Mechanism
The revolving door
Officials who move between government posts and the industries those posts regulate, contract with or fund.
Information and Perception
Medicine and Public Health
- Finding MED-6.3
- Primary record FDA's vaccine review office has been directed since 2022 by a former Merck vaccine research executive, and in 2026 a National Security Council official left government to run the soybean checkoff.
War and Defense
- Finding DEF-4.1
- Primary record Under 18 U.S.C. § 207, former executive-branch officials may not contact their former agency on behalf of others for one year (senior personnel) or two years (very senior personnel), and may never do so on matters they handled personally and substantially. The statute does not bar employment with a contractor.
- Finding DEF-4.2
- Primary record Three further rules apply to former Defense Department personnel. Certain contracting officials may not take compensation from the contractor for one year (41 U.S.C. § 2104); covered officials must seek a written ethics opinion before contractor employment within two years (FY2008 NDAA § 847); and officers of grade O-9 and above, with civilian equivalents, may not lobby the Department for two years, and O-7 and O-8 officers for one year (FY2018 NDAA § 1045).
- Finding DEF-4.3
- Primary record In 2008 the Government Accountability Office reported that 52 major defense contractors employed 2,435 former Defense Department senior and acquisition officials in 2006, and that seven of the firms employed 1,581 of them. The contractors' own data showed 1,263, and GAO described its IRS-based figure as almost twice as many.
- 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.
- Finding DEF-4.6
- Reported The Project On Government Oversight counted 645 instances in 2018 in which the top 20 contractors of fiscal year 2016 employed former senior officials, officers, Members of Congress or senior staff as lobbyists, directors or executives, 562 of them as lobbyists. Senator Warren's staff report of April 2023 counted 672 such cases for 2022, 613 of them registered lobbyists.
- Finding DEF-4.7
- Primary record Seven officials are documented moving between Defense Department posts and the boards or payrolls of defense contractors in dated steps from 2009 to 2021, under the Obama, Trump and Biden administrations. Five of them (Lynn, Shanahan, Esper, Mattis and Austin) came to senior Pentagon posts from contractor roles, and four (Work, Pawlikowski, Mattis and Austin) took contractor board seats after leaving DoD posts or the armed services.
- 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.
- Finding DEF-4.10
- Primary record A 2024 study by the Institute for Defense Analyses, commissioned by the DoD Standards of Conduct Office, found no measurable effect of the post-government employment restrictions on recruitment and retention. It also found that well under one percent of retired senior officials are registered lobbyists for the top 100 defense contractors.
Politics and Government
- Finding POL-1.5
- Primary record The 2003 registration of the Homeland Investment Coalition lists Bill Archer as a lobbyist, with the covered position "HOUSE MEMBER."
- Finding POL-1.16
- Peer-reviewed Lobbyists with experience in a U.S. Senator's office lose 24 percent of generated revenue when that Senator leaves office (Blanes i Vidal, Draca and Fons-Rosen), and Bertrand, Bombardini and Trebbi find a more consistent monetary premium for connections than for expertise.