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Confidential Financial Disclosure: An Important Tool to Prevent Conflicts of Interest

February 16, 2017

While the rest of the world is focused on Valentine’s Day in mid-February, the executive branch ethics program is focused on financial disclosure. Yesterday was the deadline for approximately 370,000 mid-level federal officials to file their annual confidential financial disclosure reports. Government ethics officials review every one of these reports, scouring them for potential financial conflict of interest. This massive undertaking is an important part of the mechanisms in place to guard the integrity of the government’s operations.

The confidential disclosure process begins with the designation of certain positions as subject to the filing requirements. Agencies identify positions with heightened risk for conflicts of interest, such as positions involving duties related to contracting, procurement, grants, subsidies, licensing, and other activities that affect the interests of non-federal entities. The law also requires special government employees (SGE) to file financial disclosure reports.

Employees in designated filing positions file financial disclosure reports when they start in the position and again each year on February 15. Agency ethics officials first review the reports to make sure the filers have satisfied the technical disclosure requirements. They then review the reports for conflicts of interest with the duties of the filers’ positions. To support them in this work, OGE conducts training for agency ethics officials.

Some agencies, such as the Department of Defense, require an additional level of review by each filer’s supervisor. This approach enhances the review because the supervisor is intimately familiar with the filer’s assignments and can help the agency’s ethics office identify conflicts of interest.

OGE’s program reviews of agency ethics programs provide a quality control mechanism for the confidential financial disclosure process. As part of the program review, OGE examines samples of financial disclosure reports to ensure that agencies are thoroughly reviewing them. In addition, OGE examines aggregate data regarding filings to ensure that agencies are acting promptly to collect financial disclosure reports, review them, and resolve identified conflicts of interest. When improvements are needed, OGE makes recommendations in the final program review report and subsequently conducts a follow-up review to assess the agency’s implementation of the recommendations.

This process is one of the ways that OGE and agency ethics officials remain vigilant in identifying and resolving conflicts of interest. To learn more about this process, you can view the recordings of OGE’s Massive Online Open Course (MOOC) on the review of confidential financial disclosure reports or review OGE’s confidential financial disclosure guide.