Petitioner seeks review of an Oregon Government Ethics Commission (Commission) order that required him to pay civil penalties totalling $9,000 and to forfeit $90,437. The sole issue is whether the Commission has authority to investigate and punish violations of ORS chapter 244 that were committed by a person as a public official, if that person is no longer a public official. We hold that the Commission has that authority.

The facts are not disputed. Before his retirement on September 30,1990, petitioner was employed by the Oregon State Police (OSP) as a major. His duties included negotiating with private parties for the development of OSP facilities. While negotiating with Norm Schroth for the development of OSP facilities in Gold Beach, Klamath Falls, Newport and Umatilla, petitioner engaged in a private transaction with Schroth. Schroth gave petitioner a motor home and a car, valued together at $11,425, and petitioner gave Schroth three handguns, valued together at $1,257. Petitioner’s net financial gain from that trade was $10,168. During that same period, Schroth also gave petitioner an expense-paid trip from Portland to Reno, Nevada, valued at $455.50, and two tickets to a professional basketball game, valued at $95.

Similarly, while negotiating on behalf of OSP with Stan, Clay and Jeff Zeeb for the development of OSP facilities in Salem and Central Point, petitioner entered into a private transaction with the Zeebs. Petitioner traded his parcel of unimproved real property, valued at $9,500, for a condominium, valued at $44,000. Petitioner’s net gain from that transaction was $34,500. At that time, petitioner also disclosed to Stan Zeeb an internal OSP memorandum that described the address of a parcel of real property in Central Point that OSP was considering acquiring, the name of the owner, and the price the owner was asking.

On October 16, 1992, the Commission voted to conduct a “prehminary review” of possible violations of ORS chapter 244 by petitioner during his tenure with OSP. It notified petitioner of its decision. Petitioner moved to dismiss *684the case on the ground that the Commission lacked jurisdiction over him, because he had retired and therefore was no longer a public official. That motion was denied.

After its investigation, the Commission sent petitioner a proposed stipulated final order, concluding that petitioner violated ORS 244.040(1),(2) and (6)1 and former ORS 244.120(l)(d)2 in his dealings with Schroth and the Zeebs. A letter enclosed with the proposed order informed petitioner that he had 21 days in which to request a contested case hearing, and that if he did not request a hearing, his right to a hearing would be waived and a default order would be entered against him. Petitioner did not request a hearing, but *685requested reconsideration of his motion to dismiss. The Commission denied petitioner’s motion for reconsideration, and entered a default order. The default order concluded that petitioner committed violations of ORS 244.040(1) on four occasions, ORS 244.040(2) on two occasions, ORS 244.040(6) on one occasion, and former ORS 244.120(l)(d) on four occasions. Consequently, the Commission imposed civil penalties, under ORS 244.350,3 and a forfeiture, under ORS 244.360, of double the financial benefit realized by petitioner as a result of his violations.

On review, petitioner renews his contention that the Commission lacked jurisdiction to investigate his violations of ORS chapter 244, or to enforce that chapter against him, because he was no longer a public official. He argues that, before the 1993 amendments, a “public official” was defined in the present tense as a person who “is serving” the state, its subdivisions or another public body as an officer, employee, agent or otherwise. Former ORS 244.020(16).4 Petitioner contends that, under former ORS 244.020(16), the Commission lacked authority to investigate those who were not presently public officials, and could not enforce the government ethics laws against such persons.

*686Petitioner’s argument misunderstands the source of the Commission’s investigatory and enforcement authority. That authority did not derive, as petitioner seems to assume, from the definition section of the statute. At the relevant time, the Commission’s authority to investigate was provided by ORS 244.260,5 which provided, in part:

“Upon its own instigation or [the] signed complaint of any person, the Commission may make investigations with respect to * * * any * * * alleged violation of any provision of this ehapter[.]” (Emphasis supplied.)

That provision explicitly gave the Commission authority to investigate alleged violations of ORS chapter 244. The Commission alleged that petitioner committed violations of ORS chapter 244 while serving as a public official. The Commission, therefore, had statutory authority under ORS 244.260 to investigate those alleged violations. They were no less violations merely because, at the time of the investigation, petitioner was no longer a public official.

The Commission’s authority to order civil penalties derived from ORS 244.350, which provided:

“The Commission may impose civil penalties not to exceed $1,000 for violating any provision of this chapter or any resolution adopted pursuant thereto except that for violation of ORS 244.045 the Commission may impose a civil penalty not to exceed $5,000. Any penalty imposed under this section is in addition, to and not in lieu of any other penalty or sanction that may be imposed according to law, including removal from office.” (Emphasis supplied.)

Like its investigatory authority, the Commission’s authority to impose a civil penalty was predicated on the violation, not the status of the violator at the time penalties were imposed. If a person violated the chapter, the Commission could impose a civil penalty. Nothing in the statutes describing the Commission’s investigatory or enforcement authority suggested that that authority was limited to cases in which the violator was still a public official.

Other provisions of ORS chapter 244 bolster our conclusion. For example, the “revolving door” prohibition, *687ORS 244.045,6 was necessarily directed only at former public officials. Nonetheless, the Commission had express authority, under ORS 244.350, to impose civil penalties for a violation of that statute.7

Petitioner does not challenge the Commission’s conclusions that he violated ORS 244.040(1), (2) and (6) and former ORS 244.120(l)(d). Because petitioner violated ORS chapter 244, the Commission had authority under ORS 244.350 to impose civil penalties against him.8

Affirmed.