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A Message From the Director
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Dear BEGA Friends and Colleagues,
Having an ethical government is still important. Ethics and compliance are far more than words that mean detecting misconduct, but when put together, they are the driving force behind avoiding risks to the government and its reputation. At BEGA, we are committed to providing awareness of the ethics rules through advice and education, as well as investigations and enforcement. While the District is facing unparalleled events, I ask that you stand with us in ensuring that ethics remains a topic priority within our government. I ask for your collaboration to foster an ethical culture within each agency. We will succeed as a government when our values and commitment to the ethics are aligned with our goals. Be sure to join us for Ethics Week 2025, "Keeping Government Transparent and Ethical" on Octover 14-17th.
Ashley D. Cooks
Director of Government Ethics
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New and Notable
Save the Date for Ethics Week 2025 – October 14-17
Ethics Week 2025: Keeping Government Transparent and Ethical will be held on October 14-17. The course schedule and sign-up information is available on the Ethics Week 2025 page on BEGA’s website. We hope you can join us for new courses and old favorites.
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FDS Enforcement
The 2025 Financial Disclosure season has closed and OGE has moved on to the enforcement process. To date, over 92% of the public officials and employees have completed their financial disclosure reports. Individuals who have not filed to date can expect to receive a $300 fine. OGE is in the process of reviewing the enforcement list and will soon start sending fine letters to late and non-filers
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25-0002-F In re Trayon White
The Board approved a Notice of Violation charging Respondent with failure to file a complete financial disclosure statement in November 2024 and May 2025 in violation of D.C. Official Code § 1‑1162.24(a)(1). The Board also approved a Scheduling Order and scheduled the adversarial hearing on February 6, 2026.
24-0007-F In re Marc Davis
The Board approved a Notice of Violation charging Respondent with use of government time or resources for other than official business, or government approved or sponsored activities, in violation of DPM § 1807.1(b). The NOV charges 196 violations of the DPM in connection with Respondent allegedly working simultaneously at
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Giant while on his district tour of duty for MPD, attending a movie while he claimed to work overtime, using his District vehicle to travel to his outside employment, and traveling to his outside employment during his tour of duty.
24-0141-P In re B. Irving
The Board approved a Negotiated Disposition and $2,000 civil penalty with Respondent, a member of the DCHFA Board of Directors, for four counts of failing to submit a full and complete financial disclosure statement in violation of D.C. Official Code §1‑1162.24(a)(1). Respondent failed to disclose his work at a development and construction company he founded and failed to disclose ownership interest in real property in the District.
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25-0070-P In re T. Clements
The Board approved a Negotiated Disposition and $500 civil penalty with Respondent, an employee with the DMV, for one count of violating DPM § 1807.1(b). Respondent used District government time and resources to assemble jewelry for her outside business.
24-0124-P In re N. Smith
The Board approved Negotiated Disposition and reprimand for Respondent a former DCPS employee, who directly of indirectly solicited or accepted a gift or donation given because of her official duty or position in violation of DPM § 1803.2(b). Respondent formed a nonprofit organization to avoid the donations process put in place by the Office of Partnerships and Grants and DCPS Central Office and accepted a $20,000 donation for use by the nonprofit to support her DCPS high school.
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Ethics in the News
The U.S. Office of Government Ethics published its 2024 Conflict of Interest Prosecution Survey detailing the Department of Justice efforts to enforce the federal criminal conflict of interest statutes at 18 U.S.C. §§ 202‑209 and related statutes for 2024. One of the matters highlighted in the survey was a Deferred Prosecution Agreement with the government involving an employee at a U.S. military medical center. The federal employee accepted an offer to perform part-time work for his former private employer without receiving requesting permission to engage in this part-time outside employment. The Deferred Prosecution Agreement included admissions that the employee violated the conflict of interest provision at 18 U.S.C. § 208 by taking actions affecting a personal financial interest. The government agreed to dismiss the charged along with related charges of conspiracy to commit wire fraud and health care fraud and defer prosecution subject to the employee’s compliance with the terms of the agreement.
The House Ethics Committee found that Representative Alexandria Ocasio-Cortez violated House Ethics Rules by receiving impermissible gifts in connection with her attendance at the 2021 Met Gala. The Committee’s investigation concluded that Representative Ocasio-Cortez failed to fully comply with the Gifts Rules by impermissibly accepting a free admission to the event for her partner and failing to pay full fair market value for some of the items she wore to the event. The Committee did not find the violations were knowing and willful but determined it would be appropriate for Representative Ocasio-Cortez to pay an additional $2,733.28 from personal funds to compensate for the fair market value of the items. Read the House Ethics Committee Report.
The chief operating officer for the National Institutes of Health was fired in July after an investigation into whether his spouse benefitted from a $3.3 million NIH contract awarded to a Louisiana company. The contract, which was awarded in July, listed the chief operating officer’s spouse as one of the staff of the company supported by the contract. The firing came three months after the official joined NIH. Read more here.
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State and Local Ethics
The state of Louisiana adopted several recent changes to anti-corruption laws in the state as part of an overhaul of the state’s ethics and campaign finance laws. Among the changes, the legislation changed conflict of interest laws to allow the executive director of the racing commission to be a racehorse owner and to allow an appointee of the board that oversees the New Orleans convention center to also serve as CEO of the convention center. At least one member of the Louisiana Ethics Board has suggested that the changes were made in response to decisions by the board that were unpopular with the governor and elected officials and that the changes are intended to essentially dismantle the ethics agency by limiting its enforcement authority. Read more about the changes here and here.
Officials in North Dakota argue that state constitution does not permit the North Dakota Ethics Commission to create or impose penalties for ethics-related violations. The agency, which was created in 2012, has been subject to ongoing disagreements with official in the state about how it operates and the extent of its authority to enforce ethics laws. The state house voted against legislation proposed by the commission this year that would have given the agency more authority, including the ability to investigate potential ethics violations that are not submitted as official complaints and allowed the agency to settle and dismiss complaints at any stage in the complaint process. Read more here.
The state was Kansas was ordered to pay over $200,000 in attorneys fees in connection with campaign finance investigations by the Kansas Governmental Ethics Commission. The commission, which investigated allegations of coordinated expenditures by individuals, political parties, and political committees during the 2020 election cycle, was ordered to pay $115,700 in attorneys fees to a Kansas law firm that represented clients who were subpoenaed as part of the investigation. The state was ordered to pay $98,500 in attorneys fees in a separate case involving regulatory action against an organization that the commission argued failed to register as a political action committee after spending money to endorse a mayoral candidate. Since July 1, the commission was renamed the Kansas Public Disclosure Commission as part of a package of changes to the state’s campaign finance laws. Read more here.
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Ask BEGA
Question: I am currently a District employee at DOES. In my role, I help advance the efficiency of our youth-related programs. I was emailed by the National Summer Youth Program Summit (“NSYPS”) about an opportunity to speak on DC’s Summer Youth Program at this year’s NSYPS Summit. My agency has agreed to allow me to attend in order to further our mission to share the District's progress regarding youth-base programs and to gain perspective on how other jurisdictions are developing programs. The invitation includes free attendance to the 3-day summit in California. My agency does not have the budget to support my travel and hotel stay; however, the NSYPS is gifting all of its speakers with free travel and accommodations. Can I accept the gift?
Answer: Under DMP § 1803.1, employees are prohibited from accepting gifts from prohibited sources, so you are not allowed to accept travel, or the hotel stay, as NSYPS is a prohibited source. However, you may be allowed to accept the travel and hotel stay if NSYPS would like to donate, opposed to gifting. In order to do so, NSYPS would need to take the steps to properly classify and donate the travel and hotel stay. Generally, a third-party offering airfare and lodging to a District employee, who they have invited to attend an event in their official capacity to speak on behalf of the agency or serve the agency's interests, should follow the District's donations process before the event occurs. Feel free to learn more about the donation process by reaching out to the Mayor's Office of Volunteerism and Partnerships (Serve DC).
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