The Review of OGE Form 450 Part 1

The Review of OGE Form 450 Part 1 Position Reviewed: Deputy CIO Instructors: Cheryl L. Kane-Piasecki and Patrick D. Shepherd February 11, 2020

Resources You Will Need

The Form

The Worksheet

Conflicts and Impartiality Playlist

Remedies and Exemptions List

The Guide https: //www. oge. gov/web/OGE. nsf/Resources/Confidential+Financial+Disclo sure+Guide+(2019)

Criminal Conflicts 18 U. S. C. 201 -209 208 Financial Interest 209 Supplemented Salary 208 Financial Interest 203 Representation 205 Representation 208 Financial Interest 207 Post-Employment 208 Financial 209 Interest Supplemented Salary 209 Supplemented Salary

Standards of Conduct & Agency Supplemental Standards 5 CFR 2635 et seq. Prohibited Holdings Impartiality Outside Activities Gifts/Impartia lity Outside Activities Misuse of Position Impartiality Seeking Employment Impartiality Gifts

Conflict Identification Duties Interests • What types of assignments might the employee participate in? • Could any interests disclosed on the Form 450 be affected by those assignments? • Any “prohibited holdings”?

Common Remedies Duties Interests • Recusal (unless/until another remedy is applied) • Part 2640 Exemptions • Divestiture • Resignation

Other Common Ethics Issues Requiring Counseling • Impartiality/Misuse • Current/ Former non-federal employer • Spouse’s non-federal employer • Businesses/partnerships • Outside Activity Prior Approval • Teaching, Speaking, Writing (2635. 807) • Use of title, position, information • Representational services/advocacy

Preparing for the Review Item üFiler’s Position üFiling status üForm completed/signed üCursory review Parts 1 -4 üPrioritize entries for review Relevance Nature of duties/government matters Types of entries expected/questions to ask Legal sufficiency Flag risks/note incomplete or ambiguous information Address potential conflicts FIRST

Instructions: For each item reported • Know what you are looking at • If you don’t, look it up on the internet (if applicable) • Identify the “nature” of the interest (employment, retirement, security, fund, position, etc. ) • Check the Review Guide for the specific type of entry • Record any questions/additional information needed from the filer • Identify any potential conflicts or other ethics concerns • Begin to identify (provisionally) any remedies

The Worksheet

Good Luck!