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Title page

Contents

Key Takeaways 1

What is a conflict of interest? 2

Who implements the executive branch ethics program? 3

What are key elements of the executive branch ethics program? 3

What is the executive branch financial disclosure program? 4

What is the legislative history of the public financial disclosure program? 5

Who files public reports in the executive branch? 5

What information are public filers required to report? 6

What is the history of the confidential financial disclosure program? 6

Who files confidential reports in the executive branch? 7

What information are confidential filers required to report? 8

Can agencies require the disclosure of additional or different information? 8

Who are special government employees? 9

Which financial disclosure reports are SGEs required to file? 9

How many public and confidential financial disclosure reports are filed each year? 10

How are conflict of interest reviews conducted? 11

What actions can be used to address conflicts of interest? 12

What evaluations of the executive branch financial disclosure program have been done? 13

What did these studies find about the financial disclosure system? 13

What are some of the proposed recommendations to improve the public financial disclosure system? 14

Conclusions 16

Matter for Congressional Consideration 16

Recommendation for Executive Action 16

Agency Comments 16

How GAO Did This Study 17

List of Addressees 17

GAO Contact Information 18

Appendix I: History of GAO Reports in the Ethics Area 18

Appendix II: Additional Information on CY2022 Financial Disclosure Reports in Agencies Covered by the CFO Act of 1990 20

Appendix III: Additional Source Information for Images, Tables, or Figures 23

Appendix IV: Comments from the U.S. Office of Government Ethics 24

Tables

Table 1. Executive Branch Financial Disclosure Reporting, 2014-2023 10

Figures

Figure 1. Conflict of Interest under Federal Law and Regulations 2

Figure 2. Executive Branch Financial Disclosure Reports Filed in 2023 4

Figure 3. Timeline of Federal Ethics Legislative Program Reforms 5

Figure 4. Steps to Conduct Conflict of Interest Reviews 11

Appendix Tables

Table 1/Table 4. Key Statistics of Calendar Year 2022 Financial Disclosure Reporting at Agencies Covered by the Chief Financial Officers Act of 1990 20