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

Client Alert | 1 min read | 07.01.08

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.

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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....

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