Press Releases

EPA Appointee’s China Ties Draw Congressional Oversight Spotlight

Committee members join Protect the Public’s Trust in investigating senior EPA leader’s continued employment relationship with China

Today, Protect the Public’s Trust applauded members of the House Committee on Oversight and Reform for demanding additional information from the Environmental Protection Agency (EPA) regarding a senior agency official’s relationship with an arm of the Chinese government. As FOIA documents obtained by Protect the Public’s Trust revealed recently, EPA has allowed Dr. Christopher Frey to continue an employment relationship with the Hong Kong University of Science and Technology (HKUST) while he serves at the Agency.

The U.S. Constitution prohibits Americans holding official office from receiving gifts, payments or titles from foreign governments. The Department of Justice has determined that Americans working for public universities in foreign countries generally are considered to be working for that foreign government. Not only do HKUST statutes declare Beijing’s hand-picked Chief Executive of Hong Kong the University Chancellor, but the recent security law essentially erased any distinction between Hong Kong and mainland China.

Despite this, EPA permitted Dr. Frey to merely take a leave of absence from his position with HKUST, presumably allowing him to return as soon as his EPA service ends, rather than forcing him to resign from his adjunct professor role. Furthermore, this relationship was omitted from both his EPA biography page and from the announcement of his appointment to the Agency.

“EPA’s endorsement of Dr. Frey’s continued relationship with an entity that is essentially an arm of the Chinese government is very troubling,” declared Michael Chamberlain, Director of Protect the Public’s Trust. “We applaud the Oversight Committee members for digging into this further. As the members mention, not only is China the world’s largest emitter of greenhouse gases but dissent and academic freedom are under increasing attack at the very institution with which Frey is affiliated. In the midst of questions swirling over the Biden family’s financial relationship with China, the EPA’s nonchalant defense of Frey’s ongoing relationship should raise serious red flags in the eyes of the American public.”


Watchdog Launches Investigation into Possible Improper Gifts and Influence Peddling at Secretary Haaland’s Wedding

Ceremony presents a prime opportunity for “prohibited sources” to circumvent ethics restrictions

Today, Protect the Public’s Trust (PPT) launched an investigation into potential ethics violations and influence peddling that may have occurred at the recent wedding of Secretary Deb Haaland. While we offer our congratulations to the Secretary, we remain committed to carrying out our mission, which requires us to protect the public’s trust that senior government officials are carrying out their duties in an objective, transparent and compliant manner. In the past, special interests have sought to circumvent rules and curry favor through impermissible gifts. Unfortunately, major events like a Cabinet official’s wedding provide an opportune environment for otherwise “prohibited sources” to engage in such chicanery. It is the Constitutional obligation of senior Executive Branch leaders to avoid violations and comply with all relevant laws.

Secretary Haaland’s Native American heritage has been a prominent aspect of her tenure at Interior. Yet as the head of a large federal agency charged with managing billions of dollars and numerous Trust responsibilities, and carrying out regulatory oversight of hundreds of Tribal governments, the Secretary may have placed herself in a compromising situation if she failed to consult with ethics officials every step of the way. The public deserves to know whether Secretary Haaland has improperly solicited or received gifts (through invitation or directly) from “prohibited sources” or foreign governments and to what extent she may have used government resources to do it. We hope Interior will change course from its recent practice of stonewalling requests for information and commit to meeting its statutory obligations.

As the New York Times recently highlighted, officials are not allowed to keep gifts valued at more than $390. Federal regulations, as summarized by DOI’s gift guidance, prohibit Secretary Haaland from accepting gifts of more than $20 from prohibited sources, which include any person seeking official action with DOI, doing business or seeking to do business with DOI, conducting activities regulated by DOI, or having interests that may be substantially affected by the performance or nonperformance of the Secretary’s official duties. Additionally, under the Constitution, it is illegal for an American to accept a gift from a foreign government. These restrictions are imputed to Secretary Haaland’s spouse.

“While Secretary Haaland’s wedding is certainly an occasion for celebration, it unfortunately presents an opportunity for those so inclined to sidestep the rules that protect the interests of the American public,” declared Michael Chamberlain, Director of Protect the Public’s Trust. “The onus is on the Secretary and the Department she has been charged to lead to not only maintain compliance but be able to demonstrate that to the American public. Especially considering the documented lack of compliance with public health restrictions by participants and guests at the wedding, it’s even more vital for the Department to break with their tendencies during the Haaland era and provide the utmost transparency.”



Questions that should be answered:

  • Which DOI officials attended Secretary Haaland’s wedding? What government resources were used in the planning, preparation, and execution of the wedding?
  • Did any Native American Tribe, member of a Tribe’s leadership, employee of a Tribe or other “prohibited source” gift anything of value to Secretary Haaland or her husband? Have they reported any such gifts?
  • Was any attendee at Secretary Haaland’s wedding considered a “prohibited source”? Were the Department’s ethics officials and Solicitor’s Office made aware of this potential conflict and violation of the law?
  • Did the Secretary seek and receive approval from the ethics office prior to sending out any invitations so as to avoid the improper solicitation of gifts from potentially “prohibited sources”?
  • When will the Department release the attendee and gift lists to ensure full transparency around those who participated and provided gifts to Secretary Haaland? 
  • What analysis was conducted, if any, by the Department’s ethics officials prior to wedding invitations being sent out and wedding gifts being accepted? Will the Department release those public records as required under the law?

Update: PPT Complaint Sparks IG Investigation

PPT has received confirmation that the Department of the Interior Inspector General has commenced an investigation based upon a complaint filed by PPT. The complaint alleges DOI’s Nada Culver, Deputy Director for Policy and Programs at the Bureau of Land Management, participated in matters involving Public Land Orders (PLOs) that may have been in violation of federal ethics laws and/or the Biden Ethics Pledge.

Read more

EPA Official Permitted to Join Agency while Continuing Employment Relationship with Chinese Government

Heavily redacted documents raise legal, Constitutional and national security questions

Federal watchdog Protect the Public’s Trust is investigating a U.S. Environmental Protection Agency (EPA) high-level political appointee’s ongoing employment relationship with the Chinese government. The official, Dr. Christopher Frey, has insisted on maintaining his adjunct faculty position with an instrument of the Chinese government while serving at EPA. The information was contained in heavily redacted documents obtained via a Freedom of Information Act (FOIA) request by PPT.

The documents reveal EPA leadership authorized Dr. Frey, Deputy Assistant Administrator for Science Policy, to continue his affiliation with the Hong Kong University of Science and Technology (HKUST) in an unpaid status, despite the Department of Justice’s determination that such relationships are akin to working for a foreign government. Furthermore, the national security law passed last year in Hong Kong erased any meaningful distinction between Hong Kong and mainland Chinese authority. HKUST’s Ordinance and Statutes designate Beijing’s anointed Chief Executive of Hong Kong, a post currently held by Carrie Lam, as Chancellor of the University. It is difficult to argue that Dr. Frey’s employer is anything short of an arm of the Chinese government.

Rather than forcing Dr. Frey to sever ties with HKUST, EPA leadership permitted him to merely take a leave of absence and recuse himself from particular matters having a direct and predictable effect on the financial interests of the University. One can presume from the leave that he plans to return to his employment with the Chinese government upon completing his tenure at EPA. Dr. Frey’s relationship with HKUST, only made known via released FOIA documents, is not mentioned on his official EPA biography nor was it included in the announcement of his appointment to the Agency, further raising transparency and security concerns.

“The American public needs answers to a number of legal, Constitutional and national security questions regarding the decision of EPA to allow Dr. Frey to continue a relationship with an arm of the Chinese government,” stated Michael Chamberlain, Director of Protect the Public’s Trust. “It’s generally expected that political appointees completely break ties with private entities and foreign governments in order to serve the American public. The documents provided shed little light on who, how and why Dr. Frey was allowed to continue this foreign association. The lack of transparency is flabbergasting, especially in light of the Biden Administration’s claims to be the most ethical administration in history. PPT will continue to investigate until we get some answers.”



EPA leadership’s approval of Dr. Frey’s continued employment relationship with the Chinese government raises many questions:

  1. Will Dr. Frey participate in particular matters that involve the Chinese government’s climate obligations such as international climate agreements negotiated by the Biden Administration? 
  2. Has DOJ or the White House Counsel’s Office been consulted on whether the Emoluments Clause issues are satisfactorily resolved or dismissed, as they appear to be with the issuance of Frey’s recusal agreement?
  3. Is the EPA relying on the Foreign Gifts and Decorations Act to enable Frey to continue being employed by an instrument of China?
  4. Records show that Frey was allowed to continue publishing journal manuscripts with students at NCSU under his faculty title. Is he also continuing to do so with Chinese students? Has the agency had that conversation and expressly prohibited him from doing so? 
  5. Will a security clearance be necessary for Frey’s role at EPA?
  6. Which senior political EPA officials granted Frey permission to continue as faculty member of an instrument of the Chinese government and also to continue publishing papers in his NCSU role? Is Administrator Regan aware or concerned with the potential national security, legal, and Constitutional implications of this continued engagement?

Acting Head of EPA Office Admits to Ethics Violation

Watchdog files complaint with Agency Inspector General over actions revealed in FOIA documents

Today, Protect the Public’s Trust filed a complaint with the Inspector General at the Environmental Protection Agency (EPA) alleging a high-ranking official at EPA may have violated his ethics obligations. Documents obtained via FOIA from PPT and other organizations reveal Acting Associate Administrator for the Office of Air and Radiation Joseph Goffman may have improperly exerted his influence to arrange a high-level meeting with Agency personnel on behalf of his former employer. 

Prior to joining EPA, Mr. Goffman was the Executive Director of the Environmental and Energy Law Program at Harvard Law School, a post he held after serving as an attorney at EPA from 2009-2017 during the Obama administration. Less than two weeks after signing his Recusal Statement on April 8, 2021, he took an action that, by his own admission, “my recusal bars me from” – recommending to a subordinate that they take a meeting with Harvard – and which caused ethics officials to have to “unring the bell.” As the EPA’s top ethics official described:

[P]ursuant to Executive Order 13989, Section 2 and the ethics pledge that you signed you agreed not to “participate in any particular matter involving specific parties that is directly and substantially related to [your] former employer” for two years. Despite this restriction, upon receiving an email from an employee of Harvard University, you did not immediately recuse. Instead, you forwarded the email to a subordinate with a recommendation that the Agency should involve itself, and your subordinate agreed.

These actions appear to constitute a blatant violation of ethics rules. As a high-ranking official on his second stint with the agency, Mr. Goffman should be well aware of the ethics regulations governing political appointees. He had signed his Recusal Statement less than two weeks before the apparent violation. The email he received very clearly reveals that, not only would primarily Harvard staff be involved in the meeting, but the meeting requester’s signature indicates she is with Harvard. Furthermore, the requester appeared on Goffman’s podcast several times while he was at Harvard.

“The American public deserves to be assured political appointees are carrying out their duties in an ethical, impartial manner without favoritism toward their former employers,” stated Protect the Public’s Trust Director, Michael Chamberlain. “Asking for forgiveness after the fact, or ‘unringing a bell,’ runs completely counter to the letter, not just the spirit, of the ethics rules. Sadly, as EPA records become available to the public, it appears this is just one example of EPA’s leadership operating in the gray areas, and beyond, of their ethics obligations. The American public has every right to expect more from an administration that has anointed itself the most ethical in history.”



The American public deserves to know:

  1. Whether or not Mr. Goffman violated the Biden Ethics Pledge when he directed his subordinate to schedule a meeting with his former colleague and employer; 
  2. Whether or not Mr. Goffman violated any other ethics regulations by acting in his official capacity to urge a subordinate to accept a meeting request with his former employer; 
  3. Whether Mr. Goffman received additional training or admonishment beyond the immediate email from ethics officials confirming his violation;
  4. Whether Mr. Goffman informed his supervisor in writing, and whether those communications led to any disciplinary action;
  5. Whether or not the meeting requested by Mr. Goffman’s former colleagues ultimately took place; 
  6. If the meeting did take place, what the topics/particular matters that were discussed, the request(s) made by outside parties, the attendees, and any communications before or after the meeting;
  7. Whether Mr. Goffman’s action encouraging his subordinate to schedule a meeting with his former employer constitutes preferential treatment for the former employer and misuse of his government position;
  8. Whether or not Mr. Goffman has since had correspondence with his former employer, participated in any particular matters involving his former employer, or has committed another violation or attempted to violate his ethics obligations. 

Yet Another EPA Official Added to Watchdog’s Ethics Waiver Tracker

EPA Attorney earned apparent rebuke from Agency ethics official for attempting to stretch the bounds of the de facto waiver

Today, federal watchdog Protect the Public’s Trust announced the addition of another appointee at the Environmental Protection Agency (EPA) to its Ethics Waiver Tracker. The EPA’s Principal Deputy General Counsel, Melissa Hoffer, was granted the ability “to make policy decisions as to whether or not to continue or pursue litigation,” for more than three dozen cases involving her former employer, some of which she may have participated in personally and substantially.

The “impartiality determination” allowed Ms. Hoffer to participate in meetings and discussions regarding the “policy decisions” related to these cases, though she was still barred from participation related to the underlying merits of the cases. Yet, even with this flexibility, the EPA’s senior ethics official still had to clarify the boundaries as agency attorneys identified ways they could cross the line. “Once you determine that a case is on their recusal list,” the official intoned, “don’t interact with them on that case. Full stop.”

While the de facto ethics waiver was signed on January 19, 2021, the day before the new Administration began, the Agency had yet to disclose publicly that the EPA’s top lawyer was participating in particular matters involving her former employer. The documents were released by the Agency in response to FOIA requests for ethics records by PPT and other watchdog organizations.

“It’s clear from the documents we’ve obtained that the breadth and scope of the potential conflicts the EPA’s incoming political appointees bring with them are taxing their career ethics staff,” declared Director of Protect the Public’s Trust, Michael Chamberlain. “Unfortunately, these documents are just the tip of the iceberg. We’ve discovered several instances in which high-level political leadership pushed the envelope and operated well into the gray areas of their ethics restrictions, and possibly beyond. This behavior is a far cry from what the American public should expect from the self-described most ethical administration in history.”


Records Show Top Interior Lawyer Sought Ethics Waiver to Work With Former Clients

Documents obtained by watchdog Energy Policy Advocates reveal DOI developed “non-standard language” in order to grant Haaland’s Senior Counselor an unusual ethics waiver

Today, federal watchdog groups Energy Policy Advocates (EPA) and Protect the Public’s Trust (PPT) announced the first batch of publicly released documents obtained via EPA’s Freedom of Information Act (FOIA) litigation with the US Department of the Interior (DOI). The documents pertain to the one-time intended nominee for Deputy Secretary and current Senior Counselor to the Secretary Elizabeth Klein, raising many new questions. Immediately clear is that Klein sought to have the Department grant her an ethics waiver so she could deal with issues before the Department involving her former clients. In pursuit of this waiver, known officially as a “502 authorization,” DOI ethics officials developed what they tellingly described as “non-standard language” that departed from the typical restrictions imposed on appointees facing Senate confirmation. Communications between Interior and the Office of Government Ethics released to the nonprofit group EPA further raise questions about whether it is now Biden Administration policy to change the long-standing interpretation of the 502 ethics regulation in favor of a narrower, appointee-friendly approach.
Given DOI’s refusal to provide public records outside of litigation, the status of the ethics waivers for Klein remains unknown and the subject of two ongoing lawsuits by EPA. However, some engineering of Klein’s initial recusal list appears evident based on the records produced to EPA on Friday, July 23. For instance, three states (NY, MD, MN) that were initially cited by Klein in January as her former clients were later dropped when she sought approval to participate in an April meeting on the Alaska National Wildlife Refuge (ANWR) leasing program. Confusing matters more, even the five clients initially identified by Klein contrasts with her former employer’s website, which indicates 11 states participated in the relevant program.
The effort put into seeking a “502 authorization” for Klein represents an extraordinary step in light of the last Administration’s practice, when no such ethics waivers were granted or even requested by Interior officials.

“The Biden Administration is touting itself as the most ethical in history, but the Department of the Interior certainly doesn’t appear to have gotten that message,” stated Michael Chamberlain, Director of PPT. “From the beginning of this administration they’ve been acting as if they have something to hide and, with the documents EPA was able to obtain after filing suit, it appears they probably do. This sparks the question of what else is going on that the public should be concerned about?”

“As glad as we are breaking through the stonewall that Interior erected when faced with requests for public records,” EPA Executive Director Robert Schilling said, “the documents released, and Interior’s withholding of attachments to the emails, appear to raise more questions rather than providing any answers. Was Interior looking out for the public, or creating backdoor workarounds for high-level officials faced with ethical issues?”


EPA-acquired records raise several questions:

  1. Was Klein granted 502 authorization(s) for her former clients?
  2. Is the “Becerra approach” that relies on “non-standard language” the Administration’s policy and being used for its most senior political appointees? What other appointees have relied on this “non-standard language”?
  3. Was Klein entirely candid with the DOI and OGE ethics officials about the extent and true nature of her relationship with the nearly one third of states that sued DOI in concert with her former employer? Were these relationships analyzed as being covered relationships?
  4. What party matters involving States has Klein participated in since joining the Department? Has she participated in party matters involving the three states that dropped off her recusal list by April 2021 (New York, Maryland and Minnesota)?
  5. Once Klein’s nomination was pulled in late March, why was her ethics recusal memo not finalized until June 5?

Granholm Deputy’s Continued Possible Flaunting of Ethics Rules Sparks Call for Investigation

Watchdog Files Follow Up Complaint Raising Further Apparent Violations of Ethics Obligations by Head of Multi-Billion Dollar DOE Office

Today, federal watchdog Protect the Public’s Trust announced it has filed another complaint with the Office of the Inspector General at the U.S. Department of Energy regarding repeated possible ethics violations by Acting Assistant Secretary for Energy Efficiency and Renewable Energy (EERE) Kelly Speakes-Backman. Today’s complaint inquires whether Ms. Speakes-Backman continued to violate prohibitions against endorsing her former employer and its member organizations more than a month after an initial notice and inquiry was sent to ethics officials at DOE.

In its original letter, Protect the Public’s Trust revealed several instances in which Ms. Speakes-Backman, who served as CEO of the Energy Storage Association (ESA) before her political appointment, may have violated ethics commitments and the Biden Ethics Pledge. She appeared on a number of occasions to have participated in events in which she either endorsed her former employer or was sponsored by a major donor or board member of ESA. The Department declined to respond to PPT’s previous letter and subsequent media inquiries, and failed to produce public records regarding the senior political appointee’s conduct, in violation of federal law.  

Despite notice alerting DOE officials to this potentially improper behavior, Ms. Speakes-Backman appeared to continue the same conduct with another ESA board member-sponsored keynote address delivered to a non-public, paid-admission-only conference of energy storage industry participants seeking taxpayer funds for their various corporate endeavors. Based on the substance and alarming facts discovered in the investigation into Ms. Speakes-Backman’s most recent use of her official position to advance the interests of her former employer and its members, Protect the Public’s Trust has filed an official complaint with agency’s Inspector General.

“At DOE, the head of an office that is poised to oversee more than $4 billion (a 50 percent bump) per the Biden Administration’s budget request seems unable to avoid situations in which she appears to endorse her former employer and its donors,” Director of Protect the Public’s Trust, Michael Chamberlain, stated. “The pattern is so blatant a neutral observer is left wondering whether Ms. Speakes-Backman ever participates in events that DON’T involve her former employer or its board members. Given the ethics concerns around Secretary Granholm’s continuing to hold Proterra stock options while the administration promoted the company, and the Biden Administration’s claim of being the most ethical in history, the American public can rightfully ask why DOE is not taking these repeated apparent ethics violations more seriously.”



The American public deserves to know:

  1. Whether or not Ms. Speakes-Backman has endorsed, intentionally or otherwise, her former employer and its members while speaking in her official capacity at any of the events identified in PPT’s earlier complaint and as such violated 5 CFR § 2635.702.
  2. Whether Ms. Speakes-Backman was aware that one of her former employer’s “Leadership Council Members” was the lone sponsor for the portion of the conference where Ms. Speakes-Backman was the keynote speaker on April 21, 2021. Whether she was aware that her former employer’s board member NextEra Energy Resources was the lone sponsor of her keynote presentation on June 22, 2021. 
  3. Whether she relayed any of this information to ethics officials prior to accepting the invitations to speak. If so, what guidance, if any, did the Ethics Office provide to Ms. Speakes-Backman about possible conflicts and/or an appearance of a conflict of interest that could result from her acceptance of these invitations? Did she provide her prepared remarks for ethics approval prior to accepting these invitations and attending the events? 
  4. Whether Ms. Speakes-Backman sought guidance or received counseling to avoid participating in events that present an inherent appearance of a conflict of interest or endorsement of a former employer’s member.
  5. Whether Ms. Speakes-Backman is participating in particular matters involving her former employer or board members that may violate federal law, regulations or the Biden Ethics Pledge. In exploring this question, all records of meetings and particular matters that Ms. Speakes-Backman is or has been involved in should be reviewed and, at the appropriate time, provided to the public for review.
  6. Whether the current process for political appointees at DOE such as Ms. Speakes-Backman includes appropriately communicating with ethics officials for all public speaking engagements and whether they are appropriately informed of the particular matters they should recuse themselves from prior to deliberating, deciding, or acting upon. 
  7. Whether Ms. Speakes-Backman plans to continue participating in events sponsored by her former employer’s board members and donors. Is this a practice condoned by DOE ethics officials and consistent with past practice for senior government officials?

Watchdog Org Looks for Answers Regarding Interior’s Lack of Transparency

Haaland’s Department has lagged in providing routine ethics information 

On the eve of the members-only meeting of the Society of Environmental Journalists (SEJ) with top aides to Interior Secretary Deb Haaland, federal watchdog Protect the Public’s Trust offers a series of suggested questions for SEJ moderators and members to address transparency challenges at Haaland’s Department. 

Protect the Public’s Trust has filed more than a dozen FOIA requests with the Department, many dating back to early May and June and has received responsive documents on only one request. Even requests that have been deemed “Simple” by the Department’s FOIA staff and those for documents that have been routinely offered to the public, such as ethics guidance, calendars, and financial disclosures, have languished. PPT is not alone, as other organizations have encountered unprecedented barriers to obtaining information and transparency from the Department of the Interior under its current leadership.

  1. Why was an organization with a long-standing track record of Freedom of Information Act requests denied a fee waiver on a routine request and forced to go to court?
  2. Does the Department intend to comply with the law and respond to PPT’s outstanding FOIA requests, many of which have passed the statutory deadline?
  3. On May 25, Senior Counsel Elizabeth Klein testified at a House Subcommittee she would provide her ethics and recusal documents in place at that time. But when the Department eventually did produce documents, they were dated more than a week after her testimony. When will the Department deliver the documents in place at that time, as promised, as well as those in place from the date of her appointment?
  4. Will the Department provide these same documents, including financial disclosures, for other political appointees in response to existing FOIA requests?
  5. Previous administrations had published the calendars for the Secretary on the Department website as a matter of routine? Does Secretary Haaland’s team plan to provide this information to the public and when does it plan to begin doing so?
  6. When does the Department plan to update its online FOIA tools to provide information and reflect requests received during the current administration?
  7. Is the Department abusing the White House equity process to unnecessarily delay the release of documents routinely provided without such review? Pending litigation for records from junior staff within the Office of Congressional Affairs would seem to indicate this is the case.

“The Biden Administration has promised unprecedented levels of transparency but what we and others have encountered at Secretary Haaland’s Department of the Interior are unprecedented levels of opacity,” said Michael Chamberlain, Director of Protect the Publics’ Trust. “With all of the potential conflicts of its top leadership, such as Liz Klein and Tommy Beaudreau, does she believe the Department has something to hide? The lack of transparency at Interior does not inspire trust.”


Watchdog Questions Whether Haaland’s Top Water Attorney May Have Committed “Egregious” Violation of Federal Law

In wake of ethics questions among other appointees at Interior, Deputy Solicitor may have violated a criminal conflict of interest statute

Today, government watchdog Protect the Public’s Trust filed a complaint with the Department of the Interior asking the Office of the Inspector General to look into whether a high-ranking official may have violated his ethics obligations and Federal law. The complaint documents conduct that could constitute a blatant and egregious violation of ethics commitments.

In June 2021, Daniel Cordalis, Deputy Solicitor for Water Resources at the Department of the Interior (Department), personally rescinded a January 2021 memo issued by career attorneys. In withdrawing the earlier memo, the “Cordalis Memo” appears to have the effect of increasing funding to a Restoration Fund from which the Yurok Tribe in California has been a beneficiary. Court records indicate the Tribe was a client of Mr. Cordalis as recently as January. In addition, his wife currently serves as the Yurok Tribe’s General Counsel and has been touted by Tribal leaders as “the future” of the Tribe’s long-term success. Mrs. Cordalis testified on behalf of the Tribe at a Congressional hearing just weeks before her husband issued the Cordalis Memo.

Federal employees are required to act impartially, avoid situations that create the perception of a conflict of interest and are prohibited from working on particular matters involving entities with which they have a “covered relationship,” a category that includes former clients as well as spouse’s employers. The Biden Ethics Pledge expands such restrictions for political appointees. Employees may be granted waivers to certain requirements but are required to seek guidance from their agency’s ethics officials prior to engaging in matters that may put them in violation of these obligations. There is no such waiver posted by the Federal Office of Government Ethics, which publishes waivers granted to the Biden Ethics Pledge, and the Department has not provided any documents in response to a Freedom of Information Act request for all such waivers.

“The American public has every right to demand that high-ranking federal officials act in the best interests of the public, not the interests of former employers and clients or their spouse’s employers,” stated Director of Protect the Public’s Trust, Michael Chamberlain. “The Biden Administration promised ‘the most ethically vigorous administration in history.’ At what point does Secretary Haaland begin holding her staff to that high standard? Unfortunately, with multiple reports of misconduct among Interior appointees under review, the public is wondering whether there is a ‘culture of conflicts’ among current DOI leadership.”



The American public deserves to be assured that political appointees are carrying out their duties in an ethical, impartial manner without favoritism or unjust personal enrichment to their former clients or their family members. Protect the Public’s Trust therefore asks the Office of Inspector General and the Departmental Ethics Office to begin an immediate and thorough investigation into the following issues:

  1. Whether or not the Cordalis Memo constitutes a violation of 18 U.S.C. § 208 and thus warrants a referral to the appropriate authorities within the Department of Justice;
  2. Whether or not Mr. Cordalis sought or received guidance from the Ethics Office as to whether he should participation in the CVPIA issues addressed in the Cordalis Memo;
  3. If he did not, whether Mr. Cordalis should have sought or received guidance or approval from the Department Ethics Office (DEO) to participate in this matter given the strong potential for actual or perceived conflicts of interest;
  4. What guidance, if any, the DEO provided to Mr. Cordalis on this matter; and
  5. Whether or not Mr. Cordalis received a waiver to participate in this matter and, if not, whether his participation constitutes a violation of his ethics obligations Section 208, 502(a)(2) or the Biden Administration Ethics Pledge.