All Alerts & Newsletters

To Recuse or Not to Recuse: OGE Updates Guidance


On July 26, 2016, the Office of Government Ethics issued a final rule updating the Standards of Ethical Conduct for Employees of the Executive Branch, subpart F, “Seeking Other Employment” (5 C.F.R. 2635), to clarify recusal requirements. Recusals are required when the scope of the federal employee’s duties has a “direct and predictable” effect on the financial interest of an entity with whom the employee is either negotiating prospective employment or with whom the employee has any agreement concerning prospective employment, and the final rule also adds a new section to implement the statutory notification requirements under section 17 of the STOCK Act, which applies to individuals required to file public financial disclosure reports.

Email Twitter LinkedIn Facebook Google+

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

David J. Ginsberg
Partner – Los Angeles
Phone: +1 213.443.5545

David B. Robbins
Partner – Washington, D.C.
Phone: +1 202.624.2627

Mark Ries
Senior Counsel – Washington, D.C.
Phone: +1 202.624.2794