The Lacuna Project

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Exhibit 361

Ethics agreement of James N. Mattis, nominee for Secretary of Defense

Exhibit 361 ยท Correspondence

Ethics agreement of James N. Mattis, nominee for Secretary of Defense

Within 90 days of my confirmation, I will divest all of my General Dynamics stock and vested stock options.

Mattis resigns from General Dynamics on confirmation, recuses one year, forfeits unvested stock and options, divests stock and vested options within 90 days. Keeps Theranos stock with recusal while held.

Source
James N. Mattis to DoD Designated Agency Ethics Official; posted by U.S. Office of Government Ethics
Date
5 January 2017
Quoted from
Letter p. 1
Grade
Primary record
Document
https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/2EB12A932B2A7958852580A1002C7CAB/$FILE/MATTIS%20James%20%20Ethics%20Agreement.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Cited by

Finding DEF-4.8
Primary record Four officials who came to the Pentagon from contractor roles stated their recusal terms in their own agreements: Shanahan (Boeing), for the duration of his service; Esper (Raytheon), one year, with a continuing limit tied to his deferred compensation; Mattis (General Dynamics), one year; and Austin (Raytheon Technologies), four years. The DoD Inspector General investigated 2019 allegations that Shanahan promoted Boeing and did not substantiate any of them.