Exhibit 354

Post-Government Employment Restrictions: DOD Could Further Enhance Its Compliance Efforts Related to Former Employees Working for Defense Contractors (GAO-21-104311)

Exhibit 354 · Government report

Post-Government Employment Restrictions: DOD Could Further Enhance Its Compliance Efforts Related to Former Employees Working for Defense Contractors (GAO-21-104311)

the 10 contractors that provided personnel data reported they employed 816 potentially covered former DOD officials in 2019, while our analysis of DOD and IRS data for those contractors identified 1,149 individuals. We were unable to reconcile the differences

14 contractors employed 1,718 former senior and acquisition officials in 2019 (1,616 acquisition, 102 senior). Contractors that supplied data reported 816 against GAO's 1,149. DoD had not considered adding the lobbying ban to its acquisition regulation; DoD concurred with the recommendation.

Source: U.S. Government Accountability Office
Date: 9 September 2021
Quoted from: GAO-21-104311, p. 15
Grade: Primary record
Document: https://www.gao.gov/products/gao-21-104311
Accessed: 2026-11-09
Cited by: Findings citing this exhibit

Cited by

Finding DEF-4.4: Primary record In 2021 GAO reported that 14 major contractors employed 1,718 former Defense Department senior and acquisition officials in 2019. The ten contractors that supplied data reported 816 such officials where GAO's DoD and IRS data identified 1,149, and GAO could not reconcile the difference.
Finding DEF-4.5: Primary record The DoD Inspector General concluded in 2014 that the Department's database of section 847 ethics opinions was "of marginal value" as a management control system. In 2021 GAO recommended that DoD assess adding the lobbying prohibitions to its acquisition regulation, and DoD concurred.