Revolving Door Laws: Federal Bans and Cooling-Off Periods

Revolving door laws are the federal rules that limit what former government officials can do after they leave public service. The main statute, 18 U.S.C. § 207, does not stop you from taking a private-sector job. What it stops is using your old government connections to influence official decisions on behalf of someone else. The restrictions come in layers: a lifetime ban on working the other side of matters you handled in government, a two-year ban on matters that sat under your supervision, and cooling-off periods of one or two years that apply to senior officials, Cabinet-level appointees, members of Congress, and senior congressional staff. Violations are federal crimes carrying up to five years in prison.¹

What the Law Actually Restricts

The distinction that matters most is between employment and influence. A former Pentagon employee can go to work for a defense contractor the next day. What that person cannot do is turn around and contact former colleagues at the Pentagon with the intent to influence an official decision for the new employer’s benefit. Every layer of 18 U.S.C. § 207 targets that specific behavior: communications or appearances made to federal officials, on behalf of a private party, with the intent to influence.¹ Which contacts are off-limits, and for how long, depends on the official’s seniority, what they worked on, and how much time has passed since they left.

The Lifetime Ban on Switching Sides

The broadest restriction applies to every former federal employee, regardless of rank, and it never expires. If you participated “personally and substantially” in a particular matter involving specific parties — a contract, an investigation, a grant, an enforcement action — you can never represent anyone else before the government on that same matter.¹

“Personally and substantially” is the key phrase. Being aware that a contract existed is not enough. You had to have done meaningful work on it: reviewed the application, negotiated terms, drafted the decision, advised the decision-maker.² The restriction also only reaches matters with “specific parties,” meaning identifiable entities on each side. Broad policy work such as drafting a regulation that affects a whole industry generally does not trigger the ban, because it lacks specific parties in the statutory sense.

The Two-Year Ban on Matters You Supervised

A separate provision catches matters you did not personally touch but that fell within your chain of authority. If a particular matter involving specific parties was actually pending under your official responsibility during your last year in government, you cannot represent anyone on that matter for two years after you leave.² Official responsibility means the matter sat inside your area of supervisory authority, whether or not you ever personally reviewed it. After two years, the restriction lifts.

One-Year Cooling-Off for Senior Officials

Senior executive branch employees face an added restriction for their first year out. During that year, a former senior employee cannot contact anyone at their old agency with the intent to influence official action on any matter, not just matters they personally handled.² The scope is broader than the particular-matter bans because it covers any topic, as long as the contact is aimed at the former agency and made on behalf of another party.

Whether you count as a “senior employee” depends on pay. The statutory threshold is 86.5 percent of the basic pay for Level II of the Executive Schedule.¹ For 2025 that figure was $195,231, and it adjusts each year with Executive Schedule pay changes.³ Certain named positions also qualify regardless of salary.

Two-Year Cooling-Off for Very Senior Officials

The most restrictive cooling-off period runs for two years and applies to officials at the top of the executive branch: the Vice President, Cabinet secretaries and others paid at Level I of the Executive Schedule, employees in the Executive Office of the President paid at Level II, and certain presidential and vice-presidential appointees.⁴

The reach is wider in two ways. Former very senior employees cannot contact any officer or employee at any agency where they served during their last year, and they also cannot contact anyone holding a senior-level position anywhere in the executive branch. The covered positions are those listed in 5 U.S.C. §§ 5312 through 5316, which sweep in Cabinet members, deputy secretaries, undersecretaries, assistant secretaries, and other senior appointees across every department and agency. A former Cabinet secretary could not, for those two years, call a deputy secretary at an entirely different department to advocate for a client.

Members of Congress and Senior Staff

The legislative branch has its own set of cooling-off periods under 18 U.S.C. § 207(e). Former Senators face a two-year ban on lobbying any member, officer, or employee of either chamber, or any other legislative office. Former House members are subject to a one-year ban with the same range.⁴

Senior Senate staff, meaning elected officers and certain high-level employees, face a one-year ban on lobbying any Senator or Senate employee. Personal staff of House members are barred for one year from lobbying the member they worked for, that member’s staff, and certain committee members. Committee staff face parallel one-year restrictions tied to their committee. The salary trigger for staff restrictions is set at 75 percent of a member’s pay. With rank-and-file members paid $174,000 since 2009 and no increase enacted for 2026, that trigger sits at roughly $130,500.

Representing Foreign Governments

Anyone subject to the senior, very senior, or congressional cooling-off periods carries an extra one-year ban on representing foreign governments or foreign political parties before any federal department or agency, and on aiding or advising a foreign entity with the intent to influence a federal official’s decisions.¹ This runs alongside the domestic cooling-off periods.

One group faces no time limit at all. Former U.S. Trade Representatives and Deputy U.S. Trade Representatives are permanently barred from representing, aiding, or advising foreign governments. Separately, former officials who do take on foreign-interest work after any applicable ban expires may still need to register under the Foreign Agents Registration Act, which requires public disclosure of the relationship and its financial terms.⁵

The Procurement Integrity Act Compensation Ban

A parallel one-year restriction applies to officials involved in major procurements. Under 41 U.S.C. § 2104, if you served as a contracting officer, source selection authority, evaluation board member, or program manager on a contract worth more than $10 million, you cannot accept compensation from that contractor for one year after leaving. The bar covers employment, officer positions, director roles, and consulting.⁶

The same ban reaches officials who personally made key contract decisions: awarding a contract or task order over $10 million, setting overhead rates on contracts above that threshold, approving payments over $10 million, or settling claims above $10 million with a particular contractor. This restriction is narrower than 18 U.S.C. § 207 because it targets only the specific contractor, not all contact with the government. It also adds something § 207 does not reach: even a lawful contact with the government does not save a former official from the independent prohibition on taking a paycheck from the contractor they helped select.

Exceptions to the Cooling-Off Periods

The senior and very senior cooling-off periods carry several exceptions under 18 U.S.C. § 207(j) for former officials moving into public-interest work.

State and local government: Former senior and very senior employees may contact their old federal agencies when acting in their official capacity for a state or local agency. Former officials who become elected state or local officials are exempt from all substantive provisions of § 207.
Higher education: The cooling-off periods do not apply to contacts made on behalf of an accredited degree-granting college or university, when the former official acts in an official capacity for that institution.
Medical research organizations: Former officials working for hospitals or medical research organizations that qualify as tax-exempt under 26 U.S.C. § 501(c)(3) are also exempt.
Political campaigns: Communications or appearances on behalf of a candidate for federal or state office, or on behalf of an authorized campaign committee, national party committee, or state party committee, are exempt from the senior and very senior cooling-off periods.

Only the cooling-off periods are waived. The lifetime ban on switching sides on particular matters still applies to people in every one of these categories.⁷

Penalties for Violations

Breaking any of the § 207 restrictions is a federal crime. The penalties in 18 U.S.C. § 216 follow a two-track structure. A standard violation carries up to one year in prison, a fine, or both. A willful violation, meaning the person knew about the restriction and deliberately ignored it, carries up to five years in prison.⁸ Implementing regulations set fines at up to $50,000 per violation or the total compensation the person received for the prohibited conduct, whichever is greater.²

The Department of Justice can also seek injunctions to stop ongoing violations. Outright criminal prosecution of former officials is uncommon in practice, but the threat shapes behavior, with most compliance coming through agency ethics offices that flag potential problems before they become criminal referrals. Private companies that knowingly involve a former official in prohibited contacts also face risk, including possible suspension or debarment from government contracting.

Where the Executive Ethics Pledge Stands

Presidents have used executive orders to layer extra restrictions on top of the statute. President Biden’s Executive Order 13989, issued in January 2021, required political appointees to sign an ethics pledge that imposed a two-year ban on lobbying their former agency, prohibited “shadow lobbying” (behind-the-scenes strategic advice to registered lobbyists), and barred appointees from working on matters tied to former employers or clients for two years.⁹

That order was revoked on January 20, 2025, by Executive Order 14148.¹⁰ The current administration has not replaced it with a comparable pledge, so the additional protections that went beyond 18 U.S.C. § 207, particularly the shadow lobbying ban and the former-employer recusal, no longer apply to new appointees. The underlying statutory restrictions still apply to everyone. Some appointees who signed the earlier pledge may still be bound by its terms for conduct during the covered period, and a future administration could impose similar requirements again.

1
Office of the Law Revision Counsel. 18 USC 207 – Restrictions on Former Officers, Employees, and Elected Officials of the Executive and Legislative Branches
2
eCFR. 5 CFR Part 2641 – Post-Employment Conflict of Interest Restrictions
3
Office of Government Ethics. Effect of Pay Adjustments on Ethics Provisions for Calendar Year 2025
4
Office of the Law Revision Counsel. 18 USC 207 – Restrictions on Former Officers, Employees, and Elected Officials of the Executive and Legislative Branches
5
Foreign Agents Registration Act (FARA). Foreign Agents Registration Act
6
Office of the Law Revision Counsel. 41 USC 2104 – Prohibition on Former Officials Acceptance of Compensation From Contractor
7
U.S. Office of Government Ethics. 18 USC 207 Applicability Chart
8
Office of the Law Revision Counsel. 18 USC 216 – Penalties and Injunctions
9
U.S. Office of Government Ethics. EO 13989 – Ethics Commitments by Executive Branch Personnel
10
Federal Register. Ethics Commitments by Executive Branch Personnel