8/13/2019 Eef Complete 2012-3
1/164
Encyclopedia of Ethical Failure
Department of Defense
Office of General Counsel
Standards of Conduct Office
Updated July 2012
8/13/2019 Eef Complete 2012-3
2/164
Contents
Introduction..........................................................................................................................3
Disclaimer............................................................................................................................3
Ause of !osition................................................................................................................."
#riery $1% U.S.C. & 201'(ype )iolations........................................................................10
Compensation for *epresentational Ser+ices from ,on'-ederal Sources $1% U.S.C. &
203'(ype )iolations.........................................................................................................30
Conflicts of Interest $1% U.S.C. & 20%'(ype )iolations...................................................3%
Credit Card Ause............................................................................................................../
-raud $)iolations ,ot Co+ered lseere.......................................................................40
Gamlin5 and Oter Contest )iolations............................................................................%0
Gift )iolations...................................................................................................................%2
In+ol+ement in Claims A5ainst te Go+ernment or in 6atters Affectin5 te Go+ernment
$1% U.S.C. & 20/'(ype )iolations....................................................................................%
6isuse of Go+ernment *esources.....................................................................................%7
6orale8 9elfare8 and *ecreation $69* Issues.............................................................11
!ost'mployment )iolations $1% U.S.C. & 204'(ype )iolations..................................12%
Salary for Go+ernment 9or: from ,on'Go+ernment Source $1% U.S.C. & 207'(ype
)iolations........................................................................................................................1"2
(ime and Attendance )iolations.....................................................................................1/0
(ra+el )iolations.............................................................................................................1/4
2
8/13/2019 Eef Complete 2012-3
3/164
Introduction
(e Standards of Conduct Office of te Department of Defense General
Counsel;s Office as assemled te folloin5 selection of cases of etical failure for use
as a trainin5 tool. Our 5oal is to pro+ide DoD personnel it real e
8/13/2019 Eef Complete 2012-3
4/164
Abuse of Position
Chief AuthorityA military ser+ice Cief 6aster Ser5eant aused er autority and improperly
used a 5o+ernment +eicle en se employed a 5o+ernment +eicle and tree non'
commissioned officers under er super+ision to mo+e personal property in a 5o+ernment
rental +eicle. (e soldiers elped er for 3 ours. (e Cief 6aster Ser5eant as 5i+en
a +eral arnin5 and ad+ised of te improper use of 5o+ernment +eicles and te ause
of autority.
Abuse of Position and BriberyA military ser+ice Captain used is official position as a reser+ist to otain
contracts for pri+ate sector companies it ic e ad an affiliation. In addition8 te
Captain accepted a Bfinder;s fee $i.e.8 :ic:ac:s from one company for is efforts in
elpin5 te company otain 5o+ernment contract or:. -or is si5nificant etical failure8
te Captain as Balloed to retire at te 5rade of Commander8 tou5 e ad een
selected to e an Admiral. In addition8 te Captain as dearred for one year8 ile to
of te affiliated companies entered into administrati+e a5reements $for 3 years it te
military ser+ice.
Coercion by Supervisor(e director of a na+al ealt clinic recei+ed a 38000 loan from a suordinate
after re>uestin5 tat te suordinate loan im 8000. (e 38000 apparently asn;t
enou58 oe+er8 and te director later as:ed for 108000. (is time te suordinate
declined. After te director only repaid a fraction of te 380008 te suordinate
approaced te cain of command. In addition to ein5 directed y is commandin5
officer to repay te rest of te loan8 te director as pro+ided it a ritten letter of
counselin5 re5ardin5 is unprofessional and unetical conduct.
DoD GS-12 Removed for Misuse of Authority
A GS'12 *ecreation !ro5ram 6ana5er o super+ised appro
8/13/2019 Eef Complete 2012-3
5/164
includin5 te failure to a+oid te appearance of impropriety. (e employee mo+ed into
+isitors; >uarters on a military installation ere e stayed for si< monts itout payin5
full price for is room y pressurin5 is suordinate to ac>uiesce to is payment
arran5ements. Ee also autoried an employee to ma:e a "00 a5ency e
8/13/2019 Eef Complete 2012-3
6/164
identifyin5 erself as a -ederal A5ent. (e police officer ad not as:ed to see te
employee;s identification at all. #ecause la enforcement officials may e tempted to
treat oter la enforcement officials more fa+oraly8 te Department determined te
employee presented er 5o+ernment credentials to te police officer in opes of recei+in5
more fa+orale treatment. (e federal employee did not euests. (e O!A staff ended up Bspoon
feedin5 (ruscott;s nepe. O!A staff spent numerous ours conductin5 researc on
pulicly a+ailale information8 mailin5 te nepe ard copies8 pro+idin5 te nepeit stoc: film foota5e8 and conductin5 tours and inter+ies for te nepe. (ruscott
also as:ed employees at te !iladelpia field office to escort is nepe on tours8 and to
perform demonstrations of canine dru5 detection for im. 9en (ruscott;s nepe
re>uested to +isit te A(- ead>uarters8 (ruscott alloed im to use A(- e>uipment8
includin5 te A(-;s film studio8 cameras8 and teleprompters to film inter+ies.
Additionally8 (ruscott 5a+e is nepe tree personal inter+ies8 includin5 once at te
construction site of te ne A(- uildin5 ere (ruscott8 is assistant8 and an O!A staff
memer ad to tra+el to 5i+e te inter+ie. (ruscott also used is speecriter to draft
tal:in5 points for im to use in te inter+ies. And8 as if tat ere not enou58 after te
nepe completed te +ideo and recei+ed an BA 5rade for it8 (ruscott continued to
allo im to ma:e re>uests to te A(- for su55estions on impro+in5 te +ideo. One
employee reported spendin5 four or fi+e days complyin5 it te nepe;s re>uests.
8/13/2019 Eef Complete 2012-3
7/164
(e IG as unale to tally te total numer of employees and ours tat ere
de+oted to (ruscott;s nepe8 ut estimated tat at least 20 A(- employees ere
in+ol+ed. (e IG determined tat (ruscott +iolated 5o+ernment re5ulations proiitin5
federal employees from usin5 teir office for pri+ate 5ain8 astin5 5o+ernment resources8
and influencin5 suordinates to aste 5o+ernment resources. $Office of te Inspector
General8 *eport of In+esti5ation Concernin5 Alle5ed 6ismana5ement and 6isconduct
y Carl J. (ruscott8 -ormer Director of te #ureau of Alcool8 (oacco8 -irearms and
8/13/2019 Eef Complete 2012-3
8/164
Altou5 car5es of se
8/13/2019 Eef Complete 2012-3
9/164
(e son of a ureau director as denied a rental car ecause e as too youn5.
Outra5ed8 is fater rote a scatin5 letter $on A5ency letteread to te president of te
rental car company8 and sent it off in a U.S. posta5e'paid en+elope. (e president of te
company as not amused and returned is scatin5 response to te ead of te A5ency.
As a result of is action8 te #ureau Director as treated to a four'our etics session and
a fine for personal use of official posta5e.
But3 4ud!e3 ' didn0t !et anythin!5
An offsore safety inspector found muc of te Go+ernment;s e>uipment to e in
need of repairs to meet safety standards. Ee ten referred te usiness to is roter'in'
las repair sop. (e ri5 operators smelled a rat and called te -#I. (ey disco+ered
tat8 in return for eac referral8 te roter'in'la as treatin5 te inspector to an e+enin5
it a lady of duious morals.
(e case as rou5t to trial. In is defense8 te inspector claimed tat e ad not
recei+ed a Htin5 of +alueH in return for te referral. (e =ud5e didnt uy it ' and neiter
did is ife.
se of Contractor $ime
Alle5ations ere made a5ainst a Department of Defense $DoD official re5ardin5is use of contractor employees. (e official directed to US Go+ernment contractors to
entertain an ac>uaintance e met at a conference in urope on is ealf. (ey ere
directed to ta:e te person out to lunc as ell as out on te ton te folloin5 e+enin5.
(e contractors ri5tly elie+ed tat te re>uest as improper and as a result told te
DoD official tat tey Bad oter plans. (e DoD official told tem to Bcancel tem.
(e contractors e+entually too: te ac>uaintance out tat e+enin5 for se+eral ours.
After an in+esti5ation8 it as determined tat te DoD official ad acted in
+iolation of / C-* 23/.40" y utiliin5 contractors; time improperly. Eis super+isor
counseled im and te proper reimursements ere made.
7
8/13/2019 Eef Complete 2012-3
10/164
6eterans Affairs Supervisors Push for &riends to be )ired
A re+ie found in to instances tat Department of )eterans Affairs medical
center super+isors recommended te irin5 of close personal friends itout di+ul5in5
te relationsip to uman resources staff memers. (e re+ie team recommended tat
disciplinary action e ta:en.
'nterior "fficia# A#tered Reports and ,eaed Confidentia# 'nformation(e Interior Department;s Inspector General found tat a senior official ad
repeatedly altered scientific field reports to lessen te protections for imperiled species
and ease te impact on landoners. (e in+esti5ation also re+ealed te official8 o
or:s in -is and 9ildlife Ser+ices8 misused er position y disclosin5 confidential
information to pri+ate 5roups see:in5 to affect policy decisions. (e Inspector General
referred te case to te Department Eead for Bpotential administrati+e action.
$(e Seattle (imes8 6arc 308 2004
Bribery !" #$S$C$ % &'!(Type )iolations*
&raud3 Conspiracy3 and Bribery 7 "h My5
Criminal car5es put a computer contractor out of usiness and landed
5o+ernment employees in =ail. (o ci+ilian employees at a 6ilitary Depot8 alon5 it
te contractor;s 5o+ernment sales mana5er8 ere con+icted on +arious conspiracy and
riery car5es for defraudin5 te U.S. Go+ernment under multiple contracts in return for
cas and mercandise. (e employees ere part of a sceme in ic tey used
5o+ernment funds to purcase laptops and recycled computer components from te
contractor;s sales mana5er at inflated prices8 and split te o+ercar5ed amounts amon5
temsel+es. One employee recei+ed prison time8 tree years proation8 and as orderedto pay 308000 in restitution. (e oter employee as sentenced to 22 monts in =ail8
tree years of proation8 and ordered to pay 1%8000. (e sales mana5er recei+ed a
similar sentence. (e computer contractor as indicted on nine felony counts and
su=ected to asset forfeiture of appro
8/13/2019 Eef Complete 2012-3
11/164
in fi+e oter indi+iduals car5ed it prison time and ordered to pay a comined
1248000 in restitution.
"ne thin! #eads to another
A misuse of 5o+ernment resources in+esti5ation it uneuipment y /00 a unit. (e increase as for Badditional ser+ices tat ere
supposedly needed to resol+e a defect in te e>uipment. An in+esti5ation determined tat
tese ser+ices ere unnecessary8 and tat te /00 as paid to a sell company oned y
te !6;s ife.
11
8/13/2019 Eef Complete 2012-3
12/164
(e /00 per unit as =ust te start. Ee also used a usiness tat e controlled to
purcase 5eneric e>uipment and resell it to te Go+ernment as a name rand product far
ao+e mar:et rate. (ese endea+ors pro+ed to e >uite lucrati+e8 and te !6 profited
aout 3.2 million on te scemes. (e profit as sort'li+ed8 oe+er8 as te !6 as
indicted for riery and fraud. Ee as sentenced to fi+e years in prison8 re>uired to repay
te 3.2 million and car5ed a 28"00 fine.
Contractin! "fficia# in Af!hanistan P#eads Gui#ty to Bribery
A Go+ernment employee at #a5ram Airfield8 pled 5uilty to acceptin5 ries in
e
8/13/2019 Eef Complete 2012-3
13/164
In anoter riery case at Camp Arif=an8 anoter Army 6a=or8 James 6omon8 Jr.8
accepted cas ries from fi+e DOD contractin5 firms tat supplied ottled ater and
oter 5oods and ser+ices to ases in uait. 6omon8 a contractin5 officer at te camp8
aarded contracts and #lan:et !urcase A5reement calls to tose contractors8 recei+in5
/.% million as payment for is actions. 6omon pled 5uilty to riery and conspiracy to
commit riery. Eis sentencin5 is pendin58 ut8 li:e 6urray8 6omon faces up to 1/
years in prison and a 2/08000 fine for eac riery count8 as ell as fi+e years in prison
for te conspiracy count. 6omon as also a5reed to pay /.% million in restitution.
'nhibitin! 6ictory
A 6a=or in te U.S. Army *eser+e pled 5uilty to conspiracy and riery car5es
related to DOD contracts at Camp )ictory8 Ira>. Accordin5 to te car5in5 document8
(eresa Jeanne #a:er recei+ed money and oter items8 includin5 a Earley Da+idson
motorcycle8 from a defense contractor8 *aman Corporation8 and a former employee of
anoter defense contractor8 lie Samir Cidiac. In return8 #a:er con+eyed sensiti+e
information and fraudulently aarded contracts to te contractor. #a:er also canceled
contracts tat ere aarded to tird party contractors and fraudulently re'aarded tem
to Cidiac. #a:er;s sentencin5 is pendin58 ut te maui+alent of te tin5 of +alue recei+ed. #a:er as also car5ed it tocounts of conspiracy. ac count comes it a ma
8/13/2019 Eef Complete 2012-3
14/164
of a plea a5reement and y order of te court8 (imol also a5reed to pay restitution
of 2"81"3.
Moore Misconduct
-irst Kieutenant *oert 6oore $*et. a5reed to pay 1208000 in restitution for
acceptin5 money from contractors in e
8/13/2019 Eef Complete 2012-3
15/164
and 1 million. On a side note8 te )A employee as also indicted for conductin5 post'
5o+ernment employment ne5otiations it a company se as doin5 usiness it in er
5o+ernment capacity.
Acceptin! Gifts from 6endor Resu#ts in
8/13/2019 Eef Complete 2012-3
16/164
The Facts+An employee at te Defense 6e5aCenter at elly Air -orce #ase8
(e
8/13/2019 Eef Complete 2012-3
17/164
already ta:en. A +iolation of tis la can result in fines8 imprisonment for up to 2 years8
or ot.
ot So Much of a Bri!ht Bu#b 5
The Facts+ A former super+isor in te #ureau of Indian Affairs used a
Go+ernment'issue credit card to purcase euantities of o+erpriced li5t uls
from a ,ort Da:ota company. In eualification from oldin5 Bany office of onor8 trust8 or profit under te
United States.
&AA %mp#oyee Sentenced for Bribery
A former employee of te -ederal A+iation Administration $-AA as con+icted
of riery. In carryin5 out is primary responsiility of re+iein5 and processin5
applications for -AA'issued pilot certificates8 te employee accepted ries of 28000
and an all'e
8/13/2019 Eef Complete 2012-3
18/164
for Supplemental Social Security enefits. (ey ould offer to arran5e to a+e enefits
reinstated or to complete paperor: for te indi+idual. Afterards8 tey demanded
payment for teir ser+ices.
At teir 1774 trial in Kouisiana8 a =ud5e ordered te employee to " monts
imprisonment folloed y tree years proation. (e employees usand recei+ed 30
monts imprisonment folloed y tree years proation. (ey eac paid ac:
238%07.33.
(e offense of riery occurs en a pulic official see:s or accepts anytin5 of
+alue in return for ein5 influenced in te performance of an official act.
avy %mp#oyee Sentenced for Gratuity "ffense
A ,a+y electrical foreman as sentenced for acceptin5 78300 in ille5al 5ratuities
from a Go+ernment contractor. (e foreman as con+icted of +iolatin5 1% U.S.C. 201
and as sentenced to 3 monts proation and a 108000 fine. (e electrical foreman
assisted a Go+ernment contractor in otainin5 a contract it te ,a+al Air 9arfare
Center $,A9C. (e foreman ad autority o+er certain ,a+y contracts relatin5 to
,A9C ase maintenance.
Con!ressiona# Aide Sentenced for Corrupt ActivitiesA former staff assistant to a U.S. Con5ressman as con+icted of to counts of
acceptin5 5ratuities $1% U.S.C. 201 and one count of de+isin5 and carryin5 out a sceme
to defraud te Go+ernment $1% U.S.C. 13"1. (e aide as sentenced to 1% monts
imprisonment on eac count folloed y to years proation. (e staff assistant
accepted 38400 for assistin5 indi+iduals in otainin5 permanent residency status y
sendin5 endorsements on te Con5ressmans letteread to te Immi5ration and
,aturaliation Ser+ice $I,S. (e aide as also in+ol+ed in a sceme to defraud aliens
see:in5 permanent residency. (e aide told te aliens tat if tey ere memers in te
Se+ent Day Ad+entist Curc8 tey ould e eli5ile for permanent resident status e+en
tou5 te I,S Special *eli5ious Immi5rant 9or: !ro5ram co+ers only curc or:ers
and teir immediate families o are employed y a reli5ious or5aniation. (e aliens
1%
8/13/2019 Eef Complete 2012-3
19/164
8/13/2019 Eef Complete 2012-3
20/164
recei+e te payment. (e a5ent personally 5a+e te informant a United States (reasury
cec: in te amount of 1108%4/. 9ile ridin5 in a Go+ernment'oned +eicle8 te
informant attempted to and te a5ent an en+elope it "8000 in cas. (e a5ent
responded tat te informant sould drop te en+elope in te car ecause e could not
accept te cas directly. (e informant left te money in te car and te a5ent
reco+ered it.
(e a5ent pled 5uilty pursuant to a plea a5reement to a car5e of a criminal
+iolation of 1% U.S.C. 2078 ille5al supplementation of salary. Under te plea a5reement8
te a5ent a5reed to te imposition of a fine of "8000 y te Court8 to not see:
employment it any -ederal8 state8 or local la enforcement A5ency8 and to pay a
special assessment of 2/. In e
8/13/2019 Eef Complete 2012-3
21/164
5ratuity from te Souteastern Conference for er efforts on ealf of te pastor. On
April 28 177"8 anoter forei5n national paid te staffer 28400 for assistin5 er in
applyin5 for permanent residence. (e staffer sumitted a petition to I,S on te person;s
ealf and si5ned te application as te preparer. Altou5 te application contained a
si5nature8 ic purported to e tat of te staffer8 se claimed tat it as not er
si5nature and tat se did not see te application prior to its sumission. (e staffer :ne
tat te forei5n national as not eli5ile to ecome a permanent resident of te U.S. ut
fraudulently misrepresented to er tat se as eli5ile in order to induce er to utilie
te staffer;s ser+ices.
(e staffer as car5ed it to counts of acceptin5 5ratuities for official acts
performed8 in +iolation of 1% U.S.C. 201$c$1$# and :noin5ly ma:in5 a material false
ritin5 and presentin5 it to I,S8 in +iolation of 1% U.S.C. 1001. Se as also car5ed
it acceptin5 compensation for ser+ices pro+ided in relation to matters in ic te
United States as a direct and sustantial interest8 in +iolation of 1% U.S.C. 203$a$18
and mail fraud8 in +iolation of 1% U.S.C. 13"1. (e staffer pled 5uilty to te fi+e'count
indictment on Septemer 308 1778 and as sentenced to 1% monts of incarceration on
April 1%8 1774.
Mu#tip#e Char!es Brou!ht A!ainst Air &orce "fficer and Accomp#ice forSoft+are Scheme
An Air -orce officer as dis5runtled after recei+in5 notification tat e ould not
e promoted and as soon to e discar5ed itout a retirement annuity. Ee conspired
it a ase areouse super+isor $ile also see:in5 employment it im to
unlafully transfer superseded softare from te 6acDill A-# areouse e super+ised
to a pri+ate company for suse>uent sale. Ee arran5ed it te super+isor to remo+e
softare called Oracle (ools and Dataase $Oracle. (e Air -orce officer otained
possession of o+er 7 o
8/13/2019 Eef Complete 2012-3
22/164
8/13/2019 Eef Complete 2012-3
23/164
process and initiated some of te paperor: trou5 an emassy employee. (e *SO
retained te unspent 208000 difference eteen te purcase amount and te amount e
ad een 5i+en to purcase te cars. (e security company also as re>uired to pro+ide
eapons for its security force. (e *SO arran5ed to purcase te eapons for te
security company y first attemptin5 to a+e certain firearm companies or retailers sip
te eapons to te Dominican *epulic8 notitstandin5 te fact tat te *SO did not
a+e a license to euently8 e purcased te eapons from a #altimore 5un sop after usin5
massy letteread and representin5 tat e as autoried to purcase eapons for te
State Department. (e 5un sop refused to sip te eapons to te *SO. (e *SO ten
ent to #altimore and personally purcased te eapons and sent tem in a lead'lined
diplomatic o< to te Dominican *epulic. (e *SO 5a+e most of te eapons to te
security company8 ut sold some e
8/13/2019 Eef Complete 2012-3
24/164
(e letter carrier accepted te payment8 ic ad een mar:ed in ad+ance of its
transfer. (e letter carrier as indicted under 1% U.S.C. 201$c$1$# for acceptin5
money in e
8/13/2019 Eef Complete 2012-3
25/164
A!ricu#ture %mp#oyee Sou!ht for Approvin! &raudu#ent ,oans
A former employee of te Department of A5riculture is anted for recruitin5 is
friends to fraudulently apply for farm loans and ten 5i+in5 im money in euired forms it te information re>uired for appro+al. Under tis sceme8 te
former employee appro+ed loans totalin5 1.% million. Ee collected 3"08000 for
imself.
(e former employee as een car5ed it 7% counts includin5 / for riery.
Seven A!ricu#ture 'nspectors Sentenced for Bribery Scheme
Se+en U.S. Dept. of A5riculture fruit and +e5etale inspectors ere con+icted of
operatin5 a sceme in ic tey recei+ed cas payments from fruit and +e5etale
olesalers in return for te inspectors assi5nin5 loer 5rades to teir produce. (e
loer 5rade meant tat te olesaler could pay te 5roer a loer price for te produce
and ten re'sell it at te i5er 5rade.
All pled 5uilty to one count of riery eac. #riery occurs en a pulic official
see:s or accepts anytin5 of +alue $suc as cas in return for ein5 influenced in te
performance of an official act $suc as assi5nin5 produce 5rades.
'S 'nspector Accepts Bribes
A former Immi5ration and ,aturaliation Ser+ice inspector as sentenced for
acceptin5 ries in return for alloin5 smu55lers to import cocaine into te United States
across te order it 6e
8/13/2019 Eef Complete 2012-3
26/164
improperly told a contractor tat tey ould proaly in a contract. In return8 te
contractor 5ranted a su'contract to te -E9A employee;s ife;s Bconsultin5 firm.
(e employee;s ife ad no i5ay en5ineerin5 education or e
8/13/2019 Eef Complete 2012-3
27/164
SOCO6;s 1.% illion procurement ud5et. (e consultin5 company ten made ille5al
payments to te retired lieutenant colonel in e
8/13/2019 Eef Complete 2012-3
28/164
of 4/08000. Ee also must repay te 5o+ernment 3. million and forfeit 3. million in
assets. (e lieutenant colonels case is still pendin5.
(Source: Washington Post, February 2, 2!" #pril $!, 2!%
Car!o Contractor &aces E /ears for Bribery
A ,a+y contractor at te Space and ,a+al 9arfare Systems Center Carleston
Detacment pled 5uilty to acceptin5 ries from a frei5t forardin5 company. In
e
8/13/2019 Eef Complete 2012-3
29/164
(o or:ers at te )eterans Affair;s Consolidated 6ail Outpatient !armacy8
ic mails prescriptions to +eterans8 ere car5ed it ta:in5 :ic:ac:s for purcasin5
a product from a supplier at more tan tice te normal price. (e productP *ed tape.
(e employees ere car5ed it purcasin5 1008000 rolls of te tape8 ic is stamped
it te ord Bsecurity and is meant to deter tamperin58 at .7/ a roll rater tan its
2./0 retail +alue. In return8 tey recei+ed :ic:ac:s of more tan 1 per roll.
(e duo ill a+e plenty of time to appreciate te irony of teir situation8 as tey
face a sentence of 1/ years in =ail.
Rese##in! Commissary Goods ,ands $+o in Court
A sceme to resell military commissary atteries on te lac: mar:et resulted in
car5es filed a5ainst a +eteran and a Department of Defense employee. In+esti5ators
disco+ered tat te +eteran as riin5 te employee to sell im lar5e >uantities of
atteries from a commissary8 ic te +eteran ten resold at a profit to a distriutor.
Durin5 a one'year period8 te employee sold te +eteran 4/08000 ort of atteries8
ic netted a 208000 profit on te lac: mar:et. (e +eteran :ept 118000 of te
proceeds8 and :ic:ed ac: te remainin5 7000 to te employee.
(e +eteran pled 5uilty to a misdemeanor car5e of supplementin5 te salary of a-ederal employee8 and as sentenced to one year of proation. (e employee as
car5ed it riery and ta:en to court. It is ille5al for indi+iduals to eiter pay or
recei+e salary supplements for ser+ices performed y Go+ernment employees related to
teir Go+ernment duties.
Acceptin! Ficbacs %arns Contractor 11 /ears
A federal in+esti5ation into riery ended in tree fraud con+ictions for te Cief
of !lans8 *e>uirements8 and Ac>uisitions for te Defense Systems A5ency at te ,a+y
Sip !arts Control Center. (e Department of Defense employee accepted /008000 in
cas in e
8/13/2019 Eef Complete 2012-3
30/164
8/13/2019 Eef Complete 2012-3
31/164
9anted %mp#oyee 9ho 9i## ot Sip Meetin!s to 'ntervie+ +ith "ther
Companies
An Army #ri5adier General participated personally and sustantially as an
ad+ocate and appro+al autority in te effort to increase fundin5 on a tas: order it a
Go+ernment contractor e+en ile acti+ely see:in5 employment it tat company. Eis
efforts did not rise to te le+el of Bne5otiatin5 employment so e did not +iolate te
criminal proiition of 1% U.S.C. N20%8 ut as still in +iolation of C.-.*. 23/.0"
en e too: official action on ealf of a company it ic e as see:in5
employment instead of dis>ualifyin5 imself from te particular matter. Ee also
e
8/13/2019 Eef Complete 2012-3
32/164
A former employee of te Department of (ransportation as sentenced in te
U.S. District Court for te astern District of (e
8/13/2019 Eef Complete 2012-3
33/164
(e cler: pled 5uilty on Octoer 138 17778 to a misdemeanor +iolation of 1%
U.S.C. 203$a$18 for recei+in5 compensation for representational ser+ices rendered in
a particular matter efore a department or A5ency of te United States. On 6arc 108
20008 te moonli5tin5 employee as sentenced to pay 2/.
Con!ressiona# Staffer Accepts Cash in Return for Assistance +ith 'S
A Con5ressional staff assistant for a memer of Con5ress as assistin5 a
constituent it filin5 an application to normalie te immi5ration status of te
constituents dau5ter. 9ile doin5 so8 e solicited and recei+ed money from te
constituent in e
8/13/2019 Eef Complete 2012-3
34/164
si5ned a one'year contract it a local le+ee oard to perform an economic study. (e
contract called for te I*S employee to e paid %/ per our e recei+ed approuested tat te money e pro+ided in cas and arran5ed for it to e
deli+ered outside of te Con5ressoman;s office ere e or:ed. (e citien later
reported te matter to te -#I o introduced an underco+er -#I a5ent o purported to
a+e a or:ers compensation claim. In tape'recorded con+ersations it te under'co+er
a5ent8 te staffer solicited /0 from te a5ent. (e pay'off as +ideotaped. 9en
inter+ieed se+eral days later8 e initially stated e ne+er accepted money from a
constituent. 9en son a poto of te -#I a5ent8 e stated tat e ad een offered
money y er ut ad turned er don. 9en told tat te person in te poto as an
-#I a5ent8 te staffer statedM HI 5uess Im in a lot of troule8 arent IPH
3"
8/13/2019 Eef Complete 2012-3
35/164
Ee as car5ed it +iolations of 1% U.S.C. 201 and 203 and pled 5uilty to one
count of +iolatin5 1% U.S.C. 203. Ee recei+ed a sentence of proation and community
ser+ice8 and as ordered to pay restitution.
D"$ %mp#oyee Sentenced for 1H (S(C( 2=I 6io#ation
A former US Department of (ransportation employee as sentenced in US
District Court for recei+in5 unautoried compensation from a Go+ernment contractor
for representin5 te contractor on a contract id to te Go+ernment. (e former official
admitted tat e assisted a DO( contractor in te preparation of a id pac:a5e for a 1
million Go+ernment contract. (e =ud5e sentenced te former employee to a year of
proation and to pay a 28/00 fine.
Department of ,abor Associate Deputy nder Secretary 6io#ates 1H (S(C( 2=I
(e Associate Deputy Under Secretary for International Kaor Affairs at te
Department of Kaor as in+ol+ed in an effort to promote lo'income ousin5
susidied y te 6e
8/13/2019 Eef Complete 2012-3
36/164
pro=ect. (e pro=ect in+ol+ed te uildin5 of 8000 condominiums and ould 5enerate
aout 1080008000 in net profits. (e anticipated total cost of te pro=ect as in euestion8 re>uested tra+el autoriations and sumitted tra+el
+oucers to te Go+ernment for tra+el to 6e
8/13/2019 Eef Complete 2012-3
37/164
Ee pled 5uilty on ,o+emer 1%8 17728 to one misdemeanor count of +iolatin5 1%
U.S.C. 203 and as sentenced to one year of super+ised proation8 to pay full restitution
of 284008 and a /8000 ci+il fine.
CitiJen Gives '##e!a# Payoffs to 'RS %mp#oyee
(e defendant as audited y te Internal *e+enue Ser+ice for euipment8 and cas if
te a5ent ould elp im it is ta< prolems. (e a5ent reported is offer to I*S
internal security. Suse>uent discussions eteen te citien and te I*S a5ent8
accompanied y payments of 2"0 and 200 in cas to te I*S a5ent8 ere monitored y
I*S internal security.
(e citien pled 5uilty to a +iolation of 1% U.S.C. 2038 for compensatin5 a
Go+ernment employee for representational ser+ices it respect to a particular matter in
ic te United States ad a sustantial interest. (e defendant as 5i+en a sentence of
proation.
Con!ressiona# Staff Member P#eads Gui#ty to 1H (S(C( 2=I 6io#ation
(e defendant as a staff assistant to a U.S. Con5ressman in a district office in
Geor5ia ose responsiilities included andlin5 constituent re>uests. (e stafferdemanded and recei+ed a payment of 300 from a usinessman o as see:in5 a
-ederal 5rant to elp im start up a usiness. (e staffer also demanded a percenta5e of
any 5rant money aarded to te usinessman. Ee told te constituent tat e ould a+e
to or: ni5ts and ee:ends on is on time to elp te constituent and tat te money
as to compensate im for te or:.
(e staffer as indicted for personally see:in5 payment for official acts in
+iolation of 1% U.S.C. 201$c and for demandin5 compensation for representational
ser+ices efore te United States in +iolation of 1% U.S.C. 203. Ee pled 5uilty to te N
203 +iolation and recei+ed a sentence of proation.
And the A+ard Goes to7"ur Sponsor5
34
8/13/2019 Eef Complete 2012-3
38/164
(e Director of te ,ational Cancer Institute at te ,ational Institutes of Eealt
accepted a cas aard from a 5rant recipient ospital. (e doctor recused imself for a
period of four ee:s around te date of te aard presentation from any dealin5s it
te aardin5 ospital and noted te receipt of te aard on is financial disclosure
paperor:. Of course8 tis still lea+es te >uestion of eter te doctor as permitted
y statute to accept 5ifts from te donor or5aniation ? ic fell under te proiited
sources classification for purposes of te 5ift an ecause of te doctor;s potential
influence o+er te selection of 5rant recipients. Con5ress as re>uested documentation
on all ,IE aard recipients so stay tuned.
Conflicts of Interest !" #$S$C$ % &'"(Type )iolations*
Documentin! Misconduct
Jeffrey Da+is8 a former employee of te ,ational Arci+es and *ecords
Administration $,A*A8 faces a efty penalty for en5a5in5 in a felony conflict of
interest. 6r. Da+is ser+ed as an Arci+es (ecnician at ,A*A8 a position in ic e
assisted te pulic it re>uests for court documents maintained y ,A*A. Ee also
oned and operated a company tat car5ed its customers a fee for otainin5 court
records in addition to te fees car5ed y ,A*A. -rom Septemer 2004 to Octoer
200%8 Da+is used is official position at ,A*A to retrie+e court documents for is
company;s customers. Ee also did not pay ,A*A te applicale fees associated it te
company;s customer re>uests for court records in order to conceal from ,A*A is
affiliation it is company and to increase is company;s profits.
Da+is pled 5uilty to recei+in5 payments from is company in connection it te
retrie+al of court records from ,A*A usin5 is official position. Ee admitted suc
payments ere an ille5al supplementation of te salary paid y te 5o+ernment as
compensation for is ser+ices as a ,A*A employee. Da+is; sentencin5 is pendin58 ut
e faces te possiility of fi+e years in prison and a 2/08000 fine. It loo:s li:e is court
records usiness as left im it a court record of is on.
"ne )appy &ami#y Spends $ime $o!ether in 4ai#
3%
8/13/2019 Eef Complete 2012-3
39/164
A former pro5rams director for te General Ser+ices Administration admitted to
usin5 is position at -ort 6onmout to aard payments from te 5o+ernment to imself
and is family. (e former employee did tis y aardin5 pro=ects to to contractors
o in turn ired te employee;s personal usiness enterprise and is dau5ter as
sucontractors. O+er te course of tree years8 tey recei+ed o+er %008000 in fees from
te 5o+ernment te only catc8 neiter te employee;s personal usiness nor is
dau5ter actually performed any ser+ices for te 5o+ernment at all. Aside from te
o+ious fraud to ic te former employee8 is ife8 and is dau5ter pled 5uilty8
federal la also proiits federal employees from ma:in5 decisions concernin5 matters
in ic tey or teir family memers a+e a personal financial interest. +en if te
former GSA employee and is dau5ter ad actually rendered te ser+ices tat tey
illed for8 te former employee ould still a+e een in +iolation of federal la y
aardin5 te pro=ects to te contractors in te first place ecause is on financial
interests ere in+ol+ed. (e former GSA employee and is family ere ordered to pay
o+er %008000 in restitution8 and tey eac recei+ed prison sentences ran5in5 from 12 to
" monts.
Moon#i!htin! for Contractor Resu#ts in %mp#oyee $ermination
A contract mana5er at a (ennessee )alley Autority $()A poer plant inentuc:y found imself out to =os after in+esti5ators learned tat e ad een
moonli5tin5 for te same contractor e as o+erseein5. As part of is responsiilities
it ()A8 te contract mana5er re+ieed contractor ids and o+ersa contract
performance. (e mana5er accepted a =o it one of ()A;s contractors as a part'time
super+isor8 and or:ed for te contractor in O:laoma and Indiana on is days off and
+acation days.
+en tou5 te mana5er;s actions did not result in any identified financial loss8
e as terminated from ()A and prosecuted for a +iolation of 1% U.S.C. 20%. Ee pled
5uilty and as sentenced to proation and a 18000 fine.
(is criminal statute proiits personnel from participatin5 in official actions
$suc as re+iein5 contractor ids tat affect teir employer8 e+en if tey or: for tat
employer only part time.
37
8/13/2019 Eef Complete 2012-3
40/164
A+ardin! Contracts to &riend %arns %mp#oyee &ive /ears Probation
In+esti5ators >uic:ly sort'circuited te plans of a ,ASA employee to cas in on
an a5ency electrical ser+ices contract. (e employee or:ed as a communications
specialist at Kan5ley *esearc Center $Ka*S8 and as responsile for re+iein5 and
appro+in5 or: done on a pro=ect to install ne Btelecommunications closets in Ka*S.
(e employee recommended tat te main pro=ect contactor ire a certain sucontractor8
ic coincidentally as olly oned and operated y te employee;s friend. (e
prime contractor a5reed. (e sucontractor completed te or:8 and suse>uently id on
anoter sucontract. Upon recei+in5 tis second contract8 te sucontractor co+ertly
ired anoter company to complete te or: tis company as olly oned and
operated y te ,ASA employee imself. At tis point8 tipsters notified in+esti5ators8
o found tat te scam ad netted te pair o+er "08000.
(e employee pled 5uilty to +iolatin5 te conflict of interest statute8 and as
sentenced to fi+e years of proation and a /8000 fine. (is conflict of interest statute
proiits personnel from participatin5 in official actions $includin5 merely ma:in5 a
recommendation tat affect teir financial interests.
A+ardin! Contracts to Spouse %arns Coup#e "ne /ear in Prison
A former Department of te (reasury employee and er usand ere sentenced
to a year in prison for a sceme to funnel contracts to companies tey personally
controlled. (e employee8 o ser+ed as an mployee De+elopment Specialist8 as
responsile for determinin5 te trainin5 needs of (reasury employees and procurin5
pri+ate trainin5 ser+ices. In+esti5ators disco+ered tat o+er te course of to years8 te
employee ad aarded 10/ trainin5 contracts +alued at more tan 137800 to companies
oned y er usand.
(e employee pled 5uilty to se+eral car5es8 includin5 +iolations of 1% U.S.C.
20%8 participatin5 personally and sustantially in matters in ic se or er spouse ad a
financial interest. Se as sentenced to a year of prison and tree years super+ised
release8 and as ordered to pay /"8/00 in restitution. Eer usand also pled 5uilty to
se+eral car5es8 includin5 ire fraud and conspiracy8 and recei+ed te same sentence as
is ife.
"0
8/13/2019 Eef Complete 2012-3
41/164
A+ardin! Contracts to Spouse ''
A contractin5 officer for te General Ser+ices Administration $GSA ound up in
-ederal court after funnelin5 contracts to er usand;s employer. In+esti5ators
disco+ered tat te officer ad directed o+er 11./ million to te company tat employed
er usand o+er te span of 1/ monts8 all in te form of GSA purcases of food
preparation and ser+in5 e>uipment items. As a result of tese purcases8 te officer;s
usand recei+ed raises and a Ja5uar from is employer.
(e officer pled 5uilty to +iolatin5 conflict of interest las8 and as sentenced to
1%0 days of ome confinement and fi+e years of proation. Se additionally as ordered
to pay 118000 in restitution.
A+ardin! Contracts to Spouse '''
(e ead of te Ka nforcement Coordinatin5 Committee !ro5ram at te U.S.
Attorney;s Office for te 6iddle District of Kouisiana disco+ered e ad done is =o too
ell en e as arrested and prosecuted for +iolatin5 conflict of interest las.
Autorities learned tat te employee8 o as responsile for arran5in5 trainin5
seminars tat ould foster cooperation it state and local la enforcement8 ad
funneled seminar contracts to a certain company tis company ten sucontracted to a
company oned y te employee;s ife. (is sceme ad funneled //8000 to te
employee;s ife8 and te company ad :ic:ed ac: 208000 directly to te employee
imself.
(e employee pled 5uilty to +iolatin5 1% U.S.C. 20%8 participatin5 personally and
sustantially in a matter in ic e or is spouse ad a financial interest8 and as
sentenced to tree years of proation8 200 ours of community ser+ice8 and a /8000 fine.
And the Band P#ayed "n79hi#e the Ship San Around $hem
An Assistant Secretary of (elecommunications and Information itin te
Department of Commerce spo:e it etics officers aout a small dinner party se as
a+in5 at er ome ut ne5lected to mentionM a te party as for eteen 0 and %0
people and it as paid for y companies se as responsile for re5ulatin5. Altou5
"1
8/13/2019 Eef Complete 2012-3
42/164
te etics officers found er to e in +iolation of te department;s re5ulations8 te Justice
Department elected not to press criminal car5es.
9atch Promotin! /our Business on Government $ime5
The Facts+A Senior Ad+isor to te State Department ad an interest in a usiness
tat planned to de+elop a teme par: in te 6iddle ast. ,o prolem tere. #ut te
Ad+isor8 in is official position8 recommended to oter State Department officials tat te
State Department support te enterprise. (at +iolated te la. After a 5uilty plea8 e
as sentenced to a year of proation and ordered to perform 2/ ours community ser+ice
and to pay a 208000 fine. $SourceMFederal Ethics Report8 Dec. 2000.
The ,a-+1% U.S.C. N 20% $2003 forids any employee of te e
8/13/2019 Eef Complete 2012-3
43/164
or se8 or any person or or5aniation it om e is se is ne5otiatin5 employment8 as
a financial interest. Anyone +iolatin5 tis la Bsall e imprisoned for not more tan one
year8 fined8 or ot $see1% U.S.C. N 21. #y ma:in5 a recommendation on a contract
in+ol+in5 a company it ic e as ne5otiatin5 employment8 te official in tis case
+iolated te la.
4ud!e 'mposes Steep Prison Sentence in Conf#ict of 'nterest Case
A former employee of te District of Columia Go+ernment as sentenced in te
U.S. District Court for te District of Columia for o+erseein5 contracts in+ol+in5 an
indi+idual it om e as financially in+ol+ed. (e former employee ser+ed as cief
of te day pro5rams ranc of te D.C. 6ental *etardation and De+elopmental
Disailities Administration. (is Administration placed mentally retarded adults in non'
residential day pro5rams. (e former employee super+ised te assi5nment of mentally
retarded adults to day pro5rams and administered te rules 5o+ernin5 tese pro5rams.
Durin5 tis time8 te former employee assisted a oman in startin5 up a day treatment
pro5ram for mentally retarded adults. (e former employee made loans to te oman
and referred clients to er. (us8 te former employee ad a financial relationsip it
te oman. (e former employee as no lon5er impartial since e ad a financial
interest in seein5 er succeed so is loan could e paid ac:. In addition8 as part of is
D.C. Go+ernment duties8 e o+ersa te super+ision of er company. 9en se ould
pay ac: a portion of te loan8 se ould also pay im additional monies.
(e =ury found te former employee 5uilty of conspiracy and of +iolation of te
conflict'of'interest la. !articularly ecause of te in+ol+ement of a +ulnerale +ictim
$te mentally retarded indi+iduals in te day pro5ram8 te =ud5e sentenced te former
employee to " monts in prison8 folloed y 3 years of super+ised release to include
100 ours of community ser+ice. (e =ud5e also ordered te former employee to pay a
2/8000 fine.
-ederal conflict of interest statutes proiit employees from ta:in5 official action
in particular matters in ic tey a+e a financial interest.
"3
8/13/2019 Eef Complete 2012-3
44/164
&edera# %mp#oyee Convicted of Conf#ict of 'nterest 6io#ation 9hi#e Searchin!
for e+ 4ob
Jo'untin5 efforts y a former Commerce Department Inspector General $IG
turned up a -ederal con+iction for a conflict of interest instead of a =o. As part of te
former IGs official duties8 e re+ieed te performance of a certain company8 ic ad
contracted it te Commerce Department to update automated eater forecastin5
systems. At te same time tat e as performin5 tese o+ersi5t duties8 te former
official e5an ne5otiatin5 employment it te same company.
A -ederal criminal statute8 1% U.S.C. 20%8 proiits -ederal employees from
officially or:in5 on particular matters tat a+e a direct and predictale effect on an
or5aniation it ic tey are ne5otiatin5 prospecti+e employment. (e former IGs
re+ie of te companys performance on te Commerce Department contract +iolated
tis statute. (is is te same statute tat ars -ederal employees from ta:in5 official
action on matters tat affect teir on financial interests or tose of teir spouses or
cildren.
C'A Conf#ict of 'nterest
A CIA employee paid "%8000 to settle a complaint rou5t y te Department of
Justice tat te employee ad participated in official matters in ic is spouse ad a
financial interest. (e employee ad ser+ed as te Contractin5 Officer (ecnical
*epresentati+e $CO(* on certain contracts eteen is a5ency and a pri+ate
corporation8 ere is ife or:ed. (e contracts in+ol+ed millions of dollars aarded
to te corporation. Altou5 te employees ife did not or: on te same contracts as
te employee8 se recei+ed stoc: options for te purcase of te corporation;s stoc: tat
ere affected y te corporations profits from te contracts er usand ad or:ed on.
A criminal statute8 1% U.S.C. 20%8 proiits employees from participatin5
personally and sustantially in matters tat a+e a direct and predictale effect on teir
on financial interests or tose of teir spouses8 minor cildren8 or or5aniations in
ic tey are employed. In tis case8 te employees in+ol+ement in te corporation;s
contracts affected te profitaility of te corporation8 ic as passed on to te
employees ife trou5 er stoc: options.
""
8/13/2019 Eef Complete 2012-3
45/164
&ormer Postmaster Genera# Pays Sett#ement to %nd Conf#ict of 'nterest
'nvesti!ation
A former !ostmaster General of te United States a5reed to pay a 248//0
settlement to end a complaint rou5t y te Department of Justice pertainin5 to a
conflict of interest in+ol+in5 te official;s oldin5s in a soft drin: company. (e
complaint arose ile te !ostal Ser+ice as e
8/13/2019 Eef Complete 2012-3
46/164
(e official a5reed to pay te Department of te (reasury 2380"38 ic
represented te increased +alue of te stoc:s8 to settle te matter.
D(C( Pub#ic ,ibrary Director Sentenced for $rave# Reimbursement Scheme
(e former director of te District of Columia !ulic Kirary as con+icted for
fraudulent acti+ities in+ol+in5 Go+ernment cas ad+ances and reimursement payments.
At te time8 te director as ser+in5 as ot te ead of te D.C. !ulic Kirary and te
president of a trade or5aniation8 te American Kirary Association. (e director too:
cas ad+ances from D.C. !ulic Kirary funds to pay for e
8/13/2019 Eef Complete 2012-3
47/164
(e former a5ent as sentenced to to monts imprisonment folloed y tree
years of super+ised release for is +iolation of 1% U.S.C. 20%. (is statute ars -ederal
employees from officially participatin5 $in tis case8 e+en ma:in5 a recommendation in
particular matters $in tis case8 a contract to uy pepper spray tat a+e a direct and
predictale effect on te employee;s financial interests or tose of te employee;s spouse
or minor cildren.
Army %mp#oyee Sentenced for Conf#icts of 'nterest
A ci+ilian employee of te U.S. Army pleaded 5uilty to +iolation of te conflicts
of interest statute $1% U.S.C. 20% in -ederal Court and as sentenced to one year
proation and a 18000 fine. (e employee ad participated in te aardin5 and
administration of contracts in+ol+in5 a company in ic te employee oned stoc:8
terey participatin5 personally and sustantially as a Go+ernment employee in matters
tat affected is financial interests. (e employee8 o filed financial disclosure
statements $OG -orm "/08 ad also failed to disclose is financial interest in te
company.
Chief &inancia# "fficer and Chief 'nformation "fficer of the nited States
Department of %ducation 6io#ates 1H (S(C( 2=H
9ile te official eld te ao+e titles at te Department of ducation8 is ife
oned 00 sares of Compa> computer stoc: tat se ad inerited from er moter.
Durin5 tis period8 te official as in+ol+ed in is official capacity in issues concernin5
Compa> computers. (e Go+ernment contended tat te official +iolated 1% U.S.C. 20%8
for participatin5 personally and sustantially as a Go+ernment officer in a particular
matter in ic8 to is :noled5e8 e andor is spouse as a financial interest.
!ursuant to a ci+il settlement8 te official paid te Go+ernment 2080008 and te
Go+ernment released im from its claims.
Chief of Staff at the Department of 6eterans Affairs Medica# Center in Fansas
City3 %n!a!es in Conf#ict of 'nterest
Durin5 te same time te Cief of Staff as employed y te Department of
)eterans Affairs 6edical Center8 e as also employed as a pysician y te Uni+ersity
"4
8/13/2019 Eef Complete 2012-3
48/164
of ansas 6edical Center in ansas City8 ansas. Suse>uently8 te Cief of Staff in is
official capacity appro+ed a contract for cardiocat ser+ices to te Department of
)eterans Affairs 6edical Center y te Uni+ersity of ansas 6edical Center.
On 6arc %8 20008 te Cief of Staff pled 5uilty to a misdemeanor +iolation of 1%
U.S.C. 20%8 ic ars employees from ta:in5 official action in matters affectin5 teir
personal financial interests. On Au5ust 48 20008 e as sentenced to pay a 2/0 fine and
a special assessment of 2/.
'nterna# Revenue Service 'RS RevenueKSett#ement "fficer Prosecuted P 1H
(S(C( 2=H
An I*S employee as assi5ned to a certain I*S collection matter8 ic 5a+e
im inside information concernin5 a proposed stoc: e
8/13/2019 Eef Complete 2012-3
49/164
(e ,*CS employee as car5ed it a felony count of +iolatin5 1% U.S.C. 28
aidin5 and aettin58 and 1% U.S.C. 20%8 for participatin5 personally and sustantially as a
Go+ernment employee in a particular matter8 in ic8 to is :noled5e8 is spouse as a
financial interest. -urter8 in is position as a district conser+ationist8 e appro+ed a
contract eteen te ,CACS! and a cattle operation in ic e and is spouse ere
partners. Additionally8 e appro+ed a contract for fence construction eteen te
,CACS! and a tird party. (is contract resulted in payments tat ere transferred to a
partnersip consistin5 of te ,*CS employee8 is spouse8 and te tird party. (e ,*CS
employee as car5ed it to additional felony counts of +iolatin5 1% U.S.C. 20%8 for
participatin5 personally and sustantially as a Go+ernment employee in a particular
matter8 in ic8 to is :noled5e8 e8 is spouse8 and 5eneral partner a+e a financial
interest. A =ury con+icted te ,*CS employee on all counts. Ee as sentenced y te
court to one year of proation.
A Contractin! "fficer for the Department of the Army at &ort 4acson3 South
Caro#ina Sett#es Conf#ict of 'nterest A##e!ation
Sometime prior to ,o+emer 177/8 te contractin5 officer e5an a relationsip
it a foreman for a Go+ernment contractor. (e foreman suse>uently started is on
company and e5an iddin5 on Go+ernment contracts at -ort Jac:son. In ,o+emer
177/8 te former Go+ernment contractin5 officer assumed te title of pro=ect mana5er at
te ne company and performed +arious duties for te former foreman itout monetary
compensation. On April 78 1778 te contractin5 officer appro+ed and certified for
payment an in+oice sumitted y te company. Se continued er employment
relationsip it te company until June 177. Eoe+er8 se sumitted a ritten
statement to te Director of Contractin5 at -ort Jac:son attestin5 tat er association it
te company ended in 6arc 177.
(e former contractin5 officer as indicted on Decemer 38 1774 for +iolatin5 1%U.S.C. 20%8 ta:in5 official action in matters affectin5 an employee;s personal financial
interest. Se si5ned a !retrial Di+ersion A5reement ic re>uires tat se complete /0
ours of community ser+ice.
"7
8/13/2019 Eef Complete 2012-3
50/164
Assistant nited States Attorney ASA Convicted on Conf#ict of 'nterest and
&raud
(e AUSA for te Central District of Californiaas indicted after it as
disco+ered tat on numerous occasions e ad made fa+orale recommendations to te
court8 te proation office8 and oter prosecutin5 offices on ealf of cooperatin5
itnesses and defendants in e
8/13/2019 Eef Complete 2012-3
51/164
(e -AA employee re+ieed te applications of aircraft component
manufacturers. Ee as te -AA representati+e on a fli5t test of a Ground !ro
8/13/2019 Eef Complete 2012-3
52/164
A Coast Guard Captain or:in5 on te inte5ration of le5acy na+i5ation systems
it G!S spo:e it a 5o+ernment contractor assi5ned to te pro=ect aout post'
retirement or:. Once retired8 te captain made recommendations concernin5 purcases
to is former collea5ues still earin5 Coast Guard uniforms ? purcases tat directly
enefited te captain in is ne role as consultant. (e 5o+ernment maintained tat te
captain +iolated 1% U.S.C. N 20%$a8 y ne5otiatin5 for future employment it a
contractor e dealt it in is acti+e duty capacity8 and 1% U.S.C. N 204 $a$18 y
attemptin5 to influence 5o+ernment personnel on a pro=ect o+er ic e ad euic: sceme cost im si< years proation8 siuired to reimurse te Go+ernment
for all unautoried purcases. Ee retired soon after te in+esti5ation.
DoD %mp#oyee Char!es Caribbean 6acation to Government Credit Card
A GS'13 Department of Defense employee used er Go+ernment credit card to
pay for er personal +acation to te Cariean. (e case as referred to te U.S.
Attorney8 o declined prosecution. (e employee as counseled y er super+isor and
arned tat if any oter inappropriate car5es ere made on er account se ould e
disciplined. $Qes8 se reimursed te Go+ernment.
Department of Defense %mp#oyee Maes
8/13/2019 Eef Complete 2012-3
61/164
A former Department of )eterans Affairs employee recently pled 5uilty to one
count of teft of Go+ernment property. (e former employee used er Go+ernment credit
card to purcase e
8/13/2019 Eef Complete 2012-3
62/164
purcases from a local auto parts store and a military surplus store. (e super+isor ten
proceeded to re'sell most of te products at is ar. Some of te items purcased included
5as 5rills8 truc: parts8 and automoile tires. (e super+isor con+inced te mana5ers of te
auto parts store and te military surplus store to alter te credit card in+oices to list at
ould appear to e official military supplies8 instead of listin5 te actual 5oods
purcased. (e e+idence indicates tat te DoD super+isor defrauded te Go+ernment to
te tune of 2008000.
(e employee pled 5uilty to +iolatin5 1% U.S.C. 2%48 for sumittin5 false and
fraudulent claims8 and 1% U.S.C. 20%8 for appro+in5 te fraudulent purcases. Ee as
sentenced to ten monts in prison.
Accountant Goes to 4ai# for Misuse of $rave# Card
A super+isory accountant at te ,ational Science -oundation $,S- found erself
at te recei+in5 end of criminal car5es for 5o+ernment tra+el card auseFa situation
tat sould a+e come as no surprise8 5i+en tat er responsiilities included mana5in5
te ,S-;s tra+el card pro5ram. In+esti5ators found tat on forty'se+en separate
occasions8 te accountant used er tra+el card to ma:e personal purcases and
unautoried cas itdraals. 9en te In+esti5ator General e5an an audit of te
tra+el card pro5ram8 te accountant pur5ed er on transactions from te records in an$unsuccessful attempt to ide er misuse.
(e formerly footloose accountant as saddled it a 18000 fine and sentenced
to 20 ee:ends in =ail as a condition of a to'year proation. Eer misuse of te tra+el
card not only ended er career at ,S-8 ut arred er from all future federal employment.
Go+ernment tra+el cards sould only e used for e
8/13/2019 Eef Complete 2012-3
63/164
>uic:ly noticed te sudden oom at te pumps. An internal audit conducted y te ,a+y
re+ealed tat te loss to te Go+ernment from te to purloined cards totaled ""8%.
(e employee faces a ma
8/13/2019 Eef Complete 2012-3
64/164
SES #ses Title to Promote Non(Federal Entity
A Senior
8/13/2019 Eef Complete 2012-3
65/164
Financial Disclosure )iolations
6a##ey &raudA former official of te (ennessee )alley Autority $()A recei+ed to years
proation and as ordered to pay a /8000 fine and perform 1/0 ours of community
ser+ice for failin5 to disclose information on is financial disclosure form. Jon
Symonds pled 5uilty to +iolatin5 1% U.S.C. N 1001 for ma:in5 a false material statement
y failin5 to disclose information re5ardin5 te receipt of money from a source oter tan
is U.S. Go+ernment salary on is financial disclosure form.
9ile or:in5 as a mana5er for ()A from ,o+emer 2000 trou5 Decemer
20028 Symonds as re>uired to complete an
8/13/2019 Eef Complete 2012-3
66/164
,a+yer Says &inancia# Disc#osures Are a uisance3 C#ient Gets Probation
A orld'renoned Aleimer;s researc scientist for te ,ational Institutes of
Eealt $,IE as sentenced to ser+e to years of proation and four'undred ours of
community ser+ice after failin5 to disclose se+eral undred'tousand dollars in
consultin5 fees e recei+ed for ser+ices rendered to a proiited source F a
parmaceutical company doin5 usiness it is a5ency. (e scientist +iolated a federal
conflicts of interest statute and federal re5ulations re>uirin5 im to disclose payments
from outside sources on is financial disclosure report $-orm "/0. (e purpose of te
re>uired financial disclosure is to elp employees reco5nie conflictin5 financial interests
and a+oid +iolatin5 te la. (e scientist;s layer said tat it is common for ,IE
researcers not to file financial disclosures ecause tey consider te disclosures a
Bureaucratic nuisance. 6aye so8 ut tis scientist sould a+e :non8 as most orld'
renoned medical researcers proaly do8 tat untreated nuisances often ecome
deilitatin5 illnesses. In addition to proation and four'undred ours of community
ser+ice8 te scientist as also forced to forfeit te consultin5 fees e ad recei+ed from
te parmaceutical company8 and as depri+ed of is retirement from te 5o+ernment.
Consu#tant &ai#s to &i#e &inancia# Disc#osure Report3 Pays &ine 'nstead
A DoD Consultant failed to file te final pulic financial disclosure report en
te Consultant;s appointment e
8/13/2019 Eef Complete 2012-3
67/164
tat someone it om se as li+in5 as sumittin5 a id for te property. After te
property as purcased8 te employee;s partner transferred te property to te employee
for 1. (o pre+ent EUD from learnin5 tat te property came to te employee trou5 a
stra'man transaction8 te employee failed to list te property on er financial disclosure
report as as re>uired. (e employee as found to a+e falsified er financial disclosure
report and as fired.
&ai#in! to Report Gift ,eads to &B' A!ent Resi!nation
A Super+isory Special A5ent $SSA in te Carlotte8 ,ort Carolina -#I field
office as forced to resi5n in te a:e of re+elations tat e ad failed to disclose 5ifts
from a suspect in an or5anied 5amlin5 and money launderin5 in+esti5ation. (e SSA
ad een actin5 ead of te 9ite Collar Crime S>uad8 ic as andlin5 te
in+esti5ation e ad also ser+ed as te suspect;s official andler after te suspect a5reed
to cooperate it in+esti5ators. Due to is duties8 te SSA as re>uired to file an OG
-orm "/08 te Confidential -inancial Disclosure *eport. (e SSA certified tat e ad
recei+ed no 5ifts or tra+el reimursements from any one source totalin5 more tan
20.00. Eoe+er8 in+esti5ators soon learned tat on to separate occasions8 te SSA
ad accompanied te suspect to Kas )e5as8 ere te suspect paid for te SSA;s otel
and 5amlin5 e
8/13/2019 Eef Complete 2012-3
68/164
(e Department of Commerce e+entually referred te matter to te Department of
Justice8 ic filed a complaint alle5in5 tat te official :noin5ly and illin5ly failed
to file a financial disclosure report. -indin5 te official a totally unresponsi+e party it
fla5rant +iolations8 a -ederal court entered te default =ud5ment and ordered an 118000
fine8 te top ci+il penalty permitted under te statute. (e court empasied te
fla5rancy of te +iolation8 citin5 te employee;s coice to i5nore te multiple notices and
arnin5s pro+ided to im.
(Source: &nited States 56 7ant, *o6 2823$2, 23 &6S6 0ist6 9E'S $!2 (0606;6 .
$20038 re>uires senior officials8 o file S- 24%s8 to file a final financial disclosure
report Bon or efore te tirtiet day after termination of teir senior positions $in
addition to annual filin5 re>uirements. Anyone o :noin5ly and illfully fails to
pro+ide suc a disclosure faces prosecution and fines of up to 108000 $see / U.S.C. app.
N 101$e'$f8 app. N 10".
D(C( Mayor &inancia# Disc#osure
(e failure to report "08000 e ad earned in consultin5 contracts cost te 6ayor
of 9asin5ton8 D.C.8 1000 se+eral years a5o. (e 6ayor +iolated te citys campai5nfinance code y ne5lectin5 to report tese earnin5s on is financial disclosure report.
Under / C.-.*. 23".4018 illful failure to file a pulic financial disclosure report
$S- 24% or illful falsification of any information re>uired to e reported may result in
administrati+e actions or 108000 in ci+il penalties. In addition8 criminal actions may e
rou5t a5ainst -ederal officials o pro+ide false information on teir financial
disclosure reports.
&ormer Government "fficia# Convicted for &i#in! &a#se &inancia# Disc#osure
Report
Under te tics in Go+ernment Act8 a former Cief of Staff $CoS for te
Secretary of A5riculture as re>uired to file te !ulic -inancial Disclosure *eport $S-
24%. 9ile in office8 te CoS and is ife recei+ed payments totalin5 appro
8/13/2019 Eef Complete 2012-3
69/164
22802/ from to usinessmen o ere lon5time friends and usiness associates of te
CoS8 and o coincidentally recei+ed susidies from te Department of A5riculture
$USDA totalin5 38000 and 2%"80008 respecti+ely. (e CoS as re>uired to8 ut did
not8 report tese payments on is S- 24%. 9ile te USDA Inspector General as
conductin5 an in+esti5ation of te CoS it respect to conflict of interest alle5ations8 te
CoS made a sorn declaration tat e ad not recei+ed suc payments. Ee also stated
tat is only income from te time e ecame Cief of Staff8 aside from te sale of a
former residence8 as is USDA salary.
(e former CoS as con+icted of +iolatin5 1% U.S.C. 10018 for failin5 to disclose
te payments recei+ed from te to usinessmen durin5 on is S- 24% and for ma:in5 a
false sorn statement to te USDA Inspector General. Ee as sentenced to 24 monts
in =ail.
&ormer %%"C Chairman &ai#ed to &i#e &inancia# Disc#osure Report
(e former cairman of te >ual mployment Opportunity Commission settled
a lasuit rou5t y te Department of Justice for "8000. (e lasuit alle5ed tat te
cairman did not file a re>uired financial disclosure report for to years tat e as in
Go+ernment ser+ice. In te pre+ious year8 te cairman filed te yearly financial
disclosure report re>uired of all senior euent to years8 oe+er8 e sumitted a potocopy of te first year;s report. (e
Cairman ac:noled5ed tat te potocopied report did not reflect can5es in is
income. Ee furter maintained tat te inaccuracy as inad+ertent and te result of a
mista:e made in 5ood fait. (e Director of te Office of Go+ernment tics noted tat
te cairman did not respond to four re>uests to file te re>uired report o+er te course of
to years.
&ormer &DA Commissioner Convicted for &a#se &inancia# Disc#osures and
Conf#ict of 'nterest
(e U.S. District Court for te District of Columia sentenced a former
Commissioner of te -ood and Dru5 Administration $-DA to ser+e tree years of
proation8 alon5 it /0 ours of community ser+ice8 and to pay fines totalin5
7
8/13/2019 Eef Complete 2012-3
70/164
%78344.3. (e former Commissioner pled 5uilty to to misdemeanor car5es
in+ol+in5 false financial disclosures and a +iolation of te conflict of interest statute8 1%
U.S.C. 20%8 ic proiits a Go+ernment employee from participatin5 in any acti+ities
in ic e8 is spouse8 or minor cild as a financial interest.
#eteen 2002 and 2008 te former Commissioner eld se+eral senior positions
ic re>uired im to certify and file on si< occasions a financial disclosure report tat
included all of is in+estments +alued at more tan 18000. Altou5 te Commissioner
declared e and is ife ad sold te stoc: tey oned in numerous Bsi5nificantly
re5ulated or5aniations8 te couple failed to disclose tat tey actually retained stoc: in
se+eral of te companies. (e conflict of interest +iolation occurred en te
Commissioner as actin5 as te Cairman of te -DA;s Oesity 9or:in5 Group.
In+esti5ators disco+ered to of te companies in ic te Commissioner and is ife
eld stoc: ad a direct financial interest in te 5roup;s conclusions. Altou5 tere as
no e+idence tat te Commissioner;s financial interests altered te 5roup;s conclusions8
te Court concluded tat is participation in te delierations affected te inte5rity of
5roup;s findin5s. (Source: Federal Ethics Report, arch 24%
Fraud )iolations Not Co/ered Else-here*
Service-member Pocets BA) Money
-or to years after is di+orce8 an acti+e duty ser+ice'memer continued to list
is e
8/13/2019 Eef Complete 2012-3
71/164
ile recei+in5 o+erpayments. (ey too: no action to report te mista:e. O+erall8 te
Go+ernment lost more tan 28000. #ot ser+ice'memers ere reduced in ran: and
ordered to repay all funds.
.' thou!ht they +ere mine(
A 5o+ernment contractor stole ei5t "0'foot Container
8/13/2019 Eef Complete 2012-3
72/164
8/13/2019 Eef Complete 2012-3
73/164
tus recei+in5 more money tan e as entitled to and terefore committin5 fraud and
larceny. (e Staff Ser5eant as car5ed it larceny under te Uniform Code of
6ilitary Justice and found 5uilty y General Court 6artial. Ee as sentenced to fi+e
monts in confinement8 forfeiture of /8000 and a reduction in 5rade from Staff Ser5eant
$' to !ri+ate -irst Class $'3. In a similar case8 a Staff Ser5eant at U.S. Army
C,(CO6 as cau5t ille5ally recei+in5 #AE at te i5er married rate en e as
actually sin5le. (e soldier sumitted a false marria5e license8 ultimately recei+in5
1/8100 in #asic Alloance for Eousin5 and -amily Separation Alloance to ic e
as not entitled. Eis Bife also fraudulently recei+ed 138200 in (ricare ealtcare
enefits. (e relationsip must a+e 5one sour tou58 ecause se ended up turnin5
im in to military in+esti5ators. After suc a etrayal8 one can only assume e ill no
e filin5 for a fa:e di+orce.
A##-%>penses Paid Bache#or Pad +ith Maid Service 'nc#uded@
A Kieutenant Commander or:in5 as te ,a+al Station Great Ka:es #acelor
Eousin5 Officer misused Go+ernment resources en e li+ed in te >uarters itout
cost and recei+ed free ouse:eepin5 and amenities. Ee as car5ed on tree counts
under te Uniform Code of 6ilitary Justice $Articles %18 728 and 13" and issued a Ketter
of *eprimand as a form of ,on'Judicial !unisment. A ci+ilian Go+ernment officialo as aare of te Kieutenant Commander;s ille5al conduct8 ut failed to report it as
also issued a Ketter of *eprimand for +iolatin5 te #asic Oli5ation of !ulic Ser+ice
re>uirin5 tat e disclose any :non fraud8 aste8 ause8 and corruption $C.-.*.
23/.101$$11.
)and#in! of Service Members* 'n8ury C#aims 9ounds Government &inancia##y
A ,a+y ci+ilian 6edicare claims e
8/13/2019 Eef Complete 2012-3
74/164
memers a5ainst insurance companies8 te e
8/13/2019 Eef Complete 2012-3
75/164
(ree U.S. 6arine Corps -orces !acific8 Joint U.S. 6ilitary Group8 (ailand
$JUS6AG(EAI officers ere cau5t recei+in5 ries and :ic:ac:s from a (ai
+endor. A ,a+al Criminal In+esti5ati+e Ser+ice in+esti5ation re+ealed tat a 6arine
Corps 6a=or8 eiter directly or trou5 is ife8 accepted appro
8/13/2019 Eef Complete 2012-3
76/164
te components and te cost te company incurred to assemle eac :it8 and disco+ered
tat te contractor as mar:in5 up eac :it y appro
8/13/2019 Eef Complete 2012-3
77/164
$o Defraud or ot $o Defraud@ $hat*s an %asy uestion5
The Facts+An Internal *e+enue Ser+ice $I*S officer conspired it to pri+ate
ta< preparers to de+elop a sceme to defraud te United States Go+ernment. (e tauestion ad
insufficient assets to co+er teir dets. (is con+inced te I*S to alt collection efforts.
Stran5ely $or not8 te money paid to te ta< preparers ne+er made it to te I*S. (e tauite a Bdet of er onM Se as sentenced to 3 years and one
mont in prison8 to e folloed y 3 years of proation8 and ordered to pay in restitution
322813/.
The ,a-+1% U.S.C. N 341 $2003 autories fines and imprisonment for up to /
years for anyone conspirin5 it one or more oter persons to defraud te United States8
if any one of te conspirators ta:es any action to carry out te fraud. In tis case8 all
tree persons appear to a+e ta:en suc an act. (e I*S officer in tis case as also
car5ed under 2 U.S.C. N 421" $2003 of te Internal *e+enue Code8 ic re>uires tat
any I*S officer o conspires to defraud te Go+ernment e discar5ed from teir office
and8 if con+icted8 pay up to 108000 in fines8 ser+e up to / years in prison8 or ot.
Conf#icts of 'nterest and ,ies Garner A#der+oman and Dau!hters &edera#
Convictions
A 6ilau:ee alderoman and er to dau5ters found temsel+es as defendants
in federal court for funnelin5 city funds to a non'profit or5aniation tey ad created.
(e alderoman8 efore er election8 founded a non'profit or5aniation eli5ile
to carry out nei5orood social 5rants it as lar5ely funded y Eousin5 and Uran
De+elopment $EUD 5rants aarded to te City of 6ilau:ee. (ese 5rants ere 5i+en
to te city upon te condition tat eac 5rant recipient comply it EUD re5ulations.
Amon5 tese re5ulations as a conflict'of'interest pro+ision pre+entin5 any elected
official tat participated in te apportionment of te EUD 5rants from otainin5 a
44
8/13/2019 Eef Complete 2012-3
78/164
financial enefit Beiter for temsel+es or tose it om tey a+e usiness or
immediate family ties.
Upon te alderoman;s election8 se turned te e
8/13/2019 Eef Complete 2012-3
79/164
payments for te proper recipients8 te employee e5an to autorie payments to fello
employees. (e sceme alloed at least 2/ people to otain ille5al one'time payments
from te *etirement (rust -und8 after ic tey paid :ic:ac:s to te O!6 employees.
(e specialist as sentenced to 10 years in prison for er role as te rin5leader of
te operation. Eer coconspirators recei+ed lesser terms.
Boyfriends Can Be 6ery %>pensive &or %mp#oyees 9ho Stea# &unds
A U.S. -orest Ser+ice employee faced a ma. (e perpetrators8 a former Department of Defense $DoD employee8 se+eral
former soldiers and numerous pulic officials8 includin5 to i5'ran:in5 U.S. Army
officers8 conspired in a fraud and money'launderin5 plan in+ol+in5 contracts in te
reconstruction of Ira>.
(e (as: -orce disco+ered te co'conspirators conni+ed to ri5 ids on contracts
so tat C!A'SC aarded tem all to te same contractor. In addition8 te conspirators
stole o+er 2 million in currency tat C!A'SC ad slated for reconstruction. As a reard
for teir efforts8 te contractor pro+ided te officials it a +ariety of 5ifts8 includin5
47
8/13/2019 Eef Complete 2012-3
80/164
o+er 1 million in cas8 sports cars8 =eelry8 computers8 li>uor8 and offers of future
employment.
(e (as: -orce car5ed a former Kieutenant Colonel8 to acti+e Kieutenant
Colonels8 a Colonel and to ci+ilians in a 2/'count indictment. (e court sentenced te
ci+ilian DoD employee to ser+e 12 monts in prison8 ile te former Kieutenant
Colonel earned 21 monts in prison for is role. Anoter former soldier recei+ed nine
years in prison and a forfeiture of 3. million for car5es of conspiracy8 riery8 and
money launderin58 as ell as eapons possession car5es.
(e contractor at te center of te conspiracy pled 5uilty to related car5es8 and
recei+ed a " mont prison sentence. In addition8 te court ordered im to forfeit 3.
million. $Department of Justice 04'""78 June 2/8 20048 .usdo=.5o+
"fficia# Stea#s )imse#f 4ai# $ime
A former Intelli5ence Contin5ency -unds $IC- officer for te Department of
Defense $DoD stole o+er 1008000 from is former employer. (e IC- official pled
5uilty to one count of teft and emelement of Go+ernment property8 admittin5 tat
o+er a period of tree years e ad used is official position to itdra cas from a
Go+ernment an: account. #y falsifyin5 DoD accountin5 +oucers and forms8 te
official increased is on an: account it DoD funds ile e performed is officialud5etin58 disursin58 and accountin5 duties for IC-. (e U.S. District Jud5e sentenced
te official to ser+e 12 monts in prison8 pay 108/00 in restitution8 and ser+e tree
years of super+ised release. (Source: 0epartment of
8/13/2019 Eef Complete 2012-3
81/164
&edera# %mp#oyee Rides into $roub#e
A local motorcycle dealer sponsored a Hmotorcycle po:erH e+ent across pulic
lands. (e off'road i:es folloed a pre'set route8 stoppin5 alon5 te ay to pic: up
playin5 cards. (e one it te est po:er and at te end on a ne motorcycle. (e
innerP (e on'duty Go+ernment employee o as to follo te contestants8 ma:in5
sure tat noody ad fallen off is i:e or 5otten lost. Ee didn;t 5et to :eep te i:e
ecause e on te prie ile carryin5 out is official duty. 9ile section 23/.203$
$/ of te Standards of tical Conduct for
8/13/2019 Eef Complete 2012-3
82/164
of Go+ernment resources to carry out suc an acti+ity on Go+ernment computers. (e
5uardsmen in+ol+ed ere counseled y teir commandin5 officer.
Gamb#in! Rin! Garners &edera# Char!es
(ipped off y a coor:er8 in+esti5ators disco+ered tat a painter at te
Department of te Interior as runnin5 a full'fled5ed 5amlin5 operation on Go+ernment
premises. 9ile on official duty8 te painter recei+ed ettin5 slips from oter employees
and made payoffs. (e painter;s suse>uent treatenin5 pone call to te tipster earned
im a furter car5e of conduct unecomin5 a -ederal employee.
"1 C.-.*. N 102'4".37/ forids all persons enterin5 in or on -ederal property
from participatin5 in 5ames for money or oter personal property8 operatin5 5amlin5
de+ices8 conductin5 a lottery or pool8 or sellin5 or purcasin5 numers tic:ets.
1ift )iolations
Samp#in! of Gift ot Sufficient
A Kieutenant Colonel committed dereliction of duty en8 in +iolation of te
J*8 e recei+ed a ottle of #allantines 30 year'old Scotc +alued at "00 and failed to
report it and properly dispose of it. In lieu of a court martial8 te colonel resi5ned from
te military ser+ice for te 5ood of te ser+ice under oter tan onorale conditions.
,ie a Private )e#icopter Ride to 9or@ )o+ About a Mode# Ship@
The Facts+Accordin5 to sorn testimony and documentation ac>uired y te
office of a military ser+ice Inspector General8 a senior military officer accepted 5ifts from
te oner of a corporation tat ser+iced and pro+ided landin5 facilities for military
aircraft. (e 5ifts to te officer included a elicopter ride to or:8 a sirt it tecorporation;s lo5o8 a miniature model airplane8 meals at a Cristmas party8 and a leater
=ac:et. (e officer alle5edly returned te =ac:et ut did notin5 to compensate for receipt
of te oter 5ifts8 te +alue of ic e
8/13/2019 Eef Complete 2012-3
83/164
The ,a-+ / C.-.*. N 23/.101$$1" $2003 re>uires all -ederal employees to
a+oid any actions tat a reasonale person8 o :ne te rele+ant facts8 could ta:e to e
a +iolation of te laFincludin5 te proiition on pro+idin5 Bpreferential treatment to
any pri+ate or5aniation or indi+idual8 mentioned at N 23/.101$$%. In tis case8 te
+alue of te 5ifts te officer accepted could ma:e it appear tat e mi5t influence
Go+ernment contractin5 in fa+or of te corporation. (o e sure8 e en=oyed some neat
5iftsFfor a time. Eoe+erM B!ulic ser+ice is a pulic trust8 and it re>uires tat -ederal
employees place loyalty to Bte las and etical principles ao+e pri+ate 5ain $N
23/.101$$1.
+en more directly on point8 / C.-.*. NN 23/.202$a and 23/.203$d apply te
5eneral principles mentioned ao+e y proiitin5 -ederal employees from $amon5 oter
tin5s solicitin5 5ifts or acceptin5 5iftsFeter solicited or notFfrom any person o
BTdoes usiness or see:s to do usiness it te employee;s a5ency.
(ere are some e
8/13/2019 Eef Complete 2012-3
84/164
Great dinner3 thans for the tip(
Just prior to a ma=or contract aard8 a #ureau Director ent out to dinner it
one of te potential competitors at a san:y 9asin5ton restaurant. (e ine alone cost
o+er 100 per ottle. (oo ad te Director didnt realie tat a Washington Postreporter
as at te ne
8/13/2019 Eef Complete 2012-3
85/164
Gift from a Prohibited Source
As a 5esture of tan:s8 a retailer 5a+e an Army soldier a riefcase after te
soldier8 usin5 is Go+ernment credit card8 ad purcased office supplies from te retailer.
(e soldier accepted te riefcase in +iolation of te Standards of tical Conduct for
mployees of te uestionin58 te employee ac:noled5ed acceptin5 fi+e different medications from
representati+es of four parmaceutical companies8 5ifts totalin5 approuired a pysician to si5n for te samples. 9ile a
pysician did indeed si5n off8 e testified tat e only did so due to pressure from te
employee. (e in+esti5ation unco+ered a5ency'ide confusion re5ardin5 te acceptance
of dru5 samples.
%/
8/13/2019 Eef Complete 2012-3
86/164
-ederal 5ift rules proiit an employee from acceptin5 or solicitin5 a 5ift from a
person doin5 usiness it te employee;s a5ency. An employee may accept unsolicited
5ifts a+in5 a mar:et +alue of 20 or less per occasion8 pro+ided tat te a55re5ate
mar:et +alue of indi+idual 5ifts from any one person does not euired er to pay te United
States 1138000 for tis and oter +iolationsFnot a typical attorney;s fee $SourceMOffice of Go+ernment tics memorandum8 Oct. 2002.
The ,a-+ 1% U.S.C. N 20/ $2003 forids any current -ederal employee from
actin5 as an attorney in prosecutin5 a claim a5ainst te United StatesFere tis is not
performed as part of is or er official duties for te -ederal Go+ernment. -or any suc
+iolation8 te la autories fines and possile imprisonmentFof not more tan one
year8 unless te conduct is Billful8 in ic case it can e for up to / years $see 1%
U.S.C. N 21$a.
Department of 4ustice Attorney Sentenced for $+o &e#ony Counts
%
8/13/2019 Eef Complete 2012-3
87/164
8/13/2019 Eef Complete 2012-3
88/164
An en5ineer employed y te -ederal A+iation Administration $-AA at te 6i:e
6oroney Aeronautical Center in O:laoma City as car5ed it +iolatin5 1% U.S.C.
20/ $amon5 oter car5es. 9ile employed y te -AA8 te en5ineer attended and
5raduated from ni5t la scool. (e ne attorney continued is employment as an
en5ineer ut prepared ills8 poers of attorney8 and oter le5al documents on is on
time. 9itout permission from te -AA8 e a5reed to represent a fello -AA employee
o as te tar5et of a criminal in+esti5ation y te U.S. Attorneys Office8 and
suse>uently contacted te U.S. Attorneys Office on ealf of is client.
(e United States rou5t a ci+il action a5ainst te -AA employee pursuant to 1%
U.S.C. 20/$a$2 and 1% U.S.C. 21. (e parties entered into a consent =ud5ment in
ic te -AA employee a5reed to pay a 18200 penalty.
Deputy Secretary of Commerce 'mproper#y Contacts "fficia# at Department of
6eterans Affairs
(e Deputy Secretary of Commerce recei+ed from is fater'in'la8 te oner of
a company doin5 usiness it te Department of )eterans Affairs $)A8 a letter
complainin5 of delays euic:ly tan it ould
a+e8 asent te action y te Deputy Secretary.
A complaint for ci+il penalties as filed pursuant to 1% U.S.C. 21$ for a
+iolation of 1% U.S.C. 20/. (e Deputy Secretary a5reed to a ci+il settlement8 includin5 a
/8000 fine8 ic ould a+e een te ma
8/13/2019 Eef Complete 2012-3
89/164
An arcitect employed y te Department of )eterans Affairs $)A as car5ed
it +iolatin5 1% U.S.C. 20/. 9ile employed y )A8 te arcitect represented a
#elts+ille8 6aryland8 company in connection it an application for a contract it te
United States A5ency for International De+elopment in Dacca8 #an5lades. (e arcitect
made to trips to #an5lades to represent te company ile employed y te )A8
includin5 a trip for ic te company paid im 28070. !rior to te effecti+e date of is
resi5nation from te )A8 te arcitect as paid an additional /803 y te company.
Durin5 tis same period of dual employment8 e earned /8/"0 from te )A.
(e arcitect as car5ed it +iolatin5 1% U.S.C. 20/$a$2. Ee as sentenced
to to years proation8 100 ours of community ser+ice8 and as re>uired to pay a fine
of 18000. Section 20/ proiits -ederal personnel8 oter tan in te proper discar5e of
teir official duties8 from actin5 as an a5ent or attorney for anoter efore any -ederal
a5ency or court8 in connection it a particular matter in ic te United States is a
party or as a direct and sustantial interest.
4isuse of 1o/ernment .esources and Personnel
Pointin! and Shootin! for Persona# Gain
An O'/ in communications decided tat is day =o asn;t enou58 so e started a
side usiness poto5rapin5 local sports e+ents. 9ile on duty8 e as:ed a suordinate
to create poto products for is personal usiness durin5 official time. (e officer also
re>uested a press pass on ealf of te Defense 6edia Acti+ity8 ic e ten used to
5ain e
8/13/2019 Eef Complete 2012-3
90/164
Bnecessary teamuildin5 e+ents. It turns out tat te e+ents ere not so Bnecessary
after allM no employees ere actually re>uired to attend te e+ents8 ic too: place off'
site. (e Inspector General found tat te SS ad improperly autoried te use of
appropriated funds for tese e+ents8 ic ere not necessary. Se as counseled y er
superiors as a result.
A Persona# Posta# Service
One audacious officer stationed in Af5anistan de+eloped a lo+e for fancy ru5s
and sot5uns produced in (ur:ey. Ee li:ed tem so muc8 in fact8 tat e created is
on courier ser+ice to 5et e
8/13/2019 Eef Complete 2012-3
91/164
stas te stolen 5oods8 efore ta:in5 tem ome. (e ,CO admitted to stealin5 te
items8 and as forced to ta:e an early retirement.
't*s &ive "*c#oc Some+here
A 5o+ernment employee attaced to a Ser+ice ase in te United States ended up
ta:in5 a permanent +acation after a pattern of or:in5 an are+iated or: ee:. (e
in+esti5ation soed te employee or:ed an a+era5e of tree ours a day8 efore
lea+in5 around nine or ten eac mornin5 to spend te rest of te day drin:in5 at a local
ar. (e employee put in for retirement in lieu of disciplinary action
n-Captain-#ie Behavior
A Ser+ice Captain lost is command for ausin5 is position8 committin5 larceny8
and acceptin5 5ifts. (e Captain coerced te sip;s 69* committee to purcase is
personal items8 for cas8 to use as pries in a command 5olf tournament. Durin5 port
+isits8 e used is position to mandate compulsory ardroom attendance to sales e+ents
e orcestrated it specific +endors8 in euet it an ally military command8 te Captain +entured into te oter
military;s Admiral;s 6ess and remo+ed a pair of ceremonial salt and pepper sa:ers.
#ac: in port8 e accepted a elicopter ta
8/13/2019 Eef Complete 2012-3
92/164
Go Speedracer
A ci+ilian reported seein5 tree Go+ernment +eicles tra+elin5 at i5 speeds8
tail5atin5 and ea+in5 trou5 traffic in a dan5erous manner. 9en >uestioned8 se+eral
ser+ice memers admitted to dri+in5 in e
8/13/2019 Eef Complete 2012-3
93/164
ours of duty time on personal telepone calls to er friends and family o+er a fi+e mont
span.
%mp#oyee Receives Reprimand for )is Side Business
A ci+ilian employee as reported for runnin5 a side usiness trou5 is office. It
turns out tat te employee ad de+eloped a computer pro5ram durin5 duty ours and on
Go+ernment e>uipment. Ee ten mar:eted te pro5ram8 and is consultin5 ser+ices8 +ia
te internet. Ee also used is Go+ernment A!O address as is usiness address so tat e
ould e ale to andle all of is personal usiness at is Go+ernment office. (e
employee recei+ed a letter of reprimand and as forced to stop sellin5 te softare.
Since it as de+eloped on Go+ernment time and usin5 Go+ernment resources te
pro5ram as deemed Go+ernment property.
$ain! the B#acha+ "ut for ,unch
A concerned citien contacted te Inspector General after seein5 a #lac:a:
elicopter par:ed in a field eind a restaurant. Inside8 e found fi+e ser+ice memers
tat ad stopped for lunc and ere en=oyin5 teir meal it se+eral ci+ilians. An
in+esti5ation re+ealed tat te
Top Related