It’s been more than two years since President Donald Trump, who rallied campaign supporters with calls to “drain the swamp” of lobbyists and their ilk, took office. But despite that campaign promise, Washington influence peddlers continue to move into and out of jobs in the federal government.

In his first 10 days in office, Trump signed an executive order that required all his political hires to sign a pledge. On its face, it’s straightforward and ironclad: When Trump officials leave government employment, they agree not to lobby the agencies they worked in for five years. They also can’t lobby anyone in the White House or political appointees across federal agencies for the duration of the Trump administration. And they can’t perform “lobbying activities,” or things that would help other lobbyists, including setting up meetings or providing background research. Violating the pledge exposes former officials to fines and extended or even permanent bans on lobbying.

But loopholes, some of them sizable, abound. At least 33 former Trump officials have found ways around the pledge. The most prominent is former Interior Secretary Ryan Zinke, who resigned in December after a series of ethics investigations. He announced Wednesday that he is joining a lobbying firm, Turnberry Solutions, which was started in 2017 by several former Trump campaign aides. Asked whether Zinke will register as a lobbyist, Turnberry partner Jason Osborne said, “He will if he has a client that he wants to lobby for.”

Among the 33 former officials, at least 18 have recently registered as lobbyists. The rest work at firms in jobs that closely resemble federal lobbying. Almost all work on issues they oversaw or helped shape when they were in government. (Nearly 2,600 Trump officials signed the ethics pledge in 2017, according to the Office of Government Ethics. Twenty-five appointees did not sign the pledge. We used staffing lists compiled for ProPublica’s Trump Town, our exhaustive database of current political appointees, and found at least 350 people who have left the Trump administration. There are other former Trump officials who lobby at the state or local level.)

As we’ve reported before, some former officials are tiptoeing around the rules by engaging in “shadow lobbying,” which typically entails functions such as “strategic consulting” that don’t require registering as a lobbyist. Others obtained special waivers allowing them to go back to lobbying. In a few cases, they avoided signing the pledge altogether. Legislation aimed at closing some of the loopholes is contained in the Democratic-led ethics reform package, HR 1, the “For the People Act,” which had its first hearing in front of the House Judiciary Committee last month. (The same bill was proposed in the previous session of Congress, and the sponsors cited ProPublica’s reporting.)

Increasingly, both lobbyists and the firms that hire them are taking advantage of a loophole unique to the Trump ethics pledge: A clause that allows former political appointees to lobby on “any agency process for rulemaking, adjudication or licensing” despite the five-year lobbying ban. “Rulemaking” includes deregulation, a Trump administration priority. “Rulemaking is mostly what agencies do, and that’s what most lobbyists do. So that’s a pretty big carve-out,” said Virginia Canter, a former Obama administration ethics attorney who now works for the nonprofit Citizens for Responsibility and Ethics in Washington. Companies have taken notice.

(n) “Lobbying activities” has the same meaning as that term has in the Lobbying Disclosure Act, except that the term does not include communicating or appearing with regard to: a judicial proceeding; a criminal or civil law enforcement inquiry, investigation, or proceeding; or any agency process for rulemaking, adjudication, or licensing, as defined in and governed by the Administrative Procedure Act, as amended, 5 U.S.C. 551 et seq. —An excerpt from the Trump ethics pledge

Of course, the lobbying-government revolving door isn’t new. The Obama administration hired dozens of previously registered lobbyists, and many officials returned to K Street firms afterward. The “Daschle loophole” is named after former Democratic Senate Majority Leader Tom Daschle, who sidestepped lobbying laws after he left the Senate by becoming a “policy adviser.”

Such influencers, more numerous than registered lobbyists, are allowed to operate because they don’t meet the legal threshold requiring them to list themselves as lobbyists. By law, registration is required if a person spends 20 percent or more of his or her time lobbying. That leaves a lot of leeway, said Paul Miller, president of the National Institute for Lobbying & Ethics, an association for what it calls advocacy professionals. (“We’re just like you,” the organization’s website states.) Miller said he hears from people who do lobbying work, but haven’t registered, and “their phones are ringing off the hook.” Miller added, “It’s our No. 1 priority and concern.”

Ex-lobbyists play prominent roles in the Trump administration. The acting administrator of the Environmental Protection Agency (and nominee for the permanent job), Andrew Wheeler, is a former coal industry lobbyist. David Bernhardt, the acting Interior Department secretary and nominee for the permanent position, was chair of a lobbying firm’s natural resources division.

By our count, at least 230 former and current registered lobbyists have worked in the Trump administration.

The departments of Commerce, Defense, Energy, Interior, Justice and Treasury, as well as the Office of Management and Budget, did not respond to questions about their former employees-turned-lobbyists. The Department of Homeland Security directed questions to the White House, which declined to comment. The departments of Health and Human Services and Housing and Urban Development noted that the ethics pledge doesn’t prohibit former Trump officials from lobbying Congress or career employees at the agency.

At least 18 former Trump officials have become registered lobbyists at the federal level. Typically, they have been careful to avoid violating the ethics pledge. That usually means they interact with representatives, senators and congressional staff, but not with appointees at federal agencies or the White House. Here are several who have gone into lobbying jobs in the past year:

Courtney Lawrence was a longtime aide for Reps. Bill Cassidy and Tom Price and a federal lobbyist for the insurance trade association America’s Health Insurance Plans before taking a job as assistant secretary for legislative affairs at Health and Human Services in March 2017, when Price briefly headed the agency. Lawrence stayed for 18 months before leaving in August 2018 for a director role at Cigna Corp., the health insurance conglomerate.

Lawrence registered as a lobbyist with Cigna in October. Her disclosure forms state that she was working on proposed changes to Medicare, the Affordable Care Act and prescription drug rebates. Federal lobbying disclosures show that Lawrence was one of several lobbyists to communicate with federal agencies and the White House, and not just members of Congress. In a statement, Cigna asserted that the lobbying disclosure — which was prepared by the company — is inaccurate. Cigna blamed a “formatting issue.” The statement said Lawrence “does not and will not lobby the Executive Branch.” The company said it would correct her lobbying disclosure form

Jared Sawyer, a longtime Senate committee attorney and lobbyist, was deputy assistant secretary for financial institutions policy at the Treasury Department, overseeing two offices that regulate and monitor financial institutions and insurers. Sawyer was the lead policymaker on a set of proposed rule changes that would ensure that asset management and insurance firms don’t face the same regulations as banks.

In June, Sawyer left and took a job as a principal at Rich Feuer Anderson, a Washington lobbying firm catering to the financial services industry. He disclosed a host of clients, including BlackRock Capital, JPMorgan Chase and the Property Casualty Insurers Association of America, all of which were seeking guidance on navigating the offices Sawyer oversaw in the Trump administration. Rich Feuer Anderson did not respond to requests for comment.

Jason Larrabee was the Department of the Interior’s principal deputy assistant secretary for Fish and Wildlife and Parks before taking a lobbying job at Van Ness Feldman in May. In announcing Larrabee’s hiring, Van Ness Feldman noted his “deep understanding of our clients’ industries.” Larrabee has mostly lobbied congressional leaders on issues unique to the Interior Department, including National Park Service concessions, California water policy and Interior Department appropriations. In a statement, Van Ness Feldman said Larrabee signed the ethics pledge and is following its rules.

Larrabee worked on at least one project involving the agency he used to work for. Van Ness Feldman was hired last year to represent San Francisco-based ferry service company Hornblower Cruises and Events, which was seeking a new contract with the Interior Department to run passenger ferries to Alcatraz island. Congressional records show four lobbyists, including Larrabee, working for Hornblower. Larrabee is the only one with previous federal government work experience.

Larrabee “has not engaged in any DOI agency contacts” and “any such contacts were undertaken by other individuals” listed in lobbying disclosures, Van Ness Feldman said. In December, Hornblower was awarded a 15-year contract from Interior’s National Park Service to run the Alcatraz ferries.

(In response to ProPublica’s questions, Van Ness Feldman also said it would be correcting other lobbying disclosure reports the firm prepared, which it said incorrectly listed Larrabee and others as lobbying the Interior Department. “The firm takes ethical obligations seriously,” it said in its statement.)

Jonny Slemrod was the chief legislative aide for Mick Mulvaney at OMB. In November, he became a partner at Harbinger Strategies, a boutique lobbying firm founded by onetime aides to former House Majority Leader Eric Cantor and Sen. Trent Lott. Slemrod told Politico at the time that he would register as a lobbyist, but three months later, he has yet to do so. At OMB, Slemrod helped secure congressional support for the Tax Reform and Jobs Act of 2017 and, according to his online biography, he was Mulvaney’s “lead liaison to Congress and negotiator on numerous policy issues including all appropriations and authorizing measures.” Harbinger lobbied on behalf of the nation’s largest banks during the negotiations on the tax law. Now, the firm employs a person who helped formulate the law, though, because of the lack of disclosure, it’s impossible to determine whether Slemrod is involved in such work. Harbinger did not respond to requests for comment.

Other former Trump officials-turned-registered lobbyists include Shannon McGahn, a former Treasury attorney (and the wife of former White House counsel Don McGahn), who is now the top lobbyist at the National Association of Realtors; Alex Campau, a White House health policy aide now running the health lobbying team at Cozen O’Connor; Downey Magallanes, who was deputy chief of staff for policy at Interior before running Capitol Hill lobbying for BP America; Matt Kellogg, who was Treasury’s deputy assistant secretary for banking and finance before taking a lobbying job at HSBC; Beth Zorc, who now works as head of public policy at Wells Fargo after a stint as principal deputy general counsel at Housing and Urban Development; and Hunter Hall, who served as the Commerce Department’s deputy director of advance before taking a job as deputy director of federal affairs at the Picard Group. Chris Shank, a senior adviser to Air Force Secretary Heather Wilson, left to join lobbying firm Van Scoyoc Associates then returned to the Defense Department in August 2018 as director of the Strategic Capabilities Office. (BP America said Magallanes is only lobbying the House and Senate, and HSBC said Kellogg is in compliance with lobbying rules and honoring the ethics pledge. Wells Fargo declined to comment. Cozen O’Connor, Picard Group and the Defense Department did not respond to requests for comment.

An increasingly common tactic by ex-Trump officials is to create their own advisory and consulting firms that carefully skirt the line between lobbying and other services, like strategic or crisis communications, advocacy work or policy expertise. After leaving the Defense Department last year, Sally Donnelly and Tony DeMartino formed Pallas Advisors, described as a strategic advisory firm with “decades of experience at senior levels of the public and private sector” and providing “insight into how governments think and operate,” according to its website. Donnelly and DeMartino had previously worked together at a strategic advice firm that Donnelly used to own, SBD Advisors, with a client list that included Amazon Web Services, Bloomberg and Uber.

Donnelly and DeMartino have come under scrutiny. The tech giant Oracle is embroiled in a closely watched lawsuit with the Pentagon over a $10 billion cloud computing contract that experts expect Amazon to win. Oracle alleges, among other things, that the Defense Department allowed Donnelly and DeMartino to work on the project despite conflicts of interest. Oracle claims that DeMartino manipulated proposal requirements for Amazon’s benefit. (The Government Accountability Office looked into those claims and found that Donnelly played no significant part in the contract selection process and that DeMartino played no substantive role in the proposal requirements.)

At their new firm, Pallas, Donnelly and DeMartino don’t have to disclose their clients. A Pallas spokesman, attorney Michael Levy, said Donnelly and DeMartino signed the ethics pledge, are complying with all post-government restrictions and are not lobbying.

Scott Krause was executive secretary at the Department of Homeland Security, overseeing briefings and acting as a gatekeeper for the department’s senior leadership. He left after more than a year in the job, in May 2018, to start his own consulting firm, Krause Transformation. Its website says the firm “provides business transformation consulting, Department of Homeland Security (DHS) business development” and other services.

Krause told ProPublica that he signed the ethics pledge and doesn’t plan to lobby, adhering to a five-page memo he received from Homeland Security’s general counsel. But while he can’t talk to most of his former Homeland Security colleagues, he said he is allowed to offer “behind the scenes assistance with a company regarding DHS, which is why my company offers DHS expertise.”

“Behind the scenes” work is a gray area in government lobbying and legal circles, allowing former government officials to help clients navigate federal processes and relationships without violating conflict-of-interest laws. “There’s always been a question about what’s permitted as far as communication before the federal government and what’s permitted behind the scenes,” Canter said. When firms represent foreign interests or work on trade issues, Canter and others said, legal restrictions come into play. When they don’t, it’s usually fair game.