CLC Alleges that USDA Secretary Brooke Rollins Made Personal Appearances and Maintained Close Ties with Outside Organizations in Violation of Her Ethics Agreement and Federal Ethics Laws

Campaign Legal Center writes to request that the U.S. Department of Agriculture (USDA) Office of the Inspector General (OIG) investigate whether the USDA Secretary Brooke Rollins violated federal laws, ethics regulations, and her ethics agreement by maintaining close ties with her former employers and clients, America First Policy Institute (AFPI), Texas Public Policy Foundation (TPPF), America First Works (AFW), and the Mouradian Foundation. First, Rollins agreed to refrain from participating personally and substantially in any particular matter involving specific parties where her former employers were or represented a party for one year, in accordance with the requirements of the impartiality regulation. Despite this, Rollins made at least four appearances at events hosted by AFPI and TPPF in her official capacity throughout 2025. Second, Rollins may have received a covered payment under 5 C.F.R. § 2635.503 from AFPI prior to entering government service, which would extend her recusal obligations toward AFPI for up to two years. Finally, public information suggests that Rollins has not fully resigned from her senior positions with outside entities TPPF and AFW, in addition to continuing to provide services to her former clients TPPF and Mouradian Foundation. The culmination of these facts suggests that Rollins has failed to comply with her ethics agreement and federal ethics laws since becoming USDA secretary.