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Greetings Ethics Counselors and BEGA Friends! Thank you for contributing to another successful financial disclosure season. We closed the season with 8,321 of the 10,147 designated filers submitting their statements before the filing deadline. This is in large part due to your efforts within your respective agencies. |
While your efforts at the beginning of the filing season have been noticed, we are still in need of your assistance through the completion of your financial disclosure review report.
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If you have not already submitted your report, please send it to us as soon as possible. Our next goal is to begin enforcement action against delinquent filers and to audit certain financial statements.
Ashley D. Cooks
Director of the Office of Government Ethics
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Financial Disclosure Enforcement
The May 15th deadline for timely filing of Public and Confidential Financial Disclosure Reports has now passed. OGE is in the process of reviewing financial disclosure review reports from agency ethics counselors and will soon start sending notices to delinquent filers.
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Uniform College Athlete Name, Image, or Likeness Emergency and Temporary Amendment Acts of 2025
The Council has passed emergency and temporary legislation that halts the financial disclosure filing requirement for 43 boards and commissions that were designated as filers in BEGA’s September 27, 2024 rulemaking. The measures provide that the filing obligations for the designated boards and commissions will not be effective until January 1, 2026.
Welcome Shannon Monk
OGE welcomes new attorney advisor Shannon Monk to BEGA. Shannon joins us from the U.S. Office of Government Ethics, where she provided advice and training to government ethics officials. She received her JD from Syracuse Law and MPA from Florida International University.
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24-0010-F In re Marcellus Willis
After an adversarial hearing, the Board issued a Final Decision and Order in this matter involving misuse of the District purchase card by Respondent, a former employee of the University of the District of Columbia. The Board found that Respondent violated DPM §§ 1800.3(g) and 1808.1 by using a government issued purchase card to make unauthorized, fraudulent transactions. The Board ordered the Respondent to pay a $26,000 fine. Read the Final Decision and Order.
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25-0001-F In re A. Lozada
The Board approved a negotiated disposition and $2,500 civil penalty with Respondent Lozada, an employee of the Office of Labor Relations and Collective Bargaining for violations of DPM §§ 1807.1(a) and (b), engaging in outside employment that is reasonably likely to interfere with official duties and using government time and resources for other than official business. Respondent conducted physical training and fitness classes during her official District tour of duty. Read the negotiated disposition.
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24-0124-P In re A. Smith
The Board approved a negotiated disposition and $2,500 civil penalty with Respondent Smith, a former employee with DCPS for a violation of DPM § 1807.1(b), use of official time for other than official business. Respondent reported working a regular full-time schedule while she was on vacation, including outside the country. Read the negotiated disposition.
Complaint Summary
The Complaint Summary and Heat Map for the second quarter of FY2025 is available on BEGA’s website.
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The U.S. Office of Special Counsel (“OSC”) rescinded two Hatch Act advisory opinions issued by the office in 2024. OSC will return to its previous practice of referring potential Hatch Act violations by White House employees to the President and will not pursue any new disciplinary actions under the Hatch Act for former federal employees pending resolution of a matter before the Merit Systems Protection Board involving a former federal employee. Finally, OSC concluded that implementing a “year-round workplace political item prohibition” for items related to campaigns of “current or contemporaneous political figures” placed too great a burden on First Amendment interests and it is reverting to its previous advice that the Hatch Act does not prohibit displaying campaign items in the workplace after election day. Read the advisory opinion and OSC guidance here.
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The Office of Congressional Conduct, formerly the Office of Congressional Ethics, the office charged with investigating House members, is back up and running after the appointment of four board members. Prior to the appointment of the board members by Speaker Johnson, the office was unable to open investigations or issue reports on its activities. The four-month delay in appointing members is the longest period the office has been dormant. The office was established in 2008 to receive complaints from the public after a series of ethics scandals involving lawmakers. Read more here.
The U.S. Government Accountability Office (“GAO”) issued its 18th annual review of federal lobbying activity. The report provides GAO’s assessment of lobbyists’ compliance with the requirements of the Lobbying Disclosure Act of 1995 (“LDA”), identification of the challenges or improvements lobbyists report in complying with the LDA disclosure requirements, and a review of efforts by the U.S. Attorney’s Office for the District of Columbia to enforce compliance with the LDA. The report notes one civil enforcement action and no criminal enforcement actions against lobbyists in 2024. Read the GAO report here.
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Maryland Governor Wes Moore recently signed bipartisan ethics legislation that would require future governors to put their financial holdings in a blind trust or divest entirely. The bill, which the Maryland legislature passed unanimously, was in response to reports that former Governor Larry Hogan approved millions of dollars in affordable housing awards to clients of his real estate firm. Read more here.
Illinois Senate President Dan Harmon is appealing a dispute with the State Board of Elections regarding the board’s decision that he improperly accepted nearly $4.1 million in contributions over the limit. The dispute is based on the board’s decision that the so-called “money bomb” loophole in state law that allows a candidate to accept unlimited contributions if any candidate in their race reaches a specified self-funding threshold did not apply to Harmon’s election after March 2024. In addition to appealing the Board’s decision, Harmon sought to add language in ethics legislation under consideration that could have codified his interpretation of the provision, thereby eliminating his dispute with the Board and any potential fine. The legislation did not pass before the end of the Illinois General Assembly’s spring session. Read more here.
In other ethics news out of the state, former Illinois House Speaker Mike Madigan, is due to be sentenced this week. Madigan was convicted of federal bribery, conspiracy, and fraud charges in connection with a scheme to help a utility company with legislation in exchange for no-show jobs for his allies. Prosecutors are seeking a 12 ½ year prison term and $1.5 million dollar fine. Read more here.
A state representative in Massachusetts was charged with wire fraud and falsification of records for allegedly defrauding a local trade association to fund personal and campaign expenses and falsifying records to conceal the conduct. In addition to paying for campaign mailers, the indictment alleges that the funds from the trade association were used to pay for “personal psychic services”. Read more here.
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Question: What happens if I did not file my Financial Disclosure Report by the May 15th deadline?
Answer: BEGA will begin enforcement for the 2025 Financial Disclosure filing season on June 15, 2025. Filers who are current employees and failed to timely file will be garnished $300 and face continued enforcement action until they file this year's form. Garnishments can be expected on a rolling basis throughout the summer and fall. Filers who are separated from District government employment and failed to timely file will have their $300 fine sent to the District's Central Collection Unit or other collections entity and face continued collection and enforcement action until they file. Filers can complete the form here.
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