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A Message From the Director
Greetings BEGA Friends!
The Financial Disclosure Statement filing season has ended and we will begin the review and enforcement process. We've received over 8,300 timely financial statements. I'd like to especially thank our FDS team and agency ethics counselors for making this year's season a success. As we finalize FDS season, we continue our stride through political activity season. As such, it is imperative that employees remember the political activity restrictions set forth by the Local Hatch Act. These restrictions ensure that the government operates in a nonpartisan manner. Visit our website for Hatch Act information.
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Ashley D. Cooks
Director of Government Ethics
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New and Notable
Financial Disclosure
The May 15th deadline for timely filing of Public and Confidential Financial Disclosure Reports has now passed but this does not mean the end of financial disclosure season. OGE is reviewing the Financial Disclosure Review Reports from agency ethics counselors and will start sending out notices to delinquent filers. We will also continue to reach out to ethics counselors as we audit the filed Financial Disclosure Reports to identify potential conflicts of interest.
Ethics counselors are reminded that filers who are leaving District employment should file a termination financial disclosure report within three months of their departure from the office or position. Ethics counselors should work with agency HR to advise departing employees about their disclosure obligations and to make sure the agency has the correct address and personal email for departing employees to ensure they meet their filing obligations.
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Ethics Week
OGE is starting to plan our annual Ethics Week program. We welcome suggestions for topics you would like us to consider as well as thoughts on favorite programs you would like to see return for another session. Contact BEGA's Supervisory Attorney Advisor and Ethics Week coordinator, Amber Anderson, at [email protected], with your suggestions. Look out for details about the dates and programming coming soon.
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25-0002-F In re Trayon White
The Board found that Respondent, a Councilmember, violated D.C. Official Code §1-1162.24(a)(1) by failing to file three Public Financial Disclosure Statements, due November 2024, May 2025, and November 2025 and approved a $300 penalty for each report, for a total civil penalty of $900. The Board also approved a public censure for Respondent, finding that his failure to file the disclosures undermines the public's trust. Read the Final Decision and Order.
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26-0004-F In re C. Subido
Respondent appealed the $300 ministerial fine issued by the Director of Government Ethics for violations of 6B DCMR § 18108.1 by using her District government email account for unauthorized purposes. The Director found that Respondent misused her government email account to send and receive personal and private business emails between February 2021 and June 2022. The adversarial hearing before the Board is scheduled for September 3, 2026.
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24-0069-P In re M. Johnson
The Director of Government Ethics issued a $1,000 ministerial fine to Respondent, a teacher with DCPS for violations of the Code of Conduct for operating a business in the same school in which she worked. The Director found that Respondent violated DPM § 1807.1(h) by providing before and aftercare services at her DCPS school and by entering into agreements with DCPS and the school on behalf of her company in violation of the restrictions on representing a third party in any matter before the District. Read the Order.
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Ethics in the News
Disclosure forms filed late by President Trump listed at least $220 million in transactions in securities, including those linked to companies such as Oracle, Meta Platforms, Bank of America, Microsoft, and Goldman Sachs. Transactions in securities exceeding $1,000 are required to be reported no later than 45 days after the transaction. President Trump was fined $200 for each late transactions report, with each report including multiple late transactions. Read more about the filings here.
A nonprofit organization has asked the U.S. Department of Transportation’s Office of the Inspector General (“DOT IG”) to investigate whether Transportation Secretary Sean Duffy violated federal ethics rules by participating in a reality show called “The Great American Road Trip.” The group is asking the DOT IG to investigate whether the show, which involved Secretary Duffy and his family touring the country, violated gifts and travel rules and other standards of conduct. DOT has stated production costs for the trip were paid for by an outside organization, the Great American Road Trip, Inc., but the complaint alleges the trip was funded by contributions to that nonprofit from companies regulated by DOT including United Airlines, Toyota Motor Corporation, and Boeing. Read more here and read the complaint here.
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State and Local Ethics
Washington State’s Legislative Ethics Board recently held a public hearing on charges that state Representative Tara Simmons violated conflict of interest and special privilege laws by using her position as a lawmaker and surplus campaign funds to assist two nonprofit organizations, including one organization where she worked as a contractor. The Legislative Ethics Board concluded that “reasonable cause existed” to conclude that Simmons violated conflict of interest and special privilege laws by securing a $500,000 grant from the state’s 2024 supplemental budget for an organization where she served as a contractor and donating surplus campaigns funds to another nonprofit organization after asking them to hire her personal friend. If Simmons is found to have breached the rules, she could be fined up to $5,000 per violation and ordered to pay the state’s costs.
Los Angeles County is on track to create a new county Ethics Commission and Office of Ethics Compliance, set to launch later this year. Establishment of an independent ethics commission is intended to promote accountability, transparency, and good government in the county government. The Los Angeles County Commission would be the third county commission in California, joining the City and County of San Francisco and Orange County. Read more here.
A North Carolina grand jury indicted four lobbyists on charges they violated the state’s gift ban by convincing their clients to provide funds in connection with a bourbon tour of Kentucky sponsored by a nonprofit organization that paid travel, meals, and hotels for state legislators. Three of the lobbyists represented alcoholic beverage companies while the fourth lobbyist represented a racecourse. The lobbyists each face a misdemeanor charge of solicitation to commit violations of the prohibition against gifts from lobbyists and lobbying principals. The trip came to the attention of investigators after an employee at one of the distilleries complained about the group’s behavior in a post on Reddit. Read more here.
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Ask BEGA
Question: I serve as Chief of Staff at a District agency. As the mayoral race heats up, there’s growing concern about our agency’s future—policies and budgets could shift dramatically depending on who’s elected. At a candidate forum I attended last night, Candidate A claimed that if Candidate B wins, our agency’s budget will be eliminated, and 50 employees will be terminated. I want to address this with staff to prepare them, but I’m uncertain about the Local Hatch Act limits. Specifically, may I hold an optional all-staff, after-hours meeting—solely to inform them that their jobs could be at risk if Candidate B is elected—and remind them to consider this when voting? I wouldn’t tell anyone how to vote; I just want to make them aware. Does this comply with the Local Hatch Act?
Answer: Thank you for reaching out to BEGA. I’m sorry to hear that you are experiencing a challenging crossroads. We understand that you want the best for your staff and your agency as a whole; however, District government employees have a duty to comply with the Local Hatch Act. The Local Hatch Act is the District law that restricts political activity by District government employees to ensure that government resources, authority, and the workplace are not used to influence the outcome of an election. Under the Local Hatch Act, District government employees:
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MAY NOT use their official authority or influence for the purpose of interfering with or affecting the result of an election.
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MAY take an active part in political management or in political campaigns, including working on or managing a campaign.
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MAY NOT knowingly solicit, accept, or receive a political contribution from any person for a partisan District‑regulated election (unless the employee is a filed candidate).
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MAY contribute money to political campaigns, political parties, or partisan political groups.
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MAY attend and be active at political rallies and meetings.
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MAY NOT file as a candidate for election to a partisan political office in a District‑regulated election.
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MAY file as a candidate for election to a nonpartisan political office in a District‑regulated election.
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MAY NOT coerce, explicitly or implicitly, any subordinate employee to engage in political activity.
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MAY register and vote as they choose.
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MAY assist in voter registration drives.
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MAY attend and be active at political rallies and meetings.
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MAY NOT engage in political activity while:
- on duty
- in any room or building occupied in the discharge of official duties of the District government
- wearing a uniform or official insignia identifying the office or position of the employee
- using any vehicle owned or leased by the District
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MAY join and be an active member of political clubs or parties.
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MAY hold office in political clubs or parties.
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MAY express opinions about candidates and issues. If the expression is political activity, it may not occur while on duty, in a District building, wearing an official uniform/insignia, or using a District vehicle.
Based on these rules, and your position as COS, you are subject to the Local Hatch Act, thus you may not hold a staff meeting, during or outside work hours, in your official capacity to warn employees that their jobs may depend on the outcome of a mayoral race or to encourage them to consider this when voting. Doing so would be considered using your official authority to influence your subordinates’ political decisions, which is prohibited.
If you have questions about the Local Hatch Act, please contact BEGA at (202) 481‑3411.
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