How does paragraph 4 affect “very senior employees?”
Very senior employees, as described in 18 U.S.C. 207(d)(1) and 5 C.F.R. 2641.104, are not covered by 18 U.S.C. 207(c), and therefore they are not subject to the two-year restriction in paragraph 4 of the Pledge. However, these very senior employees are already subject to a similar two-year cooling-off period under section 207(d) itself (as well as additional restrictions on contacting Executive Schedule officials even in agencies in which they did not serve).
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