Alleged Violations of Ethics Pledge by a Senior DOI Political Employee

We investigated allegations that a then senior political employee of the U.S. Department of the Interior (DOI) did not comply with his Federal ethics pledge under Executive Order No. 13770 when he communicated with a former employer during the required 2-year recusal period following the political employee’s Federal appointment in the fall of 2017. We identified a number of interactions between the senior political employee and representatives of the former employer—namely, several email exchanges, three phone calls, one in-person meeting, and one presentation at an event hosted by the former employer. While some of these interactions with the former employer may have been relatively minor in nature, we found that the senior political employee nonetheless did not comply with the ethics pledge because those interactions occurred during the 2-year recusal period. In contrast, we found that, under the circumstances, a presentation made by the senior political employee at an event hosted by the former employer was permissible under the ethics pledge because the senior employee attended in his official capacity. In making these findings, we note that the senior political employee told us he initially did not understand that his unpaid, volunteer position with an entity related to an organization (the former employer described above) was itself considered former employment under the ethics pledge. In fact, the organization itself as well as the related entity are considered a “former employer” under the pledge. After it was alleged that the senior political employee violated ethics rules in his interactions with the former employer, the Departmental Ethics Office (DEO) provided the senior political employee with written guidance about communications with former employers and specifically found that the organization in question qualified as a former employer under the ethics pledge. In its written guidance, the DEO acknowledged that the senior political employee had not received specific written or verbal guidance from the DEO identifying the organization as a “former employer” for purposes of the ethics pledge. We found no further communications between the senior political employee and representatives of the organization after the senior political employee received this guidance. We provided our report to the Chief of Staff for the Office of the Secretary for any action deemed appropriate.