Revolving-Door Cooling-Off Period¶

Personnel policy — instantiates Capture-Resistant Institutional Design

A mandatory waiting period before people may move between the institution and the actors it governs, cutting the career pipeline that turns a future job offer into present-day leniency.

A Revolving-Door Cooling-Off Period puts a time boundary across the door between the institution and the actors it governs. Someone leaving the institution may not take a job with, or lobby on behalf of, the regulated actor for a defined stretch; often symmetrically, someone arriving from the actor must wait or recuse before acting on matters that touch their former employer. The distinguishing idea is that it targets the career channel of capture — the anticipation of a lucrative future post that quietly softens today's decisions — with a structural, ex-ante time gap applied to a whole class of people, rather than a case-by-case judgment made after a conflict has already formed.

Example¶

A senior defence-procurement official has spent years overseeing billions in contracts to a major contractor. With no boundary, she could retire on Friday and start Monday as that contractor's vice-president for business development, monetising precisely the relationships and inside knowledge she built while regulating it — and every official watching would absorb the lesson that leniency pays later. A cooling-off rule bars her from lobbying or representing the contractor before her former office for ≈1–2 years, and from touching the specific programs she oversaw for longer. The aim is not to punish her; it is that the entire workforce now makes today's calls without a pending job offer riding on them, because the payoff has been pushed out of reach of the decision.

How it works¶

A boundary in time, applied ex-ante. It is a gap imposed on a class of people before any specific matter arises — not a ruling on one decision after the fact.
Often bidirectional. A post-employment restriction going out, and a recusal or cooling-in period coming in, so the interlock is blocked from both sides.
Scoped by matter and seniority. The more someone influenced, the longer and wider the bar — from specific-matter restrictions up to sector-wide ones for the most senior.
Backed by disclosure and penalty. Post-employment moves must be disclosed and breaches carry consequences, which is what separates a real boundary from a nominal one.

Tuning parameters¶

Duration — longer periods weaken the capture pull but also deter capable people from ever joining, and strand expertise on the far side.
Scope — narrow (the specific matters someone handled) versus broad (the whole industry). Broader is far harder to evade but costs more expertise.
Symmetry — outbound restriction only, or inbound cooling-in as well; two-sided closes the reverse route.
Seniority gradient — heavier bars for those who wielded more influence, lighter for junior staff, so the restriction tracks the actual risk.
Enforcement teeth — disclosure plus penalties versus an honour system; this dial alone decides whether the rule bites or is cosmetic.

When it helps, and when it misleads¶

Its strength is that it closes a capture channel that operates silently and prospectively — one a per-case conflict screen cannot reach, because at the moment of the decision there is no conflict to find, only a future the official is quietly steering toward.

Its failure modes are twofold. The door keeps spinning through loopholes — "senior advisor" or "consultant" titles that dodge the statutory definition of lobbying, or the period simply waited out and then the same move made. And set too long or too broad, it becomes brain drain, starving both the institution and the industry of scarce expertise and deterring good people from public service at all.^[1] The disciplines that keep it honest are defining the restricted activity by function rather than job title, sizing the duration to the influence actually held, and pairing it with disclosure so evasions surface instead of vanishing into a new business card.

How it implements the components¶

This policy fills the boundary-and-screening components on the personnel side:

cooling_off_and_rotation_boundary — it is this boundary: the enforced time gap (and rotation) on movement of people between the institution and the actors it governs.
conflict_and_interlock_screen — it screens the career-interlock form of conflict prospectively, barring the employment ties that would otherwise interlock overseer and overseen before any specific matter arises.

It does not adjudicate a present, specific conflict case-by-case (that is Conflict-of-Interest Disclosure and Recusal), wall off financial dependence (Funding Firewall Rule), or provide the standing independent body that reviews decisions (Independent Oversight Board).

Instantiates: Capture-Resistant Institutional Design — it severs the career pipeline through which soft capture accumulates.
Sibling mechanisms: Conflict-of-Interest Disclosure and Recusal · Funding Firewall Rule · Capture Risk Audit · Countervailing Stakeholder Panel · Enforcement Pattern Dashboard · Ex Parte Contact Disclosure Rule · Independent Oversight Board · Mandatory Reason-Giving for Exceptions · Privileged Access Log · Public Comment Docket · Sunset and Reauthorization Review · Third-Party Technical Replication

References¶

[1] The revolving door — the movement of personnel back and forth between an institution and the actors it regulates, and the soft capture it produces when the prospect of future employment shapes present decisions. A cooling-off period is the standard structural counter, trading some access to expertise for distance from that pull. ↩