On November 27, 2015, the Office of Government Ethics (“OGE”) issued a proposed rule that would revise the portions of the Standards of Ethical Conduct for Executive Branch Employees that govern the solicitation and acceptance of gifts from outside sources (“Standards”). See 5 CFR § 2635. Although it is a proposed rule (with the comment period closing on January 26, 2016), the OGE has identified several areas in which the new language is meant to “clarify” the existing rules and “incorporate past interpretive guidance.”
Ashley Bailey is a senior counsel in the Washington, D.C. office of Crowell & Moring and a member of the firm's White Collar & Regulatory Enforcement Group. She is a trial lawyer with more than 15 years of experience litigating criminal and civil matters. Ashley represents business entities and individuals in all manner of criminal and civil proceedings and government and internal investigations and has represented companies and individuals in matters concerning the FCPA, domestic bribery and gratuity provisions, federal conflicts of interest, procurement fraud, honest services fraud, RICO, federal election and campaign finance law, laws governing lobbyists and foreign agents, the Anti-Kickback Act, numerous environmental laws, including the Clean Air, Clean Water, and Lacey Acts. She represents defendants through all phases of criminal litigation, including pre-indictment, trial, sentencing, appeal, and post-conviction relief, and she counts the rarely granted Presidential Pardon among the successes for her clients. Ashley's practice includes extensive regulatory compliance counseling in many of the areas identified above. She serves as Crowell & Moring's General Counsel for lobbying, election, and gift law and leads her firm's election, lobbying, and government ethics compliance practice, including day-to-day counseling of Fortune 500 companies, government contractors, trade associations, major universities, and other U.S. and foreign law firms.