Stopping the Revolving Door: Preventing Conflicts of Interest from Former Lobbyists

Issues
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People going through a revolving door.

President Donald Trump’s second administration has appointed dozens of former lobbyists to important government roles, including leadership positions in the very agencies they formerly lobbied. Consequently, special interests have been given undue influence on major policies that impact American life.

This phenomenon, commonly referred to as the “revolving door” between the public and private sectors, has been creating new pathways for wealthy special interests to exert undue influence over our government for years. Past presidents historically have imposed ethics guardrails to prevent lobbyists from prioritizing the best interests of their former clients over the American people; the second Trump administration, however, has not done the same.  

Campaign Legal Center (CLC) has identified at least 47 former lobbyists nominated for or currently serving as senior political appointees as of April 2, 2026. More than 15 of those officials likely would have been banned or faced limits under the ethics pledges of the previous three administrations.  

Congress must implement and enforce new laws to prevent the conflicts of interest at hand and ensure that government officials act in the best interest of the public, not on behalf of special interests.

The Trump administration’s abandonment of the rules impacts federal policy.

There are no permanent rules to prevent former lobbyists from holding high-level positions in government, and there are very few laws preventing them from using their positions to advance their former clients’ interests. As such, President Trump’s failure to implement restrictions on former lobbyists entering the administration has resulted in former industry advocates overseeing the very industries they lobbied on behalf of. Examples include:

  • Kyle Kunkler lobbied the Environmental Protection Agency (EPA) on behalf of the American Soybean Association to allow the use of the controversial pesticide dicamba shortly before he was appointed to be the Deputy Assistant Administrator for Pesticide Programs at the EPA. After he joined the agency, the EPA reversed their policy despite concerns from environmental groups and “Make America Healthy Again” activists.  
  • Douglas Troutman lobbied on behalf of the American Cleaning Institute for nearly two decades, where he urged the EPA to weaken protections against toxic chemicals before he was appointed Assistant Administrator for Chemical Safety and Pollution Prevention. While Troutman was an advisor to the agency, the EPA released a proposal to loosen reporting requirements on “forever chemicals.”
  • Matthew Giacona appears to have lobbied the Department of Interior (DOI) on behalf of the offshore drilling industry for six years before being appointed as Principal Deputy Director of the Bureau of Ocean Energy Management within DOI. In his new role, Giacona quickly facilitated a meeting between top Interior Department officials and oil industry representatives to discuss a contentious agency review of offshore oil and gas operations in the Gulf of America to ensure they comply with the Endangered Species Act.
  • Wayne Palmer appears to have lobbied the Mine Safety and Health Administration (MSHA) on behalf of the Essential Minerals Association (EMA), which submitted comments to the MSHA arguing against adopting a new action level limiting exposure to harmful chemicals in metal and nonmetal mines. Palmer now oversees the government agency responsible for developing and enforcing these mining regulations.

These appointments allow former lobbyists to make decisions that directly benefit their former clients, raising serious concerns about whether they can be impartial.

We need permanent rules to restore trust in government.

Relying on each presidential administration to voluntarily impose ethics guardrails is not a reliable system for protecting the interests of Americans against the deep-pocketed industries seeking to purchase political favor.  

Congress needs to step in and pass legislation to ban former lobbyists from serving in these roles. Additionally, if lobbyists are appointed to an agency they did not lobby before joining the government, they still should be prohibited from participating in any matter they lobbied on within the two years before their appointment.  

Moreover, Campaign Legal Center is calling on Congress to address the full range of consequences of President Trump’s abandonment of ethics standards across government. Beyond the actions of his executive branch, the president himself has a long list of conflicts of interest — and has time and time again proven his eagerness to use his political power to benefit his friends, allies and donors.  

Americans need to know that government officials are acting in their interest, not for personal gain or the benefit of private industries and the president.

By passing permanent ethics rules, Congress can help ensure that government officials — at every level — serve the public and maintain the integrity of their positions.

Campaign Legal Center has a long history of fighting for a more ethical and transparent government. Join the fight today to help hold our government officials accountable. 

Sophia is a Senior Researcher/Investigator on CLC's Campaign Finance/Ethics team.
People going through a revolving door.
Check Out Our Research on the Influence of Lobbyists in the Trump Administration