Section 847 Ethics Requirements for Senior Defense Officials Seeking Employment with Defense Contractors

摘要

Our objectives were to (1) address the central database and DoD IG oversight provisions of Public Law 110-181, The National Defense Authorization Act for Fiscal Year 2008, Section 847, Requirements for Senior Department of Defense Officials Seeking Employment with Defense Contractors, January 28, 2008; (hereinafter referred to as section 847); (2) address subsequent direction from the House Armed Services Committee (HASC); and (3) accordingly determine: (1) Whether written legal opinions required by section 847 were being provided and retained in accordance with the requirements of this section. Public Law 110- 181, section 847 (b) (210101) The Department of Defense's record of compliance with section 847 of Public Law 110-181. (HASC Report on the National Defense Authorization Act For Fiscal Year 2013). (3) Quantitative data specified by the HASC, as follows: (a) the total number of opinions issued, (b) the total number of opinions retained in accordance with section 847, (c) any instances in which a request for a written opinion pursuant to section 847 lacked a corresponding written opinion, or (d) in which the written opinion was not provided to the requesting official or former official of the Department of Defense by the appropriate ethics counselor within 30 days after the request for a written opinion. The DoD did not retain all required section 847 records in its designated central repository, the After Government Employment Advice Repository (AGEAR). This occurred because the Department did not: implement the 2010 DoD Inspector General (IG) report recommendation to transfer historical records into AGEAR when the database became operational, centrally supervise section 847 activities by its decentralized Components, and comply with Deputy Secretary guidance making AGEAR use mandatory as of January 1, 2012.