Introduction

Federal law restricts what jobs you can take after government service, even on terminal leave.

Under 18 U.S.C. § 207, you face a lifetime ban on representing employers on matters you personally worked on, a two-year ban on matters under your responsibility, and additional cooling-off periods for senior roles.

Here's what happens: You're finishing 20 years, polishing your resume, interviewing with defense contractors. You get an offer. You accept. You start on terminal leave.

And you just violated federal ethics law.

Your new employer assumes you handled compliance. You assume terminal leave means you're clear. Neither is true.

Without written ethics clearance, you risk criminal penalties, contract termination, and a dead career before it starts. The Joint Ethics Regulation spells out post-government employment ethics restrictions for veterans that apply the moment you receive compensation from a new employer.

This guide covers what restrictions apply, when they kick in, and how to get documented clearance before your first day.

What Post-Employment Ethics Restrictions Apply to Military Personnel?

Federal law under 18 U.S.C. § 207 creates three main restrictions that kick in the day you separate:

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The Lifetime Ban

You can never represent an employer on any specific matter you personally and substantially worked on while in service. If you managed Contract X as a program manager, you cannot represent a company bidding on Contract X. Ever.

The Two-Year Ban

For matters that were under your official responsibility in your final year of service, you face a two-year representational ban. You supervised an acquisition program? You can't represent contractors on that program for two years after separation.

The One-Year Cooling-Off Period

Senior personnel (O-7 and above, SES, flag/general officers) face additional restrictions. You cannot represent anyone back to your former agency on any matter for one year.

Terminal leave doesn't fully protect you. You're still a federal employee until your official separation date. While you can start work for a contractor during terminal leave, you cannot appear in government workplaces or represent them to the government. Officers face stricter representational restrictions than enlisted members during this period.

Special Rules for Acquisition Personnel

If you worked in contracting or procurement, the Procurement Integrity Act adds restrictions. You cannot disclose contractor bid information or source selection data. You cannot accept compensation from a contractor whose bid you evaluated for one year.

What This Looks Like

An Army contracting officer evaluated bids for a logistics contract. She cannot work for any company that submitted a bid on that contract for one year. She also cannot represent any contractor on contracts she supervised for two years.

The lifetime ban (18 U.S.C. § 207(a)(1)) applies to all service members, not just senior officers. An E-5 who personally managed a specific IT project faces the same lifetime ban on that project as a colonel would. However, officers face additional representational restrictions under 18 U.S.C. § 203 and 205 that do not apply to enlisted members.

How Do You Get Written Ethics Clearance Before Starting a New Job?

Understanding these post-government employment ethics restrictions for veterans is one thing—getting proper clearance is another. Contact your installation JAG ethics attorney or Standards of Conduct office at least 30-60 days before your separation date. Don't wait until you have an offer in hand—start the conversation during your final interview stages.

Who to Contact

Your service has designated ethics counselors who handle post-employment questions:

• JAG ethics attorney at your installation legal office

• Standards of Conduct office for your service branch

• Designated Agency Ethics Official (DAEO) for agency-specific guidance

What to Bring to Your Ethics Consultation

Show up prepared with:

• Your new employer's job description (exact duties, not just a title)

• List of contracts, programs, or matters you worked on in your last 12-18 months

• Your current duty position description

• Names of companies or organizations you'll represent

The ethics counselor will walk through specific questions: Did you personally work on matters involving this employer? Did you supervise programs they bid on? Will your new role require you to represent them back to your old office?

Get It in Writing

Verbal advice doesn't count. You need a signed, written ethics determination that includes:

• Your name and separation date

• Specific restrictions that apply to you (lifetime, two-year, one-year)

• Duration of each restriction

• What work you CAN do without violating the law

According to the Joint Ethics Regulation, departing DoD personnel must receive ethics counseling that documents post-employment restrictions before separation. This written determination protects you if questions arise later.

If restrictions limit your job options, BMR's resume builder helps you create targeted versions for different roles that stay within legal boundaries.

Why Your New Employer Needs This Documentation Too

Once you have your written ethics determination, don't file it away—your new employer needs to see it. Defense contractors, consulting firms, and companies doing federal work face serious penalties if they hire someone who violates post-government employment ethics restrictions for veterans.

Here's what happens when you skip this step:

Major defense contractors usually ask for ethics clearance documentation during onboarding. They know the rules. But smaller firms or companies new to federal contracting may not request it. That doesn't mean you're off the hook.

Six months into your new role, an audit reveals you're working on a contract you previously managed. The company pulls you off the contract immediately. Your position gets eliminated. You're job hunting again, but now with a compliance issue on your record.

Smart approach: Share your written ethics determination during onboarding.

Give a copy to your hiring manager and HR. This protects both of you. You have documented proof you followed the law. They have proof they did their due diligence.

Your ethics clearance should specify:

• Which restrictions apply to you

• How long each restriction lasts

• What work you CAN do without conflicts

• Your official separation date

If ethics restrictions limit your options with one employer, don't panic. Use BMR's resume builder to create versions targeting different roles at companies where you have no conflicts. You've got options beyond the first offer.

Conclusion

Post-government employment ethics restrictions for veterans are real, legally binding, and apply even while you're on terminal leave.

The three-step process protects both you and your future employer: identify what programs you personally worked on, consult your JAG ethics attorney or Standards of Conduct office, and get written clearance before accepting any compensation from a new employer.

Most violations happen because people don't know these rules exist, not because they're trying to break them. A polished resume gets you the interview. Ethics clearance gets you the job without legal risk hanging over your head.

The Joint Ethics Regulation spells out exactly what restrictions apply to departing DoD personnel. Read it before your terminal leave starts.

BMR's career coaching resources help you plan a compliant transition strategy that maximizes your options while staying within legal boundaries. Get the clearance, document it, and move forward with confidence.