This time last year, Andrew Wheeler was a registered lobbyist working for the interests of one of the country’s largest coal-mining companies and a major uranium mining company. Starting Monday, he’s expected to become the acting administrator of the Environmental Protection Agency, where he’s been deputy administrator since April.

The top EPA position has been under a cloud of scandal for a year — as gloomy and persistent as a smoggy sky. The controversies surrounding Scott Pruitt, the head of the EPA whose resignation was announced by President Trump on Thursday, were plentiful and varied: accusations of run-of-the-mill abuses of power, mismanagement of staffers, and a potentially unethical business arrangement with an industry lobbyist. It’s unclear what caused Pruitt to quit, but the full scope of these scandals has prompted questions from the media and Pruitt’s critics about just who the EPA administrator was working for. Americans? Himself? His lobbyist landlord?

But while Pruitt’s ethics problems compounded during his time in office, Wheeler’s potential conflicts of interest are embedded in his résumé. And he’s emblematic of a sort of political dynamic that has come under increased scrutiny in the last decade — a reverse revolving door, through which lobbyists and consultants join the government and regulate the people who used to be their co-workers.

“There’s no one who would have thought Pruitt was coming in to run the agency with a deep and abiding love of its mission,” said Lisa Gilbert, vice president of legislative affairs for Public Citizen, a consumer advocacy organization that tracks connections between politics and business. And, in that way, he and Wheeler appear to be alike. Both have ties to Oklahoma Sen. James Inhofe, an outspoken climate change denialist, and both have publicly questioned the science behind climate change.

Pruitt’s philosophy of narrow EPA powers and state-led environmental regulation was certainly friendly to the oil and gas industry, but he was not formerly employed by it. His lapses have largely come in the form of ethical pratfalls, banana peels that he put on the floor and slipped on in the course of duty. Wheeler’s potential to favor former clients, in contrast, is a part of him.

Although the reverse revolving door gets less attention than the practice of former politicians and government workers becoming lobbyists, it’s common, Gilbert said. And it happens among congressional staffers on both sides of the aisle. A 2011 investigation by the Center for Responsive Politics, a nonpartisan group that tracks money in U.S. politics, found that the number of “critically important” congressional staffers who previously worked as lobbyists was on the rise, increasing from 60 in the 111th Congress (2009-11) to 128 in the 112th (2011-13), with the biggest increases coming from the energy and natural resources industry. And a 2013 investigation by The Nation found that some of the people leaving industry for Congress received bonuses and incentive pay from the company they were leaving as they were heading out the door to take a government job.

Wheeler is hardly the first presidential appointee to come in backwards through the revolving door. President Obama signed an executive order banning the hiring of lobbyists under certain circumstances but used a system of ethics waivers to get around that rule — ultimately issuing about 70 waivers across the federal government during his eight years in office (16 were for White House staff). Trump, who retained the bulk of Obama’s ethics rules, hired at least 187 former lobbyists in his first year in office, according to a ProPublica investigation, including 18 in Senate-confirmed positions who had been active lobbyists within the previous two years. In his first year, Obama hired 14 recent lobbyists.

Meanwhile, according to an investigation published in March 2018, the Associated Press tracked 59 EPA administration staffers that had been hired under Trump and found that about a third had been lobbyists or lawyers for fossil fuel producers, chemical companies or other corporate clients. In June 2017, Public Citizen analyzed the backgrounds of 115 Trump nominees to sub-Cabinet roles; 25 were current or former lobbyists or corporate consultants, 26 were corporate lawyers, and 29 were current or former corporate executives. Not all of those people were being hired to regulate the industries they’d recently left, but some were.

And that has consequences. We know from scientific research that our opinions and behavior can be swayed in exchange for even very small gifts — like doctors prescribing more of a certain pill after a pharmaceutical executive buys them lunch. Imagine, then, the influence of an industry that paid your salary for years.

Or don’t imagine. There are examples. Sen. John Thune of South Dakota was a lobbyist for a railroad company before he was elected in 2004. In his first year, he wrote legislation expanding federal loan money available to businesses like his former client. (The client’s loan application was later denied.) Maine’s top environmental official between 2011 and 2015 was former industry lobbyist Patricia Aho. She was accused of favoring former clients in multiple situations, including failing to enforce laws she had previously lobbied against. Carl Icahn, a former adviser to President Trump — and also a billionaire investor — dumped millions of dollars in steel stock before the announcement of new tariffs and has been accused of using his influence to make sure that a bet against renewable fuel credits panned out.

We don’t know what Wheeler’s tenure as acting administrator of the EPA will be like, nor if his past indutry jobs will influence how he performs his new one. We don’t even know how long it will last (he told The Hill last month that he isn’t interested in holding the job permanently). But we do know that Pruitt’s departure isn’t the end of potential conflicts of interest at the EPA. And we know that conflicts can sometimes work out in the interests of corporations, not the public.