On January 21, 2009, President Obama issued Executive Order 13490, Ethics Commitments for Executive Branch Personnel. One of the requirements under the Executive Order is that appointees of his Administration sign an Ethics Pledge confirming a commitment to abide by the provisions the President has set forth in the Order. Non-career appointees at the Department of Justice, with few exceptions, must execute the Ethics Pledge and are subject to its provisions. The Office of Government Ethics (OGE) has issued guidance on the Pledge provisions; their interpretive memoranda are linked below.
The applicability of certain Pledge restrictions depends largely upon a determination whether persons or entities are lobbyists or lobbying organizations "registered" under the Lobbying Disclosure Act (LDA), 2 U.S.C. § 1601, et seq. Lobbyist registration is determined through searchable databases maintained by the Secretary of the Senate and the Clerk of the House of Representatives. In interpreting the provisions of the Ethics Pledge, these are the only databases upon which appointees and ethics officials may rely in order to determine that a party is a registered lobbyist.
OGE Interpretive Memoranda