OGE Issues Final Rule On Post-Employment Conflict Of Interest Restrictions

The Office of Government Ethics (OGE) issued a 42-page final rule (http://www.crowell.com/PDF/Federal-Register_06-25-08.pdf) providing guidance, including examples, on various post-employment restrictions under section 207 of title 18, including the permanent, one-year, and two-year representational bans applicable to former government employees and, relatedly, the companies that hire them. Because some of the key terms in title 207 are also used in other conflict of interest statutes and regulations -- e.g., the procurement integrity compensation ban in title 41 and FAR 3.104, as well as the conflict of interest restriction governing employment discussions between government personnel and the private sector under section 208 -- the OGE rule has broad applicability and relevance.