We investigated an allegation that Douglas Domenech, Assistant Secretary for Insular and International Affairs, U.S. Department of the Interior (DOI), violated his Federal ethics pledge under Executive Order No. 13770 by meeting with an official from his former employer, the Texas Public Policy Foundation (TPPF), during the required 2-year recusal period following Domenech’s resignation from the TPPF.
Although we did not find that Domenech violated his ethics pledge as alleged, we found that he did violate Federal ethics regulations that prohibit Federal employees for 1 year from participating with their former employers in particular matters involving specific parties. Domenech, who began working for the DOI in January 2017 as a special Government employee (SGE), arranged and held two meetings with a TPPF attorney in April 2017 about issues in litigation between DOI bureaus and the TPPF. Domenech had a duty to consider whether his involvement in these meetings would cause a reasonable person to question his impartiality, and his failure to make that determination violated the regulation.
Domenech did not violate his ethics pledge, however, because he was an SGE when the meetings took place and thus was not required to sign the pledge at the time. He signed the pledge in September 2017, after he became a permanent DOI employee.