Were You An Attorney At 
EPA (Even If You Didn't Practice)?
Lawyers are reminded to consult their state bar rules which may differ from 18 USC § 207. Even if you were not working at EPA as an attorney, if you are admitted to practice, then you should review your bar rules. Though the federal post-employment laws permit “behind the scenes” conversations, the American Bar Association (ABA) restricts such communication. ABA Model Rule 1.11 permits a former government employee to represent a client in connection with a matter in which the lawyer participated personally and substantially as a “public officer or employee” only if he first obtains consent from the appropriate government agency.
The District of Columbia (DC) Bar is even more restrictive than the ABA. DC Bar rule 1.11(a) prohibits the former employee from accepting employment in connection with a matter which is the same as, or substantially related to, a matter in which the lawyer participated personally and substantially as a public officer or employee. Under this rule, there is no waiver possibility, and the former government lawyer is not permitted even to provide “behind the scenes” work.
For these rules to apply, you do not need to have been classified as an attorney in the government; rather, you need only to have been a government employee who is licensed to practice law. So if you are lawyer working in a non-lawyer job in a program office and decide to leave federal service, you may have additional restrictions set forth by your State bar.
