“Communications” Under 18 U.S.C. § 207

A former high-ranking government official proposed establishing a consulting firm—as a sole proprietorship, a partnership, or a corporation—in which he would be one of a very few employees, or perhaps even the sole employee.  If, as hypothesized, the consulting firm prepares a report on behalf of certain clients, which is submitted directly to his former agency by the consulting firm or, with the former official’s knowledge, by his client with the report bearing the consulting firm’s name, and it is expected by the former official that his identity as the author of the report may be commonly known throughout the industry and at his former agency, he would be making a communication prohibited by 18 U.S.C. § 207(c).