Post-Government
Employment Guidance
Ethics Guidelines
Post-employment information is provided by the Office of the General Counsel (OGC) at the Army & Air Force Exchange Service. It is intended for former Exchange associates who received ethics support from the Exchange OGC and have left Exchange employment. Current associates should consult the General Counsel page on the Exchange portal for in-service ethics guidance.
How to Get Advice on Your Situation
The Exchange
Army and Air Force Exchange Service
ATTN: GC-E (Ethics – Post Employment)
P.O. Box 650060
Dallas, TX 75265-0060
ethics@aafes.com
Advice from ethics counselors is advisory only, provided under 5 C.F.R. § 2635.107 and 41 U.S.C. § 423 (Procurement Integrity Act). Ethics counselors act on behalf of the United States, not as your personal representative. No attorney–client relationship is created by consultation.
Post-Government Employment:
Federal Ethics Rules for Former Exchange Associates
If you’ve left the Army & Air Force Exchange Service (AAFES) and are seeking or starting private employment, federal ethics laws may affect what you can do while job-hunting and after separation. The summary below highlights key restrictions; for fact-specific guidance, email ethics@aafes.com.
Who Should Read This
Former Exchange associates who received ethics support from the Exchange Office of General Counsel (OGC) and are moving to the private sector. Current associates should consult the General Counsel page on the Exchange portal.
Key Restrictions at a Glance
- Lifetime Ban: Representing on the “Same Particular Matter”
After leaving government service, you may not represent another party to the U.S. Government on particular matters in which you personally and substantially participated while employed by the government. This is a permanent (lifetime) restriction.
- What is a “particular matter”?
A decision, deliberation, or action focused on specific parties or an identifiable class, such as:
- Contracts, claims, or applications
- Investigations, controversies, or charges
- Judicial/administrative proceedings or requests for rulings
- Narrowly focused legislation or policymaking affecting a distinct group
Two-Year Ban: Matters Under Your Official Responsibility
For two years after leaving, you may not represent another party to the government on particular matters that were pending under your official responsibility during your last year of service—even if you did not work on them personally.
One-Year “Cooling-Off” for Senior Employees
If you served as a senior employee during your last year (e.g., Executive Schedule Levels II–V or military O-7 and above), you are restricted for one year from attempting to influence your former agency by communications or appearances on behalf of anyone other than yourself or the United States.
This applies to any part of your former agency (e.g., the Exchange, the Army, or the Air Force) and to any Exchange member or employee, regardless of where they now work. Former senior employees are also subject to a one-year ban on assisting a foreign government or foreign political party with the intent to influence any executive branch employee.
Additional Information & Legal References
Find detailed guidance on seeking employment and post-government employment restrictions. Download the PDFs below and review the governing statutes and regulations.
Downloadable PDFs
| Seeking Employment Restrictions (While You’re Job Hunting) — PDF | Plain-language rules that apply while you are looking for a new job, including when to recuse and how to avoid conflicts. |
| Summary of Post-Government Employment Restrictions — 18 U.S.C. § 207 (PDF) | An overview of the lifetime, two-year and one-year bans on representing others before the Government after leaving federal service. |
Authoritative Legal References
- 18 U.S.C. § 207 — Post-employment restrictions (representation back to the Government).
- 18 U.S.C. § 208 — Federal conflicts of interest (financial interests).
- 5 C.F.R. § 2635.107 — Enforcement and remedial action under the Standards of Ethical Conduct.
- 5 C.F.R. Part 2635, Subpart F — Seeking Other Employment (recusal and negotiation rules).
- 5 C.F.R. Part 2635, Subpart H — Outside Activities (limitations on outside work).
Need tailored guidance? Email the Exchange Ethics Office at ethics@aafes.com for fact-specific, advisory assistance.