January 19, 2001
A former high-ranking government official proposed establishing a consulting firm as a sole proprietorship, a partnership, or a corporation, in which he would be one of a very few employees, or perhaps even the sole employee. If, as hypothesized, the consulting firm prepares a report on behalf of certain clients, which is submitted directly to his former agency by the consulting firm, or with the former officials knowledge, by his client with the report bearing the consulting firms name, and it is expected by the former official that his identity as the author of the report may be commonly known throughout the industry and at his former agency, he would be making a communication prohibited by 18 U.S.C. § 207(c).
https://www.justice.gov/file/19276/download