I'm not used to thinking about the Anti deficiency Act in those terms, it's usually about not spending or obligating funds in excess of an appropriation or OMB apportionment. I'm not sure the Act cares as much about who's doing the obligating.
I did a quick search, and I can't find a single case where someone was charged under 31 USC § 1350.
Considering the conduct proscribed there overlaps with 18 USC 641, but applies only to fed employees and features lower penalties, it doesn't surprise me.
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Considering the conduct proscribed there overlaps with 18 USC 641, but applies only to fed employees and features lower penalties, it doesn't surprise me.