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Home News Archive More General Misconduct

More General Misconduct

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As we wrote a while ago, “Nobody should be surprised that employees will abuse company credit cards. It’s a known thing….” By no means is the abuse limited to corporate employees. Indeed, we’ve written several articles on the misuse of credit cards by both contractor employees and government employees. It’s an equal opportunity phenomenon.

We’ve also written before about abuse of privileges by the highest ranks of senior military leadership. For example, this article described how Major General William Ward “engaged in multiple forms of misconduct related to official and unofficial travel, misused a Government vehicle, misused Official Representation Funds [by distributing them to persons not authorized to receive them], wasted Government funds, and misused his position [by permitting staff members to perform personal services for him].” Not to be outdone, other military services—including both the US Air Force and US Navy—have had their own share of high-rank misdeeds.

Today’s story, however, is brought to you by the US Army and the Department of Defense Inspector General. Not to mention Major General Ronald Lewis, who served as Senior Military Assistant (SMA) to the Secretary of Defense.

The DoDIG investigated three allegations made about MG Lewis, including that he—

(1) misused his government travel charge card (GTCC) for personal expenses;

(2) made false official statements regarding his GTCC misuse;

and (3) engaged in a course of inappropriate behavior that included patronizing an establishment off-limits to U.S. military personnel, drinking to excess in public, and improper interactions with females.

The DoDIG substantiated all three allegations.

We are not going to delve into the salacious details of the DoDIG report. We included a link (above) so you can find them out for yourself, if you have a mind to.

What’s interesting (to us) is that MG Lewis was alleged to have made false statements. Specifically, the IG found that –

… MG Lewis violated the Uniform Code of Military Justice (UCMJ), Article 107, which prohibits individuals from making false statements related to their official duties, when he made false official verbal statements to subordinates and a false official written statement to Citibank regarding his GTCC use in Itaewon, Seoul. His GTCC statement and receipts confirm that he visited the off-limits Candy Bar club, where he charged $1,121.25 in personal expenses to his GTCC, and received some form of services or benefits from those transactions. When Office of the Secretary of Defense staff asked MG Lewis if he made the charges, he denied doing so. He then executed a digitally signed declaration to Citibank attesting that he did not make the charges to his GTCC at the Candy Bar club or receive services there. MG Lewis’ verbal statements to subordinates and written statement to Citibank denying that he made charges to his GTCC at the Candy Bar club were false. He knew that he used his GTCC there and received services. His false statements violated UCMJ Article 107 because preparing a voucher for official travel reimbursement and executing a report to the GTCC issuer relate to his official duties. The false statements caused Citibank to remove all the Candy Bar club charges from MG Lewis’ GTCC account, causing financial loss to Citibank.

We always make it a point to tell our clients that they must not lie or mislead government auditors in any manner. We now note that a similar prohibition applies to military personnel when conducting official duties; or, in this case, when making official statements about conduct that was definitely not a part of their official duties.




In March 2009, Nick Sanders’ article “Surviving Government Audits: Have the Rules of Engagement Changed?” was published in Government Contract Costs, Pricing & Accounting Reports (4 No. 2 GCCPAR P. 11). Apogee Consulting, Inc. is proud to announce that Mr. Sanders’ article was selected for reprint and publication in Thomson West’s The New Landscape of Government Contracting.  Mr. Sanders, Apogee Consulting’s Principal Consultant, joins such distinguished contributors as Professors Steven Schooner and Christopher Yukins, Luis Victorino and John Chierachella, Joseph West and Karen Manos, Joseph Barsalona and Philip Koos and Richard Meene, and several others.  The text covers a lot of ground, ranging from the American Recovery and Reinvestment Act (ARRA) to Business Ethics and Corporate Compliance, and includes several articles on the False Claim Act and the Foreign Corrupt Practices Act.  In addition, the text includes the full text of many statutory and regulatory matters affecting Government contract compliance.


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