Payment of Moving Expenses as Supplementation of a Government Officer’s Salary


Private employer’s payment of prospective federal officer’s moving expenses does not constitute a supplementation of his federal salary in violation of 18 U.S.C. § 209, where the payment is contractually or routinely paid to departing employees, where the purpose of the payments is other than to compensate federal employment, and where the entitlement and amount of the payment do not favor federal employment.

While neither the prospective officer’s continued affiliation with his private employer, nor its payment of his moving expenses, create an immediate or anticipated conflict of interest with his governmental duties, the Justice Department’s Standards of Conduct might require that he disqualify himself from any official participation in a matter affecting his private employer’s interests.

Updated July 9, 2014