Mr. David Huitema
Assistant Legal Adviser
Alternate Designated Agency Ethics Official
Office of the Legal Adviser
Department of State
 

Re:

Ethics Undertakings

Dear Mr. Huitema:
I am committed to the highest standards of ethical conduct for government officials. If
confirmed as Senior Adviser to the State of Israel, as required by 18 U.S.C. § 208(a), I will not
participate personally and substantially in any particular matter in which I know that I have a
financial interest directly and predictably affected by the matter, or in which I know that a person
whose interests are imputed to me has a financial interest directly and predictably affected by the
matter, unless I first obtain a written waiver, pursuant to 18 U.S.C. § 208(b)(1), or qualify for a
regulatory exemption, pursuant to 18 U.S.C. § 208(b)(2). I understand that the interests of the
following persons are imputed to me: any spouse or minor child of mine; any general partner of a
partnership in which I am a limited or general partner; any organization in which I serve as
officer, director, trustee, general partner or employee; and any person or organization with which
I am negotiating or have an arrangement concerning prospective employment.
I understand that a heightened prospect of a conflict of interest could exist as to
companies that maintain a presence in the State of Israel, because they may be more likely than
other companies to seek official assistance from or make contact with the Embassy or otherwise
be affected by policies and engagement implemented by the Embassy. I will remain alert to the
possible need to recuse where appropriate.
Upon confirmation, I will resign from my position Beis Medrash of Woodmere and my
unpaid position as a Committee Member of the Shulamith School for Girls. For a period of one
year after my resignation, I will not participate personally and substantially in any particular
matter involving specific parties in which I know the Beis Medrash of Woodmere or the
Shulamith School for Girls is a party or represents a party if I determine that a reasonable person
with knowledge of the relevant facts would question my impartiality in the matter, unless I am
first authorized to participate, pursuant to 5 C.F.R. § 2635, subpart E.
Upon confirmation, I will resign or will have already resigned from my positions with the
following entities: Copia Interactive and Shining City Community. For a period of one year
after my resignation from each of these entities, I will not participate personally and substantially
in any particular matter involving specific parties in which I know that entity is a party or
represents a party, unless I am first authorized to participate, pursuant to 5 C.F.R. § 2635.502(d).
I will retain my positions with Etsah LLC, L3C Capital Partners and Light Stone Three
LLC though I will not participate personally and substantially in any particular matter that to my
knowledge has a direct and predictable effect on the financial interests of Etsah LLC, L3C
Capital Partners and Light Stone Three LLC unless I first obtain a written waiver, pursuant to 18
U.S.C. § 208(b)(1), or qualify for a regulatory exemption, pursuant to 18 U.S.C. § 208(b)(2). In

 addition, I will not participate personally and substantially in any particular matter involving
specific parties in which I know a former client of mine is a party or represents a party for a
period of one year after I last provided service to that client, unless I am first authorized to
participate, pursuant to 5 C.F.R. § 2635.502(d).
Based on work that I performed for the Legacy Foundation in 2016-2017; Copia
Interactive in 2016; and Shining City in 2016-2017, these three entities are under a contractual
obligation to make certain payments to me for services performed. I will not participate
personally and substantially in any particular matter that to my knowledge has a direct and
predictable effect on the ability or willingness of the Legacy Foundation, Copia Interactive, and
Shining City Community to provide this contractual benefit to me, unless I first obtain a written
waiver, pursuant to 18 U.S.C. § 208(b)(1).
In addition, I will recuse myself from participation on a case-by-case basis in any
particular matter involving specific parties in which I determine that a reasonable person with
knowledge of the relevant facts would question my impartiality in that matter, unless I am first
authorized to participate, pursuant to 5 C.F.R. § 2635.502(d).
I understand that as an appointee I will be required to sign the Ethics Pledge required
under the Executive Order dated January 28, 2017 (“Ethics Commitments by Executive Branch
Appointees”) and that I will be bound by the requirements and restrictions therein in addition to
the commitments I have made in this ethics agreement.
I have been advised that this ethics agreement will be posted publicly, consistent with
5 U.S.C. § 552, on the website of the U.S. Office of Government Ethics with ethics agreements
of other Presidential nominees who file public financial disclosure reports.

Sincerely,

Aryeh N. Lightstone