The Foreign Service Journal, June 2010

J U N E 2 0 1 0 / F O R E I G N S E R V I C E J O U R N A L 33 cases, much later). The single fac- tor that appears to link them all is a pattern of questionable ethical choices. The earliest of these poor ethical choices typically played out in two distinct areas: 1) Gifts. Whether in the form of chocolates from an immigration firm at the holidays, a cake baked by a grateful immigrant visa recipient, or a free hotel room on the coast, presents are generally inappropriate and should be politely declined with a brief reference to the strict legal guidelines under which we operate. That said, sometimes accepting a gift is not only ap- propriate but essential. All officers should refer to the ethics guidelines available from L/Ethics on iNet for any clarification of what is and is not acceptable under the gift regulations. Any specific questions should be referred to L/Ethics by submitting a question on the L intranet site: http://l.s.state.sbu/sites/emp/pages/ askquestion.aspx. 2) Conflicts of Interest. CID has noted that malfeasant employees often did not recuse themselves from cases involving their neigh- bors, business associates, relatives or others to whom there was a per- ceived connection. While an actual conflict of inter- est is clearly a problem, even a per- ceived one can be harmful. Again, transparency is key. Lax Management. In nearly every case analyzed, managers failed to ensure that procedures were properly taught and followed, personnel were adequately super- vised, or appropriate management controls were in place. Instead, they appeared to confuse the existence of man- agement controls with a lack of trust in employees. In reality, management controls and appropriate over- F O C U S In reality, management controls and appropriate oversight help create a situation where trust is possible.