Managing Conflict of Interest - Organisation for Economic Co ...

Implementation and Enforcement Tools 127a matter affecting the Government. An even quicker look at theevidence, though, shows that there was not even a hint of criminalintent in this government official’s actions. He was motivated solelyby charity and was therefore neither criminally nor civilly pursuedunder the COI statutes. While it is not clear whether there wereadministrative sanctions levied, the most likely outcome wouldhave been a requirement that he take additional ethics training tobetter learn the rules.ConclusionIn summary, the statutory scheme in the United States allowsfor flexibility in enforcement that turns primarily on the intent of theparties. As a final word of advice, though, no set of COI rules orlaws, no matter how sophisticated or flexible, serves as a substitutefor common sense in the enforcement of those rules.ADB/OECD Anti-Corruption Initiative for Asia and the Pacific