Every person who joins the administration will be asked to sign a lobbying ban form that states they are not a registered lobbyist. If they are, they will have to provide evidence of their termination.

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The policy comes after days of criticism over Trump’s inclusion of lobbyists on the transition team, despite his campaign pledge to keep special interests out of Washington.

On its face, the lobbyist ban appears stringent, but it could be easily skirted if a lobbyist were to deregister to be eligible to join the administration. One sign indicates that it may already be happening: A close aide to Pence who is a Washington lobbyist, Josh Pitcock, filed paperwork with the Senate on Monday to terminate his status as a federal lobbyist. Pitcock advised Pence during the presidential campaign, and has lobbied for the state of Indiana since 2013, earning $280,000 a year to lobby on a wide range of issues including health-care marketplace exchange rates and resources for the state’s response to the Zika virus, lobbying records show. Pitcock did not immediately return a request for comment.

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The five-year ban is something Trump proposed on the campaign trail in October, and it greatly expands on lobbying ethics rules that impose a one-year or two-year ban — often referred to as a “cooling-off period” — on lawmakers and administration officials becoming lobbyists after leaving government.

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