# Cooling-Off Period
The mandatory waiting time before a former government official may lobby their old colleagues — the law's main speed bump on the [[Revolving Door]]. The core statute is 18 U.S.C. § 207: former **senators** face a two-year ban on lobbying Congress, former **House members** one year, **very senior executive-branch officials** two years and other senior officials one year on contacting their former agency. Violations are criminal — but the bans are narrow, short, and routinely engineered around.
## Why it barely works
The restrictions prohibit *lobbying contacts*, not employment: a former official can join a lobbying firm the day after leaving office, be paid handsomely for "strategic advice," direct colleagues who make the calls, and simply wait out the clock — the standard on-ramp described in [[Shadow Lobbying]]. Firm bios openly advertise the pedigree during the cooling-off window; clients are buying the relationships, which do not expire.
## The pledge whipsaw
Presidents layer executive-order ethics pledges on top of the statute, and the Trump era demonstrated their revocability: Trump's 2017 pledge (EO 13770) imposed a five-year lobbying ban and lifetime [[FARA]] ban on appointees — then **Trump revoked his own order on January 19, 2021**, his last full day in office, releasing his alumni from it. The pattern shows the deeper truth of the mechanism: post-employment ethics run on whichever administration holds the pen (see [[Office of Government Ethics]] for the machinery).
## In this KB
The census in the [[Lobbying Hub]] is largely a map of survived cooling-off periods — Ballard's Wiles/Bondi pipeline, Capitol Counsel's "Trumps Up" hires, and the committee-staff shops are all built from personnel who timed out their windows or never triggered them.
## See also
[[Revolving Door]] · [[Shadow Lobbying]] · [[Lobbying]] · [[Lobbying Hub]] · [[Office of Government Ethics]]