involved.
"Particular matter involving specific parties" means a proceeding affecting the rights of the parties or an isolatable transaction or related set of transactions between identifiable parties, and the United States must be a party to OR have a direct and substantial interest in the matter.
Note: The term "particular matter involving specific parties" includes any investigation, application, request for a ruling or determination, rulemaking that applies to specific parties, contract, controversy, claim, charge, accusation, arrest, or judicial or other proceeding. It does not include general rulemaking, general legislation or general policy issues.
"Personal and substantial participation" means direct participation as a Government employee through decision, approval, disapproval, recommendation, the rendering of advice, investigation or otherwise. It includes the participation of a subordinate when that subordinate was actually directed by the former employee in the matter. The participation must be of significance to the matter or form a basis for a reasonable appearance of such significance. Involvement on a peripheral issue may not be enough. A finding of substantiality should be based not only on the effort devoted to a matter, but on the importance of the effort.
Example 1. A Program Analyst in the Fish and Wildlife Service works on a lawsuit involving Q Company. After leaving Federal service, the former employee accepts a job with a consulting firm that has Q Company as a client. She is asked by the consulting firm to represent it before the Environmental Protection Agency in connection with that same lawsuit.
Example 2. A Government employee, who participated in recommending specifications for a contract awarded to Q Company for the design of certain ground water testing programs, joins Q Company and does work under the contract. He is asked to accompany a company vice-president to a meeting to state the results of a series of trial tests, and does so. No violation occurs when he provides the information to his former agency. During the meeting a dispute arises as to some terms of the contract, and he is called upon to support Q Company's position.
18 U.S.C § 207(a)(2). Two-year restriction on particular matters involving a specific party or parties where the matters were under your official responsibility
Prohibits all former Government employees from knowingly making, with the intent to influence, any communication to or appearance before an employee of any department, agency, or court of the United States on behalf of any other person (except the United States) in connection with a particular matter involving a specific party or parties when the employee knows or reasonably should know that the matter was actually pending under his or her official responsibility during their last year of Government service. This provision does not prohibit behind-the-scenes assistance.
IMPORTANT DEFINITIONS:
"Communication to or appearance before" - is defined the same way as for 18 U.S.C. § 207(a)(1).
"Particular matter involving specific parties" - is defined the same way as for 18 U.S.C. § 207(a)(1).
"Official Responsibility" - means the direct administrative or operating authority, whether intermediate or final, and either exercisable alone or with others, and either personally or through subordinates, to approve, disapprove, or otherwise direct Government action. Official responsibility is usually defined by statute, regulations, written delegation of authority or job description. AN EMPLOYEE'S RECUSAL FROM OR OTHER NON-PARTICIPATION IN A MATTER DOES NOT REMOVE IT FROM HIS OR HER OFFICIAL RESPONSIBILITY.
"Actually pending" - means the matter was in fact referred to or under consideration by persons within the employee's area of responsibility.
"Last Year of Service" - means this two-year prohibition only applies to matters that were under one's official responsibility during the former employee's last year of service.
Example 1. During his tenure as Division head, an employee’s subordinates undertook major changes in agency general enforcement standards. Eighteen months after terminating Government employment, he is asked to represent Z Company which believes it is being unfairly treated under the enforcement program. The Z Company matter first arose on a complaint filed after the Division head terminated his employment.
Example 2. Within two years after terminating, a bureau's former Budget Officer is asked to represent Q Company in a dispute arising under a contract which was in effect during her time in office. The dispute concerns an accounting formula under the contract, a matter on which a subordinate of the former officer was consulted.
18 U.S.C. § 207(b). One-year restriction on aiding and advising with regard to a trade or treaty negotiation.
For one year after Government service terminates, no former employee may knowingly REPRESENT, AID, OR ADVISE, on the basis of covered information, any other person (except the United States) concerning any ongoing trade or treaty negotiation in which, during his/her last year of Government service, he/she participated personally and substantially as an employee. Unlike the lifetime and two-year bans, this restriction prohibits behind-the-scenes assistance to anyone other than the United States in connection with the particular trade or treaty negotiation.
IMPORTANT DEFINITIONS:
"Trade negotiation" - means negotiations which the President determines to undertake to enter into a trade agreement pursuant to 19 U.S.C. § 2902, and does not include any action taken before that determination is made.
"Treaty" - means an international agreement made by the President that requires the advice and consent of the Senate.
"Covered Information" - means agency records which were accessible to the employee that he or she knew or should have known were designated as exempt from disclosure under the Freedom of Information Act and which concern a negotiation in which the employee participated personally and substantially during his or her last year of Government service.
EXAMPLE: A former employee attends a hearing on a treaty in which she had participated while in her last year of Government service. She speaks with the representative of a private party during the hearing. If, during that conversation, the former employee lends assistance to the representative, a violation occurs.
ADDITIONAL RESTRICTION THAT APPLIES ONLY TO FORMER "SENIOR EMPLOYEES"
Senior Employee means all positions included in Levels II through V of the Executive Schedule and those employees whose rate of basic pay (not including locality pay) is at or above 86.5% of the rate for Executive Schedule Level II ($153,105 for CY 2009).
18 U.S.C. § 207(c). One-year restriction on communications with one's former agency
For one year after service in a "senior" position terminates, no former "senior" employee may knowingly make, with the intent to influence, any communication to or appearance before an employee of a department or agency in which he/she served in any capacity during the one-year period prior to termination from "senior" service, if the communication or appearance is made on behalf of any other person (except the United States), in connection with any matter on which he/she seeks official action by any employee of such agency. This provision does not prohibit behind-the-scenes assistance.
IMPORTANT FACTORS:
1. Unlike the lifetime, two-year, and other one-year bans, this one-year "cooling off" ban does not require that the former employee have ever been in any way involved in the matter that is the subject of the communication or appearance.
2. This ban only prohibits communications to or appearances before employees of any department or agency in which he or she formerly served in any capacity during the one-year period prior to his or her termination from senior service. However, it does not prohibit “behind-the-scenes” assistance.
3. For most former Department of the Interior employees, the term "agency" is defined to mean each individual bureau or office within the Department. For example, the one-year restriction under 18 U.S.C. § 207(c) prohibits a former National Park Service senior employee from communications to or appearances only before the National Park Service; it does not prohibit the former senior employee from contacting any other bureau or component of the Department of the Interior, such as the U.S. Geological Survey or the Office of the Secretary.
4. Former senior employees of the Office of the Secretary, Solicitor, or Inspector General may not communicate or appear before any of those three offices, or any component of the Department that is not part of a bureau, but may appear before any bureau.
5. All bureaus under the jurisdiction of a particular Assistant Secretary shall be considered a single component for purposes of determining the scope of 18 U.S.C. § 207(c) as applied to senior employees serving on the immediate staff of that Assistant Secretary.
6. Individuals who have served as Deputy Secretary, Solicitor, Inspector General, as any of the five Assistant Secretaries, or as a Bureau Head (other than the Director of the Minerals Management Service) do not benefit from the special definition of "agency” because they serve in a position for which the rate of pay is specified in or fixed according to the Executive Schedule. (5 CFR § 2641.201(e)(2)(i)). These individuals are prohibited from communicating or appearing before any bureau or component of the Department of the Interior.
7. The matters covered by this ban are broader; they needn't involve specific parties, so the former employee could not, for example, attempt to influence general rulemaking, general policy issues, or general legislation.
Example 1. A Senior Employee of the Bureau of Reclamation leaves Government employment for private practice and shortly thereafter telephones a former associate urging that the Bureau (a) adopt a new procedure to put a ceiling on costs of grants; (b) not adopt a particular rule proposed for drug testing of Federal employees; (c) oppose a bill pending in Congress relating to Bureau of Reclamation programs.
Example 2. Eight months after he leaves, a former Senior Employee of the National Park Service is asked by his employer Z Company to represent them in a new matter pending before the Park Service. The former employee had no prior involvement in the matter and the matter was not previously pending before the Park Service when the employee worked there.
Example 3. Eight months after he leaves, a former Senior Employee of the Office of the Assistant Secretary for Fish and Wildlife and Parks is asked by his employer Z Company to represent them on separate matters pending before the Fish and Wildlife Service and the Bureau of Land Management.
ADDITIONAL RESTRICTION THAT APPLIES ONLY TO FORMER "VERY SENIOR” EMPLOYEES
Very Senior Employee means an Executive Schedule Level I employee.
Former Very Senior Employees are subject to all of the provisions that apply to Former Senior Employees, except that 18 U.S.C. § 207(d) applies to them instead of 18 U.S.C. § 207(c).
18 U.S.C. 207(d). Two-year restriction on communications with one's former agency and with any individual in an Executive Level position.
For two years after service in a “very senior” position terminates, no former “very senior” employee may knowingly make, with the intent to influence, any communication to or appearance before:
(1) Any individual appointed to an Executive Schedule position or,
(2) Any employee of a department or agency in which the former “very senior” employee served during the one-year period prior to termination from a “very senior” employee position.
The type of communication or appearance prohibited is one made on behalf of any other person (except the United States), in connection with any matter on which the former “very senior” employee seeks official action by any official or employee. This provision does not prohibit behind-the-scenes assistance.
ADDITIONAL RESTRICTION THAT APPLIES ONLY TO FORMER “SENIOR” AND "VERY SENIOR EMPLOYEES"
18 U.S.C. § 207(f). One-year restriction relating to Foreign Entities.
Prohibits former senior and very senior employees from knowingly aiding, advising or representing a foreign entity, with the intent to influence the official actions of any employee of any U.S. agency or department. This provision prohibits behind-the-scenes assistance.
IMPORTANT DEFINITIONS:
"Foreign Entity" - means a foreign government or political party as those two terms are defined in the Foreign Agents Registration Act.
Please note, this is another prohibition that not only prohibits direct representational activity by the former senior employee, but also prohibits aiding or advising others in their representation before federal entities.
ADDITIONAL RESTRICTION THAT APPLIES ONLY TO THOSE ASSIGNED TO DOI FROM A PRIVATE SECTOR ORGANIZATION UNDER THE INFORMATION TECHNOLOGY EXCHANGE PROGRAM
18 U.S.C. § 207(l). One-year ban on representing, aiding, counseling, or assisting.
For one year after the termination of his or her assignment from a private sector organization to an agency under the Information Technology Exchange Program (5 U.S.C., chapter 37), no former assignee may knowingly represent, or aid, counsel, or assist in representing any other person (other than the United States) in connection with any contract with that agency. This provision prohibits behind-the-scenes assistance.
OTHER IMPORTANT FEATURES OF 18 U.S.C. § 207
1. For the one-year prohibitions of 18 U.S.C. §§ 207 (c) and (f) and the two-year prohibition of 18 U.S.C. § 207(d): The period is measured from the date when an employee ceases to be a senior or very senior employee, not from the termination of Government service, unless the two occur simultaneously.
2. An exception is provided to all of the prohibitions of 18 U.S.C. § 207 when the post-employment activities are performed:
(a) in carrying out official duties on behalf of the United States, or
(b) in carrying out official duties as an elected official of a state or local Government.
3. Exceptions are provided to former senior or very senior employees for the one-year bans of 18 U.S.C. § 207 (c) and the two-year ban of 18 U.S.C. § 207(d) when the communication or appearance is made in carrying out official duties as an employee of and is made on behalf of:
(a) an agency or instrumentality of a State or local Government,
(b) an accredited degree-granting institution of higher education as defined in 20 U.S.C. § 1001,
(c) a hospital or medical research organization exempted and defined under 26 U.S.C. § 501 (c)(3), or
(d) a candidate for Federal or State office or an authorized committee, a national committee, a national Federal campaign committee, a State committee, or a political party. For this last exception (exception (d)) to apply, the former employee may not be employed by anyone other than a candidate, one of the specified political organizations, or a person or entity who represents or advises only such candidates or political organizations.
4. An exception is provided to all of the prohibitions of 18 U.S.C. § 207 for a former employee who is carrying out official duties as an employee or as an elected or appointed official of a tribal organization or inter-tribal consortium when communicating or appearing on behalf of such tribal organization or inter-tribal consortium in connection with any matter related to a tribal governmental activity or Federal Indian program or service pending before any department, agency, court, or commission, including any matter in which the United States is a party or has a direct and substantial interest. In order for this exception to apply, the former employee must advise, in writing, the head of the department, agency, court, or commission with which he or she is dealing or before which he or she is appearing on behalf of the tribal organization or inter-tribal consortium of any personal and substantial involvement he or she may have had as an officer or employee of the United States in connection with the matter involved. (See 25 U.S.C. § 450i(j).) Contact your ethics official if you think this exception may apply to you.
5. The restrictions of 18 U.S.C. §§ 207(a)(1), (a)(2), (c), and (d) do not apply to communications made solely for the purpose of furnishing scientific or technological information pursuant to agency procedures. The Governmentwide regulations treat this area realistically, providing for exchanges to determine the nature of technical problems facing the Government, to provide information to solve the problem, and to inform the Government of the practical significance of scientific and technological alternatives.
6. The restrictions of 18 U.S.C. §§ (c) and (d) do not prevent a former senior or very senior employee from making or providing a statement, which is based on the former employee’s own special knowledge in the particular area that is the subject of the statement, if no compensation is thereby received.
7. The restrictions of 18 U.S.C. §§ (c) and (d) do not apply to certain communications or appearances by former senior or very senior employees made solely on behalf of a candidate in his or her capacity as a candidate, an authorized committee, a national committee, a national Federal campaign committee, a State committee, or a political party.
8. Contacts with and appearances before Congress are not prohibited by 18 U.S.C. §§ (a)(1), (a)(2), (c), (d), and (f).
18 U.S.C. § 203
Prohibition Against Receiving Compensation for "Representational Services"
18 U.S.C. § 203 prohibits a former employee from receiving any compensation for "representational services" in connection with a particular matter in which the United States is a party or has a direct and substantial interest, if the covered representational services were provided at a time when the individual was a Government employee, and regardless of whether or not the individual personally provided those representational services.
"Representational services" means communications to or appearances before Federal entities with the intent to influence the Government on behalf of a third party. This includes legal and consulting services.
The prohibition applies equally to representational services rendered by the former employee personally or by another if the employee shares in the compensation. Accordingly, you would not be permitted to share in compensation received by your employer for representational services it provided to a third party, in connection with a particular matter in which the United States is a party or has a direct and substantial interest, at the time you were a Government employee.
PENALTIES
(a) Whoever engages in conduct constituting an offense of 18 U.S.C. § 207 or 18 U.S.C. § 203 shall be imprisoned for not more than one year or fined an amount not to exceed $100,000, or both.
(b) Whoever WILLFULLY engages in conduct constituting an offense of 18 U.S.C. § 207 or 18 U.S.C. § 203 shall be imprisoned for not more than five years or fined an amount not to exceed $250,000, or both.
(c) The Attorney General may bring a civil action in the appropriate U.S. District Court against any person who engages in conduct constituting an offense under 18 U.S.C. § 207 or 18 U.S.C. § 203 and, upon proof of such conduct by a preponderance of the evidence, such person shall be subject to a civil penalty of not more than $55,000 for each violation or the amount of compensation which the person received or offered for the prohibited conduct, whichever amount is greater. The imposition of such a civil penalty does not preclude any other criminal or civil statutory, common law or administrative remedy, which is available to the U.S. or any other person.
(d) If the Attorney General has reason to believe that a person is engaging in conduct constituting an offense under 18 U.S.C. § 207 or 18 U.S.C. § 203, the Attorney General may petition an appropriate U.S. district court for an order prohibiting that person from engaging in such conduct. The filing of such a petition does not preclude any other remedy which is available to the U.S. or any other person.
These penalties can be found in 18 U.S.C. § 216 (as modified by 28 C.F.R. § 85.3).
PROCUREMENT INTEGRITY ACT
41 U.S.C. § 423; 48 C.F.R. §§ 3.104-1 to 3.104-9
An employee may not disclose “contractor bid or proposal information” or “source selection information” other than as provided for by law.
If an employee is serving in one of seven specified positions (procuring contracting officer, program manager, source selection authority, etc.) or makes one of seven specified types of decisions (award a contract, establish overhead rates, approve issuance of a payment, etc.), on a contract over $10 million, the employee may not accept compensation (as an employee, consultant, officer, or director) from the contractor for one year. An employee should consult his or her ethics counselor for additional information on the Procurement Integrity Act.
Ethics Pledge Provisions for Political Appointees
Political Appointee. The term “political appointee” includes every full-time, non-career Presidential or Vice-Presidential appointee, non-career appointee in the Senior Executive Service (or other SES-type system), and appointee to a position that has been excepted from the competitive service by reason of being of a confidential or policymaking character (Schedule C and other positions excepted under comparable criteria) in an executive agency.
Revolving Door Ban: Appointees Leaving Government. A political appointee who is subject to the post-employment restrictions of 18 U.S.C. § 207(c) (see above) must abide by those restrictions for a period of 2 years following the end of his or her appointment, as opposed to the 1-year period that applies for non-political appointees.
Revolving Door Ban: Appointees Leaving Government to Lobby. A political appointee is prohibited, upon leaving Government service, from lobbying any covered executive branch official or non-career Senior Executive Service appointee for the remainder of the Administration. The term "covered executive branch official" means -
(A) the President;
(B) the Vice President;
(C) any officer or employee, or any other individual functioning in the capacity of such an officer or employee, in the Executive Office of the President;
(D) any officer or employee serving in a position in level I, II, III, IV, or V of the Executive Schedule, as designated by statute or Executive order;
(E) any member of the uniformed services whose pay
grade is at or above O-7 under section 201 of title 37; and
(F) any officer or employee serving in a position of a confidential, policy-determining, policy-making, or policy-advocating character described in section 7511(b)(2)(B) of title 5 (Schedule C employees).
OUTER CONTINENTAL SHELF LANDS ACT RESTRICTIONS
43 U.S.C. § 1355
No full-time officer or employee of the Department of the Interior who directly or indirectly discharged duties or responsibilities under the Outer Continental Shelf Lands Act, and who was at any time during the 12 months preceding the termination of his or her employment with the Department compensated under the Executive Schedule or compensated at a rate of basic pay equal to or greater than 120% of the minimum rate of basic pay for GS-15 of the General Schedule ($117,787.20 for calendar year 2009) shall--
(1) within 2 years after his or her employment with the Department has ceased--
(A) knowingly act as agent or attorney for, or otherwise represent, any other person (except the United States) in any formal or informal appearance before;
(B) with the intent to influence, make any oral or written communication on behalf of any other person (except the United States) to; or
(C) knowingly aid or assist (including behind-the-scenes assistance) in representing any other person (except the United States) in any formal or informal appearance before, any department, agency, or court of the United States, or any officer or employee thereof, in connection with any judicial or other proceeding, application, request for a ruling or other determination, regulation, order, lease, permit, rulemaking, or other particular matter involving a specific party or parties in which the United States is a party or has a direct and substantial interest which was actually pending under his or her official responsibility as an officer or employee within a period of 1 year prior to the termination of such responsibility or in which he or she participated personally and substantially as an officer or employee; or
(2) within one year after his or her employment with the Department has ceased--
(A) knowingly act as agent or attorney for, or otherwise represent, any other person (except the United States) in any formal or informal appearance before; or
(B) with the intent to influence, make any oral or written communication on behalf of any other person (except the United States) to,
the Department of the Interior, or any officer or employee thereof, in connection with any judicial, rulemaking, regulation, order, lease, permit, regulation, or other particular matter which is pending before the Department of the Interior or in which the Department has a direct and substantial interest.
ADDITIONAL CONSIDERATIONS FOR ATTORNEYS
Attorney Professional Responsibility. Attorneys are generally subject to the professional responsibility rules of the jurisdiction(s) in which they are licensed. These rules are separate and distinct from the Federal Government ethics statutes and regulations. For example, Rule 1.11 of the American Bar Association Model Rules of Professional Conduct contains special conflicts of interest provisions for former and current Government officers and employees. Accordingly, attorneys should check with their licensing jurisdiction(s) to determine whether any professional responsibility rules may impact their post-Government employment plans.
THIS DOCUMENT PROVIDES ONLY A SUMMARY OF THE SEEKING EMPLOYMENT AND POST-EMPLOYMENT RESTRICTIONS. IF YOU HAVE ANY QUESTIONS REGARDING ANY OF THESE RESTRICTIONS, YOU SHOULD SEEK THE ADVICE OF YOUR SERVICING ETHICS COUNSELOR OR THE DEPARTMENTAL ETHICS OFFICE AT:
U.S. Department of the Interior
Departmental Ethics Office
1849 C St. NW – MS 4251
Washington, D.C. 20240
(202) 208-7960