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To Recuse or Not to Recuse: OGE Updates Guidance

Client Alert | 1 min read | 07.26.16

On July 26, 2016, the Office of Government Ethics issued a final rule updating the Standards of Ethical Conduct for Employees of the Executive Branch, subpart F, “Seeking Other Employment” (5 C.F.R. 2635), to clarify recusal requirements. Recusals are required when the scope of the federal employee’s duties has a “direct and predictable” effect on the financial interest of an entity with whom the employee is either negotiating prospective employment or with whom the employee has any agreement concerning prospective employment, and the final rule also adds a new section to implement the statutory notification requirements under section 17 of the STOCK Act, which applies to individuals required to file public financial disclosure reports.

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Client Alert | 2 min read | 11.14.24

SEC ESG Enforcement Is Still Alive

On November 8, 2024 the SEC announced a settled enforcement action against Invesco Advisers, Inc. for making misleading statements about its integration of environmental, social, and governance (ESG) factors into the firm’s investment decisions. Invesco agreed to pay a $17.5 million civil penalty to settle the matter. This enforcement action makes it clear that, even though the SEC dissolved its ESG Task Force, the Commission continues to monitor firms’ statements and representations for misleading statements about ESG....