January 5, 2009: Clinton tells the State Department that she will go “above and beyond” the law and regulations to avoid even the appearance of conflict of interest between the department and the Clinton Foundation.

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Jim Thessin (Credit: American Airlines volvió a Paraguay)

Clinton writes a formal letter to Jim Thessin, who is a deputy legal adviser and “designated agency ethics official” for the State Department. In it, she states, “To avoid even the appearance of a conflict” of interest, she and her husband Bill Clinton are “voluntarily taking steps that go above and beyond the requirements of the law and ethics regulations with respect to [Bill’s] personal income earned from speeches and consulting as well as respect to the William J. Clinton Foundation and its initiatives.”

She goes on to list in detail more pledges to avoid any potential conflicts of interest. Regarding the Clinton Foundation, she writes: “For the duration of my appointment as Secretary [of State] if I am confirmed, I will not participate personally and substantially in any particular matter involving specific parties in which The William J. Clinton Foundation (or the Clinton Global Initiative) is a party or represents a party…”

She concludes with a catch-all, “Finally, I will recuse myself from participation on a case by case basis in any particular matter in which, in my judgment, I determine that a reasonable person with knowledge of the relevant facts would question my impartiality…”  (US Senate, 1/5/2009)