Section 847 of the National Defense Authorization Act for 2008, Public Law 110-181, requires, among other things, that ethics officials maintain a database of written post-Government employment opinions provided to current or former Federal personnel that are, or were: SES, O-7 and above, in an Executive Schedule position under subchapter II of Chapter 53 of Title 5; or, subject to the Procurement Integrity Act; who expect to receive compensation from a Defense contractor within two years after leaving service in the Department. Copies of the written opinions must be retained for five years, and are subject to periodic reviews by the Department's Inspector General. To satisfy the "database" requirement, we provide an Excel Spreadsheet Example Log to capture when advisees receive "advice memos" - with a method to create links to electronic copies of such memos (if you desire). More to follow on applying the Section 847 requirements.
The status of military Reservists as they move from inactive to active duty, and back, weekend drills, and special work makes figuring out how post-Government employment rules apply particularly challenging. This quick reference table summarizes restrictions applicable to Reserve Officers in various situations.
The FY 2007 list of agencies holding DoD contracts exceeding $25,000 has been posted in the Ethics Resource Library.
The Federal Register confirms GSA's change to the minimal value rule used for interpreting the Foreign Gifts and Decorations Act. It is retroactive for foreign gifts accepted since January 1, 2008. The reference to possible changes to related thresholds in the last advisory was over exuberant. Please wait for the Office of Government Ethics to announce any increase in the current $305 level for WAGs and other minimum values.
DISCLAIMER: The purpose of this advisory is to disseminate relevant information and sources of general guidance, policy and law on Government Ethics issues to the Department of Defense ethics community. Advisories are not intended to be and should not be cited as authoritative guidance, DoD policy, or law.