Cooling-Off Period¶

Separation rule — instantiates Rent-Seeking Channel Closure

Bars a decision-maker or gatekeeper from crossing to the parties they oversaw for a fixed waiting period, so the revolving door cannot pay off while the decision it might bias is still live.

Cooling-Off Period closes one specific rent channel: the revolving door, where an official's decisions are quietly shaped by the private job waiting on the other side. It does this not by judging any single decision but by imposing a categorical, time-bounded bar — for a set window after leaving a post, a person may not take employment, a directorship, or a lobbying brief with the parties they regulated, awarded contracts to, or supervised. The one idea that makes it this mechanism and not its siblings is that it works on the clock: it neutralises the anticipated future reward by delaying it until it can no longer bias the decisions made today. It does not detect a conflict, disclose it, or ask anyone to step aside — it simply puts a wall of time between the office and the payoff.

Example¶

A national medicines agency employs reviewers who decide whether new drugs reach the market. One reviewer has led the assessment of a large manufacturer's flagship application. The worry is not that she has done anything wrong, but that a lucrative role at that same manufacturer — offered a month after approval — would give every future reviewer a reason to be accommodating. A cooling-off rule addresses it structurally: for ≈18 months after leaving the agency, a reviewer may not accept employment or paid consultancy from any sponsor whose submission she handled. The manufacturer's standing job offer does not vanish, but it can no longer be collected while the approval it might reward is fresh. The reviewer stays; the anticipatory tilt is removed from the decision because the reward has been pushed outside the window where it could plausibly buy it.

How it works¶

The distinguishing move is that the bar is categorical and relationship-keyed, not case-by-case. It fires on a defined class of past role meeting a defined class of counterparty, with no discretionary judgement of intent required — which is exactly what makes it hard to argue around in the moment. The window is set to cover the period during which the person's inside knowledge, live relationships, and recent decisions still carry private value to the counterparty; after it lapses, the advantage is assumed cold. Enforcement leans on a declaration of post-employment, so the rule is only as strong as the disclosure regime that catches breaches.

Tuning parameters¶

Length of the window — longer periods sever the channel more completely but push able people out of the field and can look punitive; too short and the rule is decorative.
Breadth of coverage — which roles trigger it and which counterparties are off-limits. Widen it and you catch more of the channel; widen it too far and you freeze ordinary career mobility.
Scope of the barred activity — a total employment ban, or a narrower bar on lobbying one's former agency. The narrow version is easier to sustain but leaves the softer influence routes open.
Direction — forward-looking (leaving office → industry) alone, or also backward (industry → office, with a quarantine before regulating a former employer).
Enforcement teeth — disclosure only, clawback of benefits, or debarment. Without a real penalty the period is a suggestion.

When it helps, and when it misleads¶

Its strength is that it removes anticipatory bias without having to prove intent: no one need show that a decision was bought, only that the structure where it could be is closed for a while. Its failure mode is that it is easily made into theatre — a window set to expire just before the payoff lands, carve-outs for "advisory" roles, or grandfathering that exempts exactly the people it should bind. The classic misuse is to legislate a proud-sounding revolving-door rule^[1] with a period so short or so porous that it changes nothing, letting an institution claim the channel is closed while it stays open. The discipline that guards against this is to set the window against how long the private advantage actually stays live rather than to a round-sounding number, and to pair it with enough disclosure to make a breach visible.

How it implements the components¶

Cooling-Off Period fills only the structural-barrier subset of the archetype's machinery:

capture_firewall — it is a firewall, built out of time: a fixed interval that separates the exercise of public authority from its private reward.
allocation_rule_boundary — it draws a boundary around who may act, declaring recently-departed insiders out of bounds as counterparties for a defined window.

It does not map who is influencing whom or detect drift — that is Regulatory Capture Audit — and it does nothing about a live, present conflict on today's decision, which is the job of Conflict-of-Interest and Recusal Rule.

Instantiates: Rent-Seeking Channel Closure — Cooling-Off Period closes the time-adjacent revolving-door channel.
Consumes: Beneficial Ownership and Influence Disclosure supplies the post-employment declarations that make a breach detectable.
Sibling mechanisms: Conflict-of-Interest and Recusal Rule · Anti-Capture Rotation Protocol · Regulatory Capture Audit · Auction with Rent Recapture · Beneficial Ownership and Influence Disclosure · Competitive Rebid or Retendering · Sunset Clause Review · Entry-Barrier Sunset and Review · Independent Technical Evidence Panel · Performance-Based Clawback · Public Reason Docket · Randomized or Lottery Allocation · Rent-Seeking Audit · Standardized Scoring Rubric

Notes¶

A cooling-off period addresses only the future-reward channel; it is silent about conflicts that bias a decision in the present, which is why it is normally paired with a recusal rule rather than used alone. Setting the window is a genuine trade-off, not a technicality: the same length that reliably severs the channel also thins the pool of experienced people willing to take the public role in the first place.

References¶

[1] The revolving door — the movement of personnel between roles as regulators and roles in the industries they regulate — is the named channel this rule targets; cooling-off (or "quarantine") periods are the standard, and standardly-contested, instrument against it. ↩