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At the dawn of a new administration, it’s fairly routine for top-level political appointees to remind their charges of the importance of ethical behavior. But the especially blunt nature of a memo from the Defense Department’s No. 2 official is striking some Pentagon observers as a tad ironic.

The October 20, 2009 directive from William Lynn, the new Deputy Secretary of Defense, states that “operating within high ethical standards and with integrity is absolutely key to the success of the Department.” Though the memo is addressed to DOD personnel, it also stresses that government employees should “ensure industry demonstrates ethics and integrity” too. The missive adds that attention needs to be paid “particularly in the area of conflicts of interest and the revolving door between Government service and employment in the private sector.”

Lynn himself is more than a bit familiar with the revolving door. During the Clinton administration, Lynn served first as director of program analysis and evaluation in the office of Secretary of Defense, and then as DOD comptroller. Later he became the chief lobbyist for Raytheon, one of the largest defense contractors with $21.5 billion in defense sales in fiscal year 2008, according to Defense News’ rankings. Now he’s back at the Pentagon.

Following Lynn’s nomination by President Obama, hackles were raised over his employment at Raytheon and the seemingly inevitable conflicts of interest he would face in his new role at DOD. Obama even had to waive his own ethics rules to nominate Lynn. The rules prevented lobbyists from getting political appointments in his administration related to topics or agencies on which they had recently lobbied.

“Our waiver provisions are designed to allow uniquely qualified individuals like … Bill Lynn to serve the public interest in these critical times,” said Robert Gibbs, the White House press secretary.

In response to letters from Senator John McCain, Lynn wrote that Pentagon General Counsel Jeh Johnson “would screen particular matters in which Raytheon is a specific party to determine whether to authorize my participation.”

Lynn also wrote that he would abstain for one year from working on the six programs he lobbied on while he was a Raytheon lobbyist in 2007 and 2008. The programs are: the DDG-1000 ship program, the F-15 airborne radar, the Patriot Pure Fleet missile defense upgrade program, the Future Imagery Architecture spy satellite program and the Multiple Kill Vehicle component of the U.S. missile defense program.


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