Sample Letter Of Warning

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TEMPLATE: SAMPLE LETTER OF WARNING
Dear Filer:
1.
Our office reviewed your 20___ Annual Confidential Financial Disclosure Report
(OGE Form 450) covering your financial interests for fiscal year 20___. You disclosed
financial interests, including spousal employment, in DoD-prohibited sources (e.g., L3
Communications and Proctor and Gamble, Inc.). These interests are in companies that
do business with DoD or are likely to do business with DoD. To help you avoid potential
conflicts of interest with respect to your financial interests, we are providing you with
this required annual GUIDANCE/ REMINDER concerning the ethical rules pertaining to
this interest.
2.
RULE: A criminal statute, 18 U.S.C. 208, prohibits you from personal and
substantial participation in a Government assignment or project where you could
directly and predictably affect your financial interests, or those imputed to you, unless
you first obtain a written waiver or qualify for a regulatory exemption. The interests of
the following persons are imputed to you: your spouse and minor children; any general
partners; any organization in which you serve as an officer, director, trustee, general
partner or employee; and any person or organization with which you are negotiating or
have an arrangement concerning prospective employment.
3.
EXEMPTIONS: Ownership of Securities - Normally, you must disqualify yourself
from working on any project or assignment that is likely to affect your financial
interests. However, the law recognizes exemptions for investment interests which may
be too small or indirect to create an actual conflict of interest. They are:
a.
You may participate in a particular matter where the aggregate of your
interests (including those imputed to you) do not exceed $15,000 in all entities involved
in the matter, where the interests are in publically traded, long-term Federal or
municipal securities. E.g., If you were responsible for awarding a contract where
company A and B were parties. If your interest in each company was $8,000, the total
would be more than $15,000 and you would not meet this exception.
b.
You may participation in a particular matter of general applicability –
which may affect a particular class of companies--if you own no more than $25,000.00
of securities in a company that is part of the class affected by the matter.

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