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This story was originally published by ProPublica.

Lobbyists who joined the Trump administration and now want to return to their old trade have a problem: President Trump said they can’t.

Days after taking office, President Donald Trump signed an executive order requiring every political appointee to sign a pledge as a condition of taking office. The appointees agreed not to lobby the agencies they had worked in for five years after they left government service. Nor would they lobby anyone in the White House or political appointees across federal agencies for the duration of the Trump administration.

But never doubt the ingenuity of the Washington swamp class. At least eight former Trump officials have found ways around the so-called ethics pledge.

Using staffing lists compiled for ProPublica’s Trump Town, the first exhaustive database of current political appointees, we found at least 184 people who have left the Trump administration. Of those, at least six former officials are now registered lobbyists and several others work at firms in roles that resemble lobbying in all but name.

Their techniques vary from the bureaucratic to the audacious: Some former officials are tiptoeing around the rules by not registering as lobbyists or by exploiting loopholes. Others obtained special waivers allowing them to go back to lobbying. And at least one never signed the pledge at all.

Needless to say, roundtrip traffic between lobbying and government has long been endemic in Washington. The Obama administration, despite campaign promises to the contrary, hired dozens of previously registered lobbyists and many officials returned to K Street firms afterward. “The revolving door is a persistent feature of Washington if you work in an administration and you develop some expertise over an area of policymaking,” said Lee Drutman, a senior fellow who studies lobbying at New America, a left-leaning Washington think tank. “There’s a high demand for someone with your knowledge and connections.”

Candidate Trump famously vowed to put an end to such D.C. practices by “draining the swamp.” Indeed, in some respects, the Trump administration’s ethics pledge is tougher than those in place under Obama and former President Bill Clinton. Trump’s version expanded the prohibition from lobbying to what his executive order called “lobbying activities” after people leave government. This was intended to stop former officials not only from communicating directly with government officials but also from helping other lobbyists do that.

Experts warn that tougher enforcement could be spurring the growth of “shadow” lobbyists.

The goal, as Trump put it at a Wisconsin campaign rally in October 2016, was to “expand the definition of ‘lobbyist’ so we close all the loopholes that former government officials use by labeling themselves consultants, advisers, all of these different things, and they get away with murder.”

Violating the pledge exposes former officials to possible extended bans on lobbying, civil proceedings or fines, or being barred from lobbying entirely.

Paradoxically, experts warn that tougher enforcement could be spurring the growth of “shadow” lobbyists. That’s the term for those whose tasks look much like lobbying but which they label, say, “strategic consulting.” It also applies to those who don’t meet the legal threshold requiring them to formally register as lobbyists. According to the Lobbying Disclosure Act, a lobbyist must register if he or she spends “20 percent or more of his or her time in services for [a] client over any three-month period.”

But calculating that 20 percent can get mushy. “A former senior official who is now a non-lobbyist lobbyist can send a text and have it returned immediately. How do you count that against the 20 percent threshold? What is the disclosure? How do you decide how to bill for that?” said Sam Geduldig, a partner at CGCN Group, a Republican lobbying firm in Washington.

Even pinning down what constitutes lobbying—compared to, for example, advising—can be tricky. “Of course there is an incentive” for would-be lobbyists not to register, said Paul Miller, a former president of the industry trade group, American League of Lobbyists. “It’s not by coincidence that the new [lobbyists] aren’t registered and the ones who were registered are de-registering because they think they no longer meet the threshold.”

The result is that the Trump pledge is less impregnable than it might seem. Here’s how some of the president’s former appointees dodged the restrictions:

Route 1: The “Non-Lobbyist Lobbyist”

Shadow lobbying typically takes two forms, experts say. The first: Those who spend 20 percent or less of their time on lobbying and, because of the legal threshold instituted during the Obama administration, don’t have to register as lobbyists.

“Going back to be a full-time swamp creature is certainly an attractive option.”

Take the example of former White House environmental policy adviser George David Banks. Before spending a year that ended early in 2018 at the White House, Banks was an executive vice president at the American Council for Capital Formation, where he lobbied on environmental, tax and regulatory issues. And before that, Banks represented a number of utilities and energy trade groups, advocating for nuclear energy and lobbying on clean power legislation.

Banks resigned from his White House position this February; Politico quoted him saying he was denied a permanent security clearance over admitted marijuana use in 2013. The next month, Banks resumed his previous post at the American Council for Capital Formation, but has not re-registered as a lobbyist. In an interview with E&E News shortly after his resignation, Banks was quoted joking that “going back to be a full-time swamp creature is certainly an attractive option.”

Banks’ previous registration was a mistake, countered Mike Burita, a spokesman for the council. He told ProPublica that Banks’ earlier activity didn’t meet the legal threshold to register as a lobbyist because he spent “little to no time” on the Hill. Banks did not respond to ProPublica’s requests for comment.

Then there’s the second shadow route: working for strategic consulting or communications firms.

William Inglee joined the Trump administration as a senior adviser to then Secretary of State Rex Tillerson in February 2017 after leaving his own strategic consulting firm, ISM Strategies LLC, in Mount Vernon, Virginia. Inglee left the State Department four months later and returned to his company, whose website touts his “extensive career in Congress, the Executive Branch, and the private sector” and cites the State Department role.

But Inglee has also been careful to avoid the lobbyist term, describing his company as a “non-lobbying consulting firm” while still emphasizing its “high-value counsel, expert assessments, and other strategic support” for its clients.

Inglee did not respond to ProPublica’s requests for comment.

Route 2: Obtain a Special Waiver

Tucked into the Trump ethics pledge is a provision that allows federal agencies to waive the lobbying restrictions for political appointees. We found at least two political appointees who have successfully obtained these passes.

Virginia Johnson is a former congressional staffer and lobbyist for the American Red Cross who joined the Department of the Interior after Trump’s inauguration, serving as both special assistant to the secretary and as principal deputy assistant secretary for Fish and Wildlife and Parks. Johnson left Interior in July to take a job as senior vice president of government relations and external affairs with United Service Organizations, or USO, a nonprofit that provides support to military service members and their families.

Johnson signed the Trump ethics pledge, but asked for a waiver so she could lobby after leaving her post at Interior. Daniel Jorjani, Interior’s then-acting solicitor, approved the request, granting Johnson a limited waiver that lets her lobby political appointees across executive branch agencies other than Interior. Last month, she registered to lobby the Defense Department and other agencies on appropriations and other matters, lobbying records show.

USO did not respond to ProPublica’s requests for comment, other than by forwarding a copy of Johnson’s waiver. Johnson also did not respond to requests for comment.

Peacock requested an ethics waiver, arguing that he had “limited participation or influence on policies and decisions.”

Marcus Peacock worked as a senior adviser to Office of Management and Budget Director Mick Mulvaney for two and a half months after Trump took office. Peacock, who had worked in George W. Bush’s administration as a senior official in both the OMB and the Environmental Protection Agency, helped guide Mulvaney through the Senate confirmation process and was instrumental in crafting the Trump administration’s executive order cutting two existing regulations for every new regulation.

A month before he left the Trump administration, Peacock requested an ethics waiver, arguing that he had “limited participation or influence on policies and decisions that would raise the types of concerns” the pledge seeks to avoid, according to a memo he sent to White House attorneys. Because his work on the executive order dealt with “process questions,” Peacock argued, it was not a specific policy action.

On April 6, 2017, two days before Peacock resigned, he received a special waiver. James Schultz, a senior associate counsel in the White House, concluded that Peacock had not “focused on specific regulations or policies.” Peacock left to become the executive vice president, the No. 2 position, at the Business Roundtable, a lobbying group for chief executives at U.S. companies.

The waiver reduced Peacock’s lobbying ban from five years to just six months. According to Senate lobbying records, Peacock is working with colleagues on federal budget process reforms, workforce development and immigration, international trade and changes to the 2010 Dodd-Frank Wall Street overhaul, among other things.

“Legally, we’re going to separate the executive and the legislative branches, but in reality there’s going to be overlap on shared goals.”

In response to questions, the Business Roundtable noted that Peacock served at OMB for just 77 days and that he voluntarily agreed not to have any lobbying contact with OMB for six months, “more than twice the amount of time he actually worked there.”

Peacock’s waiver has drawn the attention of officials with the Office of Government Ethics, who are reviewing waivers granted by the Trump administration. But the Business Roundtable says it has not been asked about Peacock’s waiver or lobbying.

Route 3: Find the Loopholes

Several Trump political appointees who signed the ethics pledge are working around the rules. Rather than lobbying political appointees at federal agencies, which is prohibited, they’re lobbying congressional leaders on Capitol Hill, which is permitted. Their colleagues can then target the White House, federal agencies and political appointees.

That approach is perfectly legal and common at K Street firms, but lobbying experts said it’s a way to get around restrictions. “Legally, we’re going to separate the executive and the legislative branches, but in reality there’s going to be overlap on shared goals,” said Timothy LaPira, an associate professor of political science at James Madison University who researches lobbying.

Christopher Shank, a former special assistant and senior adviser to Defense Secretary Jim Mattis, worked in the Trump administration until May 2017 and then joined lobbying firm Van Scoyoc Associates. According to lobbying records, Shank is working on “nuclear related issues” and “space products and services,” including possible budget items for his old employer, the Defense Department. One of his clients, NanoRacks LLC, has government contracts to send payloads and small satellites to the International Space Station.

But Shank is directly lobbying only legislators and staffers within the U.S. Senate and House, not former colleagues within federal agencies, and is complying with all post-government employment restrictions, according to Ross Kyle, a spokesman for Van Scoyoc Associates. Shank’s co-worker lobbies federal agencies.

Jordan Stoick worked as a senior adviser for the Treasury Department from April through December 2017. He left to take a job as the lead lobbyist at the National Association of Manufacturing, a trade group that regularly weighs in on immigration reform and labor issues.

Stoick is now a registered lobbyist working on everything from agriculture legislation to coal exports and oil and gas pipelines with congressional leaders and staffers. Other members of his team direct their efforts at federal agencies and the White House. “Jordan is fully meeting his obligations under the ethics agreement he signed with the administration,” said Michael Short, a spokesman for the manufacturing group. (Short himself is a former Trump political appointee, having worked in the White House as a senior assistant press secretary.)

Nathan Bult, who worked as a special assistant in the Department of Health and Human Services from March through December 2017, is now working with Bethany Christian Services in Washington, to advocate on refugee admissions programs at the State Department and other agencies.

At least one of the non-signers has gone back into lobbying with no repercussions.

Both Health and Human Services and Bethany Christian Services said Bult signed the Trump ethics pledge but that even without a waiver, he was still able to lobby Congress and career staffers at agencies other than HHS.

Bult, who became Bethany Christian Services’ director of government affairs in January, declined to comment.

Route 4: Don’t Sign the Pledge in the First Place

Several short-lived Trump political appointees, including former national security adviser Michael Flynn and Housing and Urban Development senior adviser Shermichael Singleton, have publicly said they didn’t sign the ethics pledge during their stints in government service. In theory, that should have disqualified them, but enforcement, it appears, was less than universal.

At least one of these non-signers has gone back into lobbying with no repercussions. Robert Wasinger served as a White House liaison with the State Department for 25 days. He told ProPublica he never signed the pledge and was never asked to sign one.

Wasinger left to become a senior vice president of federal public affairs at McGuireWoods Consulting and has a client list that includes Amazon, the American Petroleum Institute, Quest Diagnostics Inc. and Verizon. Lobbying records also show that he’s been involved in lobbying on behalf of the families of State Department employees killed during attacks on U.S. embassies in Kenya and Tanzania in 1998. The State Department did not respond to ProPublica’s requests for comment.