This bill prohibits former government employees involved in Foreign Military Sales from immediately lobbying federal officials regarding those same sales after leaving office.
Warren Davidson
Representative
OH-8
The No Revolving Doors in FMS Act of 2025 establishes new restrictions for former State Department and Department of Defense employees involved in Foreign Military Sales (FMS). This legislation prohibits these former officials from lobbying Congress or federal employees regarding the specific FMS programs they worked on within the three years prior to leaving federal service. The bill aims to prevent immediate conflicts of interest by closing the "revolving door" between government service and lobbying in the FMS sector.
The No Revolving Doors in FMS Act of 2025 is a straightforward piece of legislation aimed at tightening ethical restrictions around Foreign Military Sales (FMS)—the process where the U.S. government sells defense equipment and services to foreign governments. Simply put, this bill targets the 'revolving door' phenomenon where government officials leave their public service jobs and immediately start lobbying their former colleagues for private gain. Specifically, the bill says that if you worked for the State Department or the Department of Defense and were involved in an FMS program during the three years before you left, you can’t turn around and lobby the government on those same sales. Violating this new rule could land you in legal trouble under existing federal penalties (18 U.S.C. § 216).
This isn't about stopping people from getting new jobs; it's about putting a buffer between public service and private influence, especially in sensitive areas like arms sales. The bill creates a new restriction under Section 2 of the Act, making it illegal for former officials to "knowingly try to influence any federal decision" related to the FMS programs they managed. Think of a senior defense official who spent years negotiating a massive fighter jet sale to an allied nation. Under current rules, that official could potentially leave government on Friday and be hired by the jet manufacturer on Monday to lobby their former team to sweeten the deal. This bill imposes a three-year cooling-off period on lobbying activities related to those specific sales programs, aiming to reduce the risk of former employees leveraging insider knowledge and relationships for immediate profit.
While this bill directly affects a small, specialized group of former government employees and defense lobbyists, the impact trickles down to the public interest. Foreign Military Sales involve billions of taxpayer dollars and critical national security decisions. When the public sees officials cashing in on their government experience immediately, it erodes trust in the fairness of the system. By restricting this type of immediate lobbying, the bill intends to boost the integrity and transparency of the FMS process. For the average person, this is about ensuring that these massive, high-stakes decisions are made based on national interest, not on who hired the best-connected former official.
As with any ethics rule, the devil is in the details, and this bill has some moderate vagueness. The core restriction applies to anyone who was “involved in any foreign military sales program” during the three years prior to leaving. That term—"involved in"—could be interpreted widely or narrowly. Does it only mean the person who signed the final paperwork, or does it include the mid-level analyst who ran the numbers? The clarity of this definition will determine whether the restriction is truly effective or easily skirted by positioning former employees in roles just outside the official definition of “influence.” For those former State and Defense employees looking to transition into the private sector, this new rule certainly limits their immediate job options, particularly if they were heavily focused on FMS programs. However, for the rest of us, it’s a welcome step toward making sure that when government officials leave, they don't immediately start selling access to the complex systems they just helped build.