Ethics Regulations:

Compartmentalization of Agencies Under the Ethics in Government Act

GGD-87-25: Published: Feb 11, 1987. Publicly Released: Mar 17, 1987.

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In response to a congressional request, GAO described: (1) the basis and administration of regulations which limit the application of certain conflict-of-interest restrictions to designated components of agencies and departments; and (2) the application of the regulations to the Executive Office of the President.

GAO found that: (1) the Ethics in Government Act of 1978 permits the Office of Government Ethics (OGE) to limit the application of the 1-year no-contact restriction on certain former senior-level employees by designating subagencies and bureaus as separate organizations, thus allowing a former employee of a subagency or bureau to contact other units of the parent department or agency; (2) the act permits OGE to make both statutory and nonstatutory subagency designations; (3) OGE designates subagencies and bureaus only at the request of departments and agencies; and (4) the subagency designation process is largely undocumented, even though OGE contends that its reviews of agency requests for these designations depend on the adequacy of supporting documentation. GAO also found that: (1) although the act requires the OGE Director to publish subagency designations and to review and update nonstatutory designations, OGE continues to designate some nonexistent subagencies, misname some subagencies, and never published one designation; and (2) OGE approved the division of the Executive Office of the President into nine separate components without any substantiating explanation.

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