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To Recuse or Not to Recuse: OGE Updates Guidance

Client Alert | 1 min read | 07.26.16

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.

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Client Alert | 3 min read | 05.16.25

EPA Maintains Current Drinking Water Standards for PFOA and PFOS but Plans To Reconsider Other PFAS Compounds

On May 14, 2025, the Environmental Protection Agency (“EPA”) announced that it will keep the current National Primary Drinking Water Regulations (“NPDWR”) for perfluorooctanoic acid (“PFOA”) and perfluorooctane sulfonic acid (“PFOS”) under the Safe Drinking Water Act (“SDWA”), while extending the compliance deadline from 2029 to 2031. EPA further announced it plans to rescind requirements in those regulations applicable to other PFAS and mixtures of certain PFAS in drinking water. The NPDWR consists of legally enforceable primary standards and treatment techniques that apply to public water systems and guide EPA’s enforcement of the SDWA. This announcement follows EPA’s April 28, 2025 press release outlining its priorities for PFAS enforcement, which included 21 actions EPA intends to take to address PFAS and “engage with Congress and industry to establish a clear liability framework that ensures the polluter pays and passive receivers are protected.”...