President Donald Trump this weekend signed his promised “drain the swamp” Executive Order, which imposes ethics restrictions on incoming and outgoing Trump Administration appointees. Incoming appointees would, of course, do well to carefully review the provisions of the Executive Order. But companies that deal with the Administration—whether by lobbying the executive branch, by seeing a former executive take a Presidentially appointed position, or by hiring a former Administration appointee—must also be mindful of these, in some cases, extremely restrictive provisions, lest they unwittingly get caught up in an ethics scandal.

While some in the media are claiming that the order is a significant weakening of a similar Obama-era Executive Order, the new Trump order is, in several subtle but key respects, much more restrictive than the Obama order.  Today, Covington has published a comprehensive advisory discussing these restrictions in more detail and comparing them to those imposed by President Obama when he assumed office.