New 'REVOKE Act' Mandates Loss of Security Clearance for Ex-DoD Staff Lobbying for Chinese Military Firms

This bill, officially titled the Restricting Ex-Vetted Officials from Knowledge Exploitation Act—or the REVOKE Act—is a direct response to concerns about the “revolving door” between the U.S. defense establishment and foreign interests. Simply put, the bill mandates that if you are a retired military member or a former civilian employee of the Department of Defense (DoD) and you lobby for certain Chinese military companies, you will lose your security clearance. This isn’t a suggestion; it’s a required action for the Secretary of Defense (SEC. 2).

The Security Clearance Showdown

For those who spent their careers in defense, a security clearance is currency—it opens doors to high-paying jobs in contracting or consulting. This bill targets the specific problem of former officials using their deep knowledge and contacts, often gained through classified access, to benefit entities deemed a threat. The revocation is triggered only if the lobbying is done for companies that appear on two specific U.S. government lists: the list of Chinese military companies compiled under the National Defense Authorization Act (NDAA) and the Non-SDN Chinese Military-Industrial Complex Companies List published by the Treasury Department (SEC. 2).

What Counts as Lobbying?

To keep things clear, the bill uses the established definitions of “lobbying activities” and “lobbying contact” from the Lobbying Disclosure Act of 1995. This means the rules are focused on direct attempts to influence government policy or decision-making. If a former official takes a job doing public relations or marketing for one of these designated firms, but never engages in direct lobbying with U.S. government officials, the revocation might not apply. However, if they pick up the phone to influence policy on behalf of the designated Chinese firm, their clearance is gone (SEC. 2).

The Short-Term Pass Clause

There is a very narrow escape hatch, but it’s temporary. The Secretary of Defense can issue a waiver to the prohibition, allowing the individual to keep their clearance despite the lobbying activity. But this waiver can only last 180 days, and the Secretary must certify to Congress that granting it is strictly in the "national security interest of the United States." This means the bar is set extremely high. It’s not a loophole for convenience; it’s reserved for situations where, for example, the individual's continued access is somehow vital to an ongoing counter-intelligence operation (SEC. 2. Waiver Authority).

The Real-World Impact on Careers

This bill significantly changes the post-service career landscape for former high-ranking DoD personnel. If you’re a retired general or a former senior civilian who was planning to leverage your expertise into a lucrative lobbying gig, you now have a hard choice: either avoid lobbying for these specifically designated entities or accept that your security clearance—and the access and credibility that comes with it—will be terminated. While the intent is to protect national secrets, the mandatory nature of the clearance loss is a heavy restriction on the employment options of former personnel, effectively cutting off a major income stream if they choose to work with a blacklisted company.