2024 AGENCY ETHICS PROGRAM QUESTIONNAIRE

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PART 1. INTRODUCTION

Executive branch agencies are required to submit an annual report to the United States Office of Government Ethics (OGE) concerning certain aspects of their ethics programs (Section 5 U.S.C. § 13122(e)(1)). Your response to OGE’s Annual Ethics Program Questionnaire (the questionnaire) serves as your annual report.

OGE uses the data collected through the questionnaire in many ways, including sharing information about the entire executive branch ethics program with the public, Congress, and the ethics community. OGE also uses the information to carry out its oversight role, to gain knowledge about individual programs as well as the overall ethics program, and to make informed decisions about resource allocations and priorities. OGE posts a summary of questionnaire responses and each agency’s unedited responses on OGE’s website. Therefore, please ensure your responses are suitable for publication.

OGE encourages each agency to use the annual exercise of completing the questionnaire as an opportunity to evaluate your ethics program.

DUE DATE: By regulation, the questionnaire is due to OGE by February 3, 2025. (5 C.F.R. § 2638.207(a)).

PART 2. INSTRUCTIONS

Your response to this questionnaire should reflect the 2024 calendar year (i.e., 1/1/2024 through 12/31/2024), except where specified. The answers provided should reflect the aggregate data for your agency. OGE will only accept one submission per agency.

Throughout the questionnaire you will be offered an opportunity to provide comments or explanations for your responses. Please use these comment sections to explain any discrepancies between levels of required activity and actual activity and to explain significant changes from your 2023 report. To safeguard privacy, in your responses, please avoid the use of Personally Identifiable Information (PII). After OGE has reviewed your questionnaire submission, you may be contacted for follow-up.

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If you have any further questions, please contact Nicole Stein at nstein@oge.gov

PART 3. DEFINITIONS

Agency Head: For purposes of this questionnaire, in the case of an agency headed by more than one person, the chair or comparable member of such agency.

D.C Metro Area: For purposes of this questionnaire, D.C. Metro Area means the District of Columbia, D.C.; Calvert County, MD; Charles County, MD; Prince George's County, MD; Arlington County, VA; Clarke County, VA; Culpeper County, VA; Fairfax County, VA; Fauquier County, VA; Loudoun County, VA; Prince William County, VA; Rappahannock County, VA; Spotsylvania County, VA; Stafford County, VA; Warren County, VA; Alexandria city, VA; Fairfax city, VA; Falls Church city, VA; Fredericksburg city, VA; Manassas city, VA; Manassas Park city, VA; Jefferson County, WV; and, Silver Spring-Frederick-Rockville, MD Metropolitan Division Frederick County, and Montgomery County.

Full-time Agency Employees: For purposes of this questionnaire, the term “full-time agency employees” includes employees detailed to another agency. It also includes officers, but not enlisted members, of the uniformed services.

Special Government Employee (SGE): For purposes of this questionnaire, the term “special Government employee” (SGE) means an officer or employee who is retained, designated, appointed, or employed, to perform temporary duties either on a full-time or intermittent basis, with or without compensation, for not more than 130 days during any period of 365 consecutive days. The term “SGE” does not include enlisted members, of the Armed Forces. It does, however, include these categories of officers or employees:
  • Part-time United States commissioners;
  • Reserve officers of the Armed Forces and officers of the National Guard of the United States (unless otherwise officers or employees of the United States) while on active duty solely for training or serving involuntarily.

PART 4. ORGANIZATION/RESOURCES

1. Agency

  • Department of Justice

2. Employees

  • Number of full-time agency employees as of December 31, 2024
117531

3. Information about the Designated Agency Ethics Official (DAEO):

a. Vacant (as of December 31, 2024)?
No

b. Time in current DAEO position
1 - 4 years

c. Total years performing ethics duties
10 or more years

d. Percent of time spent on ethics
0-25%

e. Is the DAEO a career employee or a political appointee?
Career employee

f. Number of reporting levels between the DAEO and the agency head.
2

4. Information about the Alternate Designated Agency Ethics Official (ADAEO):

a. Vacant (as of December 31, 2024)?
No

b. Time in current ADAEO position
1 - 4 years

c. Total years performing ethics duties
1 - 4 years

d. Percent of time spent on ethics
0-25%

e. Is the ADAEO a career employee or a political appointee?
Career employee

5. Number of employees, including the DAEO and ADAEO, who performed ethics program duties in 2024 (e.g., financial disclosure, education and training, advice and counseling, and program administration).

Number of employees by hours worked each week
Duty Station
Less than 1 hour per week
(up to .025 FTE*)
1-10 hours per week
(up to .25 FTE*)
11-20 hours per week
(up to .5 FTE*)
21-30 hours per week
(up to .75 FTE*)
31-40 hours per week
(up to 1 FTE*)
TOTAL
a. D.C. Metro area
58
86
10
8
28
190
b. Outside the D.C. Metro area
113
274
0
0
2
389
TOTAL
171
360
10
8
30
579

* FTE = Full Time Equivalent

Example: The table below provides an example of an agency with 13 employees that performed ethics
program duties in 2024.

EXAMPLE
Number of employees by hours worked each week
Duty Station
Less than 1 hour per week
(up to .025 FTE*)
1-10 hours per week
(up to .25 FTE*)
11-20 hours per week
(up to .5 FTE*)
21-30 hours per week
(up to .75 FTE*)
31-40 hours per week
(up to 1 FTE*)
TOTAL
D.C. Metro area
1
0
2
2
1
6
Outside the D.C. Metro area
1
3
3
0
0
7
TOTAL
2
3
5
2
1
13

6. In what areas did contractors support the ethics program? Select all that apply.

  • Check all that apply

IT services (e.g., developing or supporting electronic filing systems, applications, websites, and/or databases, etc.)
Administrative support (e.g., tracking filing or training requirements, sending reminders, data entry, etc.)
Substantive ethics support (e.g., providing training, initial review of financial disclosures, drafting advice for further review, etc.)

  • Please describe IT support (optional)

  • Please describe administrative support (optional)

  • Please describe substantive support (optional)

  • Specify Other
    NA

7. Did your agency receive ethics services or support from another federal agency or federal entity? (Do not include contractors, OGE support, or OMB support of MAX.gov.)

  • Select Yes or No
Yes

  • Please provide the name(s) of the federal agency or entity:
    OSC/Hatch Act Unit, Office of the Director of National Intelligence, National Security Agency, and United States Secret Service

  • Describe the services or support received:
    OSC/HAU: advice, guidance, and training on Hatch Act application and referral
    ODNI: guidance on 50 3073a such as FBI contractors' briefings and waivers (with NSA)
    USSS: collaboration on endorsement and fundraising issues w/FBI and USSS employee event

8. Did your agency provide ethics program services or support for any board, commission, or agency that is independant of your agency?

  • Select Yes or No
No

  • Please provide the name(s) of the board, commission, or agency:

  • Describe the services or support provided:

9. Does your agency's ethics program need additional resources? Check all that apply.

  • Select type of resources

    Human Capital, Technology
    Other (specify below)

  • Specify Other
    ATF: Budgetary

10. Did the agency head meet with the ethics staff to discuss the strengths and weaknesses of the ethics program in 2024?

  • Select Yes, No, or Not Applicable
Yes

  • If Not applicable above, specify why
    NA

11. Did your agency (e.g., ethics office, Inspector General, General Counsel, etc.) or any entity outside of your agency (e.g., GAO or private auditing firm) evaluate any aspect of the ethics program in 2024 (5 C.F.R. § 2638.104(c)(16))? Exclude program reviews conducted by OGE. Select all that apply.

    My agency (e.g., ethics office, Inspector General, General Counsel, etc.) conducted an evaluation

  • Please Describe:
    NA

12. What kind of changes resulted from the evaluation?

    Programmatic changes (please describe), Policy changes (please describe)



  • Please Describe: (Please describe programmatic or policy changes; Specify why no changes resulted; Specify why recommendations still being considered; Specify why not applicable)
    Programmatic -JMD/DEO: new tracking and approval system for gifts of travel expense reimbursement under 31 USC 1353 (E2 Solutions) enhanced IET notification and tracking methodology online annual ethics training launched for use Department-wide, continued modernization of ethics program
    CRM: more timely Form 278 review
    Policy-JMD/DEO: enhanced methodology for DAEO approval of ethics determinations enhanced DDAEO nomination, approval and redelegation tracking Presidential transition preparation and execution and in 2024 there was continued work on finalizing a new Department Ethics Order which was issued in January of 2025
    BOP: updated Standards of Employee Conduct, donations policy, and outside travel policy EOUST: updated guidance for employees with a personal interest in bankruptcy cases updated ethics onboarding for Trustee candidates.
    Being considered- JMD/DEO: enhanced collection methodology of speaking engagement information, event attendance information, and WAG information is being considered and developed continued modernization of the ethics program enhanced onboarding of new political appointees including collaboration with other offices such as HR and OCIO for facilitating ethics briefings and tracking of IET and financial disclosure is being considered and developed.
    BOP: considering adding more ethics officials
    EOUST: updating personal and official speaking engagement guidance, updating ethics FAQs

13. Of the following required written procedures, which did you have in place?
Check all that apply.

Financial disclosure program, including for the filing, review, and when applicable, public availability of public financial disclosure reports (5 C.F.R. § 2638.104(c)(8)(i)), Issuance of notice of ethical obligations in written offers of employment (5 C.F.R. § 2638.303), Provision of initial ethics training (5 C.F.R. § 2638.304), Issuance of ethics notice to new supervisors (5 C.F.R. § 2638.306)

  • Explain what steps you are taking to implement the required written procedures:
    NA

ADDITIONAL COMMENTS FOR PART 4. Please indicate the question number to which the comment corresponds.

  • Additional Comments
    Q9: Many components request more full-time ethics officials (human capital) to assist with increasing amounts of complicated ethics questions. Components with large financial disclosure programs request more ethics officials to assist with timely review of reports. Technology assistance is requested by most components, particularly those with large financial disclosure programs, such as a system like Integrity for use with OGE Form 450 collection and review. FDOnline has limited use in DOJ because of its cost, and its consideration for purchase by more components is on hold due to budget constraints.
    Q10: EOUSA’s Component Head communicated via memo to all ethics advisors thanking them for their service and emphasizing the importance of their work.

PART 5. EDUCATION AND TRAINING

14. Did the office(s) responsible for issuing ethics notices to prospective employees, pursuant to 5 C.F.R. § 2638.303, provide the DAEO with the written confirmation required pursuant to 5 C.F.R. § 2638.310?

    None of the offices provided written confirmation to the DAEO (explain why not all offices, then skip to #16)

  • Please Explain why not all offices:
    The Director, Departmental Ethics Office (DEO), provides the required written confirmation to the DAEO.

15. Did written offers of employment for positions covered by the Standards of Conduct include the information required by 5 C.F.R. § 2638.303?

  • Please Explain why not all offers:
    NA

  • Please Explain:
    NA

16. Initial Ethics Briefing

a. How many agency leaders, as defined in 5 C.F.R. 2638.305(a), were required to receive ethics briefings by December 31, 2024? Exclude SGEs that were expected to serve less than 60 days on a board, commission, or committee.
Total Number
3
    i. How many new agency leaders received their briefing within 15 days of their appointment?
3
    ii. How many of those leaders received their briefing beyond the 15-day requirement?
0
    iii. How many new agency leaders have yet to receive their briefing as of today?
0

    If applicable, please explain why some of the leaders received their briefing beyond the 15-day requirement or have yet to receive their briefing.

17. Initial Ethics Training

a. How many employees, as defined in 5 C.F.R. 2638.304(a), were required to receive Initial Ethics Training (IET) by December 31, 2024 (5 C.F.R. 2638.304)? Exclude SGEs that were expected to serve less than 60 days on a board, commission, or committee. (Note: Include employees who were not required to receive the interactive portion of the IET, as provided in 5 C.F.R. 2638.304(a)(2).)
Total Number
9103
    i. How many of those employees received IET within the 3-month requirement?
9086
    ii. How many of those employees received IET beyond the 3-month requirement?
17
    iii. How many of those employee have not received IET as of today?
0

Example: If an employee started at the agency on December 15, 2024, and the employee completed IET prior to the end of the calendar year, include the employee in your required and received numbers. If, on January 1, 2025, the employee has not completed IET, do not count that employee in your required numbers. Instead, include the employee in your 2025 questionnaire response to be filed in 2026.

  • If applicable, please explain why some employees received IET beyond the 3-month requirement or have yet to receive IET.
    Scheduling conflicts including extended leave and some attorneys were in trial or on travel, some minor confusion over course selection in LMS, communication delays, administrative or bookkeeping errors

18. Did the office(s) delegated the responsibility for providing initial ethics training (IET) provide the required written confirmation to the DAEO, pursuant to 5 C.F.R. § 2638.310?

    All of the offices provided the written confirmation to the DAEO

  • Please Explain why not all offices:

19. Did the head of the agency complete either initial ethics training and/or annual ethics training in 2024?

  • Select One
Yes

  • Please specify why if "No" or "Not Applicable"

20. Required Annual Ethics Training

Type of covered employees (Include SGE filers)
# Required
# Received (of those required)

    a. Executive Schedule Level I or Level II public filers (OGE Form 278e)
3
3

    b. All other public filers (OGE Form 278e)
3208
3197

    c. Confidential filers (OGE Form 450 and OGE-approved alternative confidential financial disclosure forms)
21716
21489

    d. Other employees required by 5 C.F.R. § 2638.307(a) (employees appointed by the President; employees of the Executive Office of the President; contracting officers; or, other employees designated by the head of the agency.)
68
68

TOTAL
24995
24757

  • If applicable, please explain discrepancies between the number of employees who were required to receive training and the number of employees who received training:
    Left DOJ prior to taking annual training, long term leave status, technology irregularities or confusion with LMS offerings, inadvertent mistake in notification and/or record keeping, death of filers. Ethics officials consistently follow up on all outstanding ethics training to ensure compliance.

21. Did your agency establish additional requirements for the agency's ethics education program, pursuant to 5 C.F.R. § 2638.309?

    My agency established additional training procedures (e.g., certification procedures). See 5 C.F.R. § 2638.309(c). Please describe.

  • Please Describe
    Attorneys at DOJ must complete annual Professionalism Training which includes one hour of ethics training. Purchase card holders and procurement officials receive annual ethics training. Administrative Officers/Executive Officers received focused ethics training in ’24 regardless of their financial disclosure status. Many components require annual ethics training for all employees and interns regardless of their financial disclosure status. Most components provide ethics training to departing employees focused on post-government employment restrictions. Departing political appointees received both group and individualized ethics briefings.
    CRM: employees with overseas duty stations receive additional ethics training focused on international issues and off-duty conduct.
    DEA: core employees, supervisors, Task Force Officers, and other groups of employees receive annual ethics training and IET with ethics case studies and must pass a test on the Standards of Conduct.
    OJP: ethics training provided to IPAs
    OLA: social media and Hatch Act training provided to all employees

22. If your agency assessed risk to help inform the content, format, and/or timing of ethics education and communications, select all that apply (see PA-19-05 for reference):


Reviewed advice logs for common issues, Discussed upcoming work and agency priorities with senior staff, Talked to program managers about risks inherent in their work, Conducted surveys to identify common and emerging ethics risks, Talked to employees about the ethics concerns they encounter in the workplace.

  • Please explain other:

23. If your agency evaluated the effectiveness of your ethics education and/or communication, select all that apply (see PA-19-05 for reference):


Conducted self-assessments to ensure that required employees are receiving training, Administered post-training evaluations to assess participants' perceptions of the training, Reviewed advice logs for increased activity after training presentations and communications, Held discussions with agency leaders and employees to evaluate whether the training and communications they received have supported them in managing ethics risks.

  • Please explain other:

ADDITIONAL COMMENTS FOR PART 5. Please indicate the question number to which the comment corresponds.

  • Additional Comments
    Q20: In 2024 DOJ/DEO finalized and launched new interactive annual ethics training for financial disclosure filers online via its Learning Management System (LMS) for the first time. The training fulfilled 2024 annual ethics training requirements for public and confidential financial disclosure filers. More than 7,000 DOJ employees completed the online ethics training in 2024.

PART 6. ADVICE, COUNSELING, AND REMEDIES

24. From the list below, select the three topics that your employees most frequently sought guidance on in 2024. Please rate them in order, so that the first topic is the topic on which the employees sought guidance the most frequently.

  • Conflicting financial interests
  • Gift acceptance
  • Financial disclosure reporting
  • Impartiality in performance of official duties
  • Misuse of position, government resources, and information
  • Outside employment/activities
  • Post-employment restrictions
  • Travel, subsistence, and related expenses from non-federal sources
  • Other (specify)

  • Selection 1
Outside employment/activities
  • Selection 2
Gift acceptance
  • Selection 3
Financial Disclosure Reporting

  • Explain Other 1
NA
  • Explain Other 2
NA
  • Explain Other 3
NA

25. Number of notification statements of negotiation or recusal under section 17(a) of the STOCK Act submitted to the ethics office in 2024 (see 5 C.F.R. § 2635.602(a)):

  • Enter total
254

26. Number of 18 U.S.C. § 208 waivers granted in 2024:

Number Granted in 2024
Number Sent to OGE
    a. 208(b)(1) waivers
1
1
    b. 208(b)(3) waivers
0
0

  • If applicable, please explain discrepancies between the number of waivers granted and the number provided to OGE.

27. Number of Legal Expense Fund documents filed in 2024 (see 5 C.F.R. § 2635.1007):

Number Filed in 2024
Number Sent to OGE
    a. Trust Documents
1
1
    b. Quarterly Reports
4
4
    c. Termination Report
1
0

  • If applicable, please explain discrepancies between the number of documents filed and the number provided to OGE.
    Term report is still under DDAEO review in the component and will be submitted to OGE within the timeline set forth in 5CFR 2635.1008(d)

ADDITIONAL COMMENTS FOR PART 6. Please indicate the question number to which the comment corresponds.

  • Additional Comments
    Q24: The frequency of ethics questions asked on these topics does not necessarily reflect the relative seriousness or complexity of ethics questions that employees ask.

PART 7. FINANCIAL DISCLOSURE PROGRAM MANAGEMENT AND ELECTRONIC FILING SYSTEMS

28. How often, within the 15-day deadline, did the human resources office(s) notify the DAEO of appointments to public and confidential financial disclosure filing positions (5 C.F.R. § 2638.105(a)(1))?

    a. Public Filers
In Most Cases

    • If not applicable, specify why.
      NA

    • If "never" or "in some cases", please explain further:
      NA

    b. Confidential Filers
In Some Cases (specify why, below)

    • If not applicable, specify why.
      NA

    • If "never" or "in some cases", please explain further:
      Confidential financial disclosure is decentralized at DOJ. HR is not necessarily the primary source of information to ethics officials about confidential filers. HR does not track or implement confidential financial disclosure or collect reports. Ethics officials are generally notified about new confidential filers by other means.

29. How often, within the 15-day deadline, did the human resources office(s) notify the DAEO of terminations from public financial disclosure filing positions (5 C.F.R. § 2638.105(a)(2))?

Public FilersIn Some Cases (specify why, below)

    • If not applicable, specify why.
      NA

    • If "never" or "in some cases", please explain further:
      Communication delays and difficulties with obtaining current HR related information. These are being addressed through enhancements to information-sharing tools between HR and DEO.

30. Were all public and confidential financial reports, in calendar year 2024, filed using an electronic filing system?

  • Select one
No

31. Indicate which forms your agency uses. Check all that apply.

  • Check all that apply
450 (pdf)

32. Which electronic filing system(s) does your agency use?

  • Select one
INTEGRITY and Other (specify)

  • Specify Other
    Sharepoint (ATF), Internal OGE Form 450 system (USMS), FDOnline (JMD/DEO, ATJ, BOP)

33. Indicate for which forms your agency uses the "Other" e-filing system.

  • Check all that apply
Confidential Financial Disclosure (OGE Form 450 or OGE-approved alternative form)

  • Provide the name of the other system:
    Sharepoint (ATF), Internal OGE Form 450 system (USMS), FDOnline (JMD/DEO, ATJ, BOP)

34. Indicate your agency's fiscal year 2024 actual costs for using the e-filing system. Note: Because OGE does not charge fees to use INTEGRITY, there are no reportable costs associated with the use of INTEGRITY.

Public (do not include INTEGRITY)Confidential
a. Amount paid to a non-federal vendor in FY 2024
0
125973

b. Amount paid to a federal agency in FY 2024
0		Don’t know/don’t track
0

c. Amount for all internal costs associated with operating an e-filing system (e.g., FTE, overhead, etc.) in FY 2024
0		Don’t know/don’t track

  • Please explain "Don’t know/don’t track" answer above
    Q34 a. This figure is the cost to BOP, DEO and ATJ of FDOnline for confidential financial disclosure. Q34 c. The internal systems used for confidential financial disclosure by ATF and USMS are part of the general IT costs of those components and are not separately tracked.

35. Indicate the number of filers who filed electronically in fiscal year 2024.

    a. public financial disclosure filers (exclude filers in INTEGRITY)
0

    b. confidential financial disclosure filers
4444

ADDITIONAL COMMENTS FOR PART 7. Please indicate the question number to which the comment corresponds.

  • Additional Comments


PART 8. PUBLIC FINANCIAL DISCLOSURE

36. Report the number of public financial disclosure reports (OGE Form 278e) required to be filed by December 31, 2024, excluding SGEs, and the number of reports actually filed (i.e., received) by December 31, 2024.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. New EntrantRequired
0
5
122
12
344
483
Filed
0
5
122
12
341
480
b. AnnualRequired
99
49
773
55
1942
2918
Filed
99
49
773
55
1941
2917
c. TerminationRequired
7
15
105
10
222
359
Filed
7
15
104
10
221
357
d. Combination1Required
1
0
13
1
21
36
Filed
1
0
13
1
21
36
    Total
Required
107
69
1013
78
2529
3796
Filed
107
69
1012
78
2524
3790

1 Includes reports filed to satisfy both annual and termination requirements, as well as new entrant and termination requirements.
2 Presidential appointees confirmed by the Senate.
3 Senior Executive Service, Senior Foreign Service, Senior Cryptologic Service, Defense Intelligence Senior Executive Service, etc.
4 Includes members of the Uniformed Services, Administrative Law Judges, Senior Level employees (SES Equivalent), administratively-determined positions, officials in the Executive Office of the President who do not otherwise meet the criteria of another category in the chart, etc.


Example for new entrant and termination reports: If an employee joined (or departed) the agency on December 15, 2024, and the employee filed a new entrant (or termination) report prior to the end of the calendar year, include the report in your required and filed numbers. If, on January 1, 2025, the employee has not filed a new entrant (or termination) report, do not count that report in your required numbers. Instead, include the report in your 2025 questionnaire response to be filed in 2026.

  • If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
    Two filers died. Delays in HR communications of New Entrant filers, e.g. career promotions to SL covered positions, resulted in failure to collect 3 2024 NE reports during CY2024. In EOIR and EOUSA, extensions and/or overdue filings of 2024 Term Reports extended their collection/filing dates into CY2025. All missing and overdue 278s are being investigated and pursued.

37. Report the number of public financial disclosure reports certified or otherwise closed by your agency during the calendar year. Exclude reports of SGEs. Of those reports, indicate how many were initially reviewed within 60 days and how many were certified within 60 days. “Initially reviewed within 60 days” means having completed a technical review and conflicts analysis. See 5 C.F.R. § 2634.605 and section 4.02 of the Public Financial Disclosure Guide.

OGE Form 278e Reports
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
a. New Entranti. How many reports did your agency certify or close in 2024?
0
8
124
24
469
625
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
0
5
97
19
336
457
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
0
2
56
1
202
261
b. Annual
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2024?
100
59
766
62
2413
3400
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
94
52
613
48
1596
2403
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
42
32
415
20
426
935
c. Termination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2024?
5
12
105
10
211
343
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
5
10
86
10
194
305
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
4
8
74
8
179
273
d. Combination
PAS2
Non-Career SES3
Career SES3
Schedule C
Other4
TOTAL
i. How many reports did your agency certify or close in 2024?
1
0
13
1
18
33
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
0
0
11
1
18
30
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
0
0
7
1
18
26
    Total
i. How many reports did your agency certify or close in 2024?
106
79
1008
97
3111
4401
ii. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
99
67
807
78
2144
3195
iii. Of those certified or closed in 2024, how many were certified or closed within 60 days?
46
42
552
30
825
1495

1 Includes reports filed to satisfy both annual and termination requirements, as well as new entrant and termination requirements.
2 Presidential appointees confirmed by the Senate.
3 Senior Executive Service, Senior Foreign Service, Senior Cryptologic Service, Defense Intelligence Senior Executive Service, etc.
4 Includes members of the Uniformed Services, Administrative Law Judges, Senior Level employees (SES Equivalent), administratively-determined positions, officials in the Executive Office of the President who do not otherwise meet the criteria of another category in the chart, etc.

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.
    In components with large numbers of reports, heavy workload of reviewers and certifying officials caused delays. In some components, a shortage of or turnover of reviewing officials, DDAEOs, and certifiers caused delays. EOIR: significant increase in the number of filing positions, and the general complexity of new entrant reports with no increase in the staff of reviewers caused delays. EOUSA: significantly large number of reports with consistent increase in their general complexity caused delays, as well as staffing shortage (only one reviewer).

  • If applicable, please explain why some reports were certified or closed more than 60 days after submission. Check all that apply.

    other (specify)

  • Specify Other
    In components with large numbers of reports, heavy workload of reviewers and certifying officials caused delays. In some components, a shortage of or turnover of reviewing officials, DDAEOs, and certifiers caused delays. EOIR: significant increase in the number of filing positions, and the general complexity of new entrant reports with no increase in the staff of reviewers caused delays. EOUSA: significantly large number of reports with consistent increase in their general complexity caused delays, as well as staffing shortage (only one reviewer).

38. Number of periodic transaction reports filed, excluding those filed by SGEs

    • Periodic Transaction Reports Filed
2952
Note: Count the total number of periodic transaction reports filed. Example 1: If two employees each file 5 periodic transaction reports during the calendar year, report “10” in the space above. Example 2: If an employee files one report each month, each report is counted separately. Report “12”.

39. Extensions and late fees for new entrant, annual, termination, and combination public financial disclosure reports, and periodic transaction reports, excluding those for reports filed by SGEs.

Granted filing extension
Granted waiver of late filing fee
Paid late filing fee
    a. Number of OGE Form 278e Reports
772
34
3
    b. Number of OGE Form 278-T Reports
113
36
8

40. Number of public financial disclosure filers reported in calendar year 2024 to the Attorney General for failure to file.

  • Enter total
0

41. How many requests for public financial disclosure reports did you receive in 2024? Count each OGE Form 201 as one request, even if it contains a request for documents for multiple individuals.

  • Enter total
15

42. How many documents requested under the Ethics in Government Act did you release in calendar year 2024?

  • Enter total
1250

ADDITIONAL COMMENTS FOR PART 8. Please indicate the question number to which the comment corresponds.

  • Additional Comments
    Q39: Certification of reports where late fees were incurred was delayed awaiting confirmation of late fee payment or waiver.
    Q42: Approximately 1250 reports were released.

PART 9. CONFIDENTIAL FINANCIAL DISCLOSURE

43. Report the number of confidential financial disclosure reports required to be filed by December 31, 2024, excluding SGEs, and the number of reports actually filed by December 31, 2024.

a. Required
b. Filed
21550
OGE Form 450
14700
OGE-approved alternate form
6821
Total
21550
21521

    Note: If a 450 filer leaves the filing position before the due date, the report is not required per 5 C.F.R.§ 2634.903(a).

    Example for new entrant reports: If an employee started at the agency on December 15, 2024, and filed a new entrant report prior to the end of the calendar year, include the report in your required and filed numbers. If, on January 1, 2025 the employee has not filed a new entrant report, do not count that report in your required numbers. Instead, include the report in your 2025 questionnaire response to be filed in 2026.

    If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.
  • Explain, if applicable
    Some filers left the Department before filing, some components had employees on extended leave for the entire year. Some components contacted supervisors and were still unsuccessful with employees filing. DEO has provided support and guidance to components where not all required reports were filed.

44. Report the number of confidential financial disclosure reports certified or otherwise closed by your agency during the calendar year. Exclude reports of SGEs. Of those reports, indicate how many were initially reviewed within 60 days and how many were certified within 60 days. "Initially Reviewed within 60 days" means having completed a technical review and conflicts analysis. See 5 C.F.R. § 2634.605 and the Certification Requirements section of the Confidential Financial Disclosure Guide.

a. How many reports did your agency certify or close in 2024?
b. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
c. Of those certified or closed in 2024, how many were certified or closed within 60 days?
OGE Form 450 and OGE-approved alternative
22056
21977
21977

  • If applicable, please explain why some reports were reviewed more than 60 days after submission:
    Reviewers were waiting for additional information. Some reviewers were on extended leave, and/or filers were on extended leave and unavailable to provide additional needed information.

  • If applicable, please explain why some reports were certified or closed more than 60 days after submission. Check all that apply.
    additional information was being sought

  • Specify Other
    NA

45. Number of OGE 450 or OGE-approved alternative forms granted filing extensions in 2024.

  • Enter number
439

ADDITIONAL COMMENTS FOR PART 9. Please indicate the question number to which the comment corresponds.

  • Additional Comments
    Q43 EOUSA: 6,152 line AUSAs file the alternative Form 450 (the GCO-1) in their assigned cases.

PART 10. ENFORCEMENT OF STANDARDS OF CONDUCT AND CRIMINAL AND CIVIL STATUTES

46. Number of disciplinary actions taken in 2024 based wholly or in part upon violations of the Standards of Conduct provisions (5 C.F.R. part 2635) or your agency's supplemental Standards (if applicable). For purposes of this question, disciplinary actions include removals, demotions, suspensions, and written reprimands or their equivalents.

a. Total number of disciplinary actions that met the above criteria
108

    Of those, how many were disciplinary actions were taken wholly or in part upon violations of:

    i. Subpart A (General Provisions)
22

    ii. Subpart B (Gifts from Outside Sources)
0

    iii. Subpart C (Gifts between Employees)
0

    iv. Subpart D (Conflicting Financial Interests)
3

    v. Subpart E (Impartiality in Performing Official Duties)
11

    vi. Subpart F (Seeking Other Employment)
0

    vii. Subpart G (Misuse of Position)
75

    viii. Subpart H (Outside Activities)
6

    ix. Subpart J (Legal Expense Funds)
0

    x. Agency's supplemental Standards of Conduct
0

47. Number of disciplinary actions taken in 2024 based wholly or in part upon violations of the criminal conflict of interest statutes (18 U.S.C. §§ 203, 205, 208, and 209), failure to file or filing false public financial disclosures (5 U.S.C. § 13106 or 18 U.S.C. § 1001), a civil matter involving outside earned income (5 U.S.C. § 13143), or outside activities (5 U.S.C. § 13144). For purposes of this question, disciplinary actions include removals, demotions, suspensions, and written reprimands or their equivalents:

a. Disciplinary actions taken based on violation of ethics laws
2

    Of those, how many were disciplinary actions taken based wholly or in part upon violations of:

    i. 18 U.S.C. § 203 (Compensation in Matters Affecting the Government)
0

    ii. 18 U.S.C. § 205 (Claims Against and Matters Affecting the Government)
0

    iii. 18 U.S.C. § 208 (Acts Affecting a Personal Financial Interest)
0

    iv. 18 U.S.C. § 209 (Supplementation of Salary)
0

    v. 5 U.S.C. § 13106 or 18 U.S.C. § 1001 (Failure to File or Filing False Public Financial Disclosures)
0

    vi. 5 U.S.C. § 13143 (Outside Earned Income)
0

    vii. 5 U.S.C. § 13144 (Outside Activities)
2

48. Number of referrals made in 2024 to the Department of Justice (DOJ) of potential violations of the conflict of interest statutes (18 U.S.C. §§ 203,205, 207, 208, 209), failure to file or filing false public financial disclosures (5 U.S.C. § 13106 or 18 U.S.C. § 1001), a civil matter involving outside earned income (5 U.S.C. § 13143), or outside activities (5 U.S.C. § 13144).

a. Referrals to Department of Justice
0

b. DOJ Referrals Status
Of the referrals to DOJ (line a.), please note the DOJ referral status:

    i. How many of those referrals were accepted for prosecution?

    ii. How many of those referrals were declined for prosecution?

    iii. How many of those referrals were pending DOJ’s decision as of December 31, 2024?

c. Agency Disciplinary Action Status
Of the referrals to DOJ (line a.), please note the agency disciplinary status:

    i. Of the cases referred to DOJ, how many resulted in disciplinary or corrective action?

    ii. Of the cases referred to DOJ, how many resulted in a determination not to take disciplinary or corrective action?

    iii. Of the cases referred to DOJ, how many are pending a determination as to whether disciplinary or corrective action will be taken?

    iv. Of the cases referred to DOJ, how many of those referrals involved employees who left the agency before the agency determined whether or not to take disciplinary action?

    v. Of the cases referred to DOJ, how many involved 18 U.S.C. 207, such that there was no option for disciplinary action?

49. Did your agency notify OGE of all referral(s) and disposition(s) of the referral(s) via OGE Form 202 (as required by 5 C.F.R. § 2638.206(a))?

  • Select answer
Not applicable because no covered referrals were made to DOJ

  • Please Specify Why

ADDITIONAL COMMENTS FOR PART 10. Please indicate the question number to which the comment corresponds.

  • Additional Comments

PART 11. ETHICS PLEDGE ASSESSMENT (Executive Order 13989 ("Ethics Pledge"))

50. Were any full-time non-career appointees (e.g., Presidentially Appointed Senate Confirmed (PAS), Presidentially Appointed (PA), non-career Senior Executive Service (SES), Schedule C, etc.) appointed to or by your agency from January 1 through December 31, 2024? Note: For guidance on what constitutes a full-time non-career appointee for purposes of the Ethics Pledge, LA-21-07

  • Select answer
Yes

51. For each category of appointee, provide the number of full-time non-career appointees appointed between January 1 and December 31, 2024, and indicate the number who did and did not sign the Ethics Pledge.

Number of Full-Time Non-Career Appointees
Type of Full-Time Non-Career Appointees
by Category
PAS
PA
Non- career SES
Schedule C
Other
Total
a. Appointed
    01/01 - 12/31/2024
3
0
10
20
1
34
    i. Signed the Ethics Pledge in 2024
3
0
10
17
1
31
    ii. Required to sign the Pledge in 2024 but signed in 2025
0
0
0
0
0
0
    iii. Required to sign the Pledge, but did not sign (please explain)
0
0
0
0
0
0
    iv. Not required to sign the Pledge because occupied an exempt non-policymaking position (Schedule C or other comparable authority)
0
0
0
3
0
3
    v. Not required to sign the Pledge because appointed without break in service after serving in another position for which the Ethics Pledge was already signed
0
0
0
0
0
0
    vi. Not required to sign for another reason (please explain)
0
0
0
0
0
0

  • For each appointee identified in line iii, please explain why that appointee did not sign the Pledge.

  • For each appointee identified in line vi, please explain why that appointee was not required to sign the Pledge.

52. Registered Lobbyist and/or Registered under the Foreign Agents Registration Act

    a. How many appointees were registered lobbyists and/or registered under the Foreign Agents Registration Act during the two years prior to their appointment? For purposes of this question, please include individuals appointed between January 1 and December 31, 2024, and subject to the Ethics Pledge, as well as holdover appointees subject to the Pledge (if 0 skip to Q53).
0

    b. How many of those appointees who were registered lobbyists and/or registered under the Foreign Agents Registration Act during the two years prior to their appointment have an ethics agreement addressing their obligations under paragraph 3 of the Ethics Pledge?
0

    c. For any of those appointees who do not have an ethics agreement, please provide their name and an explanation (e.g., Pledge paragraph 3 not reasonably expected to limit participation in any agency matters because appointee's duties sufficiently unrelated to prior lobbying activities).

53. Section 3 of Executive Order 13989 provides a waiver mechanism for the restrictions contained in the Ethics Pledge. Indicate below how many waivers were granted to appointees in your agency in 2024, the names of these individuals granted waivers in 2024, and which of the Pledge paragraphs were implicated.

Number of Ethics Pledge Waivers Granted
By Pledge Paragraph
Name(s) of Individual(s) Granted Ethics Pledge Waivers
Paragraph 1
0
Paragraph 2
0
Paragraph 3
0
Paragraph 4
0
Paragraph 5
0
Paragraph 6
0
Paragraph 7
0
Paragraph 8
0
Paragraph 9
0
Other
(please explain)
0

  • If other, please explain

54. Number of violations, if any, of Executive Order 13989 in 2024.
0

55. Number of enforcement actions, if any, taken in 2024 as a result of violations of the Executive Order 13989 (regardless of whether the violation itself took place in 2024 or earlier).
0

ADDITIONAL COMMENTS FOR PART 11. Please indicate the question number to which the comment corresponds.

  • Please type in the box below.


PART 12. SPECIAL GOVERNMENT EMPLOYEES (SGEs)

56. How many special Government employees (SGEs) did your agency have, in total, during calendar year 2024? (If zero, skip to Additional Comments for this Part.)

  • Enter number
14

57. Initial Ethics Training

a. How many SGEs who were expected to serve for 60 days or less on a board, commission, or committee were required to receive Initial Ethics Training (IET) by December 31, 2024 (5 C.F.R. § 2638.304(b)(2))?

Total number
4

    i. How many of those SGEs received IET before or at the beginning of the first meeting?
4

    ii. How many of those SGEs received IET after the first meeting?
0

    iii. How many of those SGEs have not received IET as of today?
0

    If applicable, please explain why some SGEs received IET after the first meeting or have yet to receive IET.

58. Report the number of SGE public and confidential financial disclosure reports required to be filed by December 31, 2024 and the number of reports actually filed by December 31, 2024.

Confidential Reports
(OGE Form 450 or OGE- Approved Alternative Form)
Public Reports
(OGE Form 278e)
required
filed
required
filed
a. Advisory Committee Members (FACA)
0
0
0
0
b. Advisory Committee Members (non-FACA)
1
1
0
0
c. Experts/Consultants
1
1
0
0
d. Board Members
3
3
0
0
e. Commissioners
2
2
0
0
f. Other
2
2
0
0
TOTAL
9
9
0
0

    Example for new entrant and termination reports: If an employee joined (or departed) the agency on December 15, 2024, and filed a new entrant (or termination) report prior to the end of the calendar year, include the report in your required and filed numbers. If, on January 1, the employee has not filed a new entrant (or termination) report, do not count that report in your required numbers. Instead, include the report in your 2025 questionnaire response to be filed in 2026.

  • If applicable, please explain discrepancies between the number of reports required to be filed and the actual number of reports filed.

59. Note the number of SGE disclosure reports certified or otherwise closed by your agency during the calendar year. Of those reports, indicate how many were initially reviewed within 60 days and how many were certified within 60 days. “Initially reviewed within 60 days” means having completed a technical review and conflicts analysis. See 5 C.F.R. 2634.605, section 4.02 of the Public Financial Disclosure Guide, and the Certification Requirements section of the Confidential Financial Disclosure Guide.

Confidential Reports
Public Reports
a. How many reports did your agency certify or close in 2024?
12
4
b. Of those certified or closed in 2024, how many were initially reviewed within 60 days?
12
4
c. Of those certified or closed in 2024, how many were certified or closed within 60 days?
10
1

  • If applicable, please explain why some reports were reviewed more than 60 days after submission.

  • If applicable, please explain why some reports were certified or closed more than 60 days after submission. Check all that apply.

    other (specify)

  • Specify Other
    Shortage of reviewers.

60. Number of SGEs excluded from all or a portion of the confidential filing requirements per 5 CFR § 2634.904(b).

  • Enter number
4

61. Extensions and late filing fees for SGE financial disclosure reports.

Granted filing extension
Granted waivers of late filing fee
Paid late filing fee
      a. Number of OGE Form 278e Reports
0
0
0

      b. Number of OGE Form 450 or OGE-Approved Alternative Forms
1

ADDITIONAL COMMENTS FOR PART 12. Please indicate the question number to which the comment corresponds.

  • Additional Comments

ADDITIONAL QUESTIONNAIRE COMMENTS:

  • Additional Comments