Even after leaving government service, former federal employees are subject to certain ethics restrictions. Most of these "post-employment" restrictions can be found in a criminal conflict of interest statute, 18 U.S.C. § 207. Regulations issued by the Office of Government Ethics supplement the statutory provisions. See 5 C.F.R. § 2641. In addition, former Commission employees must seek clearance under Commission Rule 4.1 before participating in many FTC matters that were pending or directly resulted from matters that were pending during their FTC tenure.
If a former Commission employee is prohibited from participating in a specific proceeding or investigation because that person participated personally and substantially in the same matter while working for the FTC, then that former employee’s law firm, partners, or legal/business associates are barred from participating in that same proceeding or investigation, unless they take certain measures to screen the former employee from participating and they file a screening affidavit with the Commission attesting to such measures, in accordance with Commission Rule 4.1(b)(8).
Requests for clearance and screening affidavits should be submitted electronically to ElectronicFilings@ftc.gov. If you need more information, contact: Craig Bannon at firstname.lastname@example.org or 202-326-2067 or contact Alice Bartek-Santiago at email@example.com or 202-326-2191.