No revolving doors in FMS Act of 2025

Summary

Prohibits former State Department and Department of Defense employees who worked on foreign military sales from knowingly contacting or appearing before federal agencies, officers, employees, or Congress to try to influence decisions under the Arms Export Control Act for three years after leaving government. The change amends the federal post-employment conflict-of-interest statute to add a targeted 3-year restriction tied to foreign military sales activity.

• Adds a targeted 3-year post-employment ban for former State and DoD employees who worked on foreign military sales.
• Bars knowingly making communications or appearances before federal agencies, officers, employees, or Congress to influence Arms Export Control Act determinations.
• Applies only to activities tied to chapter 2 of the Arms Export Control Act (foreign military sales).
• Focuses enforcement on communications made "with intent to influence," requiring intentional conduct for violation.
• Requires covered individuals and their private-sector employers to monitor prior FMS involvement and avoid covered advocacy for three years.
• Does not create new funding or authorize programs; it modifies an existing criminal conflict-of-interest provision.
• May reduce revolving-door lobbying influence on foreign military sales decisions while raising compliance and interpretive questions about intent.