Christopher DeLacy is a Partner at Holland and Knight's
Washington, D.C office
The National Defense Authorization Act for Fiscal Year 2018 (NDAA), signed into law on Dec.
12, 2017, imposes new lobbying restrictions on former military
officers grade O-7 and higher and civilians of the same grade
equivalents (Executive Schedule Level V and higher) at the
Department of Defense (DoD). These new restrictions apply in
addition to existing
post-employment restrictions and
Executive Order 13770.
Former military officers in grades O-7 to O-8 and their DoD
civilian equivalents (Executive Schedule V and IV) are subject to a
one year post-employment cooling off period while grades O-9 and
higher and their DoD civilian equivalents (Executive Schedule III
and higher) are subject to a two year cooling off
period. During these times, covered individuals may not engage
in lobbying activities, as defined by the Lobbying Disclosure Act
(
LDA), which includes lobbying
