Federal ethics laws recognize that a conflict of interest, or an appearance of a loss of impartiality, may arise when agency employees are seeking or have accepted future employment outside of the agency. Employees may have competing obligations between their current position and duties at the Department and future opportunities with a prospective employer.
To facilitate the identification of these types of conflicts among the most senior officials at the agency (specifically, those who are required to file public financial disclosure reports), the Stop Trading on Congressional Knowledge Act of 2012 (STOCK Act) requires certain employees to notify their agency ethics officials if they negotiate for, or reach an agreement of, future employment or compensation (including speaking engagements and book deals) with a non-federal entity. This notification, which consists of submitting the form to an ethics official, must occur within three business days after commencing the negotiation or agreement. These officials must also file a recusal statement whenever there is a conflict of interest or appearance of such a conflict with respect to the outside entity.