Office of the Inspector General 

U.S. Department of Justice 

Review of Policies and Training
 

Governing Off-Duty Conduct by 

Department Employees Working in
 

Foreign Countries
 

Evaluation and Inspections Division 15-2 January 2015 
 

 

 

 

 

 

 

 

EXECUTIVE SUMMARY 

After allegations arose regarding the conduct of U.S. government 

personnel, including three Drug Enforcement Administration (DEA) 

agents, during the President’s visit in 2012 to Cartagena, Colombia, the 

Department of Justice (DOJ or Department) Office of the Inspector 

General (OIG) received inquiries from Members of Congress regarding the 

training provided to DOJ personnel working outside the United States 

about off-duty behavior. Off-duty misconduct by DOJ employees 

working abroad can present unique concerns, particularly for those in 

law enforcement and those with security clearances. Moreover, when offduty misconduct occurs abroad, the impact on the U.S. government’s 

reputation and its law enforcement efforts can be especially damaging. 

In this review, the OIG initially sought to identify DOJ policy and 

training addressing off-duty conduct abroad. We found that, to the 

extent such policies existed, they did not specifically address off-duty 

conduct when outside the United States, but rather applied regardless of 

location. We therefore looked at DOJ’s off-duty conduct policies more 

broadly, and particularly at four behaviors, one or more of which is often 

present during off-duty incidents of employee misconduct: 

• consuming excessive alcohol, 

• using illegal drugs, 

• soliciting prostitutes, and 

• engaging in notoriously disgraceful conduct.1 

We requested any policies and training information related to these 

behaviors that applied Department-wide, as well as policies and training 

information from DOJ’s Criminal Division, which is responsible for 

several international programs, and from four of DOJ’s law enforcement 

components (the DEA; Bureau of Alcohol, Tobacco, Firearms and 

Explosives (ATF); Federal Bureau of Investigation (FBI); and 

U.S. Marshals Service (USMS)). Together, these five components have 

1 “Notoriously disgraceful conduct” is defined in the Department of State’s 

Foreign Affairs Manual (FAM) as “conduct which, were it to become widely known, would 

embarrass, discredit, or subject to opprobrium the perpetrator, the Foreign Service, and 

the United States.” 3 FAM 4139.14. 

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more than 1,200 permanent positions in foreign countries, and their 

employees make more than 6,100 trips a year to more than 140 

countries. 

RESULTS IN BRIEF 

DOJ lacks Department-wide policies and training requirements 

that address off-duty conduct, whether in the United States or 

foreign countries, although in the past it recognized its components 

had a need for them. The Department was unable to provide us with 

any Department-wide policies or training requirements that pertain to 

employees’ off-duty conduct, whether within the United States or in other 

countries. We found this troubling given the OIG’s report in 1996 about 

the Good O’ Boy Roundups and our findings at that time regarding offduty misconduct.2 In that report, we found DOJ had only very general 

provisions in place governing off-duty conduct and that many DOJ 

employees did not understand their off-duty responsibilities well. Among 

other things, we recommended the Department provide training 

regarding the regulation of off-duty conduct. In April 1997, a year after 

we issued the report, Attorney General Janet Reno issued a 

memorandum containing “basic guidance on off-duty conduct” to DOJ 

component heads. The memorandum directed component heads to 

change their training programs to ensure that DOJ employees were 

aware of and understood their “obligations to avoid conduct on or off the 

job which may have a negative impact on their ability to perform this 

mission.”3 However, we found no indication that DOJ had revisited its 

off-duty conduct policies or training in any comprehensive manner since 

then, and no indication that DOJ, despite its significant international 

presence, had established a Department-wide policy or training directed 

at off-duty conduct abroad. 

Most of the five components we reviewed convey little or no 

information about off-duty conduct before sending their employees 

abroad. While all five components had policies that touch in some way 

2 The roundups were a series of private, annual gatherings attended by off-duty 

officers from a number of federal, state, and local law enforcement agencies. U.S. 

Department of Justice Office of the Inspector General, Good O’ Boy Roundup Report 

(March 1996), http://www.justice.gov/oig/special/ 9603/index.htm. 

3 See Appendix II for the full memorandum. 

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on off-duty conduct and apply whether their employees are in the United 

States or other countries, the OIG found significant gaps in what was 

covered. Substantial gaps also exist in the training the components’ 

personnel receive before going abroad. Much of the policy and training 

that was provided did not clearly communicate what employees can and 

cannot do off duty. For example, many of the materials we examined did 

not clearly state that employees remain subject to DOJ requirements 

regardless of whether certain conduct, such as prostitution and drug 

use, is legal in the foreign jurisdiction where the DOJ employee is 

serving. 

Of the five components, the FBI has done the most to prepare its 

employees to make day-to-day decisions that reflect well on themselves 

and the FBI. Although its policies on the four specific behaviors we 

reviewed were not comprehensive, its training clearly established 

standards for employees’ on- and off-duty conduct. The FBI also 

provided employees with extensive pre-deployment training regarding 

conduct abroad. 

We found that the DOJ component with the largest international 

presence, the DEA, provided its employees with the least information 

about off-duty conduct while abroad and that its policies and training 

had significant gaps. The DEA was also the only DOJ law enforcement 

component that did not formally remind its employees after the 

Cartagena incident of the need to adhere to professional standards of 

behavior, even though DEA agents were involved.4 DEA officials told us 

that DEA delayed formal dissemination of information regarding its 

standards of behavior pending the final resolution of an appeal by one of 

the Cartagena agents to the U.S. Merit Systems Protection Board (MSPB) 

challenging his termination.5 With regard to the Criminal Division, ATF, 

4 DEA updated its personnel manual and disseminated the revised information 

DEA-wide on November 6, 2014. On December 17, the DEA informed the OIG that the 

update revised two subsections of its personnel manual to clarify that soliciting or 

engaging in prostitution is forbidden regardless of legality and that employees must 

maintain the highest standards of conduct when associating with individuals known to 

be engaged in or suspected of illegal drug or criminal activity. 

5 On January 9, 2015, DEA’s Chief Counsel Office stated that one of the DEA 

agents involved in the Cartagena incident had appealed to the U.S. Court of Appeals for 

the Federal Circuit, challenging his indefinite suspension without pay based upon the 

revocation of his security clearance. 

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and USMS, we found they also had weaknesses in their policies and 

training regarding conduct abroad, and we noted that the Criminal 

Division was in the process of strengthening its materials at the time of 

our review. 

In reviewing the specifics of the components’ policies, we 

recognized that no set of rules can cover all situations employees may 

encounter when working in foreign countries. The experiences of two 

other federal departments with significant international presence, the 

Departments of Defense and State, have shown that, rather than 

creating laundry lists of “don’ts,” organizations need to communicate 

policy in ways that establish a pervasive context employees can rely on to 

make day-to-day decisions about their behavior. We found that has 

generally not occurred in DOJ. 

The report makes six recommendations regarding the policies and 

training governing off-duty conduct by DOJ employees working in foreign 

countries. 

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TABLE OF CONTENTS 

INTRODUCTION .................................................................................. 1
 

Incidents that Prompted this Review ............................................... 1
 

Previous Concerns Raised about Off-Duty Conduct......................... 2
 

DOJ’s International Presence.......................................................... 4
 

Federal Agencies’ Authority to Limit Employees’ Off-Duty Conduct . 6
 

Four Types of Behavior Considered in this Review ........................... 6
 

Government-Wide Pre-Deployment Training Requirements ............. 8
 

RESULTS OF THE REVIEW............................................................... 10
 

Department-Wide Policies and Training Requirements Regarding 

Off-Duty Conduct While Working Abroad...................................... 10
 

Individual Components’ Policies and Training Regarding Off-Duty 

Conduct Abroad ........................................................................... 12
 

Policies .................................................................................... 13
 

Training................................................................................... 22
 

Post-Cartagena Communications with Employees .................... 28
 

CONCLUSION AND RECOMMENDATIONS ........................................ 30
 

APPENDIX I: SCOPE AND METHODOLOGY OF THE OIG’S 

REVIEW ............................................................................................ 33
 

APPENDIX II: ATTORNEY GENERAL MEMORANDUM ON OFF-DUTY 

CONDUCT, 1997 ............................................................................... 35
 

APPENDIX III: EXCERPTS FROM THE DEPARTMENT OF STATE CABLE 

ON HUMAN TRAFFICKING, 2012.....................................................40 

APPENDIX IV: DOD SOUTHCOM GENERAL ORDER 

NUMBER 1, 2012 .............................................................................. 42
 

APPENDIX V: LAW ENFORCEMENT COMPONENT TABLES OF 

OFFENSES AND PENALTIES ............................................................. 48
 

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APPENDIX VI: DEA STANDARDS OF CONDUCT QUESTIONNAIRE AND 

ACKNOWLEDGMENT FORM ............................................................. 52
 

APPENDIX VII: DEA ADMINISTRATOR MEMORANDUM ON ALCOHOL 

CONSUMPTION, 1999 ...................................................................... 56
 

APPENDIX VIII: THE OFFICE OF THE DEPUTY ATTORNEY 

GENERAL’S RESPONSE TO THE DRAFT REPORT ............................. 58
 

APPENDIX IX: OIG ANALYSIS OF THE OFFICE OF THE
 

DEPUTY ATTORNEY GENERAL’S RESPONSE .................................... 60
 

APPENDIX X: THE BUREAU OF ALCOHOL, TOBACCO, FIREARMS
 

AND EXPLOSIVES’ RESPONSE TO THE DRAFT REPORT .................. 62
 

APPENDIX XI: OIG ANALYSIS OF THE BUREAU OF ALCOHOL, 

TOBACCO, FIREARMS AND EXPLOSIVES’ RESPONSE...................... 65
 

APPENDIX XII: THE CRIMINAL DIVISION’S RESPONSE TO THE 

DRAFT REPORT ................................................................................ 67
 

APPENDIX XIII: OIG ANALYSIS OF THE CRIMINAL DIVISION'S 

RESPONSE ...................................................................................... 69 

APPENDIX XIV: THE DRUG ENFORCEMENT ADMINISTRATION'S 

RESPONSE TO THE DRAFT REPORT ................................................ 71 

APPENDIX XV: OIG ANALYSIS OF THE DRUG ENFORCEMENT
 

ADMINISTRATION'S RESPONSE ....................................................... 73 

APPENDIX XVI: THE FEDERAL BUREAU OF INVESTIGATION’S 

RESPONSE TO THE DRAFT REPORT ................................................ 75 

APPENDIX XVII: OIG ANALYSIS OF THE FEDERAL BUREAU OF 

INVESTIGATION'S RESPONSE ......................................................... 77 

APPENDIX XVIII: THE UNITED STATES MARSHALS SERVICE'S 

RESPONSE TO THE DRAFT REPORT ................................................ 79 

APPENDIX XIX: OIG ANALYSIS OF THE UNITED STATES 

MARSHALS SERVICE'S RESPONSE ................................................. 82 

Department of Justice 

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INTRODUCTION 

After allegations arose regarding the conduct of U.S. government 

personnel, including three Drug Enforcement Administration (DEA) 

agents, during President Obama’s visit in 2012 to Cartagena, Colombia, 

the Department of Justice (DOJ or Department) Office of the Inspector 

General (OIG) received inquiries from Members of Congress regarding the 

training DOJ provides to its personnel working outside the United States 

about their off-duty behavior. As representatives of the U.S. government, 

off-duty misconduct by DOJ employees stationed abroad can present 

unique concerns, particularly for employees involved in law enforcement 

and those with security clearances. Moreover, when off-duty misconduct 

occurs abroad, the impact on the U.S. government’s reputation and the 

impact on its law enforcement efforts can be especially damaging. 

Incidents that Prompted this Review 

In April 2012, agents from the U.S. Secret Service within the 

Department of Homeland Security and military personnel from the 

Southern Command of the Department of Defense were sent to Cartagena 

to prepare for President Obama’s attendance at the Summit of the 

Americas. According to reviews later conducted by the Secret Service and 

the Department of Defense, and testimony at congressional hearings, some 

of these government employees drank heavily while off duty, solicited 

prostitutes, and brought the prostitutes back to their hotel. A dispute 

between a prostitute and one of the Secret Service agents drew the 

attention of the hotel’s manager, who reported it and the incidents of 

rowdy behavior to the U.S. Embassy. That, in turn, led to a Secret Service 

investigation of the actions of 11 of its employees suspected of soliciting 

prostitutes and a Department of Defense investigation of 12 of its 

personnel. 

The Secret Service investigation uncovered a separate incident 

involving one of its agents in the presidential detail and three DEA agents 

on permanent assignment in Cartagena who had solicited and associated 

with prostitutes. The DOJ OIG investigated the DEA agents’ conduct. 

Two of those agents ultimately admitted to soliciting and paying for “erotic 

massages” for their sexual gratification while stationed in Cartagena, while 

the third admitted to compensating a woman for sex. However, all three 

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agents resisted the characterization of their engaging in sexual encounters 

in exchange for a form of payment as prostitution. The DEA subsequently 

revoked the agents’ eligibility for access to National Security Information 

(NSI).6 

OIG investigators found no evidence that the DEA agents had been 

provided any training or instruction about not soliciting prostitutes or 

sexual service providers while stationed in Colombia. The lack of 

instruction in this circumstance is of particular concern because 

prostitution is allowed in Colombia. Reportedly, some individuals who 

have solicited prostitutes there have been subject to extortion, and drug 

cartels have used prostitutes to collect intelligence. 

Previous Concerns Raised about Off-Duty Conduct 

This is not the first time that the OIG has reviewed the off-duty 

conduct policies of the Department following serious allegations of 

misconduct by DOJ law enforcement officers. As we discuss in further 

detail below, in 1996, following allegations surrounding attendance by 

DOJ law enforcement agents at domestic events called the Good O’ Boy 

Roundups, the OIG investigated the matter and issued a report. As we 

noted in that report: 

This investigation involved a murky and difficult area – the 

responsibilities of federal employees generally, and federal 

law enforcement personnel in particular, to conduct 

themselves in a manner consistent with their law 

enforcement responsibilities even when they are off-duty. 

Many DOJ employees believe that what they do off-duty is 

their business and not a proper concern of their employer. It 

is important to recognize, however, that even off-duty 

conduct can bring discredit upon the employee, the 

employee’s colleagues, and the Department of Justice. 

The existing standards of conduct regulate off-duty conduct 

when it could impair the effectiveness of DOJ employees or 

bring discredit on their employing agency. Such regulation 

is wholly appropriate. Being a federal law enforcement 

6 As of January 9, 2015, DEA’s Chief Counsel Office stated that one of the DEA 

agents had appealed to the U.S. Court of Appeals for the Federal Circuit challenging his 

indefinite suspension without pay based upon the revocation of his security clearance. 

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officer within the Department of Justice is a privilege not a 

right; it can appropriately be conditioned on maintaining a 

proper level of behavior at all times. 

Our investigation revealed, however, that such off-duty 

responsibilities are generally not well-understood by many 

DOJ employees. This lack of understanding is in part the 

result of the very general provisions that govern off-duty 

conduct. It also appears to stem from a lack of adequate 

direction to supervisors and employees regarding the 

application of these provisions.7 

In this review, the OIG looked first for policy and training 

requirements addressing off-duty conduct abroad. We found that any 

policy addressing off-duty conduct applied regardless of the employees’ 

location, and therefore we considered off-duty conduct policy more 

broadly. We particularly looked at four behaviors, one or more of which is 

often present during off-duty incidents of employee misconduct: 

• consuming excessive alcohol, 

• using illegal drugs, 

• soliciting prostitutes, and 

• engaging in notoriously disgraceful conduct.8 

We requested any policies and training information related to these 

behaviors at the Department-wide level, as well as from the Criminal 

Division, which is responsible for several international programs, – and 

from four of DOJ’s law enforcement components – the Bureau of Alcohol, 

Tobacco, Firearms and Explosives (ATF); Drug Enforcement 

7 U.S. Department of Justice Office of the Inspector General, Good O’ Boy 

Roundup Report (March 1996), http://www.justice.gov/oig/special/9603 

/gr000154.htm#E43E3. The report was investigative in nature, looking at whether any 

DOJ employees should be considered for discipline rather than whether DOJ needed to 

make institutional changes. Consequently, the OIG did not put the report’s 

recommendations through the standard resolution process it uses for audit, evaluation, 

and other reports to track and document the implementation of institutional changes. 

8 “Notoriously disgraceful conduct” is defined in the Department of State’s Foreign 

Affairs Manual (FAM) as “conduct which, were it to become widely known, would 

embarrass, discredit, or subject to opprobrium the perpetrator, the Foreign Service, and 

the United States.” 3 FAM 4139.14. 

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Administration (DEA); Federal Bureau of Investigation (FBI); and 

U.S. Marshals Service (USMS).9 

In this introductory section, we describe DOJ’s international 

presence, the authority of federal agencies to limit their employees’ offduty conduct, and the four types of behavior we considered in this review. 

We then briefly discuss a government-wide requirement for providing 

limited training to certain federal employees before they go abroad. Later 

in the report, we outline the DOJ-wide policies and training requirements 

regarding off-duty conduct while working abroad, as well as the policies of 

four of the Department’s law enforcement components and the Criminal 

Division. Lastly, we present our recommendations. 

DOJ’s International Presence 

Most of the employees representing DOJ in foreign countries are law 

enforcement agents, but a significant number of attorneys, analysts, and 

support personnel also work abroad for DOJ. They are usually there to 

establish and maintain working relationships with their counterparts in 

other nations, provide training, assist with investigations, or transport 

fugitives back to the United States. 

The five DOJ Table 1: Components’ Presence

in Foreign Countries components included in this 

review deploy all of the DOJ 

personnel stationed in 

foreign countries, according 

to the Justice Management 

Division. In July 2013, 

these five components had 

1,240 permanent positions 

abroad. Their employees 

also made more than 6,100 

trips from the United States 

to 141 foreign countries on 

DOJ business in fiscal year 

Source: OIG analysis of component data. 

*The Criminal Division positions, which involve 

what it considers to be long-term overseas 

placements, include details and term positions. 

Component 

Permanent 

Positions 

(July 2013) 

TDY Trips

(FY 2012) 

ATF 20 404 

Criminal Div. 80* 444 

DEA 833 1,751 

FBI 284 2,761 

USMS 23 799 

Total 1,240 6,159 

9 See Appendix I for the OIG’s scope and methodology for this review. 

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(FY) 2012.10 Of the components, the DEA has the largest presence abroad, 

representing two-thirds of the five components’ permanent positions in 

other countries. Although the DEA has about one-fourth of the employees 

that the FBI has (9,497 versus 35,697), it had nearly three times as many 

employees stationed abroad as the FBI (833 versus 284). Table 1 shows 

the five components’ foreign presence. 

All of the five components’ 1,240 permanent positions abroad 

require Top Secret security clearances, and many of the employees making 

TDY trips abroad also have clearances at that level, giving them access to 

national security information. If foreign intelligence services or criminal 

organizations can exploit the off-duty conduct of these employees, 

information sensitive enough to gravely compromise national security may 

be revealed. Moreover, maintaining such a security clearance requires an 

employee to undergo periodic adjudications that consider foreign 

influence, sexual behavior, personal conduct, alcohol consumption, drug 

involvement, psychological conditions, and other factors that relate to offduty conduct to determine whether the employee should continue to be 

trusted with classified information. Losing a security clearance can have 

severe consequences for an employee’s career, so a strong awareness of 

what DOJ expects of an employee during off-duty hours is important at 

the individual level as well as at the Department level. 

In addition, for DOJ's law enforcement agents, off-duty conduct can 

seriously affect the DOJ’s ability to successfully prosecute defendants 

brought to court after lengthy, complex investigations. One of an agent’s 

most important responsibilities is to provide objective and unbiased 

testimony during criminal and other proceedings. Agents whose off-duty 

conduct undermines their credibility cannot perform their official duties 

effectively. Moreover, under Federal Rule of Evidence 608(b), defense 

counsel may be able to impeach an agent during cross examination by 

asking about specific instances of past conduct that are probative of the 

agent’s character for truthfulness or untruthfulness.11 

10 This type of travel is referred to as temporary duty or TDY. In addition, this 

total does not include trips to foreign countries taken by employees of other components, 

such as the U.S. Attorneys’ Offices. 

11 See also Giglio v. United States, 405 U.S. 150, 154 (1972); Brady v. Maryland, 

373 U.S. 83 (1971). 

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Federal Agencies’ Authority to Limit Employees’ Off-Duty Conduct 

Pursuant to Title 5, United States Code, Section 7513, a federal 

employee may be disciplined for off-duty conduct if there is a connection 

(or nexus) between the offending conduct and the employee’s job-related 

responsibilities such that the proposed discipline would “promote the 

efficiency of the service.”12 Generally, a sufficient nexus can be 

established if the conduct adversely affects the employee’s or a co-worker’s 

job performance or management’s trust and confidence in the employee’s 

job performance, or if the off-duty conduct interferes with or adversely 

affects the agency’s mission or violates the culture of a workplace.13 This 

concept usually applies when the employee engages in the very type of 

behavior that the agency or the employee is charged with preventing or 

addressing. 

Four Types of Behavior Considered in this Review 

Conduct that can harm employees’ ability to carry out their 

responsibilities and DOJ’s ability to carry out its mission can take a 

number of forms. We focused on policies and training related to four types 

of off-duty behavior that can reflect questionable judgment; undermine 

DOJ employees’ integrity and credibility; impede the performance of 

employees’ official duties; create a vulnerability to exploitation, 

manipulation, or duress; and discredit their colleagues and DOJ. These 

behaviors are also considered when adjudicating security clearances: 

• consuming excessive alcohol, 

• using illegal drugs, 

• soliciting prostitutes, and 

• engaging in “notoriously disgraceful conduct.” 

12 See also Schleffer v. Department of the Army, 117 MSPR 499 (2012), citing 

Merritt v. Department of Justice, 6 MSPR 585, 596 (1981), modified by Kruger v. 

Department of Justice, 32 MSPR 71 (1987). 

13 Cases discussing the effect on coworkers’ ability to do their jobs include Doe v. 

Department of Justice, 113 MSPR 128 (2010); Dolezal v. Department of the Army, 58 MSPR 

64, 72 (1993); cases discussing management’s trust and confidence in employees’ job 

performance include Singletary v. Department of the Air Force, 94 MSPR 553 (2003), 

Fowler v. USPS, 77 MSPR 8, 13 (1997); Quander v. Department of Justice, 22 MSPR 419 

(1984); Myers v. Department of Agriculture, 88 MSPR 565, 576 (2001); Fouquet v. 

Department of Agriculture, 82 MSPR 548 (1999). 

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The Cartagena incidents included three of the four 

types of behavior we considered. 

Although consuming alcohol is legal in the 

United States and many other parts of the world, 

excessive drinking impairs judgment and impulse 

control. Its aftereffects can impair on-duty 

performance, which is particularly concerning when 

the employees are armed law enforcement agents. 

Drinking alcohol to excess also has often been a 

precursor to other problematic off-duty conduct. 

“Those who 

patronize the 

commercial sex 

industry form a 

demand which 

traffickers seek 

to satisfy.” 

U.S. Department
 

of State
 

2008 Trafficking in 

Persons Report
 

Drugs, like alcohol, can impair judgment and impulse control, but 

illegal use of drugs is even more destructive to the integrity and credibility 

of both the employee and DOJ, which is responsible for enforcing and 

prosecuting violations of federal drug laws. 

Although soliciting prostitutes is legal in some foreign countries, it is 

criminal conduct in most U.S. jurisdictions. DOJ employees who 

participate in acts of prostitution can be compromised and made 

vulnerable to exploitation, manipulation, or duress. Even where 

prostitution is legal, it is often an abusive activity that involves coercive 

relationships and it can contribute to human trafficking, a crime that DOJ 

seeks to eradicate.14 Consequently, employees who engage in the 

solicitation of prostitution while on official travel or when stationed in 

foreign countries undermine their own credibility and DOJ’s effectiveness 

in addressing this priority. 

The OIG considered a fourth type of behavior in this review, 

“notoriously disgraceful conduct,” that is proscribed in the Code of Federal 

Regulations governing employee responsibilities and conduct.15 Federal 

agencies have applied this provision when disciplining employees for 

14 White House Press Release, Trafficking in Persons National Security 

Presidential Directive, February 25, 2003, 1, and Priority Goal 4, U.S. Department of 

Justice, Strategic Plan, Fiscal Years 2012–2016 (February 2012), 2. 

15 5 C.F.R. 735.203. “Notoriously disgraceful conduct” is defined in the 

Department of State’s Foreign Affairs Manual (FAM) as “conduct which, were it to become 

widely known, would embarrass, discredit, or subject to opprobrium the perpetrator, the 

Foreign Service, and the United States.” 3 FAM 4139.14. 

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incidents such as public drunkenness, sexual assault, and attempting to 

fire an assault rifle at individuals in a bar.16 

In the Results of the Review, we examine how DOJ and its 

components address off-duty conduct, including these four specific 

behaviors, in their policies and training. 

Government-Wide Pre-Deployment Training Requirements 

The U.S. government does not require that federal employees 

traveling outside the United States for less than 30 days receive any predeployment training, but it does require training for those who will remain 

outside the United States for 30 days or longer. That mandatory training 

is administered by the Department of State and takes the form of two 

online modules called Serving Abroad for Families and Employees (SAFE). 

Agencies are permitted to provide equivalent training of their own, but 

regardless of who provides the training, agencies must affirm in their 

foreign travel requests to the Department of State that their employees 

have completed it.17 

The SAFE training provides an introduction to working in other 

countries and covers a large number of topics, with only limited guidance 

regarding improper personal conduct. The first SAFE training module 

touches on the counterintelligence issues that can arise from cohabiting, 

dating, or marrying a foreign national. The second module warns, “You 

always represent the Government of the United States while serving 

officially abroad. Your actions affect what others think of our country.” It 

also states: 

Understand your ability to consume alcoholic beverages. 

Alcoholism is far more prevalent among Americans assigned to 

posts abroad than in the general population of Americans in 

the U.S. This may be due to stress factors and the 

requirement to attend social events where alcohol is plentiful 

and free. 

16 Neal Miller, “Criminal Convictions, ‘Off-Duty Misconduct,’ and Federal 

Employment: The Need for Better Definition of the Basis for Disciplinary Action,” 39 AM. 

L. REV. (1990), 886. 

17 Course Requirements, 13 FAM 321.2(b). 

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Consider carefully how you will deal with this combination of 

factors and constantly monitor yourself. 

The module does not discuss how off-duty conduct could discredit or 

interfere with the mission responsibilities of federal employees and their 

agencies. It does not state what forms of behavior are proscribed to 

federal employees serving abroad. Nor does it explain that federal 

employees are bound by these restrictions regardless of the laws of the 

countries where they are serving. 

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RESULTS OF THE REVIEW
 

Department-Wide Policies and Training Requirements Regarding OffDuty Conduct While Working Abroad 

DOJ does not provide guidance or training requirements for its 

employees regarding their off-duty conduct while working in foreign 

countries, and it does not augment the limited SAFE training discussed 

above that is provided to its employees prior to deployments of 30 days or 

longer. DOJ does have regulations, articulated in 28 C.F.R. Chapter 1, 

that control many aspects of its work, but these regulations do not 

address off-duty conduct.18 In addition to the Code of Federal 

Regulations, DOJ’s components have misconduct policies that generally 

focus on detecting misconduct after it occurs, such as through drug 

testing, and on meting out discipline. However, these misconduct policies 

do not specifically proscribe off-duty conduct that impedes DOJ’s mission 

and do not require that components take any proactive measures to 

ensure employees going to work abroad are aware of any limitations on 

their off-duty conduct. 

In contrast, we found that two other cabinet departments with 

significant foreign presence, the Department of State and the Department 

of Defense, have policies that address the four types of behavior discussed 

in this report. Moreover, these policies clearly apply to the off-duty 

conduct of personnel serving in other countries. We further found that, 

both of these departments strongly and clearly explain why certain 

conduct is prohibited off duty.19 We found no evidence that DOJ had 

taken similar action. 

18 DOJ’s supplemental standards of ethical conduct (5 C.F.R. Part 3801) establish 

Department-wide rules regarding the use of government property, outside employment, 

and when employees must recuse themselves from a criminal investigation or 

prosecution. These standards do not establish any rules or guidance regarding 

employees’ off-duty conduct. 

19 The Department of State declined our request to publish the full cable 

describing what it considers its internal policy, but permitted us to publish certain 

portions of it in Appendix III. See Appendix IV for an example of the statement the 

Department of Defense sent to its personnel about off-duty conduct while overseas. 

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While we found that DOJ complies with the SAFE training 

requirement, that training says very 

little about prohibited off-duty 

conduct, and it is not provided to 

the DOJ employees making 

thousands of trips to foreign 

countries each year that last less 

than 30 days. We looked for any 

Department-wide training 

requirements DOJ has regarding 

off-duty conduct or conduct while 

working in foreign countries that 

would augment the SAFE training. 

The Departmental Ethics Office 

provided the OIG with information 

that discusses off-duty conduct for 

new employee training provided to 

Offices, Boards, and Divisions 

(OBD) employees in Washington. 

However, this training is not given 

to all Department employees and 

does not explicitly discuss conduct 

while working in foreign 

countries.20 We could not find, and 

DOJ could not provide us, any 

additional training information. 

We found the paucity of 

Department-wide training to be 

troubling given that, nearly 

20 years ago, the Department was 

faced with allegations of 

extraordinarily serious off-duty 

misconduct by its law enforcement 

agents in connection with their 

attendance at domestic events 

Good O’ Boy Roundups 

In 1995, members of a militia group 

seeking to discredit ATF (which at the 

time was housed in the Department of 

the Treasury) made allegations in the 

news media about the off-duty conduct 

of law enforcement officers who 

attended private, annual gatherings in 

Tennessee known as Good O’ Boy 

Roundups. The events were organized 

primarily by an ATF agent and attracted 

participants from local, state, and 

federal agencies, including DOJ. 

The OIG found that some of the 

most serious allegations were not 

substantiated, but did find the 

Roundups were characterized by 

rampant public drunkenness, 

widespread public lewdness and, in 

later years, episodes of racist conduct. 

Many of the 44 DOJ employees who had 

attended told investigators that they 

went to only one Roundup because of 

the excessive drinking and poor conduct 

they observed. 

The OIG report noted that many 

DOJ employees believed that what they 

did off duty was not DOJ’s concern. We 

found that this lack of understanding of 

off-duty responsibilities was, in part, 

the result of a lack of training and the 

very general provisions that governed 

off-duty conduct. Among other things, 

the OIG recommended that DOJ provide 

education and training because “it is 

critical for law enforcement personnel to 

be held to extremely exacting standards 

of conduct to earn and maintain the full 

confidence of all citizens.” 

20 This training for new employees in many of the OBDs in Washington was added 

as a result of the Good O’ Boy Roundups incident, described in the text box. In addition, 

the Departmental Ethics Office discusses off-duty conduct in its general reference 

materials, which are available on its website 

(http://www.justice.gov/jmd/ethics/generalb.htm). 

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called the Good O’ Boy Roundups. In 1996, the OIG reported on these offduty misconduct allegations, some of which were corroborated (see the 

text box). In response to the OIG report, Attorney General Janet Reno 

established a working group to develop guidelines for off-duty conduct by 

Department employees, wherever they worked.21 

The working group prepared a four-page paper articulating DOJ’s 

“expectation that federal employees will comport themselves appropriately 

on and off the job.” The paper also explained DOJ’s authority to limit offduty behavior and gave examples of off-duty activities that resulted in 

employee discipline. The Attorney General sent the working group’s paper 

to all DOJ component heads on April 2, 1997, directing them to 

“customize as necessary,” to “make the training guidelines meaningful and 

memorable,” and to include the information in the components’ ethics 

training, basic law enforcement training, and new employee orientation.22 

Despite Attorney General Reno’s direction over 17 years ago, our 

review found that most of the components we examined have not provided 

adequate direction to their employees regarding off-duty conduct. In the 

next section, we describe existing policies and training we found in place 

at the five components that deploy hundreds of DOJ employees abroad 

every year. 

Individual Components’ Policies and Training Regarding Off-Duty 

Conduct Abroad 

DOJ’s lack of Department-wide policy or training requirements 

regarding the off-duty conduct of employees working in other countries 

leaves individual components with the responsibility to develop their own 

policies and training. To see how DOJ components have addressed that 

responsibility, we examined the adequacy of the policies and training 

established by the Criminal Division, which is responsible for several 

international programs, and the four law enforcement components that, 

together, send thousands of employees to other countries each year to 

represent DOJ and conduct its important work abroad. 

21 Good O’ Boy Roundup Report, http://www.justice.gov/oig/special/ 

9603/index.htm. 

22 See Appendix II for the full memorandum and working group paper. Janet 

Reno, Attorney General, memorandum to Heads of Department Components, Off-Duty 

Conduct of DOJ Employees, April 2, 1997. 

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We first looked at what the five components told their employees 

about off-duty conduct before they go abroad. However, we found that, 

with the exception of one component, they generally conveyed little or no 

information at all on this topic before they sent their employees abroad. 

We next looked for any policy or training provided to employees at any 

time during their careers regarding the four behaviors considered in this 

report. We also specifically asked the components whether they had 

communicated with their employees regarding off-duty conduct after the 

Cartagena incidents. As discussed below, we found a number of 

weaknesses in the components’ policies, training, or both. We also found 

that the policies and training varied because DOJ has not provided overall 

guidance to the components. 

Policies 

In reviewing the specifics of the five components’ policies, we 

recognized that no set of rules can cover all situations employees may 

encounter. Rather than creating laundry lists of “don’ts,” the OIG believes 

organizations should work toward establishing an overall awareness about 

the bounds of proper conduct when working abroad and provide context 

for employees to rely on in making day-to-day decisions regarding their 

own behavior. 

The Criminal Division told the OIG that it relies on DOJ for its 

policies related to employee behavior rather than developing its own. 

Because DOJ has not established policies regarding employees’ off-duty 

conduct when in other countries, the Criminal Division has none. 

Unlike the Criminal Division, we found that ATF, DEA, FBI, and 

USMS do not rely on DOJ for policies regarding employee conduct. Each 

law enforcement component provided us with the relevant policies it had 

established. All four law enforcement components have standards of 

conduct (standards) for their employees that share some common 

themes.23 They direct employees to maintain standards that reflect 

23 In this report, we use the term “standards of conduct” to mean the code of 

behavior each component expects of its employees. ATF and DEA refer to these 

standards as Standards of Conduct; the FBI refers to them as a Code of Conduct; and 

USMS refers to them as a Code of Professional Responsibility. The standards are found 

in ATF Order 2130.1A, Conduct and Accountability, February 7, 2012; DEA Personnel 

Manual, § 2735.1 and § 2735.15 (A)2, undated; FBI Ethics and Integrity Program Policy 

(Continued) 

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positively on the components and to report violations of the standards. 

They warn that employees may face consequences if they violate the 

standards. In addition, they advise employees not to engage in off-duty 

behavior that affects or impedes their professional responsibilities or 

adversely affects the reputation or mission of the component. The 

standards are general and do not provide specific examples or guidance to 

assist employees in making day-to-day decisions regarding their behavior. 

Each of the four components also has a table of offenses and penalties 

that vary in how they are defined. (See Appendix V for excerpts from the 

tables of offenses and penalties.) 

Aside from these general directions regarding off-duty behavior, the 

components have various standards and policies that address employee 

conduct. In our review of those policies, we looked first for any 

prohibitions that related directly to conduct while outside of the 

United States on official business. The policies the components provided 

us do not specifically address such conduct with one narrow exception 

discussed below. We then focused on prohibitions regarding the specific 

behaviors we considered in this report: consuming excessive alcohol, 

using illegal drugs, soliciting prostitutes, and engaging in notoriously 

disgraceful conduct. In the sections below, we discuss what we found in 

each of the law enforcement components’ policies regarding those 

behaviors. 

Consuming Excessive Alcohol 

All federal agencies prohibit their employees from drinking alcohol 

while on duty and on government property, but agencies differ in how they 

address off-duty alcohol consumption and work-related risks associated 

with excessive alcohol consumption. When we reviewed the law 

enforcement components’ policies, we found that in almost all cases, they 

lack explicit language regarding consumption of alcohol either while off 

duty or on official travel (see Table 2). In addition, we found that the 

policies often do not address particular circumstances when employees 

should limit their alcohol consumption, such as when carrying firearms. 

Implementation Guide, Chapter 3, October 5, 2011; and USMS Policy Directive 1.2, Code 

of Professional Responsibility, January 8, 2009. 

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Table 2: Law Enforcement Component Policies Regarding Alcohol Components

Contains Restricts Consumption 

Term “OffDuty” 

Provisions on 

Consumption 

while on Official 

Travel 

For Specified 

Time Period 

Prior to Duty 

Hours 

While 

Carrying 

Firearms 

Driving 

Motor 

Vehicles 

For 

Those 

Subject 

to Recall 

to Duty* 

ATF    ** 

DEA    

FBI   

USMS 

Legend:  Policy contains language or provision listed. 

* “Recall to duty” refers to employees who could be ordered back to work from off-duty
 

status on short notice.
 

** ATF’s policy applies to all employees who handle firearms or explosives.
 

Sources: OIG analysis of component policies.
 

None of the components’ policies discuss consumption of alcohol 

while on official travel outside of the United States. Instead, the policies 

apply regardless of the employee’s location. 

The components vary in the scope of their restrictions on alcohol 

consumption outside of work hours. The FBI and USMS instruct 

employees not to report to work under the influence of alcohol. The FBI 

also prohibits its employees from carrying firearms when impaired by 

alcohol consumption.24 In contrast, ATF uses an approach similar to the 

Federal Aviation Administration’s regulations for airline crews: It prohibits 

consuming alcohol during off-duty hours within a specific period before 

employees engage in activities that raise safety concerns.25 ATF employees 

24 The FBI Alcohol Policy (Policy Directive 0358D and its corresponding Policy 

Implementation Guide 0358PG) defines “impaired” as when an individual’s faculties are 

diminished so that their ability to see, hear, walk, talk, and judge distances is below the 

normal levels as set by local, state, and federal law. 

25 14 C.F.R. § 91.17(a)(1) states that no one may act or attempt to act as a 

crewmember of a civil aircraft if they have consumed any alcoholic beverage during the 

previous 8 hours. 

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who handle firearms or explosives cannot consume alcohol within 6 hours 

of their scheduled duty hours or when they may reasonably expect to be 

called to perform official duties. 

When we asked the DEA for its policies pertaining to alcohol 

consumption, the DEA provided an employee acknowledgment form it uses 

to reinforce its standards of conduct each year (see Appendix VI). The 

form asks if the employee is aware that being under the influence of 

alcohol during duty hours is prohibited, but the form does not address offduty alcohol consumption. We subsequently found two other DEA 

documents relevant to off-duty alcohol consumption: a section of the 

DEA’s current personnel manual and a 1999 memorandum from a former 

DEA Administrator. The section of the personnel manual states: 

Off-duty DEA personnel subject to recall to duty shall not 

permit themselves to be rendered unavailable for duty through 

the consumption of intoxicants.26 

The DEA Administrator’s memorandum, dated January 21, 1999, 

went further. The memorandum noted that the DEA allows its agents to 

carry their weapons while off duty and that agents may then encounter 

situations that require them to use their weapons (such as witnessing a 

crime that has put someone in imminent danger). The memorandum 

stated that agents are not to become inebriated off duty: 

The reason for this stringent standard is to avoid the . . . 

problem of an agent in a public setting being required to take 

emergency action if their abilities are impaired by the use of 

alcohol. Questions could . . . legitimately be raised by . . . the 

public about the professionalism and the stability of an agent 

who lacks the self-restraint and judgment to appear in the 

public in an inebriated condition. [See Appendix VII for full 

text.]27 

When we asked the DEA if the January 21, 1999, memorandum was 

still in effect, the DEA responded that when a DEA Administrator issues a 

memorandum “it is immediately made into policy and incorporated in the 

26 DEA Personnel Manual, § 2735.15.P.4. 

27 The topic of alcohol consumption was reiterated in an October 6, 1999 

Memorandum from the Acting DEA Administrator regarding conduct of DEA employees. 

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Agents Manual.” The DEA gave us excerpts from two sections of that 

manual, neither of which addressed off-duty alcohol consumption.28 We 

concluded that the 1999 memorandum had not been wholly incorporated 

in the DEA’s manuals and that its message or its equivalent is not being 

conveyed to employees today.29 

Consuming Drugs 

We reviewed the components’ drug policies for definitive prohibitions 

on illegally consuming drugs while off duty and found all four components 

had policies that did so (see Table 3). Although the phrasing varies, all 

components have policies that specifically prohibit illegal consumption of 

controlled substances off duty.30 

28 The first excerpt addressed undercover operations and stated that on-duty 

drinking is not permitted except during certain controlled undercover activity. The 

second excerpt applied to all DEA employees and prohibited operating government-owned 

vehicles after drinking alcohol. DEA Agents Manual, § 6621 D and § 6124.32 A. 

29 The DEA told the OIG that the memorandum can be found on DEA’s WebSter 

for reference. WebSter is DEA’s Intranet website. 

30 All four components’ policies prohibit illegal drug use on duty as well as off 

duty, but phrase the prohibition differently. ATF’s policy states that illegal drug use on or 

off duty detracts from the public’s confidence in ATF. The DEA’s policy states that it is a 

condition of employment to refrain from using illegal drugs on or off duty. The FBI’s 

policy states that illegal drug use on or off duty may subject employees to disciplinary 

action. The USMS’s policy states that employees, on or off duty, are prohibited from 

unlawful use of drugs listed by the federal government as Schedule I and II controlled 

substances. 

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Off Duty 

 

 

 

Table 3: Law Enforcement Component 

Policies Regarding Drugs 

ntsnepomoC

Prohibits Illegal Consumption of 

Controlled Substances 

At Locales Where 

Legal 

ATF  

DEA  

FBI  

USMS   

Legend:  Policy contains language or 

provision listed. 

Sources: OIG analysis of component policies. 

The clearest, most comprehensive language we found was in the 

questionnaire the DEA requires employees to complete each year: 

Are you aware that you, as a DEA employee, may not use a 

controlled substance which has not been properly prescribed by a 

licensed physician or properly obtained for the treatment or illness 

of a condition?31 

Because some countries permit the use of drugs that are prohibited 

in the United States, we also looked for language in the components’ 

policies regarding employee conduct while in such countries. We found 

that only the USMS had a policy stating that its employees must refrain 

from using prohibited controlled substances even when those substances 

are commercially available without a prescription, or are ingested legally, 

in a foreign country. 

Soliciting Prostitutes 

We reviewed component policies to determine whether any prohibit 

soliciting prostitutes while off duty, on official travel, or in locations where 

prostitution is legal; prohibit sexually oriented massages or entering 

establishments known to support prostitution; or explain why these 

31 See Appendix VI for a copy of the DEA standards of conduct questionnaire and 

acknowledgement form. 

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activities are prohibited. We found no such provisions in any of the 

components’ policies.32 

However, the former FBI Director did address “personal relationship” 

issues in a 2001 memorandum to all employees. In explaining to 

employees what they must disclose to the FBI, the memorandum warned 

employees of “harmful institutional consequences” that may result from 

certain personal relationships.33 The memorandum advised that 

employees were subject to discipline for offenses involving prostitution. 

However, the memorandum did not specifically address soliciting 

prostitutes where it is legal to do so. 

In 2012, the FBI established a working group to review the adequacy 

of its policies pertaining to conduct that may be legal, but violates ethical 

standards and the FBI’s principles, specifically including the solicitation of 

prostitutes. The working group’s report stated that the FBI had adequate 

policies and procedures in place to address the issues it examined. 

However, the working group recommended that the FBI strengthen its 

personal relationships policy to make it clear that employees are 

prohibited from soliciting prostitutes under any circumstances. The group 

recommended that the policy be amended to read: 

Certain conduct that is prohibited in most states is subject to 

discipline even when it occurs in a jurisdiction that does not 

prohibit that conduct. For example, although prostitution is 

legal in foreign countries, it is criminal conduct in the vast 

majority of U.S. jurisdictions . . . . Accordingly, [FBI] 

employees are subject to discipline for . . . the solicitation of 

32 On December 17, 2014, the DEA informed the OIG that it had revised and 

disseminated two subsections of its personnel manual to clarify that soliciting or 

engaging in prostitution is forbidden regardless of legality and that employees must 

maintain the highest standards of conduct when associating with individuals known or 

suspected of illegal drug or criminal activity. The DEA provided the OIG with a copy of 

the revised language in its manual. The policy updates, which were one of the 

recommendations made by a Task Force the DEA established to review employee 

misconduct related issues shortly after the Cartagena incident in April 2012, became 

effective on November 6, 2014. 

33 The FBI told the OIG that the memorandum makes clear that employees’ 

personal relationships are subject to inquiry when they might violate the law, or violate 

FBI regulations, or negatively impact the FBI’s ability to perform its responsibilities. 

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prostitution regardless of where that conduct takes place, 

whether within the United States or abroad. 

The FBI told the OIG that it has not revised its personal 

relationships policy and that it believes that the existing policy allows for 

the imposition of appropriate discipline. Further, the FBI stated that 

through its training and Office of Professional Responsibility (OPR) 

quarterly e-mails, it makes clear to all employees that the solicitation of 

prostitutes is misconduct regardless of where the conduct takes place.34 

The FBI stated that it continues to monitor the situation and will make 

policy revisions if necessary to promote compliance. 

Engaging in Notoriously Disgraceful Conduct 

The Code of Federal Regulations prohibits federal employees from 

engaging in “notoriously disgraceful” conduct. We reviewed the 

components’ policies to determine whether they contain the term 

“notoriously disgraceful conduct” or apply a different term to such 

behavior. Where the policies specifically mentioned “notoriously 

disgraceful conduct,” we looked for definitions or examples for the term. 

ATF, DEA, and USMS policies use the term “notoriously disgraceful 

conduct.” (See Table 4.) All three policies use language that mirrors the 

Code of Federal Regulations, which states that an employee shall not 

engage in criminal, infamous, dishonest, immoral, or notoriously 

disgraceful conduct, or other conduct prejudicial to the government.35 

None of the components’ policies defines what types of behavior constitute 

“notoriously disgraceful conduct,” and none specifically addresses conduct 

while working in foreign countries. 

34 According to the FBI, the training provided to personnel deployed overseas for 

30 days or more stresses that soliciting prostitutes will be treated as misconduct even 

when the conduct is legal in the foreign country. Deployment training is discussed later 

in this report. 

35 5 C.F.R. § 735.203, Employee Responsibilities and Conduct. 

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Table 4: Law Enforcement Component Policies 

Regarding Notoriously Disgraceful Conduct 

ntsnepomoC

 

 

 

 

 

 

 

 

 

ATF  

DEA  

FBI 

USMS  

Contains 

Defines 

Notoriously 

Disgraceful 

Conduct 

Provides 

Examples of 

Notoriously 

Disgraceful 

Conduct 

Term 

“Notoriously 

Disgraceful 

Conduct” 

Term 

“Off-Duty” 

Provisions 

Regarding 

Behavior on 

Official 

Travel 

Legend:  Policy contains language or provision listed.
 

Sources: OIG analysis of component policies.
 

Although the FBI does not use the term “notoriously disgraceful 

conduct,” it does remind employees to “conduct their personal activities in 

a manner that does not impede their professional performance or tarnish 

the reputation of the FBI.” However, the policy does not elaborate on the 

types of activities that may tarnish the FBI’s reputation and does not 

specifically address conduct while working in foreign countries. 

Comprehensive Approach 

We note that establishing clear policy requiring personnel to refrain 

from off-duty conduct that interferes with their ability to carry out their 

agencies’ mission is not, by itself, a sufficient safeguard. Changing 

decisions personnel make about their off-duty conduct takes time and can 

be greatly influenced by colleagues’ conduct. After the incidents in 

Cartagena, the Secret Service invited the FBI and other agencies to advise 

it on strengthening its internal controls on professional conduct and other 

areas that required improvement.36 Although the Secret Service 

consequently instituted a number of reforms, a subsequent incident was 

publicly reported in April 2014, involving excessive off-duty drinking by 

36 U.S. Department of Homeland Security Office of Inspector General, Adequacy of 

USSS Efforts to Identify, Mitigate, and Address Instances of Misconduct and 

Inappropriate Behavior, OIG-14-20 (December 2013), http://www.oig.dhs.gov/assets 

/Mgmt/2014/OIG_14-20_Dec13.pdf (accessed April 17, 2014), 7. 

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Secret Service agents deployed to protect the President during a summit in 

Amsterdam.37 

That such incidents continue to occur underscores the fact that 

agencies can expect to invest long term in efforts that guide the off-duty 

behavior of employees representing the United States while working in 

other countries. In the next two sections of this report, we look at the 

steps the five DOJ components have and have not taken toward providing 

a comprehensive approach to guiding their employees’ off-duty conduct 

abroad. 

Training 

While putting clearly worded policy in place is the first step in 

addressing employees’ off-duty conduct abroad, expectations have to be 

effectively communicated and reiterated so that employees will act in 

accordance with DOJ’s core values wherever their jobs take them.38 We 

examined whether the components provided their employees with training 

throughout their careers that emphasized responsibility for their personal 

conduct. 

We found that the components varied in the training they provided. 

Only one component, the FBI, had a comprehensive program that laid a 

strong foundation regarding off-duty conduct during new employee and 

new agent training and provided additional training when employees were 

to be deployed abroad. The other components provided limited training 

regarding off-duty conduct to new employees and new agents, but do not 

follow up with periodic refresher training and have relatively little or no 

training on off-duty conduct before employees are deployed abroad. 

37 Michael S. Schmidt, “Secret Service Employees Reassigned,” New York Times, 

Apr. 8, 2014, A11, http://www.nytimes.com/2014/04/09/us/secret-service-employeesreassigned.html?_r=0; Carol D. Leonnig, “Secret Service removing supervisor, tightening 

rules after drinking incidents,” Washington Post, Apr. 8, 2014, http://www. 

washingtonpost.com/politics/secret-service-removing-supervisor-tightening-rules-afterdrinking-incidents/2014/04/08/576d0f58-bf39-11e3-bcec-b71ee10e9bc3_story.html. 

38 DOJ’s core values are equal justice under the law, honesty and integrity, 

commitment to excellence, and respect for the worth and dignity of each human being. 

Department of Justice Strategic Plan, FY 2014 – 2018, http://www.justice.gov 

/jmd/strategic2014-2018/doj-fy-2014-2018-strategic-plan.pdf, 3. 

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Training for New Personnel 

New Employee Training. The ATF, Criminal Division, and USMS 

do not offer formal presentations on conduct during new employee 

orientation. The Criminal Division told the OIG that its new employees 

receive training regarding off duty conduct from the Departmental Ethics 

Office, but the Division does not provide any additional training of its own 

regarding conduct to new employees. ATF and USMS do have some 

limited measures intended to acquaint new employees with the standards 

of conduct. 

ATF requires supervisors to discuss ATF’s standards of conduct with 

new employees. The standards touch on off-duty conduct and alcohol 

consumption. The USMS requires new employees to acknowledge that 

they have read the agency’s standards of conduct, which discuss alcohol 

consumption, drug use, and off-duty conduct.39 

Similar to the USMS, the DEA requires new employees to 

acknowledge that they have read the agency’s standards of conduct, which 

discuss alcohol consumption, drug use, and off-duty conduct. In addition, 

the DEA discusses off-duty conduct in its new employee training. 

The FBI provides a more extensive presentation to new employees 

that includes materials on conduct, a discussion of the FBI’s core values, 

and sample cases to teach new employees how to apply standards and 

expectations to day-to-day situations. 

New Agent Training. The ATF, DEA, FBI, and USMS include 

discussions of off-duty conduct in new agent training. 

39 In addition, the USMS requires its employees to read a document (“Important 

Information about Employee Responsibility from the Office of the Director, the Office of 

Inspection and the Office of General Counsel”) discussing employee responsibility, which 

covers receipt of ethics and conduct materials and examples of the most common USMS 

misconduct cases, including discussion about alcohol consumption, drug use, and offduty conduct. All employees are required to acknowledge electronically, on an annual 

basis, that they have read the document. 

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ATF’s new agent training has two sessions where presentations are 

made that discuss alcohol use, drug use, and off-duty conduct. In 

addition, the new agent training offers instruction on standards of 

conduct. It familiarizes trainees with a set of “commonsense, practical 

guidelines on which to build a safe, successful, and productive career as a 

special agent.” One of these guidelines is ATF’s rule on alcohol: “Do not 

drink any alcohol while, or within 6 hours before, 

carrying a firearm or operating a Government The law enforcement owned vehicle.” The presentations also cover drug officer shall be use and make general reference to notoriously mindful of his special disgraceful conduct in the discussion regarding off- identification by the duty conduct. However, there is no discussion public as an upholder 

regarding the solicitation of prostitutes. of the law. . . . [H]e 

will ...conduct his 

The DEA’s new agent training also offers private life [so] that 

limited discussion about standards of conduct and the public will regard 

him as an example of off-duty conduct. However, the DEA has recently stability, fidelity, and updated its training materials to include specific morality. discussion about the four behaviors examined in 

this review. Canons of Police Ethics 

(1957), Article 6: Private 

The USMS's new agent training includes Conduct 

modules that provide some discussion on 

misconduct offenses, such as driving under the influence (DUI), and 

emphasizes that USMS employees are held accountable for their action on 

and off duty. 

The FBI’s new agent training is more comprehensive. The FBI told 

us that during new agent training it emphasizes the need for agents to 

behave professionally, on and off duty. The training includes a discussion 

of the Canons of Police Ethics that lay out 11 principles for law 

enforcement officers, including Article 6, quoted in the inset, specifically 

addressing off duty conduct. A training packet we reviewed included 

warnings about alcohol use and conduct that might be considered 

notoriously disgraceful, and said in part: 

The essence of the FBI Standards of Conduct . . . is that the 

FBI “expects its employees to so comport themselves that their 

activities both on and off duty will not discredit either 

themselves or the Bureau.” 

All trainees must read and sign the “Rules, Regulations and 

Requirements at the FBI Academy for new Agent Trainees.” This 

document reminds agents that, because they hold a position of trust and 

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authority and are often seen in the public eye, they are held to a 

significantly higher standard of conduct than the average citizen. 

Training for Personnel Going Abroad 

The components provide training to some of their employees going 

abroad, but that training varies by component and by the duration and 

destination of the employees’ trips.40 Some employees sent to other 

countries on official business receive no pre-deployment training. 

Deployments of 30 Days or More. As discussed previously, the 

federal government requires that all of its employees going abroad for 

30 days or more receive Department of State training, referred to as SAFE, 

or its equivalent. Included in the SAFE training is a brief reminder that 

employees “always represent the Government of the United States while 

serving officially abroad,” and it also briefly discusses circumstances that 

can lead to excessive drinking when abroad. 

When we examined the components’ pre-deployment training, we 

found that at the Criminal Division, three of the four sections that send 

employees to foreign countries provided nothing in addition to SAFE. Only 

the Office of Overseas Prosecutorial Development, Assistance, and 

Training (OPDAT) provided pre-deployment training in addition to SAFE.41 

OPDAT officials who have led the training said they emphasize that 

40 We found that two components provide briefings to personnel being deployed to 

specific countries, regardless of how long they will be there. The FBI provides a briefing 

for employees going to countries considered “hostile,” warning them against many 

circumstances they may encounter, including the ploys of hostile intelligence services. 

Employees are told to avoid moral indiscretions and vices and to “[r]emember you are a 

representative of the United States.” 

The USMS provides a briefing for all employees going to Colombia. The briefing 

includes the Department of State’s cable prohibiting the solicitation of prostitutes. It 

also includes a U.S. Ambassador’s firearms policy that prohibits: (1) consuming any 

alcohol while armed or 6 hours prior to being armed, (2) drinking alcohol to the point of 

having impaired judgment or the inability to perform duties, and (3) using medications or 

drugs while armed that may impair judgment or ability. USMS personnel told the OIG 

that since April 2013, it requires all USMS employees deployed to Colombia to complete 

and sign a form acknowledging that they received the briefing. The form is not used 

agency-wide and is specific to the requirements of the Chief of Mission in Colombia. 

41 OPDAT’s mission is to work with host countries to develop fair and accountable 

justice sector institutions and to strengthen their capacities to combat domestic and 

international crimes consistent with international norms and standards. 

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employees represent DOJ at all times. The OPDAT officials said that, after 

the incidents in Cartagena, they began emphasizing that employees should 

be aware that what is legal in foreign countries may not be legal at home. 

In addition, the Criminal Division’s Deputy Designated Agency Ethics 

Official (DDAEO) stated that she is invited to participate in OPDAT’s predeployment training. The DDAEO said she includes a discussion about 

the Standards of Conduct and what it means for employees deployed 

overseas and reminds employees that their conduct is a reflection on the 

Department. She indicated that the pre-deployment training discussion 

covers the use of drugs, excessive alcohol consumption, prostitution, and 

other disgraceful behavior. OPDAT has since notified the OIG that it has 

made conduct guidance a standard part of its pre-deployment training. 

OPDAT officials stated that the training addresses the various 

responsibilities inherent in representing the Department and the U.S. 

government overseas and includes a review of generally acceptable and 

expected standards of conduct.42 

Of the law enforcement components, ATF has minor training 

requirements in addition to SAFE that pertain to the behaviors covered in 

this review, while the USMS has none. ATF stated that it required its 

employees to read and acknowledge its standards of conduct, described 

above, covering off-duty conduct, including restrictions on alcohol 

consumption.43 The USMS reported having no training of its own for 

employees who are deployed for 30 days or more. 

The DEA provided the OIG with information from its Foreign 

Orientation Training Program handbook, which states that behavior the 

host government finds objectionable, unacceptable, or intolerable may 

result in the employee being expelled from the country. In addition, DEA’s 

Office of Professional Responsibility provided the OIG with training 

material for the Foreign Orientation Training Program that discusses the 

prohibition on the solicitation of prostitutes, reminds employees that they 

42 OPDAT officials also stated that the training program is no longer limited to 

employees deploying for the first time, but is now also required, to the extent practicable, 

of employees rotating to new posts. 

43 ATF Order 2130.1A, Employee Conduct and Accountability. 

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are “always on-duty,” and states that if “you wouldn’t do it in the U.S. – 

don’t do it in a foreign country.”44 

In contrast, the FBI conducts comprehensive pre-deployment 

training that addresses the four types of behavior we considered. The FBI 

requires its employees to take two courses it designed.45 The first includes 

a module that helps students identify threats and precautions associated 

with the consumption of alcohol and drugs. The second includes a 

Department of State-approved alternative to a portion of the SAFE training 

as well as the portion of the Department of State’s online SAFE training 

that warns briefly against excessive drinking. The FBI also requires 

employees to review briefing slides linked to a form they must file prior to 

foreign travel. Among the slides’ tips are three that tell employees not to 

bring narcotics in or out of the foreign country, respond to sexual 

overtures, or “over indulge” in alcohol. 

The FBI training emphasizes that employees may be at higher risk 

for misconduct while working abroad “because the employees will be 

removed from their emotional and psychological support structures – 

including relatives, friends, church members, neighbors, and the like.” 

The training materials we reviewed remind employees that the FBI will not 

tolerate improper behavior at home or abroad. The FBI also told us the 

training stresses that soliciting prostitutes, using drugs, and engaging in 

similar behavior will be treated as misconduct even when the conduct is 

legal in the foreign country. The FBI stated that the training highlights the 

potential for misconduct that might arise during “liaisoning” activities with 

foreign officials, especially when those officials are themselves misusing 

alcohol or drugs, patronizing strip clubs or similar establishments, or 

otherwise engaging in notoriously disgraceful conduct. 

44 DEA’s Office of Professional Responsibility also provided the OIG with copies of 

slides dated July 24, 2014, which mention off-duty misconduct and the four behaviors 

that are discussed in this review. DEA officials told us that this information was part of 

training classes conducted in July and September 2014. 

45 The FBI courses are the Overseas Security Awareness Training and the 

Overseas Survival Awareness Program. In addition, the FBI’s Office of Integrity and 

Compliance (OIC) and its Office of Professional Responsibility (OPR) provides a block of 

instruction during the pre-deployment training in which employees are cautioned to 

conduct their professional activities in a manner that does not impede their professional 

performance or tarnish the FBI’s reputation. Employees are reminded to think about the 

potential ramifications of their actions. 

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Deployments of Less than 30 Days. The U.S. government does not 

require federal employees traveling for less than 30 days to take 

pre-deployment training. Similarly, ATF, the Criminal Division’s OPDAT, 

DEA, and USMS have no training requirements for these employees. 

In contrast, the FBI provides training to its employees going abroad 

for less than 30 days and includes a module that tells employees not to 

overindulge in alcohol and not to bring narcotics or contraband into or out 

of the country. The FBI also requires employees making trips of less than 

30 days to review the briefing slides linked to the form they must file prior 

to foreign travel of any length, including the tips described above. 

Post-Cartagena Communications with Employees 

We specifically asked the law enforcement components whether they 

had responded to the incidents in Cartagena by communicating with their 

employees about professional behavior while working abroad. The ATF, 

FBI, and USMS issued reminders within weeks to all employees about the 

components’ policies and standards: 

•	 The ATF memorandum stated that its standards of conduct apply 

during international travel, and it reminded employees that their 

personal and professional conduct must be able to withstand 

public scrutiny. ATF also instituted a new policy requiring 

employees to certify that they have read ATF’s standards of 

conduct prior to each international trip. 

•	 The FBI sent an e-mail to all of its employees stating that 

employees are representatives of the FBI while traveling on 

official business and their conduct must reflect the FBI’s 

standards on and off duty. The e-mail also specifically advised 

employees that they must adhere to U.S. legal requirements 

rather than foreign law, custom, or expectation. The message 

further stated that the FBI “will not tolerate improper or unlawful 

behavior, at home or abroad.” 

•	 The USMS memorandum reminded employees of its directive on 

professional responsibility and the federal standards on ethical 

conduct for executive branch employees. The memorandum 

stated that USMS policies regarding professional responsibility 

and conduct apply during domestic and international travel, and 

that employees are expected to follow all statutes, regulations, 

and policies that govern employee conduct wherever they may be. 

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DEA officials told the OIG that shortly after learning about the 

Cartagena incident, the DEA established a Task Force, consisting of 

representatives from various DEA offices, to review employee misconduct 

related issues throughout the agency and identify any trends. DEA 

officials stated that the Task Force made several recommendations, 

including revising sections of the DEA personnel manual, issuing a 

reminder to all DEA employees about inappropriate conduct, and 

publishing “fact or fiction” questions for training on conduct. The 

reminder to all DEA employees about inappropriate conduct was finalized 

on October 22, 2014, and the “fact or fiction” questions were published on 

October 28, 2014. On November 6, 2014, the DEA formally disseminated 

the revised sections of the DEA personnel manual to DEA employees 

regarding the solicitation of prostitutes.46 

DEA officials told the OIG that DEA executive officials also held 

several meetings with DEA supervisors to discuss what actions could be 

taken to reinforce the DEA’s expectations for its employees’ conduct. DEA 

officials stated that these actions included requiring that supervisors 

provide more detailed input regarding the performance of employees they 

recommend for foreign country assignments; requiring supervisors in 

foreign countries to conduct individual meetings and briefings with new 

employees selected for such assignments; and requiring employees to 

complete a Department of State diplomatic security form and briefing 

before they are permitted to arrive at post. 

Finally, the DEA Academy developed and presented training to 

newer employees, agents, and supervisors about off-duty conduct. In the 

standards of conduct portion of the training, information is provided about 

overseas and off-duty conduct. DEA employees who are to be assigned 

abroad receive additional training about the solicitation of prostitutes as 

part of the Foreign Orientation Training Program. However, we found no 

indication that the DEA has provided additional training to DEA employees 

already working in foreign countries or to those about to travel on short 

term assignments. 

46 We understand that the decision to delay implementation was made after DEA 

leadership consulted with the DEA’s Office of Chief Counsel and out of concern for a 

pending MSPB proceeding. We are concerned that this decision delayed for over two 

years the implementation of some of the reforms that DEA management concluded were 

necessary in light of the events in Cartagena. 

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CONCLUSION AND RECOMMENDATIONS 

Employees should be made aware that poor decisions about their 

off-duty conduct have serious ramifications for their careers and DOJ’s 

ability to carry out its mission. We found that, for most DOJ employees 

sent abroad, little is done to inform and guide their judgment. The types 

of off-duty behavior discussed in this report can lead to incidents that 

undermine DOJ’s credibility and effectiveness. The behaviors also make 

employees vulnerable to exploitation by foreign intelligence services or 

criminal organizations. The absence of Department-wide policy and 

incomplete component policies and training efforts regarding off-duty 

conduct pose a risk to DOJ and its mission. 

As a general matter, DOJ has not vigorously and effectively 

communicated its authority and expectations regarding off-duty conduct. 

As far back as 1997, the Attorney General recognized that all DOJ 

employees needed to understand their obligations to avoid conduct on or 

off the job that might have a negative impact on their ability to perform 

DOJ’s mission. However, 17 years later, the OIG found that DOJ has not 

established any Department-wide policies or training requirements 

regarding its expectations for employee conduct off duty. 

Although DOJ has a significant international presence, the OIG 

believes DOJ has not taken sufficient steps to minimize the risk of 

employee off-duty misconduct. Unlike the Departments of Defense and 

State, DOJ has not established policies or training requirements regarding 

its employees’ off-duty conduct when they are representing the 

U.S. government in foreign countries. As a result, not all employees have 

been provided with a foundation on which to make sound day-to-day 

decisions, especially with regard to behaviors that may be otherwise 

acceptable in some countries, but conflict with DOJ’s core values or be 

illegal at home. 

Despite DOJ’s general inaction, we found that the FBI has taken 

more steps than other components to prepare its employees even when 

specific rules do not exist to guide their actions. We found its training 

establishes standards for employees’ on- and off-duty conduct that reflect 

the FBI’s core values. The training specifically addresses potential 

conflicts between what is permissible conduct for others abroad and what 

is required for FBI employees. We found that the new employee and new 

agent training is a good foundation to prepare FBI employees to make 

decisions that are consistent with the FBI’s mission. In addition, prior to 

foreign travel, the FBI provides all of its employees with extensive 

pre-deployment training regarding conduct. We believe this training 

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serves as a timely reminder that helps minimize the risk of misconduct. 

Nevertheless, the FBI’s policies on the four specific behaviors we reviewed 

were not comprehensive. 

The policies and training of the other four components fall short. 

The ATF, DEA, and USMS have not developed clear policies that guide 

their employees’ behavior at all times and in all places. These three law 

enforcement components have not developed comprehensive new employee 

training regarding off-duty behavior. However, off-duty behavior is covered 

briefly in some context during the multi-week new agent training programs 

for ATF, DEA, and USMS candidates. As for the Criminal Division, it has 

not developed policies related to employee behavior, and three of the 

Division’s four sections that send employees to foreign countries provide 

no training beyond the Department of State’s SAFE module. The fourth 

section, OPDAT, did provide some additional training and has taken steps 

to improve that training. 

Moreover, none of these four components has developed predeployment training to prepare their employees to deal with off-duty 

conduct in a foreign environment. They have done little to supplement the 

required Department of State training for federal employees who travel 

abroad for 30 days or more. Furthermore, the Department of State 

training’s treatment is cursory when dealing with off-duty conduct and the 

types of decisions employees may have to make about their personal 

behavior. As a result, meeting this training requirement may give 

component managers a false sense that those they send to work abroad 

are well prepared. Shorter term travelers are provided scant, if any, predeployment training regarding personal behavior. 

Our review revealed that, with the exception of some of the FBI 

training discussed above, DOJ and its components generally have not 

clearly communicated employees’ off-duty responsibilities when in the 

United States or working abroad. While the components took some limited 

steps to communicate their expectations to employees, there have been 

delays and much more is required. In sum, there is a critical need for 

DOJ to develop clear policies and comprehensive training that create a 

consistent message that employee behavior must be beyond reproach at all 

times. Included in that message must be clear notice that employees 

remain subject to DOJ’s requirements regardless of foreign law. 

So that DOJ employees working abroad understand how their offduty conduct can affect DOJ’s mission, the OIG recommends that DOJ: 

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1. Develop and disseminate clear and comprehensive Departmentwide policy that communicates DOJ’s authority and expectations 

regarding off-duty conduct. 

2. Identify best practices for guiding employee behavior and ensure 

that these practices are shared with all components that send 

employees to work in foreign countries. 

3. Ensure that the components develop clear, complementary, and 

consistent policies in a timely manner. 

The OIG also recommends that the Criminal Division, ATF, DEA, 

FBI, and USMS: 

4. Disseminate clear, complementary, and comprehensive policy to 

all personnel regarding off-duty conduct, including provisions for 

employees representing the government in other countries. 

5. Raise awareness of that policy and how it applies to a variety of 

situations through existing basic law enforcement training, new 

employee orientation, and periodic training throughout 

employees’ careers. 

6. Reinforce the policy and how to apply it through pre-deployment 

training for employees being sent abroad. 

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APPENDIX I: SCOPE AND METHODOLOGY OF THE OIG’S REVIEW
 

To conduct the analysis for this report, the OIG compiled data 

regarding DOJ positions abroad and employees’ trips to other countries. 

We focused our review on four types of off-duty, unprofessional behavior: 

consuming excessive alcohol, using illegal drugs, soliciting prostitutes, 

and engaging in notoriously disgraceful conduct. 

We researched the federal government’s authority and governmentwide policies governing employees’ off-duty conduct. We examined 

policies and guidance, along with new employee, new agent, and other 

training, regarding conduct while on foreign travel and while off-duty. 

We collected the law enforcement component tables of offenses and 

reviewed DOJ’s and the Criminal Division’s standards regarding 

misconduct and associated penalties. 

Our review included discussions with DOJ officials and personnel 

at the Departments of Defense, Homeland Security, and State. In light of 

its extensive presence abroad, we reviewed the Department of State’s 

Foreign Affairs Manual and the training the Department of State provides 

prior to foreign travel and the Department of Defense’s directives 

regarding the four behaviors included in this report. 

We also reviewed documentation regarding federal government 

employees’ involvement with prostitutes during the 2012 Summit of the 

Americas in Cartagena, Colombia, and the aftermath of that conduct, 

including congressional testimony, news articles, and agency reports. 

We reviewed the OIG’s investigation into the DEA employees’ involvement 

with prostitutes during that time. We researched the federal 

government’s policies, reports, and statistics regarding trafficking in 

persons and related activities. We also reviewed various OIG reports and 

specifically, the OIG and Treasury Department’s reports regarding the 

Good O’ Boy Roundups. In addition, we searched for Department-wide 

policies or communications regarding off-duty conduct issued after the 

OIG Roundups report or after the incidents in Cartagena. 

After our initial working draft was provided to the components for 

technical comments, the DEA informed the OIG that it did take actions 

after the 2012 Cartagena incident and had revised its training materials. 

The OIG had previously requested this information from the DEA several 

times during fieldwork, but did not receive anything, so it had appeared 

to us that the DEA had not taken any action following the Cartagena 

incident. When asked why this relevant information was not provided to 

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us at the time of our requests, DEA officials were unable to provide an 

explanation. The OIG requested and was entitled to this information 

from the outset of our review, and the failure to provide it in response to 

our requests during fieldwork unnecessarily delayed our work. 

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APPENDIX II: ATTORNEY GENERAL MEMORANDUM ON
 

OFF-DUTY CONDUCT, 1997 

~ffiu gf ill" Attarn,,!! Cirnrral 

lIIU~in!!hUl. E. ([ 2LtS30 

Apr:1l 2. 1997 

MEMORANOUMFO:R HEADS 

FROM: 

SUBJECT: 

My May 16, 1995, memorandum informed yo~ of the Inspector General's report voicing Concern abo~t the level of awareness on 

the part of Department employees of their obligation to retrain 

from off-duty conduct that negatively affects their jOb 

performance. It also informed yo~ of a working group, convened 

by the Assistant Attorney General for Administration, that was 

tasked with dev .. lopinq written materials that could be used for 

this purpose. 

The working group--consisting of representatives from the 

Office of Inspector General, the Immigration and Naturalization 

Service, the Executive Office for United states Attorneys, the 

Bureau of Prisons, the United StAtes Marshals Service, the 

Federal B~r.a~ of Investigation, the Drug Enforcement 

Administration, the Criminal Division, and the Justice Management Division--has now completed its work. The group has developed, 

and reco~mended that I distribute, the attached document. 

The document provides some basic guidelines on off-duty conduct. This document is not intended for distribution to all 

employees, but instead, should be customized as necessary by your trainin~ staffs, and incorporated into your current ethics 

awareness programs. In this manner, each component can take 

advantage of its own experiences and case histories in order to . make the training quidelines meaningful and memorable. Please 

make this document aVailable to those in your component 

responsible for ethics training, basic law enforcement training, and new employee orientation, and have them incorporate its 

content into those programs. 

As Z stated previously, it is the mission of the Department of Justice to enforce and interpret the laws of the United States .in a 1'air ,md unbiased manner. It is o.ur responsibility to 

ensure that all Department employees are aware of and understand 

their Obligations to avoid conduct on or off the job which may 

have a negative impact on their ability to perform this mission. 

Attachment 

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Off-Duty Conduct 

The recent participation of federal employees in the "Good 

0' Boy Roundup" raises concern about the level of awareness on 

the part of Department employees regarding their obligation to 

refrain from off-duty conduct that may negatively impact upon 

their ability to perform their jobs or detract from the 

Department's mission. The following sets forth the baSis for the 

expectation that federal employees will comport themselves 

appropriately on and off the job; explains the legal foundation 

for the principle that off-duty conduct may be grounds for 

discipline; and gives examples of off-duty activities that have 

resulted in employee discipline. 

Executive Order 12674 as modified by Executive Order 12731 

provides that "Public service is a public trust, requiring 

employees to place loyalty to the Constitution, the laws, and 

ethical principles above private gain." Relevant to activities 

outside of the workplace~ the Executive Order states that 

Employees shall [1] satisfy in gOOd faith 

their obligations as Citizens, including all 

just financial obligations . . . that are 

imposed by law ... (2) adhere to all laws 

and regulations that provide equal 

opportunity for all Americans regardless of 

race, color, religion, sex, national origin, 

age, or handicap ... {and 3J avoid any 

actions creating the appearance that they are 

violating the law or the ethical standards 

promUlgated pursuant to this order. 

office of Personal Management Regulation provides at 5 CFR § 

732.203 that 

[a l n employee shall not engage in criminal, 

infamous, dishonest, immoral, or notoriously 

disgraceful conduct, or other conduct 

prejudicial to the Government. 

An employee may be disciplined for off-duty conduct if there 

is a nexus (connection) between the offending conduct and the 

employee'S joh-related responsibilities so that the proposed 

diSCipline would "promote the efficiency of the service." 

Generally, a sufficient nexus or connection can he 

established if the misconduct adversely affects the employee's or 

his. co-workers' job performance or management's trust and confidence in the employee's job performance. 

Nexus may also be proven by showing that an employee engaged 

in off-duty conduct that interferes with or adversely affects the 

agency's mission. This usually applies where the employee 

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engages in the very type of behavior which the agency and/or the 

e~ployee is charged with preventing or addressing: 

Where an employee's off-duty behavior is 

blatantly inconsistent with the mission of 

the employer and is known or likely to become 

known, most any employer, publi c or private, 

however broad minded, would want to fire the 

employee and . . . we find no evidence that 

Congress intended to deny this right to 

federal agencies. 

Wild v. United States Department of Housing and Urban 

Development, 692 F.2d J.J.29 (7th Cir. J.982). 

Some off-duty conduct is considered to be so egregious that 

the nexus to federal employment "speaks for itself" and raises a 

rebuttable presumption of nexus to the e ffi ciency of the service . 

Graham y. U.S. Postal Service, 49 MSPR 364 - (1991). There is an 

automatic presumption that a federal employee's co~ission of a 

violent crime adversely effects the efficiency of the service 

arid is so grievous as to raise a rebuttable presumpti on that 

discipline is appropriate. Similarly, sexual misconduct with 

minors is regularly held to provide a presumption of nexus 

warranting removal, Which is effectively impossible to .rebut. 

Higher-level employees and those entrusted with sensitive 

responsibilities are subject to closer scrutiny and greater 

potential discipline for off-dl.lty misconduct reflecting on 

honesty and integrity than those employees with less 

responsibility. For example, law enforcement officers are 

entrusted with responsibilities (such as conducting arrests, 

searches and seizures, and providing testimony in criminal 

proceedings) Which, if abused, could severely impact the lives of 

innocent people. Therefore, law enforcement officers may be more 

severely punished than other fedara-l employees for many types of 

off-duty misconduct, and/or may be puniShed for SOme conduct that 

other employees would not be punished for at all. 

one of the law enforcement officers' most important 

responsibilities is to provide objective and unbiased testimony 

during criminal and related proceedings. Federal Rule of 

Evidence - 608(b) allows _defense counsel to impeach an officer 

during cross examination by asking about specific instances of 

past conduct which are probative of veracity or bias. Giglio v. 

Uni ted States, 405 U.S. 150, 154 (1972); Brady v. Maryland, 373 

U.S. SJ (1971). 

Accordingly, while the most serious misconduct--e.g . the 

commission of a violent crime or illegal drug -use--may well be 

the basis for criminal prosecution; any off-duty conduct on the 

part ot a law enforcement officer that would undermine his or her 

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credibility or de~onstrate bias could adversely affect the 

ability of such officer to perform his or her official duties. 

Specific off-duty conduct which has resulted in federal 

employees being disciplined, and in some case~ dismissed, 

includes: 

• sexual misconduct; 

• racist or sexist remarks or conduct; 

• threats against coworkers or supervisors; 

• fraud; 

• falsification to obtain employment, employment 

benefits, workers' compensation, disability, or 

sick leave; 

• failure to pay just debts, inCluding taxes; 

• misuse of a government credit card; and 

• conflicts of interest (improper use of one's official 

position for private gain). 

One particularly sensitive area of off-duty conduct involves 

speech and expression. While all citizens ·of the united States. 

including Government employees, enjoy the First Amendment 

constitutional right to . freedom· of expression and association. it 

is within the power of the government to restrict employees' 

activities, and impose discipline for certain remarks, in ways 

that would be unconstitutional if applied to the pUblic at large. 

United states v. NTEg, 115 S.ct. 1003, 1012 (1995). The Supreme 

Court has establiShed a test which requires "balancing the 

interests of the (employee). as a citizen. in commenting upon 

matters of public concern, and the interests of the State, as an 

employer, in promoting the efficiency of the public services it 

performs through its employees." Pickering y. Board of 

Education, 391 U.S. 563, 568 (1968). 

Speech is considered a "matter of PUblic concern" if it is 

for the purpose of commenting on an issue of importance to the 

public or inciting debate upon such an issue. Connick v. Myers, 

461 U.S. 138 (1983). Even Where the particular speech at issue 

meets this standard, however, the government interest in 

efficient operation may still outweigh the employee's interest 

and justify discipline where the speech: (1) threatens the 

maintenance of diSCipline or harmony among coworkers; (2) has a 

detrimental effect on close working relationships where personal 

loyalty and confidence are necessary; (3) impedes the speaker's 

proper performance of his or her daily duties; or (4) interferes 

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with the regular operation of the off ice generally. Rankin v. 

McPherson, 483 U.S. 378, 387 (1987) . 

Racist conduct byDOJ personnel is inconsistent with the 

mis sion of the Depar~ent to enforce the laws against racial 

discrimination , and certain fo~s of racist speech or conduct may 

seriously undermine the reputation and effectiveness of the 

employee involved and the agency as a whole. Mings v. Dept. o f 

Justice, 813 F.2d 384 (Fed.Cir. 1987). Where the employee's 

conduct is inconsistent with the mission of the agency, dismissal 

may be appropriate even without proof of a specific detrimental 

effect on the employee'S ability to do his or her job. Speech 

expressing a Viewpoint on issues of race, such as discrimination, 

affirmative action, and racial harassment, has been interpreted 

to address matters of publi c concern and to be protected under 

the First Amendment. Boger v. Wayne Countx, 950 r.2d 316 (6th 

Cir. 1991); Meyers v. City of Cincinnati, 934 F.2d 726 (6th Cir. 

1991); Matulin v . Village of Lodi, 862 F.2d 609, 612 (6th cir. 

1988). on the other hand, disruptive racist speech furthering 

sOllie "purely private interest" is not protected. Tindle v. 

CaUdell, 56 F.3d 966, 970 (8th Cir. 1995). For example, the 

First Amendment generally dOes not protect mere racial epithets. 

Waters y. ChurChill, 114 S.ct. 1878, 1886 (1994). 

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APPENDIX III: EXCERPTS FROM THE DEPARTMENT OF 

STATE CABLE ON HUMAN TRAFFICKING, 2012 

The following three paragraphs are excerpts from the 2012 Department of State cable 

related to human trafficking: 

3. It is the position of the U.S. government that the procurement of commercial sex 

can fuel the demand for sex trafficking. Women, children, and men are trafficked into

the commercial sex trade regardless of whether prostitution is legal or criminalized 

in a country, and thus, the procurement of commercial sex runs the risk of 

facilitating or supporting human trafficking. There are concerns that prostituted

youth, including LGBT youth, are especially vulnerable to human

trafficking and other forms of exploitation. Department employees should understand 

that a victim of sex trafficking may not appear to be under duress, given

that coercion and threats of violence are often used to hold people in servitude.

Indeed, there is a good chance that a sex trafficking victim will appear to be

engaging in a commercial sex transaction willingly. Flirtatious or seductive behavior 

is a necessary element of attracting clients to prostitution and does not/not (sic)

signify the consent of a person engaging in a commercial sexual activity; individuals

who engage in such behaviors may well be trafficking victims. Department

employees should also know that sex trafficking is not confined to street-based

prostitution or inexpensive brothels. This crime occurs in residences, high-end

hotels and entertainment venues, as well as in massage parlors and the back areas of 

small bars or restaurants. Further, assumptions based on appearances as to whether

or not an individual is 18 years old are frequently erroneous, as many brothel 

managers and pimps dress minors to look older. Purchasing sex from a minor is a

serious crime under U.S. law. 

4. In addition to the human rights implications noted above, involvement with the

commercial sex industry is unacceptable in light of the diplomatic and foreign

policy goals of the United States and the conduct that is expected of Foreign Service 

personnel. As stated in 3 FAM 4111, the attainment of U.S. foreign policy objectives 

depends substantially on the confidence of both the American and foreign public in

the individuals selected to serve in the Foreign Service. The U.S. government

therefore requires the maintenance of the highest standards of conduct by employees

of the Foreign Service, including an especially high degree of integrity, reliability,

and prudence. Given the representational nature of employment in the Service and the 

diplomatic privileges and immunities granted employees of the Service abroad, it is

necessary that employees observe such standards during and after working hours, as 

well as when the employee is on leave or in travel status. 

5. Foreign Service personnel and all other personnel under Chief of Mission Authority,

including federal government employees from Tenant Agencies, should not in

any way abet sex trafficking or solicit people in prostitution, irrespective of

whether prostitution is legal in the host country. As long established in the

FAM, frequenting prostitutes is considered "notoriously disgraceful conduct" and 

Foreign Service personnel who engage in this conduct may be subject to disciplinary

action. (See 3 FAM 4138, 4139.14, 4300.) Penalties range from admonishment, reprimand, 

suspension, to separation from the Department, depending on the circumstances. In

some instances, such conduct may also have an adverse impact on an employee's 

Department of Justice 40 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

 

security clearance. Disciplinary action has been taken against employees in the past 

for this behavior. Locally Employed Staff (which includes Ordinarily Resident

Americans and Foreign Service Nationals) will be subject to discipline by post 

management. 

Department of Justice 41 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

APPENDIX IV: DOD SOUTHCOM GENERAL ORDER NUMBER 1, 2012 

DEPARTMENT OF DEFENSE 

UNITED STATES SOUTHERN COMMANO 

OFFICE OF THE COMMANDER 

9301 NW 331'10 STREET 

DORAL, FL 3311Z-12t12 

Sccc 28 May 2012 

GENERAL ORI)J;;R NUMJ3ER 1 

TITLE: Prohibited Activities for U.S. Department of Defense and Certain U.S. Coast Guard 

Pmonncl Present Within the United States Southern Command (USSOUn 'ICOM) Arca of 

Responsibility (AOR) 

PURPOSE; To identify and regulate conduct thllt is prejudicial to tho maintcmlllcc of good 

order and disci pline of forces in the [)SSOUTHCmd AOR. 

AUTHORITY: Title 10, United Slates Code, Section I 64(c); the Unifonn Code of Military 

]u!)ticc (UCMJ), Title 10. Unitcd States Code, Scctions 801·940; and DOD Instru(..1ion 3020.4l. 

dated 20 D<:ct'mbcr 20 II. 

1. APPLICABILITY: 

a. This Genera1 Order applies to the fo llowing personnel while present ill the 

USSOUTHCOM AOR: 

(1) A.II United States Department of Defensc military personnel and civilian employcc.,'s: 

(2) All United States Coast Guard personnel a.~signe , attached, or TACON to 

Dcpartmcnt of Defcnsc organizations; 

(3) All United Stutes (;Qvenlluent agency IUld department liaison olIicers and detailees 

assigned, attached, or TACQN to Department of Defense gatJi ati s; and 

(4) All contingf.,'ncy contructor personnel (as defined in DOD Instmction 3020.41, dated 

20 De<:ember 2011 ) serving with, employed by. or accompanying the .L\rrned Porees Qfthe 

United States. 

b. nus Gener-II Ord r does.nOI lIppiy 10 persOlmd assigned to: Defense Attache Ollil'es; 

United States Marine Corps Security Detachments; sensitive intelligence and counterintelligence 

activities that are. conducted under the directioll and control of the Chief of Mission/Chief of 

StOllion: or other United States Govcmm(..-nt agencies lllld departments, cxceptlls referenccd in 

pill"agfilph l.a above. 

c. The specific prohibitions contained III parugnlph 4.b nrc applicable only to individuals 

(including civilians as referenced in paragraph I.a above) with duty in the USSO COj\' ~ 

AOR and while participating in exerois<!.~ or specified operations, regardless of whether the 

Department of Justice 42 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

sccc 

SUBJECT: GENERAL ORDER NUMBER 1 

indi vidual is pen1llUlenl part y, deployed, or on temporary duty to the AOR and regardless of 

whether the individual i!; on or 00" duly_ Members ofSecurily Cooperation OfTiccs who only 

provide routine logis(ical or administrative support (such as fad! itn.ling country clearances or the 

movement Qf supplies or equipment) are nOI considered to be partit:ipating in an exercise or 

specified oper.Jlion. 

(1) 111e applicability ofparagrapb 4.b(1 ) to exercises extends from 12 hours before 

STARTEX llutil ENDEX. These prohibitiolls do not otherwise appl y to site visit." or ot/lcr 

preparatory activities in advance of an exercise. 

(2) '1110 ternl "specified operations," for purposes of this GClleral Order, is us dctined as 

operations which are directed pursuant to a DEPORD, EXORD, or OPOR!). llle ternl does not 

inelude ongoing detention operations at Joint Task Foree-Guantanamo, rOlltine'ship 

deployments, or other routine d:lily operations of USSOUTHCOM subordinate organizations. 

2. PUNITIVE GENERAL ORDER: Paragraph 4 of this General Order is puniti\ie. All 

persolls subject to the UCMJ who violate the prohibitions contained therein are subject to 

proseL:utioll and/or di iplinary and adl1linistrali vc ucti qll under Article- 92 of the ueMJ. U.S. 

govenunent employees who violate these provisions are subject to admillistrati ve or discip linary 

action under applicable directives or implementing instructions governing civi lian disciplinary or 

ndmi nislrlllivc actions. Oontingency contractors who violate ll,ese pro \' s arc :mbjC1Jt to 

administrative action under DOD instnlction 3020.4 1. 

3. STATEMENT OF MILITARY PURPOSE: Operations and exercises place United States 

Anned Forces within USSOUll·rCOM AOR countries. Some or these cOllntries hllve local laws 

and l:llstClms that pemlit or allow VariOliS activities that are prohibited Or reslri(:ted by the laws of 

the United States and policies of the Department of Defense. Maintaining the higb standards of 

conduct of 11 strong tUld disciplined force, maintaining pers{mnel health and sarety, IUld adhering 

10 the core values expc!Cted orlhe U_S- Ann ed Forces i!; <!!;sentialtf,l pre!;erving PO!;ilive rdalions 

with our host nations and ensuring the success of operations and exercises in USSOU·t:HCOM 

AOR countnef>. In addition, the high opemtionaltempo combined with fast-paced duties 

required or U.S . . Arnled Forces make il pmdenl to restrict certain acti vities in order to maintain 

good order and discipline and ensure optin1tull force readiness. Activities prohibited by this 

General Order create signilicllllt risk to OPSEC and fNFOSEC. Furthennore, excessive a]c()hol 

consumption in particulUJ' has been a contributing factor in the majority of injuries and accidents, 

as well as diplomatic incidents and criminal misconduct involving military personnel and DOD 

civilians in this AOR. 11,ef>e incidents have lhe potenlial to adversely afTect U.S. fClreign poli cy 

and the Command's. theater engagement goal!; and objecti ves. 

2 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

43 
 

 

SCCC 

SUBJECT: GENERAL ORDER NUMBER I 

4. PROHIBITED ACTIVITIES: 

il. AI All Times. 

(I) It is prohibited to introduce, purchase, possess. use. sell. transfer, manufacture, or 

conSllllle any controlled substances without a valid prescription unless ~c ifi cl1 l1 y authorized for 

au a tTicial purpose (such As the authorized transport of military medical supplies). Prescription 

drugs must be accompani ed by the ori ginal prescri ption label which identifies the prescribing 

medical facility or authority, 

(2) It is prohibited to knowingly enter into contact with a prostitute or a person who 

provide!; nexua ll y oriented 11la!;sages. Ira person subject to thi!> General Order unkll()wingly 

enters into oon1.1cl with a prostitut.e or a person who provides sexually oriented massages, other 

than a passing, unwanted so licitation by the other person. the person subjrxt to Ihis Gcllernl 

Order is required to immediately cease the contact and report the incident to the first offi cer in 

the Chain of Command. 

(3) It is prohibited to paironize a prostitute or receive a sexually OIiented massage. 

(4) It is prohibited to directly or indirectly arrange for a prostitute or sexually Qrienled 

masseuse to come to your own hotel room or other quarters or to go to the hotel room or other 

quarters occupied by any person subject to this Ckneral Ordcr. 

(5) It is prohibited 10 USe an escort service or dating service. 

(6) It is proh ibited to entcr an cstablislmlcnt that is off-limits or where it is kuown by the 

person subj ect to this General Order that any of the tollowing are present or habitually present: 

prostitution, sexually oricntcd massage. or illicit dmg usc, lfa person subject 10 Ihis General 

Order unknowingly enters any establishment that is olT-limits or wherc pmstituti(ln, sexuall y 

oriented massage, or dmg lise are present or habitually present, tbat person is required 10 

imlllcdiately leave. the cstabli hlll cnt al,ld report the incidenltQ thc first offi cer in the Chain or 

Command . 

(7) II ~ prohihited to rcnl(lVC, possess, sell , deface, or destroy archeological artiraeL" or 

naiional treasLlrcf;. 

(8) 11 it; prohibited to ~c1I, barter, or excha.nge any CurrenCy other than allhe offi cial hostnation exc111Ulge rate or commercial rate commonly available at hotels. 

3 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

44 
 

 

SCCC 

SUBJECT~ GENERAL ORDER NUMBER 1 

h. While Parlicipfflu'g ill Exercise. .. or Specified! Opera,wm. 

(I) It is prohihiltld to introduce. purohase, consume, sell, or Iransfh alcohol. II is nO' 

prohibited to ot herwise possess closed col)laincrs of alcohol during an exercise or specified 

operation acquin:d prior 10 the exercise or opcr:lli on or as lin unsolicited gin from II partner 

nalion representative, if they are intended for consumption after the exercise or operation. 

(2) It is prohihited to introduce. Jlurchase. pO!lgess, use. or sell privatel y O\vned fireamlS. 

ammunition, or explosives. 

5. AD()lTIONA(' REQUIREMENTS: 

a. All personnd 11 01 covered under the provisions of paragraph 4.b orlhe General Order will 

exercise restraint, in the consumption of alcohol and display a professional demeanor al all limes 

and follow Ihe loca l alcohol policy nfthe Senior Defense OlTiciallDefen:;:e lla h~ or that of the 

Security Coopcndi on Office, if one is in d]~ t. 

b. All personnel not coyered under the provisions of paragraph 4.b of the General Ord.:r will 

ensllre that :my purc]ul."e. poss~s ion" US<l, or ~a e of privatel y owned fireamls, ammunition. or 

explosives, is consistent with both U.S. and host nation la\,' or policy. 

c. SOUn co~" subordinate org,mizations and Senior Defense Offioials are free to issue. 

more restrictive orders than those cont aincd 111 this GClIeral Order. 

6. INDIVIDUAL DUTY: All pcrsons 10 whom Ihis General Order is npplicabl\.J. arc responsible 

for knowing :ll1d understanding tIle prohibitions contained herein. All h persons are further 

charged wilh the responsibility to become. familiar with and respect the laws, rcgu lations, and 

customs of thdr host nation. whi le still maintaining strictest compliance with U.S. law and DOD 

policy. Acts of disrespect or violations of host nation laws, regulations and ClLStomS may be 

punished undirr 3pplicahle (;rimill31 talllt~ and ;Idministrati ve regulations. 

7. UNIT COJ\o[MANDER RESPONSIB.ILITY: Commanders, Security Cooperation Office 

Chiefs, r OTCe Protection Officers, and military and civili an supervisors are charged with ensuring 

that ALL PERSONNEL arc briefed on the prohibitions and ret\uiremt:nts ol" lhili Gcneml Order. 

'nlt! llcl o~ed t3riefing Paper may be lI ~e d for this purpose, but the text of the General Order it:;elf 

con tams thc binding proVililOllli. Commanders may further limit thcir force s liS Ihey deem 

necessary. 

8. CONFISCATION OF OFFENOIN(; ARTlCLES: Items deknnined to violate this General 

Order may be considered contraband by command 0 1"' law enforcement authorities if found in the 

USSOUTHCOM AOR. Bclore tmCli n of contrab:md, commanders or law CI11oreL'1l1ent 

I For a definition tlf"spreified tlperatitlns, " see paragroph 1.c(2). 

4 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

45 
 

 

SCCC 

SUBJECT: GENERAL ORDER NUMBER I 

personnel will consult with their servicing judge advocate. Military customs and other preclearance offi cials will enforce this General Order during their inspections of personnel prior to 

departure to and from the AOR and return to CONUS, 

9. EFFECTIVE DATE: This General Order is effecti ve immediately. 

10. EXPlRATION: This General Order will expire when rescinded by the Commander, 

USSOUTHCOM, or higher authorities. 

11 . WAIVER AUTHORITY: Authority to waive or modify the prohibitions in Paragraph 

4.b(l) of this General Order is hereby delegated to USSOUTHCOM Component Commanders 

and to the Senior Defense Official in the corresponding country. Component Commanders are 

authorized to delegate their waiver authority to no lower than the 0-6 level. Any waivers 

granted sball be in writing and reported immediately to the Chief of Staff. USSOUTHCOM, 

through the Office of the Staff Judge Advocate, USSOUTHCOM. Contact (305)437-1 307 for 

processing instructions. 

GO 

Ends 

I Briefing Paper 

a~r/f{·~ General . U.S. Air Force 

Commander 

5 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

46 
 

 

Briefin g Palle r on SOUTHCOM Genera' Order #1 

). Ba('kgrouud . 

• :. SOUTHGOM Genera] Order # 1 is new, but incorporates, updates, and replaces the previous SOllTHCOl'l·1 

Alcohol Po licy (Policy MemoflUldum 37-12, I Feb 2012) . 

• :. GO 1 11.pplics to all OOD pcrsOIUlel, USCG and ccn ain oth.::r interagency personnel (while TACON to DOD), 

and ..:crtain contllldon> \lIhi1.:: in !he SOUTHCO:"'I AOK 

',' Part 1 (~4 ) applic:> to ch persons while in the SOUTHCOM AOR at all times and prohibit~; 

,. Use, pun:hasc, possession. _ of coni rolled ub lancC!; without a prcsLlTiption; 

,. Knowingly having contact with a prostitute or someone that gives ~c)l; uall y oriented massagcs; 

,. Patronizing'l prostitute or receiving a sexuall y onenltld massage; 

)- Arranging ror a prostitut e or ~~" uall y oriento:d massell s~ to Gome 10 a hotel room or other quarten;; 

}- Ul'ing an I!.~cort or dating ~erv (;l:;l ; 

). Knowingly entering an establishment that prov ide~ prostitutinn, se;';ually oriented m3.lSSage, or illicit drug:;; 

). Removing, posseRsing, selling, defacing, or destroying archeological anifacts or national treasures; and 

). Selling, bartering, or exchanging currency on the- black marke-t. 

.:0 Part 2 ('114.b.) applies to persons while in the SOUTHCOM AOR only while participating in e:rareises or in 

operation!! \~ ith a DEPORD, EXORD. orOPORD (other than !"Qutine daily erati ~) and prohihit1i: 

). Consumption, purchase elc. of aJC:ohol ~ and 

> Use, purchase, possession. etc. of privately owned firearms, ammunition, or explosives. 

-:0 Alcohol prohibition during exercises applies from 12 hours before STARTEX to ENDEX . 

• :. Alcohol prohibition may be wai"ed in writing by a Component Commander or the Senior OGtense. Official. 

Component Commanders may dd<;lgato: tht':ir waiver authority to no lowertllat the 0 -6 1;:v;:1-

.:. Component COlllmandeTll or Senior Derense Offi.::iab may set more !';tringent requirements. 

3 . • 'AQ_ 

Q 1 ompermanenliy a.rsigned Ii) the MIJ.,.GROUJ> in cOImrryXXX . DOI!!s Ihis mean J can no longer drink 

alcohol? 

JI Just like (ulY otlll:r person (pconallcllt party, TDY_ or deployed) GO I docs Ilot prohibit you from drinking 

alcohol unless you lire participating in an exercise or specified operation. The exercise restriction only applies 

["rom 12 hours hdon: STARTEX until ENDEX. 111t: ~pe.: ifi d operation n:.strid;oll applic:s until tile oper.lti on 

is declared over or Ihe alcohol prohibition is wai v..:d_ If you arc nol participating in Ihe exercise or specifi .. -d 

Qpcratioll, thcn the ah.:{)hol pmhibition oe~ not apply to you. 

Q I am going TDY in the SOUTHCOM AORfo/" a TCA conference. Does ,his mean I tanTlQt drinka!cohoJ 

during rhe-conference? 

11 No. A TCA .:onfcrcll!::c, Subjc.:t Matli::r Exchaoge, or similar event is 110t a ··specified op<.'Tilti on," so [he 

alcohol prohibition does not apply. 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

47 
 

 

 

 

APPENDIX V: LAW ENFORCEMENT COMPONENT TABLES OF 

OFFENSES AND PENALTIES 

The ATF, DEA, FBI, and USMS use tables of offenses and penalties as a management 

tool for meting out discipline. Table 5 provides the portions of the tables that are relevant 

to the four behaviors considered in this report: consuming excessive alcohol, using illegal 

drugs, soliciting prostitutes, and engaging in notoriously disgraceful conduct. The Criminal 

Division told the OIG that it does not use a table of penalties and offenses because of the 

restrictive nature of penalties and the inability to adequately adjust them to particular 

circumstances. 

Table 5: Excerpts from the Law Enforcement Components’ 

Tables of Offenses 

Component Offense Explanation (if Any) Penalty 

Consuming Alcohol 

ATF Transporting a firearm 

after consuming alcohol. 

Violation of policy as 

stated in ATF O 2130.1, 

Conduct and 

Accountability. 

1-day suspension up to 

removal. 

Operating a government 

vehicle after consuming 

alcohol. 

Operating a government 

vehicle in violation of ATF 

O 2130.1, Conduct and 

Accountability. 

3-day suspension up to 

removal. 

Driving under the 

influence (DUI) in private 

vehicle off duty. 

Unsafe operation and 

failure to obey traffic laws 

resulting in serious 

injury or loss of life. 

7-day suspension up to 

removal. 

DEA Reporting for duty under 

the influence of 

intoxicants. 

Under the influence is 

described in the 

standards of conduct. 

5-day suspension up to 

removal. Removal on 

second offense. 

Operating a government 

vehicle while under the 

influence of alcohol. 

Under the influence is 

described in the 

standards of conduct. 

60-day suspension up to 

removal. Removal on 

second offense. 

FBI Alcohol abuse – Under 

the influence while on 

duty. 

Without authorization, 

consuming alcohol while 

on duty or during a 

break; consuming alcohol 

prior to reporting for duty 

to the extent that it has 

an effect on the 

employee’s workplace or 

performance. 

Standard penalty: 15-

day suspension. 

Penalties range from oral 

reprimand up to 

dismissal. 

Driving under the 

influence (DUI)/Driving 

while intoxicated (DWI) – 

government vehicle. 

Operating any 

government vehicle while 

intoxicated or impaired 

by alcohol or controlled 

substance. 

45-day suspension up to 

dismissal. Removal on 

second offense. 

Department of Justice 48 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

 

 

Component Offense Explanation (if Any) Penalty 

DUI/DWI – private 

vehicle. 

Operating any privately 

owned vehicle while 

intoxicated or impaired 

by alcohol or controlled 

substance. 

30-day suspension up to 

dismissal. Removal on 

second offense. 

USMS Reporting for duty under 

the influence of 

intoxicants. 

Under the influence is 

described in the 

standards of conduct. 

5-day suspension up to 

removal. Removal on 

second offense. 

Operating a government 

vehicle while under the 

influence of alcohol. 

Under the influence is 

described in the 

standards of conduct. 

60-day suspension up to 

removal. Removal on 

second offense. 

Using Illegal Drugs 

ATF Possession, use, and/or 

distribution of illegal 

drugs on or off duty. 

More severe penalty will 

be imposed for 

distribution. Penalty may 

be affected by the type of 

substance. 

3-day suspension up to 

removal on first offense. 

Removal on second 

offense. 

DEA Unauthorized use or 

possession of narcotics, 

dangerous drugs, or 

marijuana. 

No explanation. Removal on first offense. 

Reporting for duty under 

the influence of drugs. 

Under the influence is 

described in the 

standards of conduct. 

5-day suspension up to 

removal. Removal on 

second offense. 

Operating a government 

vehicle while under the 

influence of drugs. 

Under the influence is 

described in the 

standards of conduct. 

60-day suspension up to 

removal. Removal on 

second offense. 

FBI Drugs – use or 

possession. 

Knowingly and 

consciously ingesting, 

injecting, inhaling, or 

possessing an illegal 

controlled substance or 

anabolic steroid, on or off 

duty, after entering on 

duty. 

Standard penalty: 

Dismissal. Penalty 

could be mitigated to 

suspension of 10-60 

days if there is minimal 

occurrence in distant 

past. 

Substance abuse – under 

the influence while on 

duty. 

Using a prescribed 

medicine in a manner 

inconsistent with the 

prescribing physician’s 

instructions, having an 

effect on the employee’s 

workplace or 

performance. 

Standard penalty: 15-

day suspension. 

Penalties range from oral 

reprimand up to 

dismissal. 

USMS Unauthorized use or 

possession of narcotics, 

dangerous drugs, or 

marijuana. 

No explanation. Removal on first offense. 

Reporting for duty under 

the influence of drugs. 

Under the influence is 

described in the 

standards of conduct. 

5-day suspension up to 

removal. Removal on 

second offense. 

Department of Justice 49 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

 

 

Component Offense Explanation (if Any) Penalty 

Operating a government 

vehicle while under the 

influence of drugs. 

Under the influence is 

described in the 

standards of conduct. 

60-day suspension up to 

removal. Removal on 

second offense. 

Soliciting Prostitutes 

FBI Indecent/Lascivious Acts Inappropriately acting in 

a manner to appeal to or 

gratify the sexual desires 

of the employee, his 

victim, or both. If a 

foreign jurisdiction 

lawfully permits acts 

described herein, this 

offense will apply if the 

act is contrary to a law 

the FBI is chartered to 

enforce. 

Standard penalty: 

30-day suspension. 

Penalties range from 

5-day suspension up to 

dismissal. 

Engaging in Notoriously Disgraceful Conduct 

ATF Conduct prejudicial to 

the government. 

Includes criminal, 

infamous, dishonest, 

immoral, or notoriously 

disgraceful conduct, or 

other conduct prejudicial 

to the government. 

Examples include, but 

are not limited to: 

retaliation for filing EEO 

complaint, whistleblower 

complaint, grievances or 

any other protected 

activity. 

Removal on first offense. 

DEA Criminal, dishonest, 

infamous, or notoriously 

disgraceful misconduct. 

No explanation. 14-day suspension up to 

removal. Removal on 

second offense. 

FBI Unprofessional conduct – 

off duty. 

Engaging in conduct, 

while off duty, which 

dishonors, disgraces, or 

discredits the FBI; 

seriously calls into 

question the judgment or 

character of the 

employee; or 

compromises the 

standing of the employee 

among his peers or his 

community. 

Standard penalty: 5-day 

suspension. Penalties 

range from oral 

reprimand up to 

dismissal. 

USMS Criminal, dishonest, 

infamous, or notoriously 

disgraceful misconduct. 

No explanation. 14-day suspension up to 

removal. Removal on 

second offense. 

Off duty misconduct. To include operation of 

private vehicle while 

under the influence. 

Reprimand or 

suspension, up to 

removal. 

Department of Justice 50 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

Sources: ATF Guide for Offenses and Penalties, revised, March 9, 2010; DEA Guide for Disciplinary Offenses and 

Penalties, undated; FBI Penalty Guidelines and Offense and Codes Explanation, effective January 15, 2012; and USMS 

Table of Disciplinary Offenses and Penalties, May 3, 2012. 

Department of Justice 51 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

APPENDIX VI: DEA STANDARDS OF CONDUCT QUESTIONNAIRE 

AND ACKNOWLEDGMENT FORM 

EIbibit JIZ7JS.I .. 

CIRCLE STANDARDS OF CONDUCT QUEmONS 

ONE 

YES NO 1. Reporting Responsibilil)'. Do you know that .fyou become aware of any 

information indkadng tIlIt anotheremplo}llC of DE A is in Yiolation of these 

Slandatds of Conduct, YOLI haye all obliga!ion 10 report that information 

immediately to your supervisor or to the Office of Professional Responsibility? 

2. OIx:LIlTences an Employee MLiSI Report to His or Her Supervisor: 

YES NO A. Are YOLlawvt: that you, as a DEA 05·1811 anployee, L1pon discharging yOlif 

firearm, in other than a sponing or teere.tionalsinwion Of practice on a ruing 

range. must report this incident 10 your supervisor? 

YES NO B. Are you aware that )'Ou, as a OEA employee must report to your supervisor all 

incidents of person ally being 1IlCStcd, taken inlo cuscody, held for inyestigation or 

detained f« questioning. regardless of your duty SlItus at the. time? 

YES NO C. Are you aware thll ·you,as a OEA employee. must· immediately report all 

inlfactions with an official goyernmenl vehicle 10 the proper supervisory leyel ? 

YES NO O. Do you know thaI you, as a DEA employee, must report any additional illegal 

activities or misc:onduct which has nor beCII mentioned. above and has not been 

reported 10 )'Out sup«vlsor? 

YES NO 3, Use of Drugs, Are you aware that you, IS a I)EA employee, may nOl use a 

conlrolled substance which has nor been properly prescribed by a licensed 

physician or properly obtained for Ihe treatment or illness ora condition? 

.... Misuse orOffice and Coercion: 

YES NO A. An, you aware tMt you, as a DEA emplo>=, may not use your official position 

fOr private gain, or coeroc or give the appearance of coc:n::ion 10 provide financial 

bencfilto youlKlfor 10 another person? 

YES NO B. Do you know that you. as I DEA emplO)'OC, may not use youroffidal position 

10 give preferential trntmenl to another employee. or IIttempito bribe public 

officials andlor witnesses? 

YES NO C. Are you awatelhal )'OLI, as a OEA employee. may nOl conduct unauthorized or 

illegal sean:ha of premises. automobiles or persons? 

YES NO D. An, you aware that you, IS I OEA employee, mly IlOl embezzle, steaf, purloin, 

sell, conveyor dispose of in an unluthOriled manner Iny record. voucher, money 

substance, or thing oevalue 10 the United S,""es. 

YES NO E. Do)'Ou know thll you, as a DEA employee, may not U5C your position 10 sell. 

ooIled for pelSOnal U5C, or otherwise dispose of controlled substances in an 

L1ltlUthoriud manner? 

PIiCJ of. IlC4 SIr<IITIV[ 

Department of Justice 52 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

OEA 5I:NSlTIV[ Thio..-JiI_~orlh< Drlar..r.-........-CDEA~ Hci\hU k ... lb __ !li~_0f1iW0fA 

C .... If_..-sidt "'DfA f'onbcr~)wihMllb< <>epa>"";_,.....-';" orlb< CllicfC ....... 

YES NO F. Do you know thai you, asa DEAemployee. may not use )'Ourposilion 10 

tamper with or ranove evidence, purchased, seized Of otherwise in Ihe possession 

of DE A Of one orits employees? 

YES NO G. Are you aware thai you, as a DEA employee, may nOl solicit or otherwise, 

Cflgage in personal business tl'lJlsaclions which involve or give !be &ppear'llIlCI; of 

involvinglhe use orofflCial time or facilities? 

YES NO H. Are you aware thai you, as a DEA employee, may not associatc with 

individuals known Of suspccled to be Involved in illepl drug trafficking Of other 

criminal activity in other than a mictly professional capacity. This prohibition also 

applies to informant contaclS. 

YES NO I. Are you aware that)'Ou may not engage in extrinsic social, fi!llllcial or business 

conlaCls wilh above referenced individuals? 

YES NO -5. Gifts. Gratuities, Entertainment and Favors. Ate)'Ou.~ that unless an 

exception applies, you. as a DEA employee, may not accepl or solicit a gift or 

gratuity fi'om a prohibited source or if given because of your official position?-

6. DEA Records and Officiallnfonnation: 

YES NO A. Are you aware that you, lIS a DEA employee, may not incentionally destroy, 

mutUale, remove. f.l5ify. cooceaI, alter or mike an W\8uthorlzed copy ofa 

government record for yoUr own purposes? 

YES NO B. Do you know that you, as a DEA employee, may not make false or fi"audulent 

statements to create any false document? 

YES NO C. Are you aWIJe thai you, as a DEA employee, may not use information which 

comes to you by reason of your employment with DEA for personallinancial gain 

or for the financial gain ofanother'l 

YES NO D. Do you know thl! you, as a DEA employee, may not knowingly or willfully 

communieate, fumish, tI'IJIsmit or otherwise divulge privileged, administratively 

controlled OfclassifMlll infoltt1llion to an unauthorized person which reasonably 

could be expected to cause damage to the National Security of the United Stales, 

would adversely affect !he accomplishment ofDEA's opemion and mission, or 

would be centrary to law, regulation or public policy? 

7. Use ofGovemment Property: 

YES NO A. Are you aware that you, as a DEA employee, may not knowingly purchase or 

have another pel'$Ofl purchase on your behlf, property &om the Federal 

govemmentlhat was seized by DEA Of another Federal acency during an 

investiption in which DEA employees pIIrticipa1ecl? 

YES NO 8.00 you know that )'Ou, as a DEA employee, may not disclose to another ~ 

any infonnlllion concerning such propcrty (i.e., appnised value, etc.) which would 

give IhIt person an advantage over perspective bidders at auction? 

YES NO C. Are you aware that you. as a DEA employee. may not utilize a government 

vehicle while under the influence of alcohol Of drugs? 

Page 2 of4 

,,"'''''''''' ......... 

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Evaluation and Inspections Division 

53 
 

 

TIIio~"'1IIe~f1f""'o.,.Ea*-Adrnio""""'jDEJ.~Ncillocrft_"_lIIO)'bo~....ucrafIhoDf.A .u """"'" 

C .... Ir~ __ oIllEA. fwIl\cf d~lwid!oI:llbo __ ..mra. ........... J"", CtridCoonod. 

YES NO D. Are yOIl aware that you, as a DEA employee, may not engage in an 

unauthorized use ofa government owned or leased vehicle? 

8. Use offntoxiealing Beverages: 

YES NO A. Are you aware that you, as a DEA employee, may not consume alooholic 

beverages in DEA offices or on government property designated for theconduCI of 

official business? 

YES NO B. Are you aware thai you, as a DEA employee, may not be under the influence of 

intoxicants at the stan oro; at any lime during working hours, and further you may 

not consume alcoholic beverages during your assigned duty hours,. to include lime 

taken for meals, or when you will be operating an official government vehicle 

(OGV)? 

YES NO C. Are you aware orlhe fact thai theonly [wo exceptions to hem B above involve 

Ca) the consumption of alcohol in fill1herance ofa specific law enforcement 

operation for purposes of securing evidence or (b) while representing DEA on an 

approved duty assignment? In each inStance, prior approval by a supervisor of the 

GS-IS rank or higher and superior in rank to the employee inyolved must be 

obtained. 

YES NO D. Are you aware that If you., as a OEA employee.. ate engaged in one of the 

exccplions noted in Item C above, any consumption of alcohol must be strictly 

limited to ensure that the employee is not impaired from perfonning assigned 

duties or operating an otrJCiai government vehicle? 

YES NO 9. Unauthorized Recording of Employee Conversations. Are you aware that you. 

lIS a OEA employee, may not rcoord conversations of other employees without the 

consent of all parties. except in the conduct of officially authorized investigations? 

YES NO -10. Finam;iallnterest. Are you aware that you, as a DEA employee, cannot 

participate personally and substantially in most official matten; that may affect 

)'Our personal fmancial interests or those financial interests imPUled 10 you (e.g. 

spouse, dependent child)'1-

YES NO J I. Gambling, Betting and Lotteries. Arc you IIWate thaI)'Ou, as II DEA employee, 

(nay nOI participate in gambling, belting or management of lotteries while on 

govemment~wned or leased propet1)' while on official duty? 

-12. Speeches, Lectures and Publkadons: 

YES NO A. Arc you aware that you, as a OEA employee, may not receive a fee or 

remuneratioo from an outside source (or a public appeanuw;;e, speech. lecture or 

publkition when ils oorItcnt came from official data or ideas which ate not public 

Infonnation? 

PageJof4 

DU S£NS1TlVI. 

I 

j 

I 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

54 
 

 

~'£NSmvt _ llIio ...-lirlhc -'Y 0(l1li DnII ~ AdnIinidn&Ion \0£A1 NriIhct il .... ib _ ltIIIS "'"l' II< d;""" __ auoido orVlc ~ 

\0<. if ....... auuidc afDEA, ~ ~l"'; '" _...nu... pmnission of ... Clri.rCOIIIIId. 

YES NO B. Do you know that you, as a DEA employee, may no! engage in leaching. 

writing or lecturing (with or without compensation) that is dependent on 

information obIained as a result of your govemmetlt employment, unless the 

infonnalion has been made available 10 the general public and otherwise complies 

with 5 C.F.R. § 2635.807~ 

·13. Employmen! Outside of DE A: 

YES NO A. Are you aware that you, as a DEA employee, may nol engage in any outside 

employment which will create or appear 10 create a conflict ofinteresl as defined 

by 18 U.S.C. § 20a, 5 C,F.R. §§ 2635.402 and 2635.502, 5 C.F.R.·§ 380[, and 28 

C.F.R. § 45.2, reflect adversely upon the Departmen! of Justice, or in any manner 

interfere with availability or the proper and effective perfonnance of your dulies? 

YES NO 8. Are you aware tkat you, as a DEA employee, while engaged in outside 

employment may not use appropriated funds or items purchased or leased through 

expenditures of appropriated funds in furtherance of your outside employment? 

YES NO C. Are you aware that you, as a DEA employee. may not engage in the misuse of 

office space, government vehicles, 80vernment furnished transportation, other 

government employees such as couriers, franked envelopes or franked mail 

stickers, computer hardware and software. wireless mobile devices. reproduction 

equipment, bulletin boards, telephone service or any other i!eJns of service 

purchased by appropriated funds? 

I have acknowledged each of the questions conrained in this document pertaining to my 

Standards orConducL I recognize the fact that these responsibilities represent the prescribed 

minimum acceptable behavior for employees ofDEA. They are not to be considered all-inclusive 

and may be supplemented by DEA as necessary. Therefore, with my signature, I certify that I 

hive familiarized myself with the content of these Standards ofCondUCIllld understand the 

persona.! responsibilities they represent. 

Employee's Signature _ _ __________________ _ 

"", __ 1 __ 1_ -

Employcc's Printed Name and title; ________________ _ 

Supervisor's Signature _ ___________________ _ 

Date J J 

Supervisor's Printed Name aod title: ________ ________ _ 

Page40U 

.u """"'" 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

55 
 

 

APPENDIX VII: DEA ADMINISTRATOR MEMORANDUM ON ALCOHOL 

CONSUMPTION, 1999 

.6 •••••••••••••••••••••••••• • •• 

.....•.....•........••••....... UNCLASSIFIED 

<men> 99-00029611 <pree> IMMEDIATE 

<c1as> UNCLASSIFIED <orig> RUEABND 

<dtg> 212325Z JAN 99 <55n> 1291 

<id> DEA 01291 

<date> 99/01/21 23:36:09 

OATUZYUW RUEABND1291 0212330-UUUU--RUEABND. 

ZNR UUUUU 

o 21 :1325Z .TAN 99 

<fm> OM DEA HQS WASH-INGTON DC 

<to> TO DEA WORLDWIDE 

RUNGCAF/DEA GUAM ISLAND GU 

RUEHBJ/AMEMBASSY BEIJING 

RUEHRL/USOFFICE BERLIN 

RULSAD-T /NDIC JOHNSTOWN PA 

<info> INFO RUEABND/DEA HQS WASHINGTON DC 

<text> 

BT 

UNCLAS DEA 01291 

POST FOR DEA ONLY 

<sub> 

SUBJECT: STANDARDS OF CONDUCT RELATING TO THE CONSUMPTION OF ALCOHOL 

(FFS: 060-01) 

<text> 

ATTENTION: ALL DEA EMPLOYEES 

1. ON OCTOBER 27, ~924, I ISSUED A CLEAR DIRECTIVE REGARDING THE USE 

OF ALCOHOL BY DEA EMPLOYEES WHILE ON OR OFF-DUTY. ~HE DIRECTIVE 

STATES: 

2. THE DEA STANDARDS OF CONDUCT HAVE LONG FORBIDDEN EMPLOYEES TO 

CONSUME ALCOHOL WHILE ON GOVERNMENT PREMISES OR TO BE UNDER THE 

INFLUENCE OF ALCOHOL WHILE ON DUTY. EFFECTIVE IMMEDIATELY, DEA 

EMPLOYEES ARE FORBIDDEN TO CONSUME ALCOHOLIC BEVERAGES DURING THEIR 

ASSIGNED DUTY HOURS, TO INCLUDE TIME TAKEN FOR MEALS, OR WHEN THEY 

lULL BE OPERATING AN OFFICIAL GOVERNMENT VEHICLE (OGV). 

3. THE ONLY EXCEpTION TO THIS PROVISION, wHICH MUST BE APPROVED IN 

ADVANCE BY A SUPERVISOR OF THE GS-lS RANK OR HIGHER, AND SUPERIOR IN 

RANK TO THE EMPLOYEE INVOLVED, IS WHEN SUCH CONSUMPTION OCCURS DURING 

THE COURSE OF A SPECIFIC LAW ENFORCEMENT OPERATION FOR PURPOSES O~' 

SECURING EVIDENCE OR WHILE REPRESENTING THE DEA ON AN APPROVED DUTY 

ASSIGNMENT. 

4 . ANY CONSUMPTION UNDER THE ABOVE EXCEPTION MUST 8E STRICTLY LIMITED 

TO INSURE THAT THE EMPLOYEE IS NOT IMPAIRED FROM PERFORMING ASSIGNED 

DUTIES OR OPERATING AN OFFICIAL GOVERNMENT VEHICLE_ 

5. EMPLOYEES WITH LAW ENFORCEMENT RESPONSIBILITIES MAY HAVE TO RETURN 

TO DUTY AT ANY TIME AND SHOULD NOT ENGAGE IN THE CONSUMPTION OF 

ALCOHOL TO SUCH AN EXTENT THEY ARE UNFIT TO RETURN TO DUTY. 

Department of Justice 56 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

6. ALL DEA EMPLOYEES SHOULD BE AWARE THAT VIOLATIONS OF THE ABOVE 

STANDARDS MAY RESULT IN SEVERE DISCIPLINARY ACTIONS, UP TO AND ' 

INCLUDING REMOVAL. 

7. THE PREMISE OF ALLOW~NG DEA AGENTS TO CARRY WEAPONS IN AN OFF-DUTY 

STATUS IS RELATED TO THE INHERENT DANGERS FACED BY ALL LAW ENFORCEMENT 

OFFICERS . IN ORDER TO PROTECT OUR AGENTS FROM VIOLENT DEFENDANTS OR 

CRIMINAL ORGANlZATtONS NHO MAY TARGET THEM, WE HAVE AS A MATTER OF 

POLICY, ALLOWED OUR AGENTS TO CARRY THEIR WEAPONS WHILE IN AN OFF-DUTY 

STATUS. HOWEVER. THAT AUTHORITY CARRIES WITH IT SIGNIFICANT 

RESPONSIBILITY . 

8. ONE OF THOSE RESPONSIBILITIES IS THAT ·AGENTS SHOULD NOT USE 

ALCOHOL TO SUCH A LEVEL THAT THEX BECOME INTOXICATED AND CANNOT RETURN 

T'O DUTY. THIS STANDARD OF MODERATION IS ANALOGOtJ.S TO THE LAWS WHICH 

I,IMIT THE AMOUNT OF ALCOHOL AN INDIVIDUAL CAN UTILIZE AND OPERATE A 

MOTOR VEHICLE IN ~ SAFE HANNER . 

9 . THE REASON FOR TH~S STRINGENT STANDARD IS TO AVOID THE POTENTIALLY 

SERIOUS PROBLEM OF AN AGENT IN A PUBLIC SETTING BEING REQUIRED TO TAKE 

EMERGENCY ACTION IF THEIR ABILITIES ARE IMPAIRED BY THE USE OF 

ALCOHOL . QU"EST'IONS COUL,D EASILY AND LEGITIMATELY BE RAISED BY MEMBERS 

OF THE PUBLIC ABOUT THE PROFESSIONALISM AND THE STABILITY OF AN AGENT 

WH.o LACKS THE SELF RESTRAINT AND JUDGEMENT TO APPEAR IN TilE PUBLIC IN 

,AN INEBRIATED CONDITION. 

10 . THE RESPONSIBILITY FOR AVOIDING THIS DANGEROUS SITUATION RESTS 

WITH INDIVIDUAL AGENTS AND THEIR IMMEDIATE SUPERVISOR . THE FAILURE OF 

AGENTS TO ADHERE TO BOTH ON DUTY AND OFF DUTY STANDARDS WILL RESULT IN 

THE MOST STRINGENT DI SCIPLINARY ACTIONS. SUPERVISORS WILL ALSO BE 

iiE:LD ACCOUNTABLE. WHERE APPROPRIATE. FOR VIOLATIONS OF THESE RULES OF 

CONDUCT,. 

11. THE OVERALL IMAGE OF DEAAS A PROFESSIONAL AND HONORABLE LAW 

ENFORCEMENT AGENCY DEPENDS ON ALL OF OUR ,MEMBERS ACTING IN A 

PROFESSIONAL MANNER. THOSE WHO VIOLATE THESE RULES HARM THE 

REPUTATION O,F TIiE OVERWHELMING NUMBER OF HARD WORKING HONORABLE, AND 

HEROIC DEA AGENTS. ~ 

12 . SPECIAL AG"ENTS I N CHARGE SHOULD INSURE THAT ALL AGENTS IN THEIR 

COMMAND ARE IMMEDIATELY HADE AWARE OF THIS TELETYPE AND INSURE THAT 

THEY HAVE READ THE INSTRUCTIONS . 

THOHAS A, CONSTANTINE 

ADMI.NISTRATOR 

• UNCLASSIFIED 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

57 
 

 

APPENDIX VIII: THE OFFICE OF THE DEPUTY ATTORNEY GENERAL’S 

RESPONSE TO THE DRAFT REPORT 

U. S. Department of Justice 

Office of the Deputy Attorney General 

Associme Depuly Anorney General WOl'h illgtun. D.C. 20530 

December 17,2014 

MEMORANDUM 

TO: Michael Horowitz 

Inspector General 

U.S. Department of Justice 

FROM: Carlos Felipe Uriarte c.flA.. 

Associate D eputy Attorney General 

SUBJECT : Resp o nse: Review of Policies and Tra ining Governing Off-Duty Conduct 

by Departmen t E mp loyees Wo rking in Fore ign Countries 

We appreciate the audit undertaken by the Department of Justice (DOJ or the 

Department), Office of the Inspector General (OIG) regarding the Department's policies and 

training governing off-duty conduct by Department em.pJoyees working in foreign countries. [n 

this review, o ro reviewed the off-duty conduct policies for the Criminal Division and four of 

oors law enforcement components (the Drug Enforcement Administration; Bureau of A lcohol, 

Tobacco, Firearms and Explosives; Federal Bureau ofInvestigation; and u.S. Marshals Service). 

The report makes six reconlmendations regarding the policies and training govenling off-duty 

conduct by DO] employees working in foreign countries. three of which ate directed to the 

Department. We address these recommendations below. and concur with all three. 

Department of Justice 58 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

Recommendation No.1 to the Department of Justice: Develop and disseminate clear and 

comprehensive Department-wide policy that communicates DOrs authority and expectations 

regarding off-duty conduct. 

Response: Concur. The Department will develop clear and comprehensive Departmentwide policy guidance that communicates the Department's expectations regarding offduty conduct. We expect that this guidance will assist the Criminal Division, the Bureau 

of Alcohol, Tobacco, Firearms and Explosives, the Drug Enforcement Administration, 

the Federal Bureau ofInvestigation, and the U.S. Marshals Service in developing their 

own policies regarding off-duty conduct in response to Recommendation No.4. 

Recommendation No.2 to the Department of Justice: Identify best practices for guiding 

employee behavior and ensure that these practices are shared with all components that send 

employees to work in foreign countries. 

Response: Concur. The Department will develop best practices for guiding employee 

behavior that will be included with the Department-wide policy guidance that will be 

shared with all components that send employees to work in foreign countries. 

Recommendation No.3 to the Department of Justice: Ensure that the components develop 

clear, complementary, and consistent policies in a timely marmer. 

Response: Concur. The Department will ensure that all components that send 

employees to work in foreign countries develop clear, complementary, and consistent 

policies that are consistent with the Department-wide policy guidance that communicates 

the Department's expectations regarding off-duty conduct. 

cc: Mark Giuliano, Federal Bureau oflnvestigation 

Leslie Caldwell, Criminal Division 

Michele Leonhart, Drug Enforcement Administration 

B. Todd Jones, Bureau of Alcohol, Tobacco, Firearms and Explosives 

Stacia Hylton, United States Marshals Service 

-2-

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

59 
 

 

APPENDIX IX: OIG ANALYSIS OF THE OFFICE OF THE 

DEPUTY ATTORNEY GENERAL’S RESPONSE 

The Office of the Inspector General (OIG) provided a draft of this report to the Office 

of the Deputy Attorney General (ODAG) for its comment. ODAG’s response is included in 

Appendix VIII to this report. The OIG analysis of ODAG’s response and actions necessary 

to close the recommendations are discussed below. 

Recommendation 1: Develop and disseminate clear and comprehensive Department-wide 

policy that communicates DOJ’s authority and expectations regarding off-duty conduct. 

Status: Resolved. 

ODAG Response: ODAG concurred with this recommendation and stated the 

Department will develop clear and comprehensive Department-wide policy guidance that 

communicates the Department’s expectations of off-duty conduct. ODAG expects the 

guidance will assist the components in developing their own policies on off-duty conduct in 

response to recommendation 4. 

OIG Analysis: ODAG’s actions are responsive to our recommendation. Please 

provide by April 30, 2015, copies of the Department’s policy guidance on off-duty conduct. 

If the policy guidance has not been formally disseminated, please provide a status on the 

matter. 

Recommendation 2: Identify best practices for guiding employee behavior and ensure 

that these practices are shared with all components that send employees to work in foreign 

countries. 

Status: Resolved. 

ODAG Response: ODAG concurred with this recommendation and stated the 

Department will develop best practices for guiding employee behavior, which will include 

the Department-wide policy guidance, that will be shared with all components that send 

employees to work in foreign countries. 

OIG Analysis: ODAG’s actions are responsive to our recommendation. Please 

provide by April 30, 2015, examples of best practices of guidance for employee behavior 

when working in foreign countries. 

Recommendation 3: Ensure that the components develop clear, complementary, and 

consistent policies in a timely manner. 

Department of Justice 60 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

Status: Resolved. 

ODAG Response: ODAG concurred with this recommendation and stated the 

Department will ensure that all components that send employees to work in foreign 

countries develop clear, complementary, and consistent policies that are consistent with 

the Department’s policy guidance communicating Department expectations on off-duty 

conduct. 

OIG Analysis: ODAG’s actions are responsive to our recommendation. Please 

provide by April 30, 2015, a status of the ODAG’s efforts in ensuring that components 

develop clear, complementary, and consistent policies with the Department’s policy 

guidance on expectations on off-duty conduct when working in foreign countries. 

Department of Justice 61 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

APPENDIX X: THE BUREAU OF ALCOHOL, TOBACCO, FIREARMS 

AND EXPLOSIVES’ RESPONSE TO THE DRAFT REPORT 

U.S. Department or .Justice 

Bureau of Alcohol, Tobacco. 

Fireanns and Explosives 

603030:ADW W~""I"~'"". DC 10126 

8300 .......... ~'r lI"" 

DEC 17 2014 

MEMORANDUM TO: Nina S. Pelletier 

Assistant Inspector General 

Evaluation and Inspections Division 

FROM: Assistant Director 

(Office of Professional Responsibility and Security Operutions) 

SUBJECT: ATF's Response to the Office of Inspector General's Review of Policies 

and Training Governi ng Off-Duty Conduct by Department Employees 

Working in Foreign Countries, Assignment Number A-2013-003 

This memorandum serves to transmit ATF's response to the above-cited report. Attached is a 

summary of the status of the action taken relative 10 the cited recommendations. 

Should you have any questions or need additional infonnation, please contact the Chief of A TF's 

Audit Liaison Branch, Adam Pallotto at (202) 648-8706. 

Michael Gleysteen 

Altachrnent 

cc: Director 

Assistant Director (HRPD) 

Assistant Director (OS II) 

Chief Counsel 

Assistant Director, Audit Liaison Group, Department of Justice 

Department of Justice 62 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

MEMORANDUM TO; Assistant Director 

(Office of Professional Responsibility and Security Operations) 

FROM: Assistant Director (Office ofHwnan Resources and Professional 

Development) 

SUBJECT: Review ofPolicics and Training Governing Off-Duly Conduct by 

Department Employees Working in Foreign Countries 

This Bureau of Alcohol, Tobacco. Firearms. and Explosives (A TF) appreciates the opportunity to 

respond to the recommendations contained in the above cited report. The off-duty improprieties 

of employees undennine the ability of ATF to carry out our mission and adversely impact- their 

careers. We welcome the Office of Inspector General's (DIG) constructive comments and 

recommendations on this matter. 

Our reSponse to the report's three recommendations directed at the components are as follows: 

Recommendation 4: Disseminate dear, complementary, and comprehensive policy to all 

penlOnnei regarding off-duty conduct, including prol'isions ror employees represeDdng tbe 

government In other countries. 

Response (Concur): ATF will consolidate and, if netessary. develop additional policy guidance 

regarding off-duty condud while on official travel in foreign countries. The resulting policy 

directive will be 'in accordance with any forthcoming DOl guidance on off-duty conduct, 

including off-duty alcohol consumption, what constitutes notoriously disgraceful conduct, 

solicitation., and firearms use. Coordination between affected offices within ATF will take place 

when Departmental guidance is in place. 

OIG Recommendation 5: Raise awareness of tbat policy and bow It applies to • variety of 

situadons through existing basic law enforcement mining, new employee orientation, and 

periodic training throughout employees' ClI;reers. 

Response (Concur); When the policy directive that is consistent with DOJ guidance is finalized, 

the A TF National Academy will incorporate it into the training modules on conduct and ethics 

delivered during basic training. New employees who do not onboard at the ATF National. 

Academy will be provided training on the new policy as part of the required on-line courseware 

U.S. Department of Justice 

Bureau of Alcohol, Tobacco, 

Fireanns and Explosives 

603000;ARP 

6000 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

63 
 

 

-2-

Assistant Director 

(Office of Professional Responsibility and Security Operations) 

assigned to all new employees. In addition, all employees will be periodically reminded oflhe 

policy throughout their career. 

OIG Recommendation 6: Reinforce the policy and how 10 apply It through pre-depJoymeDt 

training for employees being seot abroad. 

Response (Concur): As the new policy directive thai is consistent with DOl policy is finalized, 

the A TF International Affairs Division and other divisions with international missjons will 

collaborate to determine the best course for applying the new comprehensive policy to pcedeployment training for employees being sent abroad. 

Again, thank you for the opportunity 10 respond to your recommendations. Should you have any 

questions regarding this memorandum feel free to have a member of your staff contact Adam 

Pallona, Chief orlhe Audit Liaison Branch, at (202) 648-8706. 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

64 
 

 

APPENDIX XI: OIG ANALYSIS OF THE BUREAU OF ALCOHOL, TOBACCO, 

FIREARMS AND EXPLOSIVES’ RESPONSE 

The Office of the Inspector General (OIG) provided a draft of this report to the Bureau 

of Alcohol, Tobacco, Firearms and Explosives (ATF) for its comment. ATF’s response is 

included in Appendix X to this report. The OIG analysis of ATF’s response and actions 

necessary to close the recommendations are discussed below. 

Recommendation 4: Disseminate clear, complementary, and comprehensive policy to all 

personnel regarding off-duty conduct, including provisions for employees representing the 

government in other countries. 

Status: Resolved. 

ATF Response: ATF concurred with this recommendation and stated ATF will 

consolidate and, if necessary, develop additional policy guidance on off-duty conduct while 

on official travel in foreign countries. ATF also stated that the resulting policy directive will 

be in accordance with any forthcoming DOJ guidance on off-duty conduct to include offduty alcohol consumption, what constitutes notoriously disgraceful conduct, solicitation, 

and firearms usage. Coordination among affected ATF offices will take place once the 

Departmental guidance is in place. 

OIG Analysis: ATF’s actions are responsive to our recommendation. Please provide 

by April 30, 2015, copies of any revised or additional policy guidance that was issued 

related to off-duty guidance while on official travel in foreign countries. In addition, please 

provide the status of the coordination efforts with ATF offices related to the issuance of 

Departmental guidance. 

Recommendation 5: Raise awareness of that policy and how it applies to a variety of 

situations through existing basic law enforcement training, new employee orientation, and 

periodic training throughout employees’ careers. 

Status: Resolved. 

ATF Response: ATF concurred with this recommendation and stated that when the 

Department guidance is finalized, the ATF National Academy will incorporate this guidance 

into the training modules on conduct and ethics that is delivered during basic training. 

ATF also stated that new employees who are not onboard at the ATF National Academy will 

be provided training on the new policy as part of required online courseware that is 

Department of Justice 65 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

assigned to all new employees. Further, all employees will be periodically reminded of the 

policy throughout their careers. 

OIG Analysis: ATF’s actions are responsive to our recommendation. Please provide 

by April 30, 2015, copies of the training modules that will incorporate the Department 

guidance. In addition, please provide copies of the online courseware for new employees 

that covers the new policy as well as information on how all employees will be periodically 

reminded about the policy. 

Recommendation 6: Reinforce the policy and how to apply it through pre-deployment 

training for employees being sent abroad. 

Status: Resolved. 

ATF Response: ATF concurred with this recommendation and stated that once the 

new ATF policy directive that is consistent with Department policy is finalized, the ATF 

International Affairs Divisions and other ATF divisions with international missions will 

collaborate to determine the best course for applying the new policy to pre-deployment 

training for employees who are being sent abroad. 

OIG Analysis: ATF’s actions are responsive to our recommendation. Please provide 

by April 30, 2015, copies of the information that is shared in pre-deployment training for 

employees who will be sent abroad. If the training materials have not been finalized, please 

provide a status on development of the pre-deployment training materials. 

Department of Justice 66 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

APPENDIX XII: THE CRIMINAL DIVISION’S RESPONSE TO THE DRAFT REPORT 

u.s. Dcpilrtmc.nt of Justice 

Criminal Divisiotl 

MEMOI~ANDUM 

TO: Nina S . Pelletier DEC 1 7 1014 

A,qsistnnt (nspector Gcneml 

Evaluation and 11lSpCCtiOllS Dlvisio n 

Office o f (be lru;peetor Gc:ncnd 

FROM: Leslie R. Caldwell 

Assistant Attorney General 

SUOJECT: Response to.Draft Audll Report: Rl!view ofPollcte.r an d Traln tMJI: Governing Og: 

Dldy Conduct by Department Empluyecs Working In Foreign CJJlmtrics. 

Assignment No. A-20J3-003 

This 11lCUlorandum responds to the Office of the Inspector Genem/·s (OIG) requ..st for 

commenL 011 lh ..., recoJ:llmelldatiol1.s COI\ta.iUeri in the subject d raft audit repotl. 

During the CQunJe of the ulu.lit, the CrimInal Divish;m augmc,ntcd its trai, J.i ~ and 

g uidance w ith regard to off-duty cooduct and, consistent with the recommendations in the draft 

audit report, w ill continue to do so. lndced, the Criminal D ivision's Dcputy D esignated AQ:e:ncy 

fith ics Official ( DJJ AHO) recently updated its annual tra.ining for all Criminal DiviBion 

o nployec.,,· m include training 011 policies regardLng o.(f-duty conduct, bo th domestically and 

abrQad. All Crin;tinal Division employees are Iequired to complete this {rUining by Decembcr 3 1, 

2014. 

AdditionuHy, with regard 10 the table cmtitled "'Components' Pre"encc in Foreign 

CO\u\tJ:ies" on Page. 4 of tlte draft report, (he CrimiX1Ul D ivision n otes that the 80 ··pcrm anent 

pOllitions" e ited me actuBlly detail and term positiolls, not permanent positions. 

With respect t o the 010'", recommendations in the draft report. C riminal D ivision inle nds 

to tlike Lhe .following actions; 

Recommendation 4: D bsemlnnte dear, complementary and comprehensive policy to a ll 

personnel regarding olf-duty condu ct, including prov!Ji"ns for cIIIJlI"yee~ prellelltin~ the 

governmenl in other COllntri"". 

Department of Justice 67 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

Response: The Criminal Division concurs with this recommendation. The Criminal Division 

will enhance existing guidance and disseminate a comprehensive policy regarding off-duty 

conduct, both domestically and overseas. The Criminal Division will conform its policy with the 

forthcoming DOJ guidance on off-duty couduct. 

Recommendation 5: Rllise awarencss olthat policy and how it IIpplies to a varie~ 01 

situations through existing basic hlW enforc~ment training, new employee orientation Ilnd 

periodic. training throughout employees' careers. 

R~nonse: The Criminal Division concurs with this recommendation. Once the C.rimi nal 

Division's new policy is finalized, the Criminal Division will train its employees on the policy 

during new employee orientation and existing periodic training programs. 

Recommendation 6: Reinforce the policy a nd how to apply it through pre-deploymenl 

training f()r enlilloyees being sent abroad. 

RCSPC'IQsc: The Criminal Division eoncurs with this recommendation. Once the Criminal 

Division's ncw policy is finali.zed, tbe Criminal Division will collabora\e internally to determine 

the best method of reinforcing the new poticy during pre.deployment training for employees 

being sent overseas. 

Should you bave any questions or concerns regarding this report, please contact 'tracy 

MeJtol\, Acting Executive Officer at 202-305-0534. 

2 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

68 
 

 

APPENDIX XIII: OIG ANALYSIS OF THE CRIMINAL DIVISION’S RESPONSE 

The Office of the Inspector General (OIG) provided a draft of this report to the 

Criminal Division for its comment. The Criminal Division’s response is included in 

Appendix XII to this report. The OIG analysis of the Criminal Division’s response and 

actions necessary to close the recommendations are discussed below. 

In addition, the Criminal Division stated that during the course of the OIG’s review, it 

had augmented its training and guidance with regard to off-duty conduct so that is 

consistent with the recommendations in the draft report and stated that it will continue to 

do so. For example, the Criminal Division’s Deputy Designated Agency Ethics Official 

(DDAEO) recently updated the annual training for all Criminal Division employees to 

include training on policies on off-duty conduct, both domestically and abroad. All 

Criminal Division employees are required to complete the training by December 31, 2014. 

Finally, the Criminal Division noted that the 80 “permanent positions” that are cited in the 

draft report are actually detail and term positions, not permanent positions. 

The OIG takes note that the Criminal Division continues to augment its training and 

guidance on off-duty conduct, domestically and abroad. The Criminal Division’s efforts are 

consistent with the recommendations made in this report. In addition, the OIG has made 

additional clarifications to the report related to the Criminal Division overseas positions. 

Recommendation 4: Disseminate clear, complementary, and comprehensive policy to all 

personnel regarding off-duty conduct, including provisions for employees representing the 

government in other countries. 

Status: Resolved. 

Criminal Division Response: The Criminal Division concurred with this 

recommendation and stated that the Criminal Division will enhance existing guidance and 

disseminate a comprehensive policy on off-duty conduct, both domestically and overseas. 

The Criminal Division also stated that it will conform its policy to the forthcoming 

Department guidance on off-duty conduct. 

OIG Analysis: The Criminal Division’s actions are responsive to our 

recommendation. Please provide by April 30, 2015, copies of the Criminal Division’s 

enhanced guidance and policy that discusses off-duty conduct, both domestically and 

overseas. 

Department of Justice 69 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

Recommendation 5: Raise awareness of that policy and how it applies to a variety of 

situations through existing basic law enforcement training, new employee orientation, and 

periodic training throughout employees’ careers. 

Status: Resolved. 

Criminal Division Response: The Criminal Division concurred with this 

recommendation and stated that, once the Criminal Division’s new policy is finalized, it will 

train its employees on the new policies during new employee orientation and existing 

periodic training programs. 

OIG Analysis: The Criminal Division’s actions are responsive to our 

recommendation. By April 30, 2015, please provide copies of the training materials that is 

used in new employee orientation and existing periodic training programs. 

Recommendation 6: Reinforce the policy and how to apply it through pre-deployment 

training for employees being sent abroad. 

Status: Resolved. 

Criminal Division Response: The Criminal Division concurred with this 

recommendation and stated that once the new Criminal Division policy is finalized, the 

Criminal Division will collaborate internally to determine the best method of reinforcing the 

new policy during pre-deployment training for employees being sent overseas. 

OIG Analysis: The Criminal Division’s actions are responsive to our 

recommendation. By April 30, 2015, please provide copies of the pre-deployment training 

materials that discuss the new Criminal Division policy. If the pre-deployment training 

material is still under development at that time, please provide a status report on how the 

Criminal Division plans to disseminate the information. 

Department of Justice 70 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

APPENDIX XIV: THE DRUG ENFORCEMENT ADMINISTRATION’S 

RESPONSE TO THE DRAFT REPORT 

u. S. p~lrtment of Justice 

Drug Enforcement Administration 

wlVw.dea.gol' Washington, D.C. 20537 

PEC 1 7 2014 

MEMORANDUM 

TO: Nina S. J'cllct icr 

AssisWnt Inspector General 

Evaluatio ns and Inspections 

Office orthe Lnspcctor General 

FROM: ~~~

Ac

MI

t

c

ing 

hael 

Deputy 

A: DL ... 

Chi 

~n 

Inspec

~ 

tor 

Office of In spections 

SUBJECT: DEA·s Response to the DIG Draft Report: '·Review of Policiel· alld Training 

Guverning Off-Duty Com/liel by Deparlmenl Employees Working in Foreign 

COllflfries .. 

The Drug En forccment Administration (DEA) has rev iewed the Department o f Justice (001) 

Office o f the Inspector General's (DIG) Draft Report entitled, Review of Policies and Training 

Governing Off-Dilly Cantillct hy Department Employees Working ill Foreign COl/mYies . . , DEA 

acknowledge::: D IG 's efforts in conducting a revicw 10 improve policies and training governing ofTduty conduct by DOJ employees working in fo reign countries. 

The D IG makes six recommendations in the report in which three recommendations are for the 

Criminal Division. ATF, DEA, FBI, and USMS. Below a re DBA 's responses to the 

rccommendations. 

IlccommendatiOIl 4: Disseminate cle ar, complementary, a nd comprehensive policy to all 

pcrsonnt' l regarding off-duty co nduct, int'luding provisions for employees r eprese nting the 

government in other countries. 

DEA concurs wi th this recommendation and wit l ensure lhat its policies that are provided to all 

personnel regarding off-duty cond uct. including provisions ror employees represcnting the 

government in other countries arc in line with newly developed De partment-wide policy that 

communicates DOJ's expectation regarding off-duty conduct. 

Department of Justice 71 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

Nina S. Pelletier, Assistant Inspector Gencral Page 2 

Recommendation 5: Raise awareness of that policy and how it applies to a variety of situation 

throu gh existi ng basic law enforcement training, new cmployee orientation, and periodic 

trainin g throughout employees' careers. 

DEA concurs with this recommendation and will ensure that its policies that arc provided to all 

personnel regarding ofT-duty conduct, including provisions fo r employees representing the 

government in other eountrics are in linc with ncwly developed Department-wide policy thai 

communicates DOJ's expectation regarding off-duty conduct and thaI the policy raises awareness of 

how it applies to a variely of situations through basic law enforcement training as well as new 

employee orientation, and period ic training. 

R«ommendation 6: Reinforce the Jlolicy and how to apply it through pre-deployment training 

for employees being sent abroad. 

DEA concurs with this recommendation and will ensure that its policies that are provided to all 

personnel regarding ofT-duty conduct, including provisions fo r employees representing the 

government in other countries are in line with newly developed Dcpartment-wide policy that 

communicates DOl's expectation regarding otT-duty conduct and that the policy is reinforced as to 

how it is applied through prc-deployment training for employees being sent overseas. 

If you have any questions regarding this response, please contact the Audit Liaison Team, on 

202·307-8200. 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

72 
 

 

APPENDIX XV: OIG ANALYSIS OF THE DRUG ENFORCEMENT 

ADMINISTRATION’S RESPONSE 

The Office of the Inspector General (OIG) provided a draft of this report to the Drug 

Enforcement Administration (DEA) for its comment. The DEA’s response is included in 

Appendix XIV to this report. The OIG analysis of the DEA’s response and actions necessary 

to close the recommendations are discussed below. 

Recommendation 4: Disseminate clear, complementary, and comprehensive policy to all 

personnel regarding off-duty conduct, including provisions for employees representing the 

government in other countries. 

Status: Resolved. 

DEA Response: The DEA concurred with this recommendation and stated the DEA 

will ensure that its policies are provided to all personnel on off-duty conduct to include 

provisions for employees representing the government in other countries are in line with the 

Department-wide policy that will communicate Department expectations on off-duty 

conduct. 

OIG Analysis: The DEA’s actions are responsive to this recommendation. By April 

30, 2015, please provide copies of any new or revised DEA policies on off-duty conduct that 

will be provided to employees working in foreign countries that will communicate the 

Department’s expectations on off-duty conduct. 

Recommendation 5: Raise awareness of that policy and how it applies to a variety of 

situations through existing basic law enforcement training, new employee orientation, and 

periodic training throughout employees’ careers. 

Status: Resolved. 

DEA Response: The DEA concurred with this recommendation and stated that the 

DEA will ensure that its policies are provided to all personnel on off-duty conduct, 

including provisions for employees representing the government in other countries. The 

policies will be in line with newly developed Department-wide policy communicating the 

Department’s expectation on off-duty conduct and will raise awareness of how it applies to 

a variety of situations through basic law enforcement training, new employee orientation, 

and periodic training. 

Department of Justice 73 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

OIG Analysis: The DEA’s actions are responsive to this recommendation. By April 

30, 2015, please provide copies of the training materials that will incorporate the 

Department’s policy and expectations on off-duty conduct. If the training materials are still 

being developed at that time, please provide a status report. 

Recommendation 6: Reinforce the policy and how to apply it through pre-deployment 

training for employees being sent abroad. 

Status: Resolved. 

DEA Response: The DEA concurred with this recommendation and stated that the 

DEA will ensure that its policies are provided to all personnel on off-duty conduct, 

including provisions for employees representing the government in other countries are in 

line with the newly developed Department-wide policy that communicates the Department’s 

expectations on off-duty conduct and that the policy is reinforced as to how it is applied 

through pre-deployment training for employees being sent overseas. 

OIG Analysis: The DEA’s actions are responsive to this recommendation. By April 

30, 2015, please provide information on how DEA reinforces its policies on off-duty conduct 

through pre-deployment training to employees who are being sent overseas. 

Department of Justice 74 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

APPENDIX XVI: THE FEDERAL BUREAU OF INVESTIGATION’S 

RESPONSE TO THE DRAFT REPORT 

U.S. Department of .Ju!ldee 

Federal Bureau of Investigation 

WashingtOn, D. C. 205]5-0001 

December 11 , 2014 

The Honorable Michael E. Horowitz 

Inspector General 

Office of the Inspector General 

U.S. Department of Justice 

950 Pennsylvania Avenue, N.W. 

Washington, DC20530 

Dear Mr. Horowitz: 

The Federal Bureau oflnvestigation (FBI) appreciates the opporturuty to review and 

respond to your office's report entitled, Review of Policies and Training G01lf!rning Off-Duly 

Conduct by Department Employees Working in Foreign Counlrles. 

We are pleased that you found. ..... the FBI. had a comprehensive [traini.ngJ program that 

laid a strong foundation regarding off-duty conduct during new employee and new agent training 

and provided additional training when employees were to be deployed abroad." 

We agrtIe that it is important to raise awareness of as well as reinforce policy regarding 

off-duty conduct of FBI emp!oyees including those wodcing abroad. We will tailor FBI policies 

to be consistent with any forthcoming Department Of Justice-wide guidance regarding the same. 

In that regard, we concur with your three recommendations to the FBI. 

Should you have any questions, feel free to contact me. We greatly appreciate the 

professionalism of your audit staff throughout this matter. 

Sincerely, 

ciauna 'Ii. CnS",-" / qf 

Laura R. Ingber 

'Section Chief 

External Audit and Compliance Section 

Inspection Division 

Enclosure 

Department of Justice 75 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

AUDIT-OF THE REVIEW OF pOLICIES AND TRAINING GOVERNING OFF-DUTY 

CONDUCT BY DEPARTMENT EMPLOYEES WORKING IN FOREIGN COUNTRIES 

Report Recommend.tioD #4: Disseminate clear, complementary, and comprehensive policy to 

all personnel regarding off-duty conduct, including provisions for employees representing the 

government in other countries. 

FBI Response to Recommendation 114: Concur. The FBI has clear, consistent, and 

comprehensive policies prohibiting the use of illegal drugs, excessive alcohol consumption, 

unprofessionai conduct (on and off-duty), misuse of official position, misuse ofa government 

vehicle, improper personal relationships, misuse of government property (e.g., sman phones), 

unreported contact with foreign nationals. misuse of government databases, misuse of 

government travel cards, the receipt of improper gifts, and other matters. As is made clear to aU 

employees, these policies apply whether at home or abroad. In fact. employees deploying 

abroad are advised that their conduct is subject to a heightened standard of review by virtue of 

the fact that they will be living and working in a foreign land subject to increased risks and 

potential compromises. 

Report R"ommendation #5: Raise awareness of that policy and how it applies to a variety of 

situations through existing basic law enforcement training, new employee orientation, and 

periodic training throughout employees' careers. 

FBI Response to Recommendation 1#-5: Concur. The FBI provides extensive \l'8inil18 to its 

employees, including. but not limited to, new agent training, new employee training, 

international deployment training, intelligence analyst training, summer intern training, and chief 

division counsel training. The FBI's policies cited above, ex~ted standards of conduct. and 

Core Values are discussed repeatedly in these training classes by, among others, the Office of 

Professional Responsibility (OPR), the Office of Integrity and Compliance, the Inspection 

Division, and the Office of General Counsel. 

Report Recommendation #6: Reinforce the policy and how to apply it through pre-deployment 

training for employees being sent abroad. 

FBI Response to Recommendation #6: Concur. As noted above in response to 

Recommendation 2. the FBI provides robust and highly informative pre-deployment training to 

FBI employees being sent abroad, including discussions of the polides cited above in response 

to Recommendation I. In its training, OPR cites examples of previously adjudicated cases to 

inform and instruct deploying personnel in a highly relevant manner of the expected standards of 

conduct while living and working abroad as representatives of the FBI and the U.S. Government. 

OPR emphasizes that deploying employees are bound by the FBI's strict code of conduct 

irrespective of where they find themselves, irrespective of the conduct of their internationals 

hosts, and irrespective of the law, custom or policies of the foreign government. 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

76 
 

 

 APPENDIX XVII: OIG ANALYSIS OF THE FEDERAL BUREAU 

OF INVESTIGATION’S RESPONSE 

The Office of the Inspector General (OIG) provided a draft of this report to the Federal 

Bureau of Investigation (FBI) for its comment. The FBI’s response is included in Appendix 

XVI to this report. The OIG analysis of the FBI’s response and actions necessary to close 

the recommendations are discussed below. 

Recommendation 4: Disseminate clear, complementary, and comprehensive policy to all 

personnel regarding off-duty conduct, including provisions for employees representing the 

government in other countries. 

Status: Resolved. 

FBI Response: The FBI concurred with this recommendation and stated that the 

FBI has clear, consistent, and comprehensive policies prohibiting the use of illegal drugs, 

excessive alcohol consumption, unprofessional conduct (on- and off-duty), improper 

personal relationships, unreported contacts with foreign nationals, and other matters. The 

FBI stated that these policies apply whether at home or abroad and that employees 

deploying abroad are advised that their conduct is subject to a heightened standard of 

review by virtue of the fact that they will be living and working in a foreign land subject to 

increased risks and potential compromises. 

OIG Analysis: The FBI’s actions are responsive to our recommendation. By April 

30, 2015, please provide copies of any new or revised FBI policies that are issued or as a 

result of incorporating the forthcoming Department-wide policy guidance on off-duty 

conduct. 

Recommendation 5: Raise awareness of that policy and how it applies to a variety of 

situations through existing basic law enforcement training, new employee orientation, and 

periodic training throughout employees’ careers. 

Status: Resolved. 

FBI Response: The FBI concurred with this recommendation and stated that the 

FBI provides extensive training to its employees, including, but not limited to, new agent 

training, new employee training, international deployment training, intelligence analyst 

training, summer intern training, and chief division counsel training. The FBI’s policies, 

expected standards of conduct, and Core Values are discussed repeatedly in these training 

Department of Justice 77 

Office of the Inspector General 

Evaluation and Inspections Division
 

 

classes by the Office of Professional Responsibility (OPR), the Office of Integrity and 

Compliance, the Inspection Division, the Office of General Counsel, and others. 

OIG Analysis: The FBI’s actions are responsive to our recommendation. By April 

30, 2015, please provide copies of any new or revised training materials on off-duty conduct 

that was issued or as a result of incorporating the forthcoming Department-wide policy 

guidance on off-duty conduct. 

Recommendation 6: Reinforce the policy and how to apply it through pre-deployment 

training for employees being sent abroad. 

Status: Resolved. 

FBI Response: The FBI concurred with this recommendation and stated that the 

FBI provides robust and highly informative pre-deployment training to FBI employees being 

sent abroad. The FBI further stated that in the training, OPR cites examples of previously 

adjudicated cases to inform and instruct deploying personnel in a highly relevant manner 

of the expected standards of conduct while living and working abroad as representatives of 

the FBI and the U.S. Government. It was also stated that OPR emphasizes that deploying 

employees are bound by the FBI’s code of conduct irrespective of where they find 

themselves; irrespective of the conduct of their international hosts; and irrespective of the 

law, custom or policies of the foreign government. 

OIG Analysis: The FBI’s actions are responsive to our recommendation. By April 

30, 2015, please provide a status report on any new or revised pre-deployment training on 

the subject of off-duty conduct or as a result of incorporating the forthcoming Departmentwide policy guidance on off-duty conduct. 

Department of Justice 78 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

APPENDIX XVIII: THE UNITED STATES MARSHALS SERVICE’S 

RESPONSE TO THE DRAFT REPORT 

u.s. Depa rtm en t of Justice 

United Stales Marshals Service 

Qlfice of file AS.wciale Din! ClOr.f 

.·U<,xum/riu. 1:../ 11301 

Do:ccmber 17. 2014 

MEMORANDUM TO: Nina S. Pellcticr 

Assistant Inspector General 

Eval uation and Inspections Division 

Omee orthe Inspector General 

FROM: William O . Snelson uJ ~ .D . Associate Director ror Operations LLSUBJECT: Response to Dwn Audit Repon: Review or Policics and Training 

Governing Orf-Duty Conduct by Department Employees Working 

in Foreign Countries, Assignment No. A-2013 -003 

This is in response to correspondcnce from the Office ofthc Inspector General (O IG) 

requesting comment on the recommendations assoc iated with thc subj ect draft audit report. 

We note DIG's acknowledgmem in the rcport that USMS has a policy in elTect stating 

that its employees must refrain from using prOhibited controlled substances, even w hen those 

substances are commercially available without a prescription. or are ingested legally, in a foreign 

country. \Ve also note that DIG acknowledges USMS' existing Code of Conduct (applicable to 

all USMS employees, w hcther on tnwcl o r not), and USMS' conduct-oriented training specific to 

employee missions in Colombia . 

Si nce this aud it, USMS divisions with international missions have been worki ng 10 

develop guidance and training regarding other specific types of off-duty conduct (domestically 

and internationally). Further actions we plan to take with respect to O IO 's recommendations to 

the DOJ components arc outlined in our attached response. 

S hould you have any questions or concerns regarding this response, please contact Isabel 

1·lowell, Audit Liaison, at 202-307-9744. 

Attachments 

Department of Justice 79 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

Memorandwn from Associate Director for Operations Snelson Page"2 

Subject: Response to Draft Audit Report: Review of Policies and Training Governing Off-Duty 

Conduct by Department Employees Working in Foreign Countries, Assignment No. A-2013-003 

co: Richard Theis 

Director, Audit Liaison Group 

Internal Review and Evaluation Office 

Justice Management Division 

Isabel Howell 

External Audit Liaison 

United States Marshals Service 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

80 
 

 

USMS Response to OIG Draft Report 

Review of Policies and Training Governing Off-Duty Conduct by Department Employees 

Working in Foreign Couotries, Assignment No. A-2013-003 

Recommendatinn 4: Disseminate dear, complementary, aDd C!omprebensive poliC!y to all 

personDel regarding ofT-duty C!ooduct, induding provisions for employees represeDting the 

government in other C!ountries. 

Response (Concur): USMS will consolidate and enhance existing guidance. and. as necessary. 

develop additional guidance regarding off-duty conduct while on official travel in foreign 

countries. The resulting policy directive will conform 10 forthcoming DOl guidance onoff-duty 

conduct. including off-duty alcohol consumption. what constitutes notoriously disgraceful 

conduct. solicitation, and flreanns use. USMS will also evaluate whether language regarding 

off-duty conduct should be added to its existing International Training Policy Directive. 

Collabomtive meetings and discussions between affected USMS divisions (Training Division, 

Office of Genera,! Counsel, Office of Professional Responsibility. and divisions with 

international missions) will begin once DepartmentaJ guidance is in place. 

Recommendation S: Raise awareDess of tbat policy and bow it applies to a variety of 

situatioDs througb existing basic law enforc:ement training, new employee orientatioD, and 

periodic training tbrol,lghout employees' careers. 

Response (Concur): As the new policy directive consistent with 001 policy is finalized. USMS 

divisions responsible for developing employee training modules on conduct and ethics will work 

collabomtively with the Training Division to determine how the new comprehensive policy 

directive will be incorporated into existing basic law enforcement training. new employee 

orientation, and periodic training throughout employees' careers. 

RecommeDdation 6: Reinforce the policy aDd bow to apply it tbrough pre-cleployment 

training for employees being sent abroad. 

Resp.Dnse (Concur): As the new policy directive consistent with 001 policy is finalized, the 

USMS Training Division and divisions with internationa1 missions will collaborate to determine 

the best course for applying the new comprehensive policy to pre-deployment training for 

employees being sent abroad. 

Department of Justice 

Office of the Inspector General 

Evaluation and Inspections Division 

81 
 

 

 APPENDIX XIX: OIG ANALYSIS OF THE UNITED STATES 

MARSHALS SERVICE’S RESPONSE 

The Office of the Inspector General (OIG) provided a draft of this report to the United 

States Marshals Service (USMS) for its comment. The USMS’s response is included in 

Appendix XVIII to this report. The OIG analysis of USMS’s response and actions necessary 

to close the recommendations are discussed below. 

In addition, the USMS stated that since the OIG review, USMS divisions with 

international missions have been working to develop guidance and training on other 

specific types of off-duty conduct, domestically and internationally. The OIG takes note 

that the USMS is working on developing guidance and training on other aspects of off-duty 

conduct, domestically and abroad. The USMS’s efforts are consistent with the 

recommendations made in this report. 

Recommendation 4: Disseminate clear, complementary, and comprehensive policy to all 

personnel regarding off-duty conduct, including provisions for employees representing the 

government in other countries. 

Status: Resolved. 

USMS Response: The USMS concurred with this recommendation and stated that 

the USMS will consolidate and enhance existing guidance, and, as necessary, develop 

additional guidance on off-duty conduct while on official travel in foreign countries. The 

resulting policy directive will conform to forthcoming Department guidance on off-duty 

conduct, to include off-duty alcohol consumption, what constitutes notoriously disgraceful 

conduct, solicitation, and firearms use. In addition, the USMS will evaluate whether 

language on off-duty conduct should be added to its existing International Training Policy 

Directive. Collaborative meetings and discussions among affected USMS division will begin 

once the Departmental guidance is in place. 

OIG Analysis: The USMS’s actions are responsive to our recommendation. By April 

30, 2015, please provide copies of any consolidated, enhanced, or additional guidance that 

were issued for off-duty conduct while on official travel in foreign countries or as a result of 

the forthcoming Department guidance on off-duty conduct. 

Recommendation 5: Raise awareness of that policy and how it applies to a variety of 

situations through existing basic law enforcement training, new employee orientation, and 

periodic training throughout employees’ careers. 

Department of Justice 82 

Office of the Inspector General 

Evaluation and Inspections Division
 

 

Status: Resolved. 

USMS Response: The USMS concurred with this recommendation and stated when 

the new policy directive consistent with the Department policy is finalized, USMS divisions 

responsible for developing training modules on conduct and ethics will work collaboratively 

with the Training Division to determine how the new comprehensive policy directive will be 

incorporated into existing basic law enforcement training, new employee orientation, and 

periodic training throughout employees’ careers. 

OIG Analysis: The USMS’s actions are responsive to our recommendation. By April 

30, 2015, please provide copies of the training modules on conduct and ethics that were 

developed as a result of the finalized USMS policy directive. 

Recommendation 6: Reinforce the policy and how to apply it through pre-deployment 

training for employees being sent abroad. 

Status: Resolved. 

USMS Response: The USMS concurred with this recommendation and stated that 

when the new policy directive consistent with the Department policy is finalized, the USMS 

Training Division and divisions with international missions will collaborate to determine the 

best course for applying the new comprehensive policy to pre-deployment training for 

employees being sent abroad. 

OIG Analysis: The USMS’s actions are responsive to our recommendation. By April 

30, 2015, please provide information on how the USMS incorporated its new policy directive 

to its pre-deployment training for employees being sent abroad. 

Department of Justice 83 

Office of the Inspector General 

Evaluation and Inspections Division 
 

 

 

 

 

 

 

Office of the Inspector General 

U.S. Department of Justice 

www.justice.gov/oig 

The Department of Justice Office of the Inspector General 

(DOJ OIG) is a statutorily created independent entity 

whose mission is to detect and deter waste, fraud, 

abuse, and misconduct in the Department of Justice, and 

to promote economy and efficiency in the Department’s 

operations. Information may be reported to the DOJ 

OIG’s hotline at www.justice.gov/oig/hotline or 

(800) 869-4499.