S. 1491: SGE Ethics Enforcement Reform Act of 2025

This bill, titled the SGE Ethics Enforcement Reform Act of 2025, aims to amend regulations concerning special Government employees (SGEs) to enhance transparency and enforce stricter ethical standards. Below are the main components of what the bill proposes:

Definitions and Findings

The bill identifies special Government employees as individuals serving in advisory capacities or similar roles and highlights concerns regarding their financial conflicts of interest. The findings point out that:

• Many SGEs have significant financial interests that could conflict with their Government duties.
• Current laws allow certain SGEs to avoid disclosing conflicts of interest if their work does not involve specific matters, which may hinder transparency.
• Most SGEs do not publicly disclose their financial interests, unlike senior executive employees.
• There are cases where SGEs are given high levels of responsibility without adequate oversight.
• Extended use of SGEs beyond the mandated 130 days within a year has been allowed without proper notification.

Amendments to Conflicts of Interest Regulations

The bill proposes to amend Title 18 of the United States Code, specifically concerning conflicts of interest for SGEs. Key changes include:

• Defining SGEs more clearly, noting that they must be designated on official personnel forms.
• Stipulating that SGEs who are not part of advisory committees must resolve any conflicts of interest concerning companies they are affiliated with.
• Establishing a requirement for public disclosure of any waivers or exemptions issued to SGEs within two weeks of their approval.

Restrictions on Communications

The bill introduces mandatory communication restrictions between SGEs and large companies that the Government regulates or works with, particularly focused on:

• SGEs owning or holding a position in companies worth over $1 billion in market cap or revenue.
• Preventing SGEs from having direct or indirect communications with agencies that deal with such large companies while serving in their official capacities.

Requirements for a Public Database

To promote transparency, the legislation mandates the creation of a public database that will include:

• The names of SGEs and the details of their roles.
• The duration they have served in their capacities.
• The rationale for their designation as special employees rather than regular employees.

Enhanced Financial Disclosure Requirements

The bill strengthens financial disclosure rules for SGEs by:

• Removing any exemptions for certain categories of SGEs from disclosing financial interests.
• Ensuring a review process for any exemptions claimed from filing requirements.

Modifications to Ethics Rules

Under this bill, SGEs who have served for more than 60 days in a 365-day period will be subjected to the same ethics rules as regular employees. This means

• All ethics rules must apply equally, especially for those who have served beyond 130 days.
• Any exceptions to this rule will still place them under the requirement for compliance with ethics regulations, regardless of their pay status.

Implementation and Regulation

The Office of Government Ethics will be responsible for implementing and defining the regulations necessary for the enforcement of this bill. This includes guidelines on identifying ownership of large companies and monitoring compliance by SGEs.

Relevant Companies

• AMZN - Amazon.com, Inc.: As a large company likely to engage with regulatory agencies, any SGEs associated with Amazon could face restrictions on communications under the bill.
• MSFT - Microsoft Corporation: Microsoft, as a major contractor and significant player in various regulatory discussions, would be impacted regarding its interactions with Government employees.
• GOOGL - Alphabet Inc.: Similar to Amazon and Microsoft, Alphabet may face restrictions on communications with SGEs involved in its regulatory dealings.