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99x11: Meaning of "Substantially" for Purposes of 18 U.S.C. § 207 and 18 U.S.C. § 208

April 29, 1999

A dollar-based test to determine whether an employee was "substantially" involved in a particular matter involving specific parties for purposes of the lifetime bar of 18 U.S.C. § 207(a)(1) is not consistent with positions taken by OGE and will lead to incorrect conclusions.

(link to PDF version)