CONFLICT OF INTEREST - EMPLOYMENT AND FINANCIAL INTEREST STATEMENTS

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP86B00154R000100030014-9
• Release Decision: RIPPUB
• Original Classification: C
• Document Page Count: 4
• Document Creation Date: January 4, 2017
• Document Release Date: April 10, 2008
• Sequence Number: 14
• Publication Date: October 30, 1981
• Content Type: MEMO

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OGC 81-09342
30 October 1981
MEMORANDUM FOR: Deputy Director for Administration
Deputy Director for Science and Technology
Deputy Director for Operations
Director, Intelligence Community Staff
Director, National Foreign Assessment Center
Director, Equal Employment Opportunity
Director, Office of Policy and Planning
Director of Personnel
Director, National Intelligence Council
Inspector General
Comptroller
Executive Secretariat
Deputy General Counsel
SUBJECT: Conflict of Interest - Employment and Finan-
cial Interest Statements
1. This is to remind you that you should request certain
employees in your components to file their annual statements of
employment and financial interests, as discussed below. As you
know, each year certain employees at pay levels of GS-13 or
higher are required by Executive Order .11222 and to file 25X1
financial interest statements (Form 2630) that reflect their
financial interests as of 30 June. The purpose of the require-
ment is to enable the Agency to determine the existence of a
conflict, or apparent conflict, of interests, and thus to permit
appropriate action to remove the conflict.
2. Subsequent to the enactment of the Ethics in Government
Act of 1978, which requires financial reporting by GS-16s and
above, the Director designated the Deputy General Counsel to be
responsible for CIA's implementation of the financial reporting
requirements both of the new Act and the Executive order, and the
Financial Disclosure Review Panel has been formed to assist in
reviewing these financial reports. The following procedures for
submission shall continue to apply, much as they have in the
past.
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3. Agency personnel required to file such statements (Form
2630) are as follows:
a. Employees, paid at GS-13, GS-14, GS-15, or at a
comparable pay level, in positions determined by the appro-
priate Deputy Director, operating official, or head of
independent office to be responsible for making a Government
decision or taking a Government action regarding (1).
contracting or procurement, (2) administering or monitoring
financial transactions, (3) regulating or auditing private.
or other non-Federal enterprise, or (4) other activities
where the decision or action may have an economic impact on
the interests of any non-Federal enterprise; or
b. Employees, paid at GS-13, GS-14, GS-15, or at a
comparable level, in any other positions which the appro-
priate Deputy Director, operating official, or head of
independent office otherwise has determined to have duties
and responsibilities that require the incumbent to report
employment and financial interest in order to avoid involve-
ment in a possible conflict of interest.
Employees at GS-16 or above are required to complete financial
disclosure reports under the Ethics Act and need not file a Form
2630. Also, employees covered by subparagraph a above may be
excluded from the reporting requirement by an appropriate deter-
mination that the employee falls within paragraph (d) of
Under that provision employees are excluded From the
.
reporting requirement if the designating official determines that
the duties of the employee are such that the likelihood of a
conflict is remote, the degree of supervision is such that a
statement need not be filed, or that any conflict would have only
an inconsequential effect "on the integrity of the Government."
4. I suggest that your instructions require submission of
all statements to you by 30 November and that you complete your
review no later than 31 December. Procedures for submission are
prescribed by paragraph (4) of Upon review and
approval each statement should be marked to show the date of such
action and the initials or name of the approving official. This
review constitutes a certification by the reviewing official that
the financial statement discloses no real or apparent conflict of
interest. Those statements that do indicate a conflict or raise
a question of conflict should be discussed with this Office or
the Financial Disclosure Review Panel member representing your
component.
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5. The review is designed to determine whether the duties
of the employee involve organizations, persons, or real property
in which the employee has a financial interest or an employment
relationship. As the instructions accompanying Form 2630
indicate, the relevant financial interests are those of the
employee, his spouse, his minor children, and members of his
family who reside with him.
6. It is the responsibility of this Office to ensure that
the steps outlined above have been taken and that the Agency is
in compliance with applicable law and regulations.. Therefore, I
ask that each of you or a designee submit to the me by 8 January
a report which contains the names of those employees required to
file statements, the number of statements received and approved,
and those awaiting final resolution. In the latter case, you
should briefly summarize the problem and how you are handling
it. Supplementary reports should be made every 30 days until you
have received and reviewed financial statements from all
employees required to submit them.
7. Members of this Office will be available to advise and
assist in the review of statements of employment and financial
interest, but you should feel free to consult also with the
Financial Disclosure Review Panel member designated for your
component. A current list of panel members is attached. if you
have any additional questions or comments, please feel free to
cc: General Counsel
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