Igreports

Centra!
Intelligence Agency
Washington, D.C. 20505
5 May2015
Jason Leopold
Reference: F-2015-00039 I 14-cv-19879

Dear Mr. Leopold:
This letter is in response to ym.rr 3 October 2014 Freedom of Information Act (FOIA)
request for the following information for disclosure of the following UNCLASSIFIED reports
from the Central Intelligence Agency Office of Inspector General:
I. Former Agency Officer Alleges Retaliation for Protected Disclosures- ISSUE DATE
MARCH 2013
2. Alleged Violation of CIA-Unique Post Employment Restrictions- ISSUE DATE
FEBRUARY 2013
3. Misuse of Government Systems for Database Searches- ISSUE DATE FEBRUARY
2013
4. Agency Contractor Alleged Reprisal for Whistleblowing- ISSUE DATE FEBRUARY
2013
5. Review of[redacted] Allegations from DOD- ISSUE DATE MAY 2013
6. Alleged Retribution Against Alleged Whistleblower- ISSUE DATE JUNE 2013
7. Alleged Classified Information Leaked to Foreign Army Officials- ISSUE DATE JULY
2013
8. Misuse of Agency Credential by Former (b3) Staff Officer- ISSUE DATE AUGUST
2013
9. Unauthorized Disclosure of Classified Information- ISSUE DATE AUGUST 2013
10. Request for Whistleblower Protection by Former Interrogator- ISSUE DATE AUGUST
2013
11. Counterfeiting of CIA Credentials- ISSUE DATE SEPTEMBER 2013

12. Ethics Violations Involving Film Producers- ISSUE DATE SEPTEMBER 2013
13. Alleged Use of Government Systems to Order Steroids- ISSUE DATE OCTOBER
20!3
14. Alleged War Crimes by Agency Personnel Overseas- ISSUE DATE NOVEMBER
2013
15. Alleged Abuse of Detainees Overseas- ISSUE DATE JANUARY 2014
16. Disclosure of Classified Information by Former D/CIA- ISSUE DATE MARCH 2014
17. Alleged Abuse and Misconduct Overseas- ISSUE DATE MARCH 2014
18. Alleged Misattribution of Detainee Intelligence- ISSUE DATE APRIL 2014
19. Alleged Misconduct by Polygrapher- ISSUE DATE MARCH 2014
20. Theft ofUSG Property: E Bay sale ofNVGs- ISSUE DATE MAY 2014
21. Allegation of Misconduct by Polygrapher- ISSUE DATE MAY 2014
We completed a thorough search for records responsive to your request and located
twenty-three (23) documents which can be released in segregable form with redactions made on
the basis ofFOIA exemptions (b)(!), (b)(3), (b)(5), (b)(6), (b)(7)(b), (b)(7)(c), (b)(7)(e) and
(b)(7)( d). Exemption (b)(3) pertains to Section 6 of the Central Intelligence Agency Act of
1949, as amended, 50 U.S.C. Sec. 3507 (formerly codified at 50 U.S.C. Sec. 403g), noted as
exemption (b)(3)CIAAct on the enclosed documents, and/or Section 102A(i)(l) of the National
Security Act of 1947, as amended, 50 U.S.C. 3024 (fonnerly codified at 50 U.S.C. 403-l(i)(1)),
noted as exemption (b)(3 )N atSecAct on the enclosed documents. Due to the current status of
coordinations of eight (8) of the documents we are unable to produce those at this time. We will,
however, release those to you once all relevant equity holders have completed their reviews.
Because the above-referenced request is a subject of pending litigation in federal court, in
accordance with Agency regulations as set forth at Section 1900.42 of Title 32 of the Code of
Federal Regulations, you are not entitled to appeal this determination administratively.
Sincerely,
lfcLl}~~
Michael Lavergne
Information and Privacy Coordinator
Enclosures
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Inspector General
REPORT OF INVESTIGATION
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I
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(U/IFOUO) ALLEGED VIOLATION OF CIA-UNIQUE POST

EMPLOYMENT RESTRICTIONS
(~)(3) CIAAct
11 February 2013
(b)(3) CIAAct
David B. Buckley
Inspector General
Assistant Inspector General

for Investigations
J Special Agent
c____
(b)(3) CIAAct
NOTICE: The information in this report

is covered by the Privacy Act, 5 U.S.C. S52a,
(b)(3) NatSecAct
[
_
and should be handled accordingly.
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OFFICE OF INSPECTOR GENERAL

INVESTIGATIONS STAFF
REPORT OF INVESTIGATION
ALLEGED VIOLATION OF CIA-UNIQUE
POST-EMPLOYMENT RESTRICTIONS
(U//Ffit1fi)
[ (b)(3) CIAAct
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11 February 2013
(U) SECTION A- SUBJECT

1. (U) FuiiName:C(b)(?)(c)=
(b)(1)
(b)(3) CIAAct
(b )(3) NatSecAct
(b)(7)(c)
(b)(3) NatSecAct
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(U) SECTION B PREDICATION

2. (UIIARJO~ In Septembe(!iliZl_( c )e Office of General Counsel (OGC) refem:d to the
Office oflnsJl(!Ctor General (OIG) allegations thotl
- - - - - -- -
(b)(7)(c) [Wiisengagedinactivitiesinvolving
[(b) ( 7 )(c)
!foreign entities in possible violation ofOpost-employment (b) (7)( c)
restrictions. In the course of i~atinE( b) (7) (c )activities and coo natinJ! concurrent
nv stigationsJ(b)(7)(C)____jOIG developed infonnation that
(b)(7)(c)=
(b )(7)( c)
retired CIA officer, also may have violated post-employment
1
restrictions on advising or representing foreign governments.
(U) SECTION C POTENTIAL VIOLATIONS
(b)(3) CIAAct
(5) Special Rules With Respect to Cenain Relationships with Foreign Governments or Political
Parties Follcwing Separaticlifrom CIA.
(a) (U) Section 402 of the Intelligence Authorization Act for Fiscal Year 1997 requires
the Director of the Central Intelligence Agency (D/CIA) to issue regulations requiring
designated Agency employees to sign written agreements committing not to represent or
advise, for a petiod of three. years after that employee leaves CIA employment, any
foreign govet:nment or foreign political party. Pursuant to starutory authorities, the
D/CIA has delegated to the Associate Deputy Director of the Central Intelligence Agency
(ADD/CIA) responsibility for administering the post-employment restrictions required by
section 402. The ADD/CIA shall report to the D/CIA all actions taken pursuant to
subparagraphs m(5)(e), (k). and (m) below.
(c) (U) Within 30 days after the promulgation of this subparagraph m(5), and by
31 January of each subsequent year, each directorate (including the D/CIA Area) shall
identify those positions within that directorate which are occupied by members of the
Senior Intelligence Service, whose responsibilities require them to maintain "significant
contact... with foreign government officials and it is expected that the contacts will
involve regular or recuning interaction.
(j) (U) Where it appears that a fonner employee may have violated the terms of .his or
her Post-Employment Agreement, the Inspector General will have jurisdiction to
investigate the matter, report his or her findings of fact to the D/CIA, and provide a copy
of that report to the ADD/CIA. In such cases, the ADD/CIA shall review the Inspector
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General's fmdings of fact and request the opinions of the former employee's most recent
Director or Head of Independent Office and the General Counsel.
(k) (U) After consulting with the respective Director or Head of Independent Office and
the General Counsel, if the ADD/CIA concludes that the Post-Employment Agreement
has been violated, the ADD/CIA shall impose any or all of the following sanctions upon
the former employee: (I) a post-employment letter of reprimand, (2) !he foreclosure of
any future CIA contractual or olher relationships wilh !he former employee, (3) a
determination !hat the Agency seeks as a remedy at law !he forfeiture to the U.S. of all
money or Olher consideration received by the former employee !hat is attributable to his
or her violation of the Post-Employment Agreement, and (4) forfeiture of all or any
portion of the Federal retirement benefits to which the former employee olherwise would
be entitled. For purposes of this subsection, !he term "Federal retirement benefits"
includes those benefits provided by the Civil Service Retirement System, the Central
Intelligence Agency Retirement and Disability System, !he Federal Employees'
Retirement System, !he Federal Employees' Retirement System Special Category, and
any successor Federal retirement system !he vested benefits of which are attributable to
the employee's CIAsetvice (but does not include the former employee's own
contributions, earnings on such contribution, or benefits to !he extent !hat they are
attributable to !he employee's own contributions).
(o) (U) The ADD/CIA shall provide !he Director, Office of Security information about
any final decisions made pursuant to subparagraphs m(5)(e), G), (k), or (m) above. The
Director, Office of Security shall maintain a database containing !hat information.
(U) Title 18 USC 207, Restrictions on former officers, employees, and elected officials of the
executive and legislative braches, provides in pertinent part:
(f) Restrictions relating to foreign entities, (I) Any person who is subject to the restrictions in subsections (c), (d), or (e) [applicable to
certain former senior employees of !he executive branch] and who knowingly, wilhin one year
after leaving the position, office, or employment referred to in such subsection(A) represents a foreign entity before any officer or employee of any department or agency
ofe United States wilh !he intent to influence a decision of such officer or employee
in carrying out his or her official duties, or
{B) aids or advises a foreign entity wilh !he intent to influence a decision of any officer or
employee of any department or agency of !he United States, in carrying out his or her
official duties,
(b )(7)( c)
(C) shall be punished as provided in section 216 of this title.
(b )(7)( c)
3. (U/@JOO) InC] !he year ofC}ermination of CIA employment, !he foreign
entity restrictions in 18 U.S.C. 207(f) applied to senior employees whose base pay, including
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locality pay, exceeded $140,216.50. (See generally 5 CFR 2641.104, defining "senior
employee" for purpose of 18 U.S.C. 207.) Accordiugly,CJas subject to the 207(f)
restrictions based on[)al~ at the time of[}etirement, $149,241.37.
.
(b)(7)(c)
(b )(7)( c)
4. (Uifi'Otl'O) OIG made a preliminary presentation of lhe facts concerning c:.Jto lhe
Department of Justice Public Integrity Section (DOJ/PIS) as a possible violation of 18 U.S.C.
207(f). DOJ/PIS consulted with lhe Offlce of Legal Counsel and the Office of Government
Ethicsaboutthematter. On _(b)(7)(c)
DOJ/PISdeclinedtoo nacriminalcasea ainst
(b_J_(?_J(_c_)_ ____j DOJ/PIS noted lhat "the fact lhat

the experienced and informed attorneys from [Office of Legal Counsel] and [Office of
Government Ethics] did not have a clear answer to lhe question posed in this case (nor did we),
precludes us from putting togelher a criminal case on these facts." Therefore, this report focuses
only on lhe alleged violation of the Section 402 post-employment restrictions.
L__ _ _ _ _ _ _ _ _ _ _
(U) SECTION D -INVESTIGATIVE FINDINGS

(U) BACKGROUND
5. (UI/EDOO) I
(b)(?)(c)
occupied a position subject to lhe regulatory post-employment agreement required by Congress
(b) (7) (c) in Section 402 of lhe Intelligence Authorization Act of 1997 and incorporated in L( b)( 3) C IAAct
c_---~-~~- signed a post-employment agreement not to represent or advise lhe
government of any foreign county or any political party of any foreign country, as defined in
'od immediate! followin
se
lion.
18 U.S.C. 207(f)(3) for the three ear calendar
(b)(7)(c)
(U) ETHICS ADVICE PROVIDED
(b)(7)(c)
7. (U) The CIA/OGC Ethics Counsel advised

of these restrictions in two hand(b)(?)(c) delivered letters datedC(b)(7)(c)
]and
(Exhibits_8. C) In the
c__ _ _ _ Ietter,theOGCethicscounselinfo
atthe
b)(7 c) letter (b)(?)( )
previousletterdatedL(b)(7)(c)=:::Jandwasintendedtoassist _ . n
c
understandin ... post-employment restrictions. Bolh letters advised that there is no "safeharbor" for "behind-lhe-scenes" assistance under 18 U.S.C. 207(f) or Section 402. They
further advised that the Section 402 ban on representing or advising "does not require the
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rendering of aid or advice with the intent to influence the US Government, but applies absent any
US interest or involvement in the matter at issue."
Regarding the Section 402 restriction, the OGC Ethics Counsel wrote one___ _ _ __
(b )(7)( c)
A former employee subject to this restriction would be prohibited from working for a
foreign government in any"capacity, including as an employee or contractor. Further,
regardless of whether the former employee worked directly for the foreign government,
he would be barred from "representing" a foreign government on any matter. The former-'
employee could, however, work for a consultant that advises a foreign government, and
even interact directly with the foreign government so long as the subject of the
consultation was not related to any ~r within the scope of his government
employment. The former employee also could sell goods for his new employer directly
to a foreign government, and provide advice on how to use a product, so long as the "
advice was not related to any matter within the ~ of his government employment.
The Feb!Wli)' letter continued:
(b)(7)(c)
"As you discussed with [CIA Senior Deputy Counsel] Joho Rizzo during our '----c-~
meeting, a "matter" means any particular matter with specific parties, such as a contract.
Therefore, you will not be considered to be in violation of this restriction if you are
rendering advice to a foreign government in connection with a sale of goods and services
and that advice does not intersect with any matter, including any contract, with which you
were involved as a government employee.
(b)(7)(c)
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10. (U) Concerning interaction with[ . --- . . . __ _I the OGC Ethics Counsel advised
that, so long asllcompletely avoids any discussion of matters involving the United
'-;S"'ta:-cles--'Qould not vlolate 18 U.S.C. 207(1). However, if[]aided or advised [
ren
behind-the-scenes, on a matter involving CIA or the rest of the United States Government.O
would be in violation of 18 U.S.C. 207(1). As to Section 402, the OGC Ethics Counsel advised
that
interaction witl1
[in the course of selling
goods and services 1vould
not violate Section 402 unless there is some intersection with a particular matter on which0
worked while a CIA employee.
(U) [ (b )(7)( c)-'rOST-EMPWYMENT ACTIVITIES INVOLVING FOREIGN
ENTITIES
(U) Overview
(b)(?)(c)
11. (U) The OIG investigation found thatJifrequently interacted with,---~

representatives of-foreign--governments -in a -busin~elopment role-- inciu~~,..---_j
[
[- in the months following[___FIA
retirement.
(b)(?)(c)
(b )(7)( d)
(b)(?)(c)
SllRffi'
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(b )(7)( c)
(b)(7)(c), _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __i
(b )(7)( d)
(U)I
16.
!said tha!nmade an effort to understand the applicable rules and
regulations, and to the best oflJknowi~.Owas in compliance with all oC}ost(b )(7)( c)
employment restrictions.
added thatUnever had any intention of violating or circumventing
the restrictions.
(b )(7)( c)
(b )(7)( d)
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(b)(7)(c)
(b )(7)( d)
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(b)(?)(c)
(b )(7)( d)
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(U) SECTION 5- RECOMMENDATION

(b)(3) CJAAct
[ the ADD (now titled Executive Director)
28. (U/~) Pursuant to[
should review the fmdings in this Report of lrivesttgation and seek the opinions of the Director,
National Clandestine Service (DINCS), and the General Counsel to determine wheth~ (b)(7)(c)
violated the terms oQpost-employment agreement. If the Executive Director, in consultation
with the D/NCS and the General Counsel, concludes thatc::::=JviolatedC}ost-emp~nt
agreement, the Executive Director should determine the appropriate sanctions againstL__J
consistent with[ (b )(3) CJAActnd report the results to the Acting Director, CIA._
(b)(3) CIAAct
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(U) SECTION 6- EXIDBITS
A. Post-Employment Agreement dated L(b)(?)(c1
B. Letter dated L(b)(7)(c)=from CIA OGC to~garding post-employment
restrictions
(b)(7)(c)
c.
Leru;r ~L(b)(?)(c)~ from CIA OGC t(b)(7)(c[..,garding post-employment

restncttons
D.l (b)(?)( c) Iemail exchange between OGC attorneys regarding oral infonnation provided
toj
(b)(7)(c)
]
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POST-EMPLOYMENT AGREEMENT
An Agreament
BetW1Ktn
j._-_(_bJ_(?_J_(c_J_ _ _-_--___,--[ and
the United
states.
1. Intending to be legally bound, and in consideration
of my continued service in the position that I now occupy
("llllr position") for the Central Intelligence Agency. ("CIA"),
I accept the obligations contained in this Ag~t. I
understand and accept th&t service in my position imposes
upon ma certain obligations, including the obligation not to
per.mit an'actual or potential conflict of interest or the
appearance of any actual or potential conflict of interest
to arise between the responsibilities of my poaition and llllr
relationships with certain foreign entities following my
separation from CIA.
2. I understand and agree that for the three-year
calendar periOd illlll8diately following my separation from CIA
employment I will not represent or advise the governmant or
any political party of any foreign country, as defined in
18 u.s.c. 207(f)(3). I further understand that I will not
be subject to this restriction on my post~loymant
activities if I occupy a position that has not bean
designated as being subject to these post-employment
restrictions for a period of three years or more prior to my
separation from CIA employment.
3.
I understand and.agree thst should I violate this

CIA may i111p0se upon me any or all of the
following sanctions:
(i) a post-employment letter of
Ag~nt;
reprimand, (ii) the f'oracl.osu.re of any future CIA

contractual or other reiationships with me, (iii) a
deter.mination that the Agency seeks as a r&nedy at law the

forfeiture to the United States of all money or other
consideration received by me that is attributable to my
violation of the Post-~loyment Agreement, and
(iv) forfeiture of all or any portion of the Federal
retirement benefits to which I would otherwise be entitled.
For purposes of this subsection, the term "Federal
retir8lllent benefits" includes those ben~its provided by the
Civil Service RetirGIIIent System, .the Central Intelligence
Agency Retirement and Disability System, the Federal
Employees Retirement System, the Federal Employees
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Retir1M118nt Sys~ Special category, social security benefits

based on federal employment, and any suce&asor Federal
retiremant sys~ the vested benefits of which are
attributable tc the employee's CIA service (but does not
include the former employee's own contributions, earnings on
such contributions, or b&nefi ts to the extant that they are
attributable to the employee's own contributions).
4 . I understand and agree that I may obtain a waiver of
enforcement of this Agreement in a specific instance or a
relea- from this Agr.........,t, only by written request and in
accordance with the regulations and procedures set forth by
CIA. Such a waiver or release shall be effective only if it
is in writing, signed by the Executive Director. I further
understand and agree that there is no obligation upon CIA to
grant U1IJl request for such a waiver or release, that any such
waiver or releaee if graJited must be in writing, and that,
unless and until such time as a waiver or release is granted
or if no such waiver or release is granted, I remain subject
to all of the te.rms of this Agreement.
5. I understand that U.S. Government may apply for a
court order enjoining me fran engaging ill any activities,
actual or reasonably anticipated, in violation of this
Agreement. I have been advised that such an action may be
brought against me in any of the several Ullited States
District Courts where the Ullited States Government may elect
to file the action and that court costs and reasonable
attcrnays fees incurred by the United States Government may
be assessed against me if I lose such an action.
6.
I understand that each provision of this Agreement is
severab~e,
and
that
1~
a court should find any provieion of
this Agr......,nt to be unenforceable, all the other provisions

of this Agreement shall remain in full force and effect.
This Agreement relates solely to certain of II specific
responsibilities and does not set forth any of the other
conditions or obligations that may now or hereafter pertain
to my employment by or assignment or relationship with CIA.
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.,;:
(b)(7)(c)
[(b)(7)(c)
-]
Date
(b )(6)
[(b)(7)(c)
Signature of CIA Representative
,,
Date
'
"
,_ .'1-
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CENTRAI.INTB..UGENCE AGENCY
WAIHINQTON. D.C. JOIJOt
(b)(7)(c)"]
VXA RAND DBLIVBRY
You intoed to termdnate your employment vith the Central

Intelligence Agency (AgRey) and haw requested written guidance
ccnce=ing l::ll& poatemployment rutrictions applicable to you.
Aa you are aware, a former tedezoal government employee baa
restrictions placed upon his poet-employment activitiea by both
statute and regulati~, .Ad violationa o! tbaae reatrictiona may
result" in criminal aDd civil pRAlUea. This letter ia intocded
to aaoiat you in undaratandiag the restrictions. I! queation.o
arise aa to the applicability o! tba restrictions to a
partict.a.ar aet of cireumat&.tlQea, please do not .buitate , to
cOntact me for a specific Opinion ~sed upon those facts,
You have .completed the Poet-Government Bmployment Bthico
Questionnaire dated I_______
____lam! 11rov;c!ed ~it~oDAl
information to '"" durtng our meeting on [
I I
have uaed the intomation provided. by you as the basis for the
conclusions in thia letter, The advice provided below is baaed
on the assumption the following facts are true~
You will terminate emplO)'IIIent with the Agency anD
f---------__r---" Sel!_:IJ!.t:
JntelUg~cJ>.:__$.l!lmc_e_of!ic.,;:.___ _
(b)(7)(c)
----------------------
(b)(7)(c)
(b)(7)(c)
(b)(7)(c)
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(b)(7)(c)
You will not receive a caah incentive to aeparate from

the Agency. Acco~ly, you will not b6 oubject to t.he
reatrictioaa impoaed by the CIA Voluntary Separation Pay
Act.
You will be subject to the post-employment restriction

contained in
o2 ot th 1997 Intelligence Authorization
Act.
You did have peraonal and subatantial invol~nt in

goverament contracts during your government career.
You were not involved in any Agency procurltllent in exceas

of $10 million.during your last year of governmeQt
%Vice; Tber.ef"ox:e:, .on the baeia ot your
repre118.ntii.tiona, .I .ha.ve eonc.l~ that you are not
aubj act ~o th& oae,year cCIIIIpeD.O&tion ban l.mpoaed by the
l'rQ<::uremallt Integrity Act.
You did liOt engage in.trade 8lld treaty negoti&tiOIIS aa an

.Agency employee, and, accordingly, will not be subject to
the restrictiOIIS of 18
u:s.c.
207 (b).
'
If II understellding of your employment history is incorrect and
one of the above tatements is nOt true# the advice provided in
this lett:er may:not be acct.irate and cannot be relied upon.
Should mY Unae~:atimditig of the facts be in error~ please contact
me for additional advice baeed.upon corrected information.

You arealll>ject to the peat-employment reatrictiono
a...-rizsd below. A detailed diacu88ion o! each o! these
restrictions !ollowa.
B\!B!ar\j d
oata!!lplor--t Reatriatiou
l . rou :ue baz:-:1:'~ pez:m&Aea.t:ly :from rep:. .enting' anyona

(othe:r: tb.ur t.be -us :Gov~t) JMfore anr o!fio:Lal or agency of
the -tJS Gove:nuMDt cc;mcC"D.ing .~ particular matter in which
you were pe:r:ou.a~ly aDd IIUbtaDt.ially in"'I'Qlved aa a federal
employ.e.
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(b)(7)(c)~
2. You ...-. barred for t1oo yearo from repreoontiDg anycma
(other than tb 08 Gove~t) befor any official or agency _of
the . tJS OovrDJ~eD.t cumcendng any partioular matter that were
actually pen41Dg. UDder your official reeponoibility duriDg ycur
lat year ot govera.ent exTioe.

3. You are b'""""iS for ooe year .after l~atioo fr<a
(b)(7)(c)
makLDq any caa.auication or appearance beforeiL-----~~~~--~--~
~he C1111tral Xlltelligqoa Agqoy Meldng official action

on behalf of a ~r<l party.
4. You ue ~ fOr one year aftr sepuatiou. from the

A9"1111Cy froa repraa ...tia.g, aiclia.g or advioia.g a foreign eDtity
with t;he ~.nt...t to l.nflu...ae the tlllitad Stataa.
S.
You ar b&rrad. fraa reprenting' or adviing a foreign

or foriSD politioal party for thr years aLter
aGparating f~ th Aganey.
go~t
n.tailad Diocu.aion of POit!!ployaont Reotrictiooo
Permapent !!preaeutataoa. Ban. A federal employee ia

permanently barred fr0111 representing anyone (other than the VS
Government) before any official or agency of ttuovs Govermuent
concerning any particular matter involving a specific party or
parties in which the employee was paraoaally and substantially
involved u a faderal employee. 18 u.s.c.
307(a) (1). Thia
criminal statute is called the ~switchiag sides~ or ~revolving
dOor statute.
The moat caanon example of a particUlar matter under the

statute would be a contract or a proposal for a co~tract. A
particular matter also would include a renewal, extension, or
modification of a contract. The prohibition further requires
that a sP.cific party or parties' be involved at the time of
employee a _involvement. General rulemaking usually does not
involve a aPecificp&rty or parties; contracts always involve
apecitic parties.
~o participate personally' generally means to participate
di~ectly, although an employee can participate pereocally- even
tllaugh he merely direota a subordinate's participation.
To
C06299587
(b)(~)( c)~
participate substantially means that the employee's

involvement muat have been of ignificance to the me.tter, or
form'a basis tor a reasonable appearance of significance.

Personal and substantialw involVement with a contract would
include action through decision, approval, disapproval,
recommendation, investigation, or the rendering of adVice in a
particular matter. P'urther, personal and substantial
involvement incltJdea both formal roles in the administration of
a contract, auch aa a COTR or approving contracts, as well as
more intormal rolea, aucb as supervising a contractor employee

or giving award tee input.
All communications and. appearances made on behalf Of a
third party with the intent to influence the federal government
are prohibited by the rep:i-eaentational ban. The ban, however,
c1oes not prohibit limited behind-the-scenes involvement on the
part of the former gover.ament employee in connection with the
repreaentation__ of_ a t_hird partv. _AdditionallY:- the ban doee- not
prOhibit former employee-from representing him or herselr {~s
distinguished from a corporation or consulting firm) betore"the

federal governrneta.t, B, for iaatanoe, an independent contractor.
To the extent that :You were personally and substantially
involved in a partiCUlar matter, including a contract, you will
be permanently banned !rom representing a third party on that
contract .
. 'l'worar !!!!rea...taticm BaD. ror two years after h~o

government employment ends, a former employe may not represent
.anyone (other than tbe US Government} before any official or
agency of the OS ~rnment concerning any particular matter
that the former employee knows or reasonably, should know was
pending under his official responsibility during the last year
of his government employment. 18 !J.S.C.
207 (a) (2). This ban
is identical to the permanent representational restriction
except that it. is of lhorter duration and requires only that the
former employee .have had
otficia~
reaponsibilityfor a matter
during -his last yeax- of government service, not that he.

participated paroaaUy and W>tantielly in that mat_ter.
A matter -.a actually pending l.Ulder a. former employee!&
official reaponsibil~ty if. the matter was in tact referred to or
Approved for Release: 2015/05/05 C062995"'8.._7_ _ _ _ _ _ _ _ _ _ _ __
C06299587
-----------------------(b)(7)(c)~
UDder consideration by peraona within the emplQYee'e area of
reaponoi~ility.
Tbio rootrictioa doeo not apply unleoo at the
time of the. proposed representation of another he knows or
reasonably should know that th~ matter had been under hia
reponaibility during the lat year_of Agency service.
A8 with the- permanent ban, the reatriction applies to

communications ~ appearances on behalf of & third party that
are made with the intent to influence the federal government,
but does not prohibit ..behind-the-scenes"' activities. Unl.ike
the permanent .ba.n, however, an employee's reeusal or lack ot
partidipation in a matter does not remove it from hi official
reeponaibility.
To the extant that you were not personally and
substantially involved in a particular matter, but that =atter
tell under your official responsibility during your last year of
gov.ernmene service, you will be- subject to this- two-year ban on
that matter.
OU. Year CooliDgOff Period. 18 U.S.C. 5 207(c) imposea
additional.reatrictiona on senior intelligence officers earning
over $136,757 in b&ae pay (which after 11 July-2004 includeo
lOcality pay), and, u your b&se pay will exceed the threshold
when you separate 1 you will be subject to this one-year
restriction following your separation from the Agency. Former
senior employees subject. to Section 207 (c) are prohibited for
one year after separation frgm making !EX communication or
appearance on behalf of a third party before the Central
Intelligence Agency or any federal agency in which the former
employee served in any capacity during his last year of
government service seeking official action. Like the permanent
and two-year restrictions discussed aboVe, this provision does
not prohibit behind-the acenea assistance to a third party.
The restriction, however, doee not require the former senior
employee to have ever been officially involved in the matt~r
that ia tho aubjoct of the COimllWlicat.ion or appearance.
Unlike the permanent and two-year reatrictioDS, the prohibition

applies only to the federal agency or agencies in which the
former emplOyee served in any capacity during his last year of
government service. In. your Case, Y,!2U will be barred from----,
represent.ing any third party before

the Central Intelligence Agency.
(b )(7)( c) _ _-"
C06299587
Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _ _..__ __
[(b)(7)(c)
An opinion iaauod loy the Office of IAtgal Counael, us.

Department of J\llltice (OLC) ,. .determined the conduct of a former
aenior employee would fall outide ot permi&.ible behind-the
scenea aaaiatance if the former offi~ial intended that
intormatioa. or viewa conveyed to bia tonaer agency by a third
party be attrilouted to him. The OLC opinion liata several
- l e a o! tho type of indirect communication that noay be
considered representing, including wben a high-ranking
official aggressively publicizoa the fact that he is starting a
one-man COllBUltiDg' fim, then aubt'Dits a i8port to the agea.cy
shortly thereafter under the name of that firm.
'l'he lhani.J:Lg of. ll!preentatiou. The m.eaning ot the term
.in the context of the three repreeentational bans

diacuaaed &Oove ia very broad. "'Representing" inc:ltldea all
cotnn~;unica.tione and appearance- made- -on behalf of third party
~ith the intent to influence the federal government.
It is not
limited to lolobyins or repreeentins a third party Oft contract
nagotiatiou, tor example. Rep:r-eeutation need not beon behalf
~preeenting
of the original contractor and can include virtually any
int~raction witb other federal ea>ployeea on loehalf of privat~

employer or individu.iil. tt, for instance, as a representative
ot your llAIW employer, ycu attend a meeting with any part of the
united States Government during which a particular matter in
which you were personally and substantially involved is
cUacuased. and you Offer your .opinion on the ma.tter ;. you would be
considered to be .. representing your employer. This would be a
viOlation of the crimic&l statute.
None of these representational bans prohibit behind-the

scenes involvement in a particular matter. This safe harbor
allows you to use your expertise and knowledge, but not your
influence. As noted above, bowever,. condu9t _falls outside .the
scope of permissible -bebind~thescenes involvement if, fOr
instance, a tormer govercment. official intends that information
conveyed to the federal government by a thi;d'party be
attrilouted to him. In other worcls, ycu cannot ahield youraelf

from criminal liability loy interacting with government officials
through a third party, including through a business .a.asocia.te,
if you intend that t~e information be attributed to you.
C06299587
----------------------c(b)(7)(c)
C06299587-----------~
ro...ip btlty a . . tdctiOIIII. 18 u.s.c. I 201(fl reatricta

former aenior employee whose bau pay (Which after 11 JUly 2004
includes locality pay) ia over $136,157 tot one year after
oeparation from the Agency fro~~~ representing, aiding or adviaing
a foreign entity with the intent to influence the Ollited States ..
A foreign entity is defined as a foreign government or foreign
political party. A foreign government includes any parson or
group' ot pet"ons exerciaing aOvereign de facto or de jure
political juriadiction over any ccuntry, other then the onited
States, or any part ot: such countrY. It also inoludas any
subdivision of a group and any grou.p or agency to which
sovereign de facto .or de jure authOrity~r functions are
directly or indirectly del-sated. The term also iDcludee any .
faction or body of . ineurgenta within a country aaauming to
exercise governmental authority, whether such faction or body of

insurgents has or heo not been recognized by the united States.
A foreign commercial coxporation will not generally be
considered -a foreign -ea.t-ity-- for- P'..t-""Posee- ot 18 u.s.c. I 207 (_f)

unleaa it exe"rciaes the functions of a aovereign. There is no.
safe harbor for behindthe-acenea" aaai1tance un4er 18 u.s.c.
207 (f)'
Section 402 TbreeYear PoatB!plgy!!At !qreement. Your
former position!
is a
designated position subject to the three-year post-employment
ag~eeatent required by Congress in Section 402 ot the
Intelligence Authorization Act of 1997. 50 u.s.c. 5 4034 nt.

PUrsuant. to this Act, you have 1igned an ag~eement with the
Agency that prohibits you from representing or advising a
foreign government or foreign political party for three years
after leaving employment at the Agency. (Because you held this
designated position within tbree years of leaving government
service, you will be subject to this restriction upon your
departure, even though you no longer hold this position.) "This
ban does not require the rendering of.aid or advice ~ith the
intent of influencing the U.S. Government, but applies absent
any U.S. interest cr involvement in tho matter at isauo. 'l'here
ia no aate barbol:' for behina-ehe-sCenes" a.aaistanao under
Section 402.
You hae &&ked for detailed advice- on this prohibition,

specifie&lly whether it applies when a cove:red torlDEir _emplOyee
ia selling goods or services to, but not working directly for, a
(b)(?)(c)
C06299587
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-----------------c(b)(7)(c)
foreign government. A former APloyeo aubject to this

reatrioHon would be ..prohibited from working for a foreign
government in. any capacity, including aa an employee or.a
contractor. . l'urtb.er, regakdleaa
ot whether the former employee
worked directly for the foreign goVernment, he would be barred

from representing" a. foreign government on any matter.. . (The .
broad 1Maning~ot tapreaentat.ion" diacuasec1 above would. apply.)
'I11.e former employee could., however, work for a consultant that
advises a ~oreign government, and even interact directly with
the foreign government, so long as the subi ect of the
consultation was not. related to. any matter Within the scope of
hi& government employment.
The former employee also could sell
good,e for his new employer directly to a foreign government, and_
provide advice on
~ow ~o
use a produCt, so long as the advice
was nOt related to any matter .within the scope of his government
eraployment:.
oreign Agent. Regi1tratioa Act ot_ 1938
Although you currently do not anticipate working for

foreign governmento, pelitical psrti or companies, you should
familiarize yourself with the requirement& of tho Foreign Agent
Regiatration Act of 1938 (PARA), 22 u.s.c.
601 et eeq., if you
wish to ""!>lore tllia po88ibility in the future. PARA require& a
person to register aa ,an agent ot a toreign principal" when be
or she a~ts at the order, request or under the direct control .of
a foreign. principal and engages in certain types of activities.
l'oreign princi~la include foreign .governments, and
partner.ship8, cisS"ocia.t:iona, corporations, organizations, or .
other combinations of persona organized under .th law or baving

their princi9a1 place of business -in a foreign country.
PARA bas a v~ry broad scope and you should ensure that you
comply with it"s-.registration requirements unless your activities
aro exempt frOm the Act. The Office of General counsel doesnot
make determinations concerning the applicability of tho Act.
Inquiries regarding FARA should be addresaed to: Foreign Aget~ta
Regiutr&tion uni~, U.S. Department of Justice, 1400 New York
Avenue, N:w., Room 9300, Washington, D.C. 20530. The unit's
telephone number ia 2025U1216; the fax number is 202514-
2836.
C06299587
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----------~------------
-(b)(7)(c)-
I hope that you will tiDdthe guidance contained in this

letter help!ul a1 you begin your new c:aree~. Please remember
that this letteroDly summarizes the relevant atatutOry
provisiona. The provisions must be applied to epeeitic facta on
a case-by-ca8e baaia to determine it particular circumstances
fall within .the acope of the reatrictiona. Pleaae contact me if
you have any additional questions or eoncerna. I can be. reached
atL
~
(b)(3) CIAAct
Sincerely,
(b)(3) CIAAct
Bthioa Counsel
C06299587
------- ----Approved for Release: 2015/05/05 C06299587-------------.
C06299587
------------------------CENTRALINTaUGENCE AGENCY
WAll !IemaN, D.C. 10101
VIA HAND DBLIVBRY
(b)(7)(c)
oear[(b )(7)( c)], .

You intea4 to terminate your employment with the Central
Intelligence .Agency (.Agency) and have requested written guidance
concerning the post-employment restrictions appiicabla to you.
Ius you are aware, a former federal government employee has
restrictions placed upon his post-employment activitiea by both
statute and regulation, and violations of these restrictions may
result in criminal and civil panaltiea. This latter supersedes
my previous letter of I
land ia intended to asSist
you in Wl.ders'tauding the 'reatrict.ioos. If questions arise aa to
the applicabil.ity Ot' tbe restrictions to a particular set o'f
(b)(7)(c)
circumetancea, please do nOt hea!tate to contact me !or a

specific op~on based upon those facts.
(b)(7)(c)
You have completed the Post-Government Bmployment Bthica

(b)(7)(c)
Questionnaire dated
provided adclitionel
information to me during our meeting on
and
(b)(7)(c)
during our meeti~ with John Ri:zo, Acting Gen~ral counael, on
I
I I have uaed the information provided by you aa
the basis for the concluaiona in this letter. The oclvice
provJ.ded below is baeed on the aaawapt.ioo the following f'acts
are trues
(b)(7)(c)
will te.minate employment with the .Agency on

aa a Senior rntelligence Service ottioer.
L,Y"o"'uc-co-cr-.igccine=-ll-y_.jaeparated from tho Agency o~l
You
.:==J
C06299587
Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _ _ _ _ _ __
(b)(?)(c)
(b)(?)(c)
t
.
You will not receive a oaah incentive to separate from

the Agency. Accordingly, you will not be oubject to the
reetrictiona imposed by tho CIA Voluntary Separation Pay
Act.
You will be subject to the post-employment restriction

contained in 402 of tbe ~997 Intelligence Authorization
Act~ That three-year reetriction b~a.n to zi.m on D
th~
date of your first separation from the
Agency.
You did have personal and subetantial involvement in

government conttaot during your government career.
You were not iuvolved. in any Agency procure11ant in excess

of $10 million during your laat year of government
service. TherOfore, on the a-is of your
repreaentation., I baVe donc:lu.ded that you are not
subject to the one-year compeM&tion ban imposed hy the
Procurement Integrity Act.
You did not engage in trade and treaty
negotiati~
as an
Agency emplo:.eee, and, accordingly, will not be subject to
the restrictions. of 18 u.s.c.
207 {b).
I f my underatan:ding of your employment history is incorrect and

one of the above statements is not true, the advice provided in
this letter may not be accurate and cannot be relied upon.
Should my underotanding o~ the fActs be in error, plo. . e contact
me tor additional. advice baaed upon corrected ifttormation.

You are eubjec.t to the poot-emplO}'IUent restrictione
summarized below. A detailed.diacusaion of eaCh of these
reatrictioaa.foll~.
(b)(?)(c)
C06299587
Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _ _ _ _ _~
(b)(7)(c)l
1.. You ar8 harr.c! pez:maiumtly t:roa repraeutiag ayone

(other than the t7S QoveZ1Uil8Dt) before any official or. agency o~
the trs Gcrnnuaea.t cono:erniDg those particular mattez:oa in which
you were pronally and ubatantially involv.d aa a federal
employee.
2 . You are barred for two yeara from repr.n.ting a:a.yone

(other than _the US -~eram~t) before aay offigial or agency o~
tlM 118 ~t aoacerning any particular matter that ware
actually pending under your official reoponoihility during your
year of goverument aervice.
laa~
3 l'o~ az-e barred foi one year after P:ration f"*l

aaJdng any CO"'Ittn:lcatiob or appearance before _L__=~~o-c-c-.--~
(b)(7)(c)
ltl!.
C:C.tr&l :tnt.alligonca Aganay oeold;ng ofticia:L aatic>n

ou behalf of a t!Urd party.
4.
Yo~
u barred for one year. after eparatioD from the
Jl4lenay !J:'CIIl :r:ep.....ntil>g, aiding or aclviliDg a !o:r:aign - t i ty

with tha intent to influenoa tha united Stat...
5.
You ....
;ove~t
u ..ae
barr"'-
froaa repr...,.tiDg or aclvioiDg a "foreign
or foreign political party for three
oep&:r:attcm froa
tl!.
Aganay on 1
Year~
after your
Datatl&d Diocudon of Pootl!!Pl!?)nD!Dt a.striationo
Perm.u.eat R'Preaea.tatf.oa. BaD. A fede.t'al employee is

permanently barred tr<IOI rep..eaenting anyone (othe.- than. the US
Government) hefo:r:<l any official or agency ot the us Govermnent
concerning any pttticular matter involving a specific party or
parties in which the employee waa personally and substantially
involved as afederal eployee. 18 u.s.c.
207 (a) (1). This
criminal statute is called the switching sides or revolving
door"' aca~ute,
The DIQat common exampl.e ot a particular matter" under the
atatute would be a: contraceor a
~ropoaal
for a contract.
"'particular matter .alo would iaclude & renewal, extension, or

tnodi.fica.tion of a contract. The prohibition further requires
(b){l)(c)
C06299587
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C<b)(7)(c)
that a specific party or partiea be involved at the time of
employee' a invo;Lvement.
oenera.l rulemaking uaually does not
involve a speci~iC party or p.rties; cOntract& always involve

specific partiea,
To participate personally generally means to participate
directly, although an employee can participate personallY" even
though he merely -directa a aubordinate' participation. To
-ubatanti&ll~ means that the employee's
involvement must have been of significance to the matter, or
participate
form a baeis tor &'reasonable appearance ot significance.

Personal and aubetantial involvement with a contract would
include action through decision, approval, diaapproval,
rec:ommen~tion_, investigation, or the reD.dering ot advice in a
particular matter.
Purther, pereonal and. substantial
involvement iricludea bo~ formal roles in the administration of

a contract, auc:h. as a COTR or appi"QY'ing contracts, as well &e
l'ii:Ore intormal roles, auch as aupervisi.J:l.g a contractor employee
or giving award fee input.
All communications and appearances made on behalf of a

third pany with tile intent to influence the federal government
are prohibited by the repreent&tiocilll ban.
Tbe ))a.n, however,
does not prohibit limited 'behiDdthe-acenea invol'<i11111Snt on the

part of ths former government eaployee in connection with the
repreaentation of a third party. Additionally, the ban does not
prohibit a former employee frgm representing him or heraelf tas
diatin9uiahed from a corporation or consulting firm) before' the
federal Sovernment, aa, for instance, aD independent contractor.
To the extent that you were personally and substantially
involved in a pa~~icular matter, including a contract, you will
be permanently banned from repreaenting a third party on that
cont:r_act.
Twoxear Repre1ea.tation Ban.
P'or two yeara after hie
government employment enda, a former employee may not represent

anyone (other
~-
tbe OS GovernmeAt) before
~y
ott1cial or
ageilcy of the US Gov.naaea.t coacexning any pa.rtiaular u.tter
that the fo~er employee kDova or reas~bly should. know was

pending under his offiCial responsibility during the last year
of his gov.,rnment employment.
18 tJ,S.c ..
~07(a) (~)
. .This
ban
is identical to the peX'l'Ganent representatiQna.l restriction
C06299587
8lCCept that it ia of shorter duration and requires only that the

former employee have had official responsibility tor a matter
during hi8 laet yoar of government aarvice, not that he
participated personally and substantially in that m&tter.
A matter waa actually pending under a tormer employee's
official re8p0118ibility if the matter was in fact referred to or
under consideration by persona within the employee's area of

responsibil~ty.
This restriction doea .not apply unless at the
time ot the propoSed repreeentation of another he knows or
reasonably shou1d know that the matter bad been under his
reeponsibility during the last year of Agency eervice.
As with the permanent ban, the restriction applie tO
communicatione and appearances on behalf of a third party that
are made with the intent to influence the federal. government,
but does .not prohibit behincl-the .. scenea activities. ~ike

tM pe~ent ban, however, an. employ8o' s recu-Bal or lack of
participation in a matter does not remove it from his official
responsibility.
To the extent that you ware not personally and
substantially involved in a particular matter, but that matter
fell under your official responsibility during your last year of
govertlJAeDt ervice, you Will be ubj ect to this two-year ban on
that matter.
One Year Cooli.Ds-o!f Period. 18 o.s .c. ! 207 (e) imposes
additional restriction& on senior intelligence officers earning
over $140,216.50 in base pay (which after 11 July 200 includeo
locality pay) , and, aa your baae pay will 8lCCeed the threshold
wnen you separate, you will be subject to this one-year
restriction following your aeparation from the Agency. Former
senior employees subject to Section 207(c) are prohibited for
one year after aeparation from making !nl communication or
appearance on behalf of a third party before the Central
Intelligence Agency or any federal agency in which the former
employee rved in any capacity durLag hie laet yea ot
government; service aeek~ng official action. Like the permane.nt

and two-year restrictions discussed above, this provision does
not prohibit "behind tb:e scenes assistance to a third party.
The restriction, however, d.oee not require the former senior
employee to. have ever been officially involved in the matter
that is .the sUbject of the COIIIIIUIDication or appearance.
5
C06299587
(b )(7)( c)
unlike the permanent and two-year restrictions, the prohibition
appliel only to. the federal agency or ageDciea in w~eh the
tormer employeoaerved in any capacity during hie laet year ot
govertUt~.tmt service. In your c&1e, ~u will be barred !rom
repreaenting any tbird party beforo[
(b)(7)(c)
the Central Intelltgance Agency. L----------------~~~~~
AD opi.Jtlon issued by the Office of Legal COUnsel, us

Department of. Jllstice .CoLe),: deter1ilined the COII<Iuc:t of a former
senioremployee would fall outide of.permissible behind-thescenes assistance if the former official intended that
intormation.orv.iewa ~onveyed. to his former agency by a third
party be attributed to him. The OLC opinion lilts several
examples of tba typa of indirect co=nunication that may be
considered representing, including when a high-ranking
official aggressively publicizes the fact that he is starting a
one.-man conaulti119 firm.,. then ttUbndte a report to the -agency
shortly thereafter under the name of that tirm.
n. X.aning of aeprentatton The meaning of the term

1lreprese.nting in the <:Oiltext of the three representational bans
discussed above is very broad. Representing includes' all
communications and appearances made on behalf of ~ third party
,.ith .the intent to influence the federal government. It is aot
limited to lobbying or representing a third party on contract
negotiaticna, for example. Rspreaentation need not be on behalf
of the original contractor and can include virtually any
interaction witb otbar federal employees on behalf of a private
emploYer or individual. It, t.Or ina.tance~ as a representative
of your n- employer, you attend a meeting with any part of tba
~ted States Government during whieh a particular matter in
which you.were.peraonally and substantially involved is
diacuased .and you offer your opinion on the matter, you would be
conaid,red to bB representing-: your employer. Tbia would be a
violation of the criminslatatute.
w
None of these representational hsna prohibit behind-thescenes involvement in a particular mat tel:'. This aafe harbor
allows you to use ;your expertise and knotfledge, bu.t not yOur
influence. Aa notect.al)ove,.. however, conduc:t falls outside the.
scope ot. permissible behind-tlle-acenea" involvement it, for
inatanc:e, a former government official intends that information
conveyed to the .federal government by a third party be
attributed to :him. In: other words, you cannot shield yourself
C06299587
Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _ _ _ _ ____,
=(b)(7)(c)
from criminal liability by interacting with government officials

through a third party, including through & buaineso associate,. '
it you intend that the intormation be ~ttributedto you.
roreiS!! Zntity Rea.trictione,
18 o.s.c. S 207(f) restricts
former.aenior employees whoaa.base pay (which after ll July 2004

includes locality pay) is over $140;21,.50 for one year after
separ~tion from th~ Agency. from representing, aiding or advising
a foreign entity with the intent to influence the United states.
A foreign entity is def'ined. as 'a. foreign govermnerit or foreign
political party.
A foreign government includes any person or
group .of persona exercising sovereign de racto or de jure

political jurisdiction QVe% any count%Y, other than the united
States, or any part of such country. It also includes any
subdivision of a group and any group or agency to which
sovereign de facto or de jure authority or functions are
directly_ or-indirectly delegated. The term also includes any
taction or body ot in&urgeuta within a. country Burning to

exercise governmental authority, whether aueh faction or body of
insurgents has or has not been recognized by the "United States.
A foreign commercial corporation will not generally be
considered a foreign entity for purposes .of 18 o.s.c. 5
~07(f)
unless it exerciaea the functions of a .sovereign. There is no

safe harbor for behind-the-scenes assistance Under 18 u.s.c.
207 (!) .
Section '02
'nlr-
-~~w,=t
for1118r position, ao
Your
I is .a
designated poaition s
ect to the three-year postemployment

l'greement required by congress in section iO~ of tho
Intelligence Authorization Act o!.l997. so o.s.c. S i03-4 nt.

Pursuant .to this Act, you heve signed an agreement with the
Agency that prohibits you !rc>ni repreaenting or advising a
foreign government or foreign political party for three years
after leaving employment at the Agency. (Because you held this
designated position within three years of your departure date in
~002, this restriction applies.)
This ban does DOt require the
rendering of aid or advice with the intent of influencing the
anY U.S. interest or
involvement in the matter at issue. There is no safe harbor for
behind-the .. acenes asSistance under Section 402. As mentioned
earlier in this letter, this restriction will run from three
U.S. Government . but applies absent
(b)(?)(c)
C06299587
Approved for Release: 2015/05/05 C06299587--------------,
=(b)(7)(c)
Agency on
L.~-~----'
You have asked for detai'led advice on this prohibition,

Whether it applies when a covered former employee
apeci~ically
is selling goods or services to, . but not working directly tor, a

foreign goverument. A foXller employee subject to this
reatriction_ 'would be prohibited. from working for a foreign
government in any capacity, including as an employee or a
contractor. Further, regardless of whether the fomer employee
worltecS cSirectly !or the foreign government,. he W<>uld be be=ed
(b )(7)( c)
f:r"om ropreaanting a foreign government on any matter. (The

broad ftleaning. ot repreaentation clic:uaaed above would apply.)
The formeJ: employee could, however, work tor a conaultant tbat
ad.viee a foreign government, and even interact direc:t1y with
the foreign government, ao long aa the subject of the
conaultatiou was not related to_ &rlf_ ma.ttr w~_tb~ t~ _scope of
his qoyGJ:"tUDailt -smploY!!nt
The former employee also .could sell
goods tor hia new employer directly to a foreign government, and
provide advice on how.to uae a product, ao long aa_ the adviee
was not related to any matter within the scope of his sovernment
employment. As yOu discussed with John-Rizzo during our
meeting, a aa.atter means any particular matter with
specific parties, such aa a contract~ Therefore, you will not
be considered to be in violation or this restriction if you are
rendering advice to a foreign government in connection with a
sale of goods and eervicea and that advice does not interaect
with any matter, includiug any oontract, with which you.vere
invo~vecl aa a gove%1llne!lt employee.
Poreign !gent Regitration Act of 1938

Although you currently do not anticipate working for
foreign government, political parties or companies, you should
familiarize yourself ,with tbe requirements of the Fcreign Agents
Registration Act ot 1938 (FARA), 22 u.s.c.
601 et seq., if you
wish to explore this possibility. in the future. PARA requires &
person to register as an agent or a. !oreigu principal when he
or she acts at the ol'der, request or uncle:r the direct control of
a foreign principal and engages ill certaill types ot activities.
Foreign principals include foreign governinents, and
partnerhipa, associations, corporations, organi~ations, or
Approved for Release 2015/05/05 C06299587
(b )(7)( c)
C06299587
Approved for Release: 2015/05/05 C06299587_._ _ _ _ _ _ _ _~---
(b )(7)( c)
other combinations of persons organized under the law or having

their principal place of business in foreign country.
PARA has .a very broad scope and you should ensure that you
comply with ita regi_atration requirements unless your activities
&re exempt fraJD the Act.: The Office ot General COUnsel does. not
make determinations concerning .the applicability of the Act.
Inquiries .regarding PARA should be addreaaed to' O".S.
Department of JUst~ee, Criminal Division, Internal Security
Section/Foreign Agents Regiatration Unit, 10~ ~ Constitution
Avenue, N.W., Bond Building - .Room 9300, Washington, D.c.
20530. The onit's telephone number ia ~02-514-11451 tbe.fax
number is 202-51-2&36.
I hope that you will find the guidance contained in this
letter helpful aa you. begin your new career. Please remeraber
that this letter only summarizes the relevant statutory
proviaiona. The provisions 1111st be applied to specific facts on
a casebycase basis to determine if particular ci~tances

fall. within the ~cope of the restrictions. Please contact me if
you have any additional questions or Concerns. I can be reached
at
L(b)(3) CIAAct'
Sincerely,
crb)~3)~1AAct _ _]
-l!tliica Counsel
C06299587
f-.['"
,.,,~' .,.
~----~----~------------------------Approved for Release: 2015/05/05 C06299587
L::. .
C06299587
(b)(1)
(b )(3) CIAAct
(b)(3) NatSecAct
(b)(5)
(b )(7)( c)
QQJJP:maPPw./1
'---~~---"
(b)(7)(c)
C06299587
Approved for Release: 2015/05/05 C 0 6 2 9 9 5 8 7 - - - - - - - - - - -
(b)(7)(c)
(b )(7)( c)
(b)(3) CIAAct
(b )(3) NatSecAct
. Approved for Release: 2015/05/05 C06299587
.C06299587
(b)(3) NatSecAct
uj
~-
If;~~
:!0<
r,
~'
,,'
'
~-J (b)(7)(c)
I
~r --'"-+-----
~s.!~~~~------------------
l':.' ,
.'
.~
-Approved for Release: 2015/05/05 C062995BB----------,-----
SECRET//HOFOmJ
CENTRAL INTELLIGENCE AGENCY
OFFICE OF INSPECTOR GENERAL
MEMORANDUM TO FILE
(CASE CLOSING MEMORANDUM)
I. ADMINISTRATIVE DATA
(b)(3) CIAAct
Case N o1
.
Case Title: Misuse of Government Systems
i(b)(3) CIAActl
Investigator:L
Supervisor: I
(b)(3)
Date Received: 10/31/2012
Date Opened: 11/13/2012
Date Assigned: 11/13/2012
Case Type: SR
CIAAc~
(b)(3) CIAAct
(b)(7)(c)
(b )(7)( d)
II. SUMMARY OF INVESTIGATIVE ACTIONS

(5//~H') On 31 October 2012
irectorate of
,------,---~Support, Office of Securi OS
contacted OIG and
advised that L_----~--~--~~~----~~~~
misused government systems by conducting unauthorized, non(b)(3) CIAAct official searches on sensitive Agenc4databases. According ~o
(b )( 7 )( c)
~amedl
n more than one occas10n to
(b)( 7 )(d)
ceasec:.::::Pehavior, buL
ontinued to conduct
unauthorized, non-official searches.
I
(b )(7)( c)
(b)(1)
(b)(3) CIAAct
(b)(3) NatSecAct
(b)(7)(c)
(b)(3) CIAAct
(b)(7)(c)
This docwnent contains neither recommendations nOr conclusions of the Central rntelli"gence Agency, Office of Inspector
General. It is the propertY of the CWOIG and neither the document nor its contents should be disseminated without prior IG
authorization.
~~
(b)(3) NISooAct
6:gCRIH'/fW0l'ORN
I
C06299588
Approved for Release: 2015/05/05 C06299588 _ _ _ _ _ _ _ _ _- - ,
..
(b)( 1)
(b)(3) CIAAct
(b)(3) NatSecAct
(b)(7)(c)
(b )(7)( e)
(U) This matter was briefed telephonically to Assistant United

States Attorney I
(b )(6)
IEastern District of Virginia, on 3
January 2013, and received a verbal declination at the conclusion of
the briefing.
fS/INF) On 16
2013 a PEB was held for

(b )(3) CIAAc,
1ct.----Y">T'..,---~--.--.--;,-c-;~-----,special Activities Staff,
(b)(7)(c)
e PEB recommended tha L_~-,---_jbe separated from the (b)(3) CIAAct
(b)(7)(c)
Agency and0clearances revoked.
(b )(7)( c)
----
(6//NF) _L[- - ; - - - position with the Agency.
-(b)(;~-CI_AA_c_'tL-=--'-_jjresignedD (b)(7)(c)
(b)(7)(c)
III. FINDINGS
(b)(1)
(b)(3) CIAAct
(b)(3) NatSecAct
(b)(7)(c)
(b )(7)( d)
(b )(7)( e)
Page 2 of3
SEEmf/NOFORN
I
Approved for Release: 2015/05/05 CD6299588: _ _ _ _ _ _ _ _ _ __
;!OCRE'/ /l<!OFORN
(b)(3) CIAAct
(b)(7)(c)
b )(7)( e)
tGf/~JP) OIG re-v:ievv~~L----,:::;=~Agency computer files

OIG's review did not reveal any
additional'~I~o-r_m_a_ti~.o-n-o~f~inc--te-r-es-,t-.---"
.{5//Nfi') ~!he case has been dedined for prosecution and

(b)(3) C I A J } c t h a s resigned0position. OIG w.ill defer to SAS to consider
(b)( 7)(c) any further action. This matter is closed.
(b )(7)( c)
I
IV. REVIEW M
(b )(3) C IAAct
Case Investigato
Tr
Approved by Supervis<
2/19/2013
(b)(3) CIAAct
2/19/2013
Page3 of3
SECRET/ /~JOf0R:1q
I
Approved for Release: 2015/05/05 CD6299588
col3299592
C06299592-----~-------,
SECRE'f'/;'N6Ft5ftt4
Office of Inslctor General

Investigations Staff
Administrative Data
I.
Case No.:
Investigator:
[(b)(3) CIAAct1
_
Case Title:
-~(b)(3) CIAAcL_
Supervisor:
Review of Qui Tarn Allegations

from DoD
----~(b)(3) CIAA~t
Date Received:
3 September 2012
Date Opened: _:_19:_::_Se::.Pc:te:::m.::b:::e::r_:2:::0_:;12::__ _ _ _ __
Date Assigned:
J September _,_20,_,_,12,____
Case Type:
ll.
Preliminary Investigation
Summary of Investigative Actions
I. Department of Justice (DoJ) Civil Litigation Division forwards to CIA Office of the Inspector
General- Investigations Staff(OIG INV) '"courtesy copies' of qui tam allegations against contractors
with the Department of Defense (DoD). As many contractors with the DoD can also be contractors with
the CIA, each allegation is evaluated for potential nexus with the CIA.
If~
potential nexus exists, it is
evaluated for further investigation and determination if a joint invesligatioO is to be pursued.
III.
Fiodiogs
2. This matter was considered a proactive approach to identi

vtolati<J_ns (3 I U.S.C . . 3729) which rna_>: also affectthe CIA.
(b)( 1)
--~)(3)
[_
(b )(7)( a)
tential civil false claims__
NtS,cAd
J..__From theop_ening of this proactive inquiryOIIegations from DoJ were reviewed.!
L_ _ .. _ _ _ _
_(Ofthose contractors detennined to have contracts with the CIA, no information had
be-en- uncoVered th3-i CIA is affected by the allegations in the corresponding qui tam.
(b )(1)
(b)(3) NatSecAct
4. This matter is being closed in favor of other more appropriate means of documenting the
proactive activities from this initiative. Future review and research will be documented via MOIA.
Should additional information be developed, INV may consider-reopening the matter or separate
INV-201
Pagt: ! or2
This document is controlled by the CIA/OIG and neither the document nor its contents should be
disseminated without prior IG authorization.
(b )(3) NatSecAct
srco:;;:T//NG'F8RN
-------- - -
'"'"
C06299592
'_;
Approved for Release: 2015/05/05 C06299592:--------'------,
..
5~CftEl'f//W~FO~N
Case Closing Memo.J!Pdwn
investigation if future qui tam allegations under this proactive initiative with a potential CIA nexus are
determined.
IV.
Review and Approval
Case Closing Memo submitted by Investigator to

Supervisor:
(b)(3) CIAAft -:l...""'-- \"'3.
---~~_,_,~---
(Sign I Date)
Case Closing Memo approved by Supervisor:
INV-201
Page 2 of2
_SECRS'P//NOfOFffi"
I
Approved for Release: 20 15/05/':J05"-.':C:."O':J62~9"'9"'5'-'9'!'2'-------------'----
C06299595

Tsv4cRET I
L___ _ _ _ _ _ ______..J
Office oflnspector General

InvestigationsSbdf
(b )(1)
(b )(3) NatSecAct
Case Closing Memorandum
(b )(3) CIAAct
Case No.:
CaseTitle:
Investigator:
Supervisor:
Date Received:
I. (U//Fel:le) On 10 July 2013J
(b)(3) CIAAct
Date Opened: --'l,_,l;J,ul,_y=:20:c:l.=.3_ _ _ _ _ __
!OJuly 2013
Date Assigned: _l'-'l.o:J.=ul:.cY..=20;:.;1,3_ _ _ __
II.
Classified Information Leaked to

\Army Officials
(b)(3) NatSec:P;ct
Case Type:
(b)(3) CIAAct
(b )(7)( d)-- - - - - - - - - - ,
. __
sent LOtus Note nottfymg tliis office of a possible leak of
classified information. The Lotus Note references aCintelligence report[
I
J
~;;~~rArt
3
(b)( )CIAAct
(b )(7)( d)
(b )(3) CIAAct
2. (U//F91:te10nliJuly2013,atthedirectionofSAci - -]SA
(b)(3)
and ASAC I
\met with c=]who was unable to provide additional information.L
I
C IAAct
does not work on any matter related to the information provided in thec:::Jreport, nor is any of the
(b )(3)(b )(7)( d)!\ct
1
reported subject matter inOarea of expertiseOstatedD jas sil!!JJJ concerned by the implication of
a highly placed US official leaking classified information to the
Army and wanted to make sure
(b )(7)(d)
the report was forwarded to the appropriate investigative authority.
(b )(3)
J
(b)(1) NatSecAct
(b)(3) CIAAct
-----o----!\found the identical report referenced in\L _ __,ji.<ltus Note. The (b )(3) NatSecAct
distribution list for the report includes the Justice Department.
(b)(7)(e)
(b)(3) CIAAct
(b )(7)( d)
IIL Findings
=-=_j-
(b)(1)
4
(b)(3) CIAAct--'-'--'--'=
(b )(3) NatSecAct
(b) (7) (d)
I
_{Fiirther, the Justice Department, which would be the
(b )(7)( e)
appropriate investigative authority in this matter, was included on the report's distribution list. Therefore,
this matter is being closed. Should additional information be developed, INV may consider reopening the
investigation.
INV-201
Pagel of2
This document is controlled by the CWOIG and neither the document nor its contents should be
(b)(3) NatSecAct
'-----------...L:-;;--r=='-----(b)(1)
'
T~CRET/ L___ _ _(b)(3) NatSecAct
C06299595-------------~
T~CRET/
Case ClosingMemorm..tum
IV.
L __ _ _ _ _ _ _ _ _ j
(b)(1)
(b)(3) NatSecAct
Review and Approval

Supervisor:
,----'------,
(b)i(3) CIAAct
0"1-lr=t{z.A:>,
tSig1J/Date)
(b)(3) CIAAct
L__
TOP~RET/
(Sign! Date)
INV-201
Page2of2
L _ _ _ _ ,(b)(1)
I
(b)(3) NatSecAct
C06299596
S~ORN
Office of Inspector General

I.
Administrative Data
Case No.:
Case Title:
Investigator:
Supervisor:
(U//Fffiffi) Alleged Misuse of

Agency Credential by Former[jtill7)( c)
Officer
(b)(3) C 1AAct
1
Date Received:
18 March 2013
Date Opened:
18 March 2013
Date Assigned:
18 March 2013
Case Type:
<
II.
(b)(3) CIAAct
I. iT On 8 March 2013, the CIA Counterintelligence Center (CIC),
(b) ( 3) C
!Met] notified the Office of Inspector General (OIG), via Lotus Note, that the'-;U~0S;-;Doo-e-partm---:--en--ct-of--~~
Homeland Security, US Immigration and Customs Enforcement, Homeland Security Investigations (HSJ;),
located in Indianapolis, Indiana, intercepted $185,070 in cash that was being sent via FedEx from South
Carolina to California.' Therecipientofthecash W\ISL_m m m_]afonner[u . . .
~
(b )(3) CIAActr---loffi=. HSI is seeking to determine if the cash is connected to an illegal activity. --HSI reported
(b)(7)(c)
~told HSI[]was receiving the cash from
for al
.
!company.
!attorney sent
HSI further reported that, in an attempt to reclaim the cash that HSI confiscatedl
HSI scanned copies ofj
~IC::]Special Agent (SA) badge and credential, and a CIA Earnings
( b )(3) CIAAct and Leave (E&L) statement. HSI reported that it considered this to be an administrative matter.
(b )(7)( c)
Clct::=Jadvised OIG thac=Jwas a person of interest regarding the source of the cash and that
(b )(3) CIAAct ~~~was jkin, any background inf~nnation onc=Jthat OIG could provide regarding a separate
mvesuganon of
thatOIG completed m 2012. (b)(3) CIAAct
(b )(3)
CIAAct
(b )(7)( c)
(b)(7)(c)
(b )(7)( c)
(b)(7)(c)
(b)(7)(c)
(b)(3)
CIAAct
(b)(7)(c)
(b)(1)
;--------~---------_ _ _ _ _ _ (b)(3) CIAAct

(b)(3) NatSecAct
2
-fEt_ M-as the subject of an OIG investigation'==~~~,c"' resulted in the convening of a Personn~?) ( 7 ) (C)
EvaluanOnl!'oard
on 27 June 2012. The PEB resulted m
in terminated from the CIA on
INY-201
(b)(3) CIAAct
(b)(7)(c)
(b)(3) CIAAct
Page I of3
~-.;-,.;oc~b)(3)
NtSoAct
SEC~OFORN
C06299596
SE~ORN
(b)(3) CIAAct
(b)(7)(c)
(b)(3) CIAAct
(b)(7)(c)
(b)( ) CIAA t
3
C
(b )(7)( c)
2. (U/H...'U()t On 18 March 2013. O!Gopened a preliminary investigation to determine the

circumstances surrounding
apparent possessi~_andpossible misuse oQC~SA badge
and credential. On 28 March 2013, OIG met with CI(,.L_jand provided an overview of OIG's earlier
1
investigation ofc:.:J On 8 Apri12013, OIG sei=t=}riginal two C~SA badges and one
(b)( 3 ) CIAA t ~tial from the 0. S Badge Office and placed the items into evidence.' The Badge Office advised that
C L______JSUrrendered the SA badges and credential to the Badge Office on 26 May 2011. On 2 May 2013,
(bl )(7)( c)
OIG obtained copies of the CIA Special Agent Shield Acceptance Form and the Special Agent Credential
Acceptance Form thatc::=:Jexecuted on 29. August 2007 when [lwas issued the badges and credential.
(b)(3) CIAAct
(b)(7)(c)
3. (UJI.IdtlO) On 10 April 2013, OIG met with HSI in Indianapolis to discuss HSI's
investigation. HSI advised that it intercepted, and confiscated, the shipment of cash totaling $185,070 at
the Indianapolis International Airport, where HSI operates a counterdrug operation, after a specially
(b)(7)(c)
trained ,jog sniffed the odor of narcotics on the pac.kag.e containing. the cash. HSI was ~uendy_
contacted bL:.:Jwho identified
as the shipper of the package. HSI advised L___jthaB
I
would
have
to
provide
documentation
regarding
the source of the $185,070 because the method
(b)(3) CIAAct
used
to
ship
the
cash
made
it
appear
that
the
cash
had been illegally generated. Soon thereafter, an
(b /(7)( c)
attorney, obtained by
to assist in retrieving the cash, contacted HS! and emailed scanned black and
(b)(3) CIAAct white copies ofc=::JC~SA badge and credential, as well as dnee CIA E&L statements, to HSI
for the purpose of substantiating
earlier asSertion to HSI that~s a former employee of the
(b )(7)( c)
CIA. HSI advisedc=:Jthat, in accordance with HSI policy, unlessl__jpetitioned the relevant court
I
(b)(3) CIAAct for return of the cash, the cash would be forfeited. HSI said it would not interview relevant individuals
unlessc::==lpetitioned the court. HSI provided OIG with a copy of its investigative file, which DIG
(b)(7)(c)
I
received
on 19 April2013.
!
fl
(b)(3) CIAAct
(~)(7)(c)
4. (UIH!:ffi9) On 7 May 2013, HSI advised DIG thatc=:Jsubsequendy filed a Seized Asset
Claim Form requesting that the case be referred for federal court action. HSI advised that it will
commence interviewing relevant individuals. HSI still considers the matter to be administrative and not a
criminal proceeding.
Ul.
Findings
(b)(3) CIAAct
(b)(7)(c)
(b)(7)(c)
(b)(7)(c)
(b)(7)(c)
(b)(7)(c)
(b)(3)
CIAAct
(b)(7)(c)J
\U}\1 )\<C
(b)(3)
CIAAct
(b)(7)(c)c)
\" I\- I)
(b)(7)(c)
(b)(3)
CIAAct
(b)(7)(c)
(b)(3) CIAAct
(b )(7)( c)
5. (U//Id8B)c::::::JsurrenderedL_lwo ciA[:_J SA badges and one credential before being

terminated by the Agency. However, it appears that, before surrendering these items,c:::Jmade
(b)(3) CIAAct
- - - - - . - - - - ( b ) ( 7 ) ( c ) - - - - - . - .- - - - -
(b)(3)
CIAAct
(b )(7)( c)
20 November 2012 for nususe of a govemmcnLvemcie, voucher fraud, and accepting gtfts from a contractor. The
(b)(3) CIAAct
De
ent of Justice declined
ution o~on 18 March 2011. ent's Note:
On 2 May 2013,
OS, advised OIG thatc=J
t.,P"'EB""'di"d-cn-:-:ot:--res~ulccti~n"th:c:eccre:ccvccoc:c:atl"o:-cn--:o"l~~~~"'learan==-=ce=s:-:an=d=acce=sses=beca==u=sec::re:C::vocation could not be supported
by the applicable Intelligence Community (!C) Policy Guidance. In addition,! ______ ~dvised that Scattered
Castles, the IC database containing the clearance and access status of individuals throughout the IC, reflects c=:J
(b )(7)( c)
as being debriefed ofDlearance and accesses, but not thatc::::J was terminated from CIA. Furthennore, the
database does not reflect an alert, referred to as "red flagged," that CIA should be contacted before any clearance
and access action is undertaken by another IC agen,0'~
(b)(3) CIAAct 3 (U//AW87 c:=:Jwas issued two identical CIAL_jSA badges and one credential with the same identification
(b )(7)( c)
. number. One badge was affixed to the credential holder and the other badge was affixed to a belt holder.
INV-201
Page 2of3
(b )(3)
CIAAct
(b)(7)(c)
\DJ\0)
CIAAct
(b)(3) CIAAct
(b)(7)(c)
(b)(7)(c)
co'15299679
CO~ENTIAL
I.
Admlnis1rative Data
Case No.:
Investigator:
Date Received:
Date Assigned:
n.
~) CIAAct
~
31
ca..,Title:
)b)(3) CIAAct
Ma~2013
3 June 2013
Counterleiting of CIA Credentials
:;uperv1sor:
SAc[
Date Opened:
3 June 2013
C~Type:
Full Investi~on
(b )(3) CIAAct
Summary or Iuvestigative Actions
I. (U/II'Gl:le) On 6 Fe~rum;v 2013, the Naval.Criminal Inves.tlgative. Service (N

.. CIS)
received information that a civiliant
]noB m - - - - - - lwas in
possession of multiple forms of false government credentials. In March 2013, NCIS obtained a
(b )( ) search warrant through the Eastern Disbict of Virginia (EDVA), U~-~ltomey'_s_Qffice, ancl _ _
6
executed that warrant on the[
~residence located at '---c-c---=-::-:c=-=---:-:-c:-----'
'o--.----_J Pursuant to the search, NCIS seized two government badges, one NCIS Special Agent
badge and one CIA Special Agent badge.
(b )(6)
3
(b)(3) CIAAct ~On 31 May 2013, the Chief, Counterintellgence CenteE
(b)( ) CIAAct
(Ciq___j10tified the Office of Inspector Genernl (OIG) of the NCIS activity pertaining to
(b )(6)
OIG opened an investigation into the matter. OIG evaluated the authenticity of the CIA
Special Agent badge seized by NCIS and, through coordination with the Office of Security and
the Global Deployment Center (GDC), detennined the CIA badge seized by NCIS was not
authentic. In addition to evaluating the authenticity of the badge, OIG investigated any ties
(b )(6) betweec:::Jand the CIA.
m.
(b) (6)
Findings
I. (U//FOI:JO) The OIG investigation deteqnined that the CIA Special Agent badge
possessed byc::=Jwas not authentic but did represent a similar a~ce to the official CIA
OIG Special Agent badge. The investigation also detennined thatL_jdid not have any
(b )(6)
official ties to the CIA.
INV-201
Page I of2
This document is controlled by the CWOIG and neither the document nor itS contents should be
disseminated without prior JG authorization.
(b)(3) NatSecAct
-I
(b )(6)
" co6299679
Approved for Release: 2015/05/05 C06299679'-------------,
Case ClosingcMemorandum
(b )(6)
(b )(6)
(b)(6)
6
(U//-FOUO) On I July 2013, Special Assistant US Auornev (SAUSA)j
(b)\ )
L--__,~ EDVA, accepted tl>is case for prosecution. On
the criminal infonnation
was tiled citing two misdemeanor counts of violating 18 U.S. C. 701 (False Federal Badge).
On 6 September 2013,= pled guilty to two coums of possession of badges that were of(!
colorabl.e imitation to those of the CIA Office of Inspector General and Naval Criminal
Investigative Service. He was subsequently sentenced to six months of probation, a $300.00
fine, 25 hours of community service and a $20.00 special assessment.
3. (l.l/1~) (U) An Agency Request or Notification Memorandum (Al\NM) will be
prepared for the D/OS for informational purposes.
4.
(Uif~)
Based upon the successfu.l prosecution <if the case by EDV A, OJG
considers this ma.ner closed.
IV.
Review and AJ>proval
Case Closing Memo submitted by Investigator to \
Superv~sor:
(b )(3) CIAAct
l:========rswrnwzc~_?_..s_c;_. ff:A:Jr)
(b)(3) CIAAct .

L-/---c~-----n--,--n. .,,~n1 vwe)
j)h." ,
Vr~'?-at...3
rNV-20!
Page 2 of2
C06299683

SECRET/ /NOF91"H'l

Administrative Data
Ca1;;e No.:
Investigator:
{b){3) CIAAct
sd
(b)(3) CIAAct
"-Use of Gov ~-Order Steroids _
Supe-rvisor:
(b){3) CIAAct____ _
--------------,
Dale. Received:
23 August 2013
Date Opened:
2=-:3'-''--'\"-ug"-u=-:s.:.t-=2"-0"'13'--------
Date Assigned:
29 August 2013
Case Type:
Prelill_li_~arv lnvesti_g_~''tb)(
H.
{b)(3) CIAAct
1. - -
Charge (ASAC)
(b)(7)(c)
Case Title:
review ASAC
called Var 10 fro
AnVar 10 from
On
1 )----
'{b )(3) Na!SecAct
i~~~~u?t 1~~~0flice ofl~~~:1~~Leral (OJG) Assistant Specia\~1~:~:~1

evicwed titel
discovered that
llogfiles for
During his
on 14 August 2013, JP addressC
(b )(3) CIAAct
!ordered a product
On IS August 20 I 3, the same IP address ordered a product called

Review ofrhe IP address demonstrated its association with
(b)(1)
'------------------------------~(b)(3) CIAAct
(b)(7)(c)
2. (U/,'!OOUOj On 23 August 2013, the OJG initiated a preliminary investigation (PI) into tht'
martcr. During the course of the PI the reporting agent reviewed the wehsites and the specific items
ordered. The websites identify on the homcpage of each that the- s.ites "are offering this very strong
alternative to the highly toxic drug listed at the top of the page."
identifies Var 10 as
(b )(3) Na!SecAct
{b)(7){c)
associated with the drug oxantrione. A review of the ingredient label for AnVar 10 demonstrated the
ingredients as primarily arginine hydrochloride (HCL), multiple- amino acids, and vitamjn B-6.
III.
(b )(7)( c)
Findings
3.
(b )(3) CIAAct
(U/trOUO) The OIG Investigation determined that the products ordered by IP address
I were not schedule Ill controlled substances. Neither the produeLs nor their ingredients are __
listed in 21 USC 802(41)(A) Definitions for steroid associated controlled substances. The investigation
also notes that the sites identify that these substance,s <.Ire not "drugs'' and arc alternatives to actual
steroids. This matter is considered closed by OIG.
IV.
Review and Approval
Case Closing Memo submitted by liwestigator 1J
Supervisor:
{b)(3) CIAAct
------.0?:il8)i I
c___ _ _ _ _ _ _
JAm
(b)(3) CIAAct
INV-201
Page I of l
Thi~ drn:ument is controlled by the ClA/OIG and neither the documem nor i.ts content!-! should
be
disseminated without rior rG authorization.
{b)(3) NatSecAct
-l
_j
L _ _ _ _ _ __ _ _ _
5ECRE'7P/ '::;OFORH
L~----------------------------------~
CO'b299684

I.
Administrative Data
(b)(3) CIAAct
Case No.:
----,----"'~(~b"")(='3)~C_I_AAct:ase Title:
Ll
Investigator:
sAl
Date Received:
16 June 2010
Date Openoo:
Date Assigned:
9 October 2012
Case Type:
Supervisor:
16 June 2010
~~~~-----------
Fl
II.
(b)(1)
(b)(1)
(b)(3) NatSecAct
I. ~n 14 June 2010 the Naval Criminal Investigative Service (NCIS) notified (b)(3) NatSecAct
(b)(7)(d)
the CIA ofal_____
I referral NCIS received, which alleged
;~~~~ei;~~~~:~:':~v~yre~~n~~;~~~r~~L_--_-_----=-- r~_eccfe_rro-cac-J-in~-~-_lu_d~ed_a_J)a~rt-i~al_,
i~
;g;
(b)( )
ITh-oe"'_
_jald
1
(b )(3) NatSecAct
I which alleged misconduct by an Agency officer. OIG initiated an investigation on 16
NatSecAct
(b)(?)(d)
,J_un_e_2_0t_o._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _~_ __._(b--i)(7)(d)
(b)( 1)
(b)(3) NatSecAct
(b)(7)(c)
(b )(7)( d)
.
INV-.0
Page I of3
This document is controlled by the CIA/OJG and neither the document nor its contents should be
I-''"'m<w<"~";:~:;~~~~=:'""
S~T[_~NO~N
(b )(3) f\JatSecAct
C0'6299684
. -Approved for Release: 2015/05/05 C06299684.
(b )(3) NatSecAct
S~
N~N
(b)(1)
(b)(3) CIAAct
(b)(3) NatSecAct
(b)(7)(c)
4. (UI/ffit10/ On 24 June 2010, OIG referred this matterto the Department of Justice (DOl)
Human Rights and Special Prosecutions Section (HRSP). HRSP declined prosecution of this matter on 3
August 2012, and OIG continued an administrative investigation to determine if Agency policies were
violated regarding the alleged incidents.
(b)(1)
(b)(3) CIAAct
(b)(3) NatSecAct
(b )(7)( c)
III.
Findings
\
9. {Sflfl The 'investigation by OIG did not uncover any evidence to substantiate thL(b )(7)( d)
allegations tha.
lor any other Agency staff or contractor employee, violated the rules of
engagement or otherwise unlawfully killed anyone during the assault operations examined during the
course of this investigation.
(b)( 1)
(b)(3) CIAAct
{b)(3) NatSecAct:--------------------------:::,N;:-v;-:.2~
01
(b)(7)(c)
Page2of3
~T~
fN~N
~-~
(b )(3) NatSecAct
....
- - - - .. -- ..----~----.. --------~
C0'5299684
(b )(3) NatSecAct
s~ErL_~NO~N
10. (UI~) An Action Request or Notification Memorandum (ARNM) will be submitted to
the Executive Director, and the Director of the National Clandestine Service with no response required.
The matter is considered cl~ed by OIG.
IV.
Review and Approval

Supervisor:
(b)(3) CIAA1t
JL(;JJ\l~J-
~====:::Jc=====--"-"'rlgn I Date)
(b)(3) CIAAol.,
,Case Closing Memo approved by Supervisor:
L__jl"cv-~~-.f/~,J'."'""'"ISVTTJQI
"
II(4/~~.)o;
(/)
INV-201
Page 3 of3
(b)(3) NaiSecAci
, coo299685
S~TJ
J~RN

----(b)(1)1 _ _ _ __
I.
Administrative Data
(b)(3) CIAAct
(b)(7)(c)
Case No.:
L'(b~)~(3_:_)~C---ciAAc-'c~t:::-::-_, __
_
(b)(3) CIAAct
Investigator;
- -------------------------------
Case Title:
Supervisor:
Date Received:
16 October 2013
Date Opened:
22 October 2013
Date Assigned:
16 Octobe~r~20~13:___ __
Case Type:
(b)(1)
II.
(b)( 1)
(b)(3) CIAAct
Summary of Investigative Actions~_ _ _ _ _ _ _ _ _ _ _ _ _ _ _(b )(3) NatSecAct
I. (Sm!F) On 15 October2013, thec__~=~--~---c--o-~~---,:--c--:--(b)(7)(c)
]notified the Office of Inspector General (OIG) about an alleged physical abuse involving (b )(7)( d)
____
(b)(3) NatSecActdetaineej
(b)(1)
(b)(3) CIAAct
(b )(3) NatSecAct
(b)(7)(c)
(b )(7)( d)
Pagelof3
1
(b )(3) NatSecAct
S~ET[
(b)(3) NatSecAct
------------------------Approved for Release: 2015/05/05 C06299685
. C06299685
(b)(1)
(b)(3) CIAAct
(b)(3) NatSecAct
(b)(7)(c)
(b )(7)( d)
S~ETI
(b)(3) NatSecAct
f~
INV-201
Page 2 of3
. C08299685 _ __
{b )(3) NatSecAct
S~ET[___ /No_;;N
~~~g~ CIAAct
~C~as~e~C~lo~s~in':lgz..:M=e:::m:::o~r=~d~um~------------------{b )(3) NatSecAct

(b)(7)(c)
(b )(7)( d)
III.
(b)(7)(c)
Findings
10. ~The infonnation obtained during the course of this investigation did not substantiate any
misconduct or ph~al abuse by CIA officers. During an interview with OIG.c=Jclari,fied, cOrrecteQ1.
or recanted all ofL __ _I rior admissions related t
know led e of physical abuse of detainees.
r---
(b )(7){ c)
(b )(7){ d)
(b)(1)
(b)(3) CIAAct
(b )(3) NatSecAct
(b)(7)(c)
(b )(7)( d)
(b)(1)
(b)(3) CIAAct
{b )(3) NatSecAct
L_-------------------(b)(7)(c)
12. (U//.A.II:l6) An Action Request or Notification Memorandum (ARNM) will be forwarded to the
Director of National Clandestine Service and to the Director of the Counterterrorism Center for
informational purposes.
13. (U/I'I'ffl::!e) This matter is considered closed by OIG.
IV.
Review and Approval

Supervisor:
(b)(3) CIAAct
!NV-201
~RETc=-JNo~
(b)(3) NatSecAct
Page 3 of3
C06299687
,(b)(3) CIAActl
DIR/OIG-L_
_
2 5 Apr ill..,-2"0'14,------
MEMORANDUM FOR:
FROM:
Director of the National Clandestine Service

Chief Information Officer
Director of Security
r--(b)(3) CIAAct
'Asslstant Insbector General for Investigations
SUBJECT:
(3//!IF)
Alleged Abuse and Misconduct by CIA
Offic_E!l' Invo)yJng Domestic Help I
(b)(3) CIAAct
(b)(7)(d)
1.
(5
'/111
On 25
MarcJ1 2013,
':-:.-=ocr~:c=,-;::,--~-(b)(?)(d) (b)(1)
l =~~=--==~,--=""---;cLC"""o=c::"J notified
the Offl;:c.c::.:e:....=o.:cf~~~(b)(1)
Inspector General (OIG) that A enc staff em lo ee
(b)(3) NatSecAct
(b)(7)(c)
officer may be _m;i.streat_ioo
1
domestlc help [
by not paying adequate
(b)(1)
wages, forcing long work. ours, an making threats to have
family members, who reside in I
I kiY:dld Addi.tionall.v..
(b)(3) NatSecAclthe L.::::=J alleged that I
I spouse,
abused illegal drugs and also abused their c l ren. That
investigation is now complete, and this matter is being referred
(b)(1)
to
you for information only.
(b)(3) CIAAct
(b)(3) NatSecAct
2 ''r_:((-ES't/'-f_/:!!lifF:l:_)___:Tl')h}.Eel__(:O)]:I_(;G___iin[l'VI[Eel_!s>Jtji,_gg@a_l;_t~ed;UtUhui~s;__aal_l.:Lle~a:r;a>Jt~i.!:ownLQ_t,
(b)(7)(c)
/ chHsi ab~
1,.
the 0 f f l ce o f'---.,Mc;;e"'dlo:ccoo:a"l,---cS.-;:ec;::r:o;v'i:::Cce;::cs;:;-("'O"'M"'sT)----;::co;::cn"'t"'r"i"b;;;u--;::t~e::<d-ct>e:o~t'>h~e~
investigation with interviews and medical support, and family
assessments.
3.
(8_//U_et_
(b)( 1)
(b)(3) CIAAct
(b)(3) NatSecAct
(b)(7)(c)
(b)(1)
(b )(3)
NatSecAct
(b)(3) CIAAct
(b)( 3 )
NatSecAc
(b)(7)(c)
(DJ\<5)
N. atS.e,.c,A,.c,t(c)
(b)(1)
(b)(3) CIAAct
(b)(3)
NatSecAc
(t(b~'hl
(b )(3)
CIAAct
(b)(3)
NatSecAct
(b )(7)( c)
I
(b )(3) NatSecAct
SECR~FORN
I
C06299687
SEC~ORN
(b)(1)
(b)(3) CIAAct ,
(b )(3) NatSecAct
SUBJECT:
{~//!IF)
Alleged Abuse and Misconduct by CIA Ofti<:;_ez;
Involving Domestic Help I
~
(b)(1)
(b)(3) CIAAct
(b)(3) NatSecAct
(b)(7)(c)
(b)(1)
(b)(3) CIAAct
.
~I~-=~~~-~--=>~~..,..-,-~=-,-------~~----.--c~-----c,----_j
b)
N S At
. In the absence of additional leads or information,the
( (3) at ec C alleged child abuse investigation is closed.
(b)(7)(c)
(b)(7)(c)
4.
15/~
Jeparately, there was an allegation by
the I
(b)(7)(cl
was mistreating [__]by not paying
(b)(1)
adequate wa"""' d.lrc1ng long work ho_y_r_s~---.a
making threats to
(b)(3) NatSecActhave family members, who reside in
During a
1
joint OIG I
I interview of
,
admitted paying
b)( )
the $470 per month instead of the required $1,000 per terms of
( 1
the ,cmu.rfct; however,
denied that I
I made threats to
(b)(3) CIAAct
the ~ family or that
used illegal drugs.
(b)(3) NatSecActSeparatel , a joint OIG
interview was con'ducted of
I
and c::=J admitted qaying only----$-400~ month to th_ _ e_
( b)(7)(c)
Additionally,l
J admitted th<>t L__Juses mari _llana _
and that some marijuana was present in L_] home but that ________]
had no knowledge of the il:J&gal drug use py
J until
recently informed D
thatl~ used marijuana.
On 27
September 2013, the Department of Justice declined prosecution
(b)(1)
pertaining to the alleged human trafficking allegations.
(b)(3) NatSecAct
5.
(U/ /-ffllffi) This Office considers the matter closed
and plans to take no further action. This information is
provided to you for informational purposes. No response is
required. The OIG point of contact is Special Agent L---~~~
(b)(7)(c)
I
_
j. This information is also being provided to
the D1rector of Office of Medical Services for informational
purposes.
6.
(U/ /+effe) This Memorandum contains information
protected by the Privacy Act. You should consult with the
Office of General Counsel prior to further dissemination to
ensure compliance with the Privacy Act.
cSignec!byj
L__---,-
cc:
(b )(7)( c)
(b)(1)
(b)(3)
CIAAct
(b)(3)
(tNatSecAct
(t(b )(7)(
NatSecAc
(b)( 1)
(b )(3)
NatSecAct
c)j
,,
1\
(b)(1)
(b)(3)
CIAAct
(b )(3)
NatSecAct
(b)(7)(c)
(b)(3)
CIAAct
(b)(3) CIAAct
D/OMS
SEC~OFORN
I
coo299687
SUBJECT:
(3//NE)
Alleged Abuse and Misconduct by CIA Officer
Involving Domestic Help 1
I
(b)( 1)
(b)(3) CIAAct
(b)(3) NatSecAct
(b)(3) CIAAct= (08 April 14)

Distribution:
Orig - DNCS
1 - CIO
1 - D/OS
1 - D/OMS
1 - AIG/INV
1 - CIO/FO/Review
1 - NCS Secretariat
1 - EA/D/OS
1 - DIR-OIG-INV-SAs
1 - DAIG/INV
1 - DIR/OIG/INV
1 - DIR/OIG/INV
SEC~FORN
I
C06299688
Approved for Release: 2015/05/05 C 0 6 2 9 9 6 8 8 : - - - - - - - - - - - -
CONF~OFORN
,--(b)(3) CIAAct
DIR/OIG1____
2 5 AprilL---.,2"0'1"4--------"
MEMORANDUM FOR:
FROM:
SUBJECT:
Director of Security
~(b)(3) CIAAct.
L
.
1
Assistant Inspector General for Investigations
+C//llf~
Allegation of Misconduct by Poiygraph
Examiner L(b)(3) CIAAct]
1. (C/1 NE J On 21 October 2013, the OIG commenced an

investigation relating to an allegation of misconduct by a
(b)(1)
polygraph examiner. That investigation is now complete, and
(b)(3) CIAAct this matter is being referred to you for information only.
(b)(1)
(b )(3) CIAAct
(b )(3) NatSecAct
(b)(7)(c)
(b)(3) NatSecAct
!E, '!iF~ Th 0
,
.
.~
d t
d h
2._
b)(?)( )
, >:
e IG ~ >nves_,_!_o_a_tio.n, e ermlne t at
(
C
polygraph examlner
.
J repeatedly used
techniques that vi
~
]' s policies and
. guidelines.
__ ... . .. .. . admitted to usin'il iJ~rop~r techniques in
an effort to lqn~iaht .
performance w1th
1
supervisors. I
I claimed that two of
supervisors
(b)(1)
were aware of and approved of these techn1ques; however, there
(b)(3) CIAAcl was no e;ridence to. substantiate supervisor approval of the
(b)( 3 ) NatSecActmauthonzed techmques.
(b)(7)(c)
3. (U/f'eYG.) This matter was referred to

Justice (DOJ) for criminal prosecution. DOJ
prosecution in lieu of administrative action
Office considers the matter closed and plans
the Department of
declined criminal
by the Agency. This
to take no further
(b)(3) CIAAct
(b)(7)(c)
(b)(3)
CIAAct
(b)(7)(c)
action. This information is provided to you for informational

purposes.
No response is required. The QI_point of contact is
Special Agent
_ _j
(b)(3) CIAAct
4. (U) This Memorandum may contain information protected

by the Privacy Act. You should con~ult with the Office of
General Counsel prior to further dissemination to ensure
compliance with the Privacy Act.
(b)(3) NatSecAct
I
C06299688
CONFIDE~OFORN
SUBJECT:
(C//NF)
Allegation of Misconduct by Polygraph
Examiner c=(b)( 3 ) CiAAd
Signed
bvl
(b)(3) CIAAct-
CONFIDE~NOFORN
I
C06299688
SUBJECT:
Approved for Release: 2015/05/05 C06299688:-------------
(G//!IP)
Allegation of Misconduct by Polygraph
Examiner L(b)( 3) CIAActJ
(b)(3JCIAAct -----
I (17
April 14)
L_----------------~~----------~
Distribution:
Orig - D/OS
1
AIG/INV
1
DS/OS FO Special Assistants
1
DAIG/INV
1
Counsel to the Inspector General
l
DIR-OIG-RA !NV Review
1
DIR-OIG-INV-SAs
CONFID~OFORN
I
C0303044
COUFIBBU':FI:hb
Office of Inspector .General

I.
Ollice of Jnsvector General (OIG) Administrative Data
(b)(3) CIAAct
Case No.:
(b)(3) CIAAct Investigator:
Date Received:
21 October 2013
Supervisor:
Date Opened:
Date Assigned:
5 November 2013
Case Type:
U.
Alleged Misconduct by Polygraph

'
Examiner
Case Title:
~S_A_d'--_--'(c:cb)'-'-(3=-")-'C=-ciAA'-'--'c""t_ _
21 October 2013
..
(b)( 1 )
~==- _l. -t7 On 21 October 2013, _the Office of Security's Personnel Security Group[Jb)(3 )UCiAAct
b)( ) CIAA _
hotified the Q:c-oflnsnek~eral (OIG) ofall:ed misconduct by polygraph exanu-ner
( 3
c1
IL(b )(3)CIAActalleged thatj
~ad deviated from acceptable
lb )( 1)
(b)(3) Na!Sec~Cllygrapbprocedures,whichresultedinabreachofprofessto responsibility. L(b)(3) CIAActl
(b)( ) CIAAct
3
(b )(7)( c)
discovered the allegations after an applicant challenged a statement from a polygrnph report, which
(b)( )
3
disqualifiedtlle applicant from CIA employment. Upon notification by I
(b) (3) C IAAct
(b )(3) CIAA~t> (3) CIAAct-----1initiated a review of the applicant's jlygraph examination conducted by
Na!SecAct
L____jThe intemaJL____)-eview determined that I

__ final report on the_ 'I"':_i_ c_ant ';'BS-inaccnrate. (b) (7 )(c)
J_
(b )(3) CIAAct
(,or_ ........ "" "'"'"' "" """"'"""'"
I_
1-
- -
-~
(b)(1)
____ /
(b )(3) C IAAct
\ Based upon these conclusions, the matter was referrl'd to OIG by the Office of
(b )( 3 ) NatSecA~furity and a Personnel Evaluation Board (PEB) was convened fo~
I
(b )(7)( c)
2.
~- - ---
~ 21 October 2013_,_QIG initiated a preliminary investigation on the matter.
~rovided OIG investigators with several briefings, which
(b)( 1 )
~ a baste compretlenston of the ~I aspects related to polygrnph exams.\
[also
(b)(3) CIAAct provided OIG with a summary of internal reviews conducted on\
polygra~_ll-""~,
(b )(3) NatSecAct
!>;buttal to the PEB allega?ons. PEB briefing notes, and a review oftheL(b )(3) CIAAct
(b)(7)(c)
L(b)(3) CIAActasrelatedtotheallegauons).
3. ~SeniorPolygraphExamin
(b )(3) CIAAct
were interviewed during this investigati011
(b) (7 )(c)
~
~ey had approved[:::Jimproper use of polygraph techniques.
'-----,__
(b)(7)(c)
jlenied claims by
(b)(3) CIAAct
- - - - - - - - - - - - - - - - - - - - - , ( b ) (7 )(c) INV~20l
(b)(1)
(b)(3) CIAAct
Page I of2
(b )( 3 ) NatSecA~.~s document is-controlled by the CWOIG and neither the document nor its contents should be
(b) (7) (C)
disseminated without prioriG authorization.
(b )(3) NatSecAct
I_
(b )(j)
(b)(3) CIAAct
(b )( )
3
NatSecAct
(b )(7)( C~)
\ u 1\
C IAAct
(b)(7)(c)
(b )(3)
CIAAct
(b)(7)(c)
(b )(3)
C IAAct
(b)( 7 )(c)
C06303044
(b)( 1)
Approved for Release: 2015/05/05 C06303044.
(b)(3) CIAAct
(b )(3) Na!SecAct
4. ~On30_QciQ!x;r_2QU,_aJ'~r.;Qnn_el Evaluatio:1n Bg!l[<l (PEB) c1:1nvened in relation t\1 the
(b )(7)( c)
allegatiqns againstl ______ presenteC(b )(3) CIAAcl' r~ ooard.
The PEB recqmmcnded terminatio:1n qf employment and revocat11:1n qf clearances tor~ The
PEB was co:1nducted independently and separate fmm the OIG investigatio:1n.
::J
III.
(b)(1) .
(b)( 1)
(b)(3) CIAAct
(b)(3)
Na!SecAct
(b)(7)(c)
Findings
5. (UIIf9-BO) On 18 February 2014, OIG referred this matter 11:1 the Department of Justice
(b)( 1)
(DOJ), Eastern DistrictqfVirginia, US Attorney's Office (AUS~(b)(G)=:J DOJ declined
(b)(3) CIAAct
pmsecution in lieu of administrative actiqn by the Agency.
,---~~~~~____,(b )(3)
__
6. -fETOn 28 February 2014, OIG co:1nducted im .in.terview with
Na!SecAc!
I }ulmittedtqrepeatedlyusingtechniquesthatviolatedl (b)(3) CIAAct liciesand
(b)(7)(c)
(b)(3) CIAAct \
(b 3 Na!SecAct.
.
.
said
useqfthese techmques wntnbuted t
h1gh clo:1sure rate,
)( )
n.l~Cll::Jupervsms v1ewe a' apo:1Sitlve.
sa1dOwanted to recetve p<:1sttlve feedback
(b )(7),{:3)(7)( c) fmnQupervisms and believed that these techniques allowed
stand out fmm the rest of the
pqlygraph examiners.
reiterated many qfthe statements made in0rehuttal memorandum
(b)(1)
tothePEBallegatio:1ns.
(b)(7)(c)
(b)(7)(c)
(b)(7)(c)
(b)(3) CIAAct
.
.
(b )(3) Na!SecAct . 7. (U/h"dUG) An Actiqn Request m No:1tification Memmandum (ARNM) will be forwarded to
(b)(?)(c)
mcD~rectorofSecunty.
Ow
IV.
Reyiew and Approval
Case Clo:1sing Memo submitted by Investigatm tq

Supervisor:
Case Closing Memo appmved by Supervis1:1r:
(b )(3) CIAAct
'111'.1!1
(b)(3) CIAAct
.
!
.j() ~- .'/
{/
JNV-201
Page 2 of2
CQNFIBHli'fiA"ti
(b)(1)
(b)(3) CIAAc!
(b )(3)
Na!SecAc!
(b)(7)(c)
' C06303044
Office oflnspector General

Memorandum of Investigative Activity (MOIA)
Case No.:
Case Title:
Alleged Misconduct by
Polygraph Examiner
Activity:
Source Review
Date Prepared:
II April 2014
[(b)(3) CIAAct_ __
Investigator:
. Date of Activity:
Location:
(b)(3) CIAAc,__ _
II April 2014
L(b)(3) CIAAct._ _ _ _ _ _ _ _ _ _ _ _ __
MOIApreparedby: (b)(3) C I A A c ' - - - , - - - - - - - - - ' - - - - - - - -
I. Jl!lnttt;S-) On this date, I completed a source review of the case closing memo for OIG Case
(b)(3) CIAAclJ
(b)(3) CIAAdestigator
(b)(3) CIAAct
il
OpJ !t/
INY-100
Page I of I
disseminated without prior iG authorization.
Approved for Release: 2015/05_/0_5-=.C.::.06.::.3::.c0:.:3:..::0..:4..:.4_ _ _ _ _ _ _ _ _ _ _. , - -
C 0.-6_2_9_9_5_8_6_ _ _______Approved for Rei~~~:~Jg~ffi C06299586

SE~RN

I.
Administrative Data
Case No.:
~b)(3) CIAAct j
Case Title:
Investigator:
l(b)(3) CIAAct_ _ __
Supervisor:
Date Received:
Date Assigned:
II.
(U) Former Agency Officer Alleges

Retaliation
~
, ====~-----------------
(b)(3) C IAAct
_ _ _I
- -- - - - - - - - - - -
09/26/2011
Date Opened: _0:. .:9. :. .:/2=-=6..:. .:/2:. .:0..1.:. .1: . .----------- - - - -
09/26/2011
Case Type:
----~-------------
Summary oflnvestigative Actions
......::F~1 --------(b)(3)
C IAAct
(b)(6)
(b)(7)(c)
(b)(3) CIAAct
- (b)( 6 )
i
'
(b)(1)
1. ~ On j
- -- ~ former Agency Staffofficer(b)(1)
(b)(3) CIAAct serv~dfro~.
.
.
(b)(7)(c)~ allegedthattheAgencyt~ok (b)(3) CIAAct
(b)( 3 ) NatSecACfpns~ls agamst ~tm for compla~nts he made to the Office of Inspector Generai(OIG) regardmg (b)(3) NatSecAct
(b )( )
.. nancml corruptiOn and other mtsconduct
Froml _
ser:ed a{b )(6)
6
I
(b)(3) CIAAct
. j Accordmgto(b)( 7 )(a)
(b),(7)(c)
[==: (b)(6)__j letter, the retaliation against him included: an Agency claim that he owes th'(b)( 7 )( )
Govemmen1(b )( 7 )( c)__jfor salary overpayments he received during his service as a mobilized

1 C
(b)( 1)
Reserve offi~.;~ cs uuuormed Services Employment and ReemJili>.Y!llent Rights Act (USERRA) violation
(b )( 3 ) CIAAct that occurred I
jimproperly forced him to
b)( ) N tS A rke annual leave to perform his military service in Iraq; deliberate violations in 2010 ofhis rights under .
(b )(6)
(
3
a ec C::.:-.e Privacy Act; and, after his resignation from the Agency j
the Agency's delay in
(b )(6) (b )(7)( c)
(b )(6)
tr~nsferring his securi~ clearances to his curre~t emplo~er, refus~l to ~o~plete a time~y. review of his (b )(7)( c)
(b )(7)( C)
wtfe's resume, and fat lure to transfer accurate mformatton regardtn!! hts hfe, health, vtston, and dental
~)( ) CIAA t insurance to his currentemployer. [-~also explaird in his J(b)(6)
letter that he had filed in
c the United States District Court, District of Columbia,
_ (b )(7)( c)
(b)(3)
(b )(6)
administrative claim against the Agency.
Pomplaint alleged the Agency committed
CIAAct
(b)(7)(c)
, deliberate violations of his rights under the Privacy Act.
(b)(6)
==:J
( 3
2. ~ In September 20 II, OIG initiated investigations to determine whetherC~

new claims in his [
]letter constituted acts of reprisal for his ~rotected communications to
Iprotected communications began
OIG and whether he was the victim of a USERRA violation. 11
(b)(6)
(b)(7)(c)
1
(U//~
~~ ~~~ ~( ~)
OIG investigated separately the possible USERRA violation and whether an Agency claim[_
for salary overpayments[==:Jreceived while serving as a mobilized
Reserve officer was tied to the "'-0 - USERRA violation. The results of the investi ation are re orted in case (b)(3) CIAAct_______ ____
INV-201
(b)(3) CIAAct
(b )(6)
Page l of3
(b)(6)
(b)(7)(c)
(U) This document is controlled by the CIA/OIG and neither the document nor its contents should be
(b)(7)(c)
.
(b)(3) NatSecAct
SE~ORN
Approved for Rel~l1<8SI~ C06299586
(b )!(b )(7)( c).Ct

(b)(6)
(b)(7)(c)
(b)(3)
C IAAct
(b)(6)
(b)(7)(c)
C06299586
Approved for
Rel~!i~:~~Jbeffi C06299586_ __
_ _ _ _ __
,
(b)(1)
SECRfl'itt~ePem<: (b)(3) CIAAct
(b )(3) NatSecAct
(b)(6).
,
_(b)(6)
.
in \ (b)f )(lc)drelatedpr_imarilyt?claimsthat \
(b)(7)(c)
J ad
7
haras""u \ulu dftd engaged m financaal and otherwrongdOIJ'I~ tn~
~ OIG considered
(b)(3) CIAAct
these issues of possible wrongdoing in other cases? [
ijn hl( b)( 3) C IAAct again accused
(b)( )
6
(b)(3) CIAAc(] ofretaliatory acts against him,[
_ _
(b)(6)1Consequently, OIG
(b)(6)
~nsidered whether - - [might have suffered retaliation froiD[ (b)( 7 )(c)_ _
~ (b)(7)(c)
7
(b)( )(c)l
(b)(3) CIAAct
.
-,
~
(b)(3) CIAAct
3. ~ OIG obtamed and examine<\_ (b)(6)_
e-mail mes~ges and the
1
(b)( 3 ) C IAAct [(b)(3) CIAAct~essages of his supervisor and (b)(7)(c)(b)(3) CIAAct
during
b)( )
Performance Appraisal Report~ securitv file. and
(b)( 1)
the period\_(b)(3) CIAAct reviewedc =
6
(
Official Personnetl'older. OIG obtained and reyiewe_q
(b )(7)( e)_ _
~essage
(b)(7)(c)
and debt calculations\
(b)(3) CIAAct
_ j In addition, OIG obtained and reviewed
(b)(3) CIAAct
I
(b )(3) CIAAct 1_
!time and attendanCe records from the _eeriods when he was performing his military service. (b )(3) NatSecAct
(b)(6)
OIGinterviewed ! -- _
(b)( 1)--=:] oiGalsoconsultedwi1(b)(6)
(b)(7)(c)
a legal expert on ~ower reprisals.
(b)( 3 ) CIAAct .
(b)(7)(c)
_j
c-=
(b)(3) NatSecAct
m.
c
(b)(3) IAAct
(b )(6)
Findings
(b)(7)(c)
(b)(3) CIAAct
_
!allegations of reprisals.
(b)(6)
(b)(6)
Regarding[
J USERRA claim, which OIG considered separately[ (b)(3) CIAAct~OIG did
(b)(7)(c)
(b )(7)( c)
not determine that Agency officers committed USERRA violations against[
_j md found no
1
evidence that an Age~cy claim for [
n salary overpayments t==]received during his
6
(b )( )
service as a mobilize
\Reserve officer was connected to the alleged USERRA violation or
(b)(6)
(b)( 7 )(c)
inappropriately calculated. The lack of substantiation for matters (b)(3) CIAActjrenders of no
(b)(7)(c)
(b )(3) C IAAct practical significance [ _ ~etaliation claims related to .USERRA and Agency debt repayment
(b )(6)
demands. In July 2012:-c=:::Jsettled his[
j claim against the Agency, and so OIG did not, as part
of this matter, consider whether Privacy Act violations occurred againstl
~s reprisals. Regarding
(b )(3) CIAAct
. (b)(7)( c)
' (b )( 3 ) CIAAct other, new allegations c = Jincluded in his
_j letter, OIG did not find that reviewable
(b )(6)
personnel actions, as defmed in Agency guidance or guidance found in Presidential Policy
b)( )
(b)(7)(c)
( 6
Directive/PPD-19, were present to warrant a complete investigation. Specifically, OIG found that the
non-transfer of accurate information regarding life, health, vision, and dental insurance to
(b )(3) C IAAct
' (b )(7)( C)
4. .
(U/~) OIG did not substantiate[
(b)(3) CIAAct
.
(b)( 3 ) CIAAct
. .
.
(b)(6)
2
(b)(6)
~ 01Gconsadered(b)(6 ) [prevaouscomplamtsmthefollo\(b)-(3)--CIAA t
(b)(!)(c)
(b)(7)(c)
_
c
lD){d) GIAAct
th\13) CIAActl~!?.}(JHc) _(b)(6) . .Jdealt..witl((b)(6)):1aimsofharassmentby l (b)(6)J
(b)(3) CIAAc!
_
(b)(7)(c)
_
. (b)(7)(c) c=Jhadfiledafornrb)f7)(ct
(b)(6)
. Equal Employment Opportunity (OEEO) harassment claim, OIG deferred to OEEO on the matt'b. \ub
(b)(3)
(b) ( ) (C)
OEEO inquiry rendered a false finding, meaning that harassment did not occur.
7
CIAAct
.
(b)(3) C IAAcU Thiscase, C
(b)( 6 )
elatedto?ultipleallegationstha~[~adein
(b)(6)
a 14-page amended submissaon to Olt(b )(7)( C )gataons related to tssues of harassment~ dascnmmatton, and
false reports/statements by [
.
J
also _(b)((.~)(7)(c)
(b )(3) C IAActted thatj
jwas involved in financial imprQPrieties and other misconduct. OIG handled the case
(b)(3) CIAAct
(b)(6)
as a grievance, and the case closure,L(b)(6)~reported that:
.
(b)(3)
All elements of Complainant's. subl(b \(7)(c )C f~n_d to have been pre~iously a~dress~d by ~ther
NatSecAct
(b )(7)( c)
means, and no grievance was appropn&,c. vn~ addat10nal concern submitted dunng an mtervaew was
checked and found to be unfounded. The case was completed with that action.
(b)(6)
(b)(7)(c)
3
~ The Assistant Inspector General for Investigations detennined [ (b) (6) ~ that this investigation
will focus only on the alleged reprisals
(b )(7)( c)
fand the Agency
cannot implement relative to him OIG recommendations suggesting disciplinary or ameliorative measures.
INV-201
(b)(3) CIAAct
Page 2 of 3
(b)(6)
(b)(7)(c)
5ECRTN~~OF0~(
Approved for Re11:a41Si..1(85l~ C06299586
co6299586
Approved for
Rel~~~:~~}beffi C 0 6 2 9 9 5 8 6 - - - - - - - - . SE~ORN
Case Closing Mem orandum

. current employer and the Agency's delay of four months to transfer his security clearances to his current
employer did not involve, as required in guidance:
A decision concerning pay, benefits, or awards, or concerning education or training if the
education or training may reasonably be expected to lead to an appointment, promotion,
performance evaluation, or other action ... [bold and italics added].
(b)(3) CIAAct
(b)(6)
Relative to \ _ __\ claim that the Agency retaliated against him by refusing to complete a timely review
(b)(7)(c)
of his wife's resume, OlG also determined that the claim is not a reviewable personnel action, as the
action allegedly occurred against\_ _
\wife, not against him.
--==:1rinb~ informed of the results ofthis
(b)(3) CIAAct
5. (U/~ I
- um:stigation and ofrelatedOIG investigation L
(b)( )
6
(b)(3) CIAAct' matter is closed.
(b)(3) CIAAct
(b)(6)
(b)(7)(c)
(b)(7)(c)
IV.
Review and Approval

Supervisor:
Case Closing Memo approved by SuperVisor:
j
L
l
(b)(3) CIAAct ) jPltJ
"{SlgiifDate)
,/13
---,
(b )(3) C IAAct.--rf.:w~j_f-1-,,;)....3'_ _ _ _ _
(Sigh Tliate)
J;NV-201
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~ORN
Approved for Rel~i..1(S5J~ C0629958~'--------------
C06299597
Approved for
Rel~~~:~~}o~ffi C06299597------~------.
SDCRB'f//UOPOR:!i
Office of Inspector Genera'


I.
Administrative Data
(b)(3) CIAAct
~-=-
Case No.:
(b)(3) CIAAct
.
mvesugator:
= . _____
_!
Unauthorized Disclosure of
Cla'isified
Case Title:
-=~~~====,====--------
Supervisor:
SAcJ (b)(3,_
) .::_
c ;.:
'IAA
..:::_:_c.::..:t:___ _ _
Date Received:
17 October 20 12
Date Opened:
l9 October 2012
Date Assigned:
19 October 2012
Case Type:
Full Investigation
fl.
--=
1. "'(~//HF)- On 17 October 2012, the Office of Inspector General (OIG) received notification
from the Office of Security (OS) that j
(b)(6)_
~ad found cla<>!'.ified
material on personal hard drive seized from l(b )(7)l c);e of a former Agency contractor. The classitied
data was(b )(6)b>l_~xaminers during tilt.:n analysis of the hard drive a<> part of an unrelated
inv~tig~(b)( 7 )(c)~mo~y. The subject was identified as [_ _
_ _l a contractor
(b )(3) C IAAct
Jwas terminated and his clearances
(b )(6)
~~okeal - (b)( 6 ) _j for misusing government systems related to the sexual exploitation of
(b)(7)(c) children.
(b)( 7 )(c) .
.
---==
--::=_
(b)(3)
CIAAct
- (b)(6)
(b)(7)(c
2. ~.Vfci~ The OIG obtained a copy of the data from OS and rt.:vit.:wed it to confirm the
classification. The OIG confirmed that document'i labeled "Top Secret" were present and contacted the
Federdl Bureau of Investigation (FBI) to obtain a search warrant to review the computer eguioment_i_n__t.M
custody [ _ ~ The OIG seized the equipmentL
~~
~
~~
The OIG referred the findings to the FBI and to the Counterintelligence Center
(CIC), and supported their investigative efforts. The FBI and CIC stopped providing updates t(b )( 1}IG
j
jand have not requested assistance from the OIG since that date.
(b )(3) CIAAct
:=J
L _
111.
'
.
(b)(3) NatSecAct
,
(b)(6)
(b)(7)(c)
3. f~:@l~ 0~ (b )(7)( c)__] the OIG notified the Department of Justice of the t(b )(7)( e)
classified material. On
~ the OIG formally referred the matter to the FBI. On!
I
~- Jthe OIG executed a search warrant for possession of child pornogr.t..l.'.!!Y_!o seize the
(b )(6)
com
(3) CIAAct
6)
)(c)
Findings
C__
j <
=-~u;pment belonR; w[ J ,. w" ;n the""'""'';"" of lh<~:b )( )~
b )(7)( c)
m~ ~ r---
(b)(3) C IAAct
t-= 4. ~
(b)(3) NatSecAct
-==----'----"== = -- - '==::...-.:__:===-(b )(7)( c )
(b)(7)(e)
-INV-201
Page I of J
,dis.eminatcd_withou.Lnrior IG_authorization
(b)(3) NatSecAct
-SECRET I lbJQFOR:N
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C06299597
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Rei~~~:~~J5~f:B C06299597
- - - - - - -------------- -- - -- -- - - - - - -- -- ------------ - --- -- -

..._9ECPi:T/ /!i6PORN

(b)(3) CIAAct [ ~personal laptop contained files with personal data including social security numbers, dates
(b )(6)
of birth, and clearances on t (b)(3) CIAAct~Agencv-affilialed.indi.Y.idu~
(b)(1)
(b)(7)(c)
(b)(3) CIAAct
I
L _________ __
_ (b)(3) NatSecAct
(b)(3) CIAAct
(b)(?)(c)
(b )(6)
Numerous technical document<; related to Agency systems were found on L ]laptop.
(b)(3)
(b)(?)( c)
5. ~5/Rlf) Based on the results ofthe initial review, OIG referred the matter to the
C IAAct
Counterintelligence Center's
- (b)(3) CIAAct_
=The CIC5 - (b)(6)
and the FBI began a joint counterintelligence investigation into[
[activitiesl
__
(b )(7)( c)
[--=-
___
- -
___
_j
.
6. 'fflHNfi_ On l(b )(7)(c)_the1r request. I
,he OIG turned over all of the evidence gathered to H(-bco)( )-:tt
1 ~
(b)(1)
(b)(3) CIAAct
-(b)~ 3 ) N tSecAct
- (b)(3) NatSecAct
7. ~ Th(b)(Cl(C)ntified approximo..~ 1
,..~,~ .......... ~uments present o..!!.l(b)(7)(e)
personal systems, which were confirmed by a subject matter expert
_ (b )(3) C IAAct_ _
I
[
_(b)(3) CIAAct
~dditionally, more than [..=limages allegedly containing child (b)(3) CIAAct
pomogmphy were identified onl _ jcomputers.
~}fZ)__{fl
(b )(6)
r== -
(b)(1)
(b)(3) CIAAct
(b)(3) NatSecAct
(b)(6)
(b)(7)(c)
(b)(7)(e)
(b)(7)(c)
(b)(3) CIAAct
(b)(6)
_ __ (b)(7)(c)
9. fS#NfJ On [
~leaded guilnjof possession of child pornography.[
j;as sentenced
b)(3) CIAAct_
and registration as a sex offender.
b)(6)
- (b)(6)---,
b){ 7 ){ )
C
(b)(3) CIAAct
(b)(6)_
(b)(7)(c)
[counts
10. ~ On [- (b )(7){ c)the Office of General Counsel notified the OIG that the FBI had
executed a search warrant on1
JfeS'.dence and obtained an 8GB tlash drive[
__
[
~ The OGC advised that the FBI would be completing the
==.J
forensic analysis of the flash drive and closing the case, pending the receipt of additional information.
II. ~lf4f7 The FBI ha<> ao;sumed the investigation a.'i the primary investigative agency and the
OIG has not received any requests for additional support since March 2013. As a result of no further OIG
investigative activity occurring and the FBI jurisdiction over the case, the OJG is closing this
investigation. Should additional information be developed, the OIG may consider reopening the matter.
INV-20 1
Page 2 of 3
SECRET I /NOF9FMf
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(b)(3)
CIAAct
(b )(6)
(b)(7)(c)
C06299597
--Approved for
Rei~~~:~Jgef:B C0629959l- --
- --
----.
~CRFT/ /14'0F URN

IV.
Review and Approval

Supervisor:
(b)(3) CIAAct
-L_
(b)(3)
ate)
CIAAc~~~~, } a.pJo:f
INV-201
Page 3 of 3
_ru;;CRET/ /N9P8R:l~
Approved for Rel~i2(851ffitiln C06299597
Centrallntelligence Agency
Washington, D.C. 20505
6 August 2015
Jason Leopold
Reference: F-2015-00039 I 14-cv-19879

Dear Mr. Leopold:
This letter is the fourth and final response to your 3 October 2014 Freedom of Information Act
(FOIA) request for disclosure of the following UNCLASSIFIED' reports from the Central Intelligence
Agency Office of Inspector General:
1. Former Agency Officer Alleges Retaliation for Protected Disclosures- ISSUE DATE MARCH
2013
2. Alleged Violation of CIA-Unique Post Employment Restrictions- ISSUE DATE FEBRUARY
2013
3. Misuse of Government Systems for Database Searches- ISSUE DATE FEBRUARY 2013
4. Agency Contractor Alleged Reprisal for Wbistleblowing- ISSUE DATE FEBRUARY 2013
5. Review of[redacted] Allegations from DOD- ISSUE DATEMAY 2013
6. Alleged Retribution Against Alleged Wbistleblower- ISSUE DATE JUNE 2013
7. Alleged Classified Information Leaked to Foreigu Army Officials- ISSUE DATE JULY 2013
8. Misuse of Agency Credential by Former (b3) Staff Officer- ISSUE DATE AUGUST 2013
9. Unauthorized Disclosure of Classified Information- ISSUE DATE AUGUST 2013
10. Request for Whistleblower Protection by Former Interrogator- ISSUE DATE AUGUST 2013
11. Counterfeiting of CIA Credentials- ISSUE DATE SEPTEMBER 2013
Please note that these reports are not in fact UNCLASSIFIED.
12. Ethics Violations Involving Film Producers- ISSUE DATE SEPTEMBER 2013
13. Alleged Use of Government Systems to Order Steroids- ISSUE DATE OCTOBER 2013
14. Alleged War Crimes by Agency Personnel Overseas -ISSUE DATE NOVEMBER 2013
15. Alleged Abuse of Detainees Overseas- ISSUE DATE JANUARY 2014
16. Disclosure of Classified Information by Former D/CIA- ISSUE DATE MARCH 2014
17. Alleged Abuse and Misconduct Overseas- ISSUE DATE MARCH 2014
18. Alleged Misattribution of Detainee Intelligence- ISSUE DATE APRIL 2014
19. Alleged Misconduct by Polygrapher- ISSUE DATE MARCH 2014
20. Theft ofUSG Property: E Bay sale ofNVGs- ISSUE DATEMAY 2014
21. Allegation of Misconduct by Polygrapher- ISSUE DATE MAY 2014
We completed a thorough search for records responsive to your request and although our prior
responses stated that we located twenty-three (23) responsive documents, further review of one of those
documents indicates that the document is not one of the IG reports listed in the FOIA request and is,
therefore, not responsive. Thus far, we have produced nineteen (19) documents in segregable form and
denied two (2) in their entirety. At this time, one (1) additional document can be released in segregable
form with redactions made on the basis ofFOIA exemptions (b)(l), (b)(3), (b)(6), (b)(7)(c), and
(b)(7)(e). Exemption (b)(3) pertains to Section 6 of the Central Intelligence Agency Act of 1949, 50
U.S.C. 3507, noted as exemption "(b)(3)ClAAct" on the enclosed document, and/or Section 102A(i)(l)
of the National Security Act of1947, 50 U.S.C 3024(i)(l), noted as exemption "(b)(3)NatSecAct" on
the enclosed document.
Because the above-referenced request is a subject of pending litigation in federal court, in
accordance with Agency regulations as set forth at Section 1900.42 of Title 32 of the Code of Federal
Regulations, you are not entitled to appeal this determination administratively.
Sincerely,
;lJM)~~~
Michael Lavergne
Information and Privacy Coordinator
Enclosure
C06299690

L
Administrative Data
Case No.:
{b)(3) CIJI.f.~c~t_ __
Case Title:
Investigator:
~b)(3) CIAAct]
Supervisor:
Theft ofUSG Property: B-Bay Sale

ofNVGs
(b)(3) CIAAct
Date Received:
30 November 2012
Date Opened: 4 December 2012
Date Assigned:
4 December 2012
Case Type:
H.
Full Investigation
(b)(1)(b )(3) CIAAct

(b )(3) NatSecAct
(b )(6)
(b)(7)(c)
1. ~SIR~ On 30 November 2012,

(b)( 1)
notified the Office of Inspeetor General (OIG)"Lth~a~t~at~leas~t~o-ne_p_arr~-o"fAN""t"A'V""S"-6cc(V)"""N~igh~t'"V~i~sio_n_ _
(b)(3) CIAAct
(b)(3) NatSecAcbggles (NVG), which were believed to be A encyproperty, were reported to be for sale on eBay, an
(b)(6)
internet auction website. According to
eD
ent of Defense OD) initially discovered
(b)(1)
theNVGs for sale and reported thema(ter
on 30November2012. (b)(7)(c)
(b )(3) NatSecAct~taff queried Agency records and determined that the reported NVG serial number was associated
(b)( ) with Agency Shipment Order Number (Sm(b)(3) CIAActch was a shipment of 17 sets ofNVGs
(b)(1)
1
I
_ (b)(3) CIAAct
(b)(3) NatSecAct
2. (SIINH:) On 4 December 2012 the OIG opened an official investigation into the ma\ter. on(b )(3) NatSecAct
7 December 2012, OIG interviewe (b)( 1 )
d reviewed documeotiltion .,eruunin to the NVGs
(b )(3) NatSecAc
According
from both
(b)(3)
(b)(3) CIAAct to Agency records, theNVGs arrived at
on 2June 2011, at which time alii? sets ofNVGs were
CIAAct
(b)(6)
inventoriedandaccountedfor. On21June2011,1
lanA~encycontractorl
I
(b)(6)
(b )(7)( c)
received SOJ(b )(3) CIAAc!transported the 17 NVGs to th~
}warehouse, located[
I
(b)(7)( c)
L___
__j ~-~designated the NVGs for disposal by.secure destruction on 28 February 2012. The
NVGs were last inventoried on 15 March 2012 by propertv tnmCin (PTI) personnel '(b)( 1 )_::]in
. (b)(1)
preparationfrirdestruction.
(b)(1)
(b\(3) NatSecAct
(b)(3)
(b)(3) NatSecAct
'
(b )(3) NatSecAct
3. fU'JIIQWl On 10 Decemher2012, OIG contacted the Pentagon point of contilct for the
CIAAct
Ureferral,
(b)( 6)
referred OIG to US Army Criminal Investigative Division (CID),
(b)(6)
SA
On II January 2013, OIG coordinated with the US Army CID Field Investigative Unit (FlU)
(b)(7)(c)
to obtain further ioformation concerning the matter. FlU advised OIG that the NVGs were in the
(b )(6)
possession ofCID office, Carlisle Barracks, PA.
(b)(7)(c)
c=
!NV-20!
Page I of2
I disseminated without nrior IG an~:;:~:atSecAct
I
I.
.SFCPF'P//N8F6ltl4' ,
C06299690

SEefffi'f//l15PO!tN

4. (U/!f'eOO) According to CID's investigation, the NVGs were first documented in the
possession of the Defense Reutilization and Marketing Office (DRMO), Tobyhanna AnnyDepot. PA
where they were erroneously designated for sale to the public. A private company, Gll..CO, then
purchased the NVGs legally from a government auction. CID at Carlisle Barracks seized the NVGs from
Gll..CO, pursuant to their investigation related to government property being sold on eBay.
5. fflffl<f') On 24July 2013, OIG obtained from CID 7 sets of AN/AVS-6 NVGs which directly
correlated by serial number to those inventoried under SON
CID obtained all 7 sets of NVGs
from GILCO during their investigation. CID also provided OIG with a copy of their Report of
Investigatiol! pertaining to the NVGs, which was appended to the case file.
(b )(3) CIAAct
m.
(b )(1)
6. -ceTThe OIG investigation found that 17 Agency-owned NVGs were received by c=(b )(3) NatSecAct
and destined for destruction; however, by unknown means, at least 7 were transferred to DRMO at
Tobyhanna Anny Depot, PA. The DRMO subsequently released the NVGs for sale to the public without
the requisite demilitarization of the equipment. GILCO LLC, of Muncy, PA, subsequently obtained the
NVGs through a government auction, and later posted the NVGs for sale on eBay.
7. i7" Due to a lack of evidence to suooort the alleoation of theft of US ovemment oronertv,
this matter is being cl~(b)( 1)
(b)(3) CIAAct
(b)(7)(e)
IThe investi~ration found no evidence to
indicate that the NVGs were stolen. I
(b )(1)
L-~~~~~~~~~~-------(b)(3) CI_AA_c_t_ __ j
(b)(7)(e)
IV.
Review and Approval
Case Closing Memo submitted by Investigator

Supervisor:
11
(b)(3) CIAAct
1"'"6'"'
.L
(_b)-(3-)-C-IAA_ct_
__
_...,
lp,L~
__j~ 4 jz>/3
INV-201
Page2of2.
SECRE'3?//NOF9R:Ii

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Centra!

Washington, D.C. 20505

Reference: F-2015-00039 I 14-cv-19879

11. Counterfeiting of CIA Credentials- ISSUE DATE SEPTEMBER 2013

----Approved for Release: 2015/05/05

. CIA/OIG Loan Copy

(U/IFOUO) ALLEGED VIOLATION OF CIA-UNIQUE POST

Assistant Inspector General

NOTICE: The information in this report

and should be handled accordingly.

Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _ _ __

CWOIG Loan Copy

OFFICE OF INSPECTOR GENERAL

(U) SECTION A- SUBJECT

Approved f~_r Release 2015/05/05 C06299587

Approved for Release: 2015/05/05 C06299587 _ _~--------....,

CWOIG Loan Copy

(U) SECTION B PREDICATION

(U) SECTION C POTENTIAL VIOLATIONS

Approved for Release: 2015/05/05 C06299587

Approved for Release: 2015/05/05 C06299587~-----------,

CWOIG Loan Copy

Approved for Release: 2015/05/05 C06:=2c"9=95"'8"'7'-------------

-Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _ _ _ _ _""""1

CWOIG Loan Copy

(b_J_(?_J(_c_)_ ____j DOJ/PIS noted lhat "the fact lhat

(U) SECTION D -INVESTIGATIVE FINDINGS

(U) ETHICS ADVICE PROVIDED

7. (U) The CIA/OGC Ethics Counsel advised

Approved for Release 2015/05/05 C06299587

Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _ _ _ _ ___,

CWOIG Loan Copy

Approved for Release: 2015/05/05 C06299587

Approved for Release: 2015/05/05 C06299587_ _ _ _ _ _ _ _ _ _ _ _...,

CWOIG Loan Copy

(U) [ (b )(7)( c)-'rOST-EMPWYMENT ACTIVITIES INVOLVING FOREIGN

11. (U) The OIG investigation found thatJifrequently interacted with,---~

Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _ _ _ _ ___,

---------------------CWOIG Loan Copy

Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _ _ _ _ _,

CWOIG Loan Copy

Approved for Release: 2015/05/05 C06299587

Approved for Release: 2015/05/05 C06299587

CWOIG Loan Copy

Approved for Release: 2015/05/05 C06299587

Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _ _ _ _ __

CIAIOIG Loan Copy

(U) SECTION 5- RECOMMENDATION

Approved for Release: 2015/05/05 C06299587

Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _...,._ __

Leru;r ~L(b)(?)(c)~ from CIA OGC t(b)(7)(c[..,garding post-employment

Approved for Release: 2015/05/05 C06299587

Approved for Release: 2015/05/05 C06299587

Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _ _ _ _ __

j._-_(_bJ_(?_J_(c_J_ _ _-_--___,--[ and

I understand and.agree thst should I violate this

reprimand, (ii) the f'oracl.osu.re of any future CIA

deter.mination that the Agency seeks as a r&nedy at law the

Approved for Release: 2015/05/05 C06299587

Approved for Release: 2015/05/05 C06299587_ _ _ _ _ _ _ _ _ _ __

Retir1M118nt Sys~ Special category, social security benefits

I understand that each provision of this Agreement is

a court should find any provieion of

Approved for Release: 2015/05/05 C06299587 _ _ _ _ _ _ _ _..