Former Federal Trade Officials: Laws on Post-Employment Activities, Foreign Representation, and Lobbying

Congress has enacted laws to safeguard against former federal employees, including former trade officials, from using their access to influence government officials. These former officials' post-employment activities are restricted by a federal conflict of interest law, known as the "Revolving Door" law. Two other laws--the Foreign Agents Registration Act (FARA) and the Lobbying Disclosure Act (LDA)--are disclosure statutes that do not prohibit any activities per se, but require individuals conducting certain representation activities to publicly disclose them. FARA and LDA are not specific to former federal officials; they apply to all individuals. GAO was asked to provide a summary of the Revolving Door law, FARA, and LDA. GAO reviewed these laws, as well as guidance from the Office of Government Ethics (OGE). GAO interviewed ethics officials at three agencies whose missions focus on trade--the United States Trade Representative (USTR), the International Trade Administration (ITA), and the International Trade Commission (USITC)--and collected data on the number of senior officials who separated from these agencies from 2004 through 2009. In addition, GAO interviewed Department of Justice (Justice) officials concerning enforcement of these laws. GAO makes no recommendations in this report.