Shortly after Reagan was sworn in for his second term, he appointed Keating to serve as an assistant secretary of the Treasury and later elevated him to associate attorney general, the third ranking official within the U.S. Department of Justice.
On November 14, 1991, Bush nominated Keating to a seat on the U.S. Court of Appeals for the Tenth Circuit, but with Democratic control of the U.S. Senate Judiciary Committee, Keating's nomination languished and no hearing was held before Bush's presidency ended.