28 Op. O.L.C. 237: Ethics Issues Raised by the Retention and Use of Flight Privileges by Employees of the FAA

Although flight privileges generally do not require disqualification under 18 U.S.C. § 208 from all matters involving the relevant air carrier, a Federal Aviation Administration employee who holds such flight privileges must disqualify him or herself from particular matters where FAA action may have a direct and predictable effect on the relevant air carrier's ability to honor the employee's flight privileges.

https://www.justice.gov/file/18826/download