Anti-Corruption

Real-time asset disclosure for all federal officials, candidates, and senior appointees in machine-readable public format

This rule requires all federal officials and candidates to disclose their assets in real-time in a format the public can easily search. It replaces slow, paper-based disclosure systems.

All Members of Congress, federal judges, executive branch officials at GS-15 level and above, candidates for federal office, and all Senate-confirmed appointees must file financial asset disclosures in a machine-readable, publicly searchable format within 30 days of taking office and within 15 days of any transaction exceeding $1,000. The Office of Government Ethics must conduct independent annual audits of all disclosures and must refer materially inaccurate or late filings to the Department of Justice for criminal investigation. Disclosure databases must be accessible to the public at no cost in formats compatible with standard data analysis tools.

Addresses the gap between nominal annual disclosure requirements and meaningful real-time transparency. Current requirements under the Ethics in Government Act and STOCK Act require annual reporting with long filing windows; disclosures are frequently in non-machine-readable formats not practically searchable by the public. Machine-readable real-time disclosure is the minimum necessary for civil society and journalism to function as accountability mechanisms.

No shell company anonymity for political donors — beneficial ownership certification required for all contributions of $5,000 or more

This rule requires any organization making a political donation of $5,000 or more to disclose who really controls it. It prevents wealthy donors from hiding behind shell companies.

Any entity making a federal campaign contribution, independent expenditure, or electioneering communication of $5,000 or more must disclose the identity of all beneficial owners holding 25% or more of the entity and all officers exercising substantial control, as a condition of the contribution being accepted. LLCs, trusts, and shell companies may not be used to obscure the identity of the ultimate human donor. The FEC must require beneficial ownership certification consistent with FinCEN Corporate Transparency Act standards before accepting any contribution above the threshold. Fraudulent beneficial ownership certification in connection with a political contribution is a criminal offense carrying a mandatory minimum of five years.

Shell companies, LLCs, and trusts are routinely used to obscure the true source of political contributions. Current FEC rules require attribution only to the registered entity — not to the humans behind it — creating a dark-money vector that operates below the 501(c) threshold. No comparable federal requirement currently mandates beneficial ownership certification as a condition of accepting political contributions.

Mandatory annual disclosure of all foreign financial ties for anyone holding federal office or a security clearance at SECRET or above

This rule requires anyone with a federal security clearance or holding federal office to annually disclose all foreign financial ties. It helps identify potential conflicts of interest and foreign influence.

Any person holding a federal security clearance at the SECRET level or above, or any federal officer or senior appointed official, must annually disclose all foreign-source income, foreign investments, foreign business relationships, foreign real property interests, and immediate family members who are foreign nationals or hold dual citizenship with any foreign government. Failure to disclose must result in automatic suspension of clearance and removal from office pending review within 30 days. The Department of Justice must investigate any foreign financial relationship that creates a potential conflict with the official's duties and must report findings to the relevant congressional oversight committee within 90 days.

Foreign financial entanglements create documented vectors for leverage, compromise, and conflicted decision-making by federal officials. Current disclosure requirements for clearance holders are inconsistently applied and rarely result in automatic consequences for omissions. No comprehensive statutory requirement mandates disclosure of foreign national family members for officials with policy responsibility toward those governments.

Constitutional amendment to overturn Citizens United and restore congressional authority to limit political spending by corporations and outside groups

This rule calls for a constitutional amendment to overturn the Citizens United Supreme Court decision. It would restore Congress's authority to limit political spending by corporations and outside groups.

Congress must pass, and actively campaign for ratification of, a constitutional amendment restoring the authority of federal, state, and local governments to set reasonable limits on campaign contributions and independent expenditures by corporations, unions, and other non-human entities. Pending ratification, Congress must enact the most restrictive statutory limits on corporate and Super PAC spending that current First Amendment doctrine permits, litigate test cases to rebuild the doctrinal record supporting expenditure limits, and must decline to confirm any federal judicial nominee who cannot articulate a coherent basis for distinguishing corporate from individual political rights.

Citizens United v. FEC (2010) and McCutcheon v. FEC (2014)^[9] have systematically dismantled spending limits by treating money as protected speech and corporations as rights-bearing persons equivalent to individuals for political spending purposes. No statutory fix alone can permanently resolve Citizens United; a constitutional amendment is the only durable remedy. The We the People Amendment and related proposals have been introduced in multiple Congresses without advancing.

Federal 6:1 small-dollar public matching fund for contributions under $200 — structurally shift candidate incentives toward small donors

This rule establishes a public financing program that matches small donations at a 6-to-1 ratio. It encourages candidates to focus on small donors instead of wealthy contributors.

Congress must establish a federal public financing program matching small-dollar contributions at a 6:1 ratio for any candidate or authorized committee that opts in and agrees to a per-election spending cap. Qualifying contributions are capped at $200 per donor per election cycle for matching purposes. The matching fund must be financed through a dedicated revenue mechanism — such as a surtax on political advertising expenditures above a cycle threshold — rather than through general appropriations that can be zeroed out by a hostile Congress. Candidates and committees opting in must refuse contributions from registered lobbyists, Super PACs, and any entity that has spent more than $50,000 on independent expenditures in the same cycle.

New York City's small-dollar matching program (8:1 for contributions up to $250) has demonstrably diversified the donor base for participating candidates relative to non-participating races.^[10] Federal adoption would structurally shift candidate incentives toward small donors across all 435 House races, 33 Senate races per cycle, and presidential contests. No federal small-dollar matching program currently exists.

Complete ban on direct and indirect electoral spending by foreign nationals — mandatory criminal penalties and automatic FARA registration trigger

This rule completely bans foreign nationals and foreign governments from spending money on U.S. elections. It includes mandatory criminal penalties for violations.

Foreign nationals, foreign governments, foreign political parties, and any U.S. entity acting at the direction of a foreign principal are completely prohibited from making any contribution, expenditure, donation, or disbursement in connection with any federal, state, or local election. Indirect spending — including funding of pass-through U.S. entities that then make political expenditures — is equally prohibited and must be criminally prosecuted. Knowing violations carry mandatory minimum criminal sentences of five years. Any U.S. entity that receives funds from a foreign principal and makes any political expenditure within two years of receipt must register under FARA regardless of whether political activity was the stated purpose of the foreign funds.

Current law (52 U.S.C. § 30121) prohibits foreign national contributions but enforcement has been inconsistent and penalties inadequate to deter sophisticated foreign influence operations that funnel money through domestic intermediaries. High-profile cases involving Russian, Saudi, Israeli, and Chinese funding of U.S. political activity have documented the inadequacy of existing deterrents. No automatic FARA trigger currently links receipt of foreign funds to subsequent domestic political activity.

5-year revolving door cooling-off period for all former Members, cabinet officials, and senior staff; lifetime ban on lobbying for foreign adversary governments

This rule requires former members of Congress, cabinet officials, and senior staff to wait five years before becoming lobbyists. It includes a lifetime ban on lobbying for foreign adversary governments.

Former Members of Congress and their senior staff at GS-15 equivalent and above, former cabinet officials, and all senior executive branch officials including EOP staff and Senate-confirmed appointees are prohibited from any compensated lobbying of any federal agency, official, or congressional office for five years following separation from federal service. Any former federal official who engages in compensated work on behalf of a foreign government designated by the State Department as a foreign adversary is subject to a lifetime ban, mandatory criminal penalties, and permanent bar from future federal employment or contractor positions. For purposes of this prohibition, "lobbying" must include "strategic advisory," public relations, and any compensated activity designed to influence specific federal legislative or regulatory outcomes regardless of formal registration status.

The current one-year cooling-off period for Members and two-year period for senior officials is routinely circumvented through "strategic advisor" roles, law firm positions, and think-tank fellowships that perform lobbying functions without formal registration.^[11] A five-year period meaningfully disrupts the revolving door's ability to convert government access into immediate commercial value. No current statute imposes any lifetime ban for foreign adversary lobbying by former officials.

Expand lobbyist registration to cover "strategic advisors," PR firms, and law firms compensated to influence any specific federal policy outcome

This rule expands lobbyist registration requirements to include strategic advisors, PR firms, and law firms paid to influence federal policy. It closes loopholes that let influence peddling go undisclosed.

The Lobbying Disclosure Act must be amended to require registration and public disclosure by any person or entity compensated to: develop or coordinate strategies for influencing federal legislation or regulation; provide public relations, media, or communications services aimed at shaping federal policy outcomes on specific matters; or provide legal advice in connection with federal regulatory proceedings in which the client has a direct financial interest in the outcome. The LDA's current 20% threshold for lobbying activity — which enables evasion by structuring formal lobbying time below one-fifth of total work — must be eliminated. Any compensated activity directed at influencing a specific federal legislative or regulatory outcome must trigger registration regardless of what percentage of total work time it constitutes.

The most effective lobbyists today frequently avoid LDA registration thresholds by operating as "strategic counselors," "public affairs" consultants, or attorneys while performing functionally equivalent lobbying activity. The 20% rule is a documented avoidance strategy used across Washington's influence industry.^[12] Expanding registration to cover functional conduct rather than formal categorization would capture the shadow lobbying system.

Zero-tolerance gift and travel ban — no Member of Congress or federal employee may accept anything of value from a lobbyist or any entity with a financial interest in their official duties

This rule prohibits members of Congress and federal employees from accepting anything of value from lobbyists or anyone with a financial interest in their work. It's a zero-tolerance gift ban.

No Member of Congress, congressional staffer, federal officer, or federal employee may accept any gift, travel, lodging, meal, entertainment, or thing of value from any registered lobbyist, any organization that employs a registered lobbyist, or any individual or entity known to have a financial interest in legislation or regulation within the official's jurisdiction. The prohibition must have zero exceptions for "widely attended events," "informational meetings," or other currently exploited categories. Violations by Members carry mandatory public disclosure and ethics referral. Violations by executive branch employees carry removal for a second offense. The gifting entity faces civil penalties equal to ten times the value of the prohibited benefit, and competing parties harmed by the improper access have a private right of action.

Current gift rules contain exceptions — "widely attended events," "informational meetings," and de minimis thresholds — that function as practical loopholes for lobbyist access to officials unavailable to ordinary constituents. A zero-tolerance standard removes interpretive ambiguity and eliminates the incentive to structure access-buying just below existing thresholds. No current statute provides a private right of action for competing parties harmed by improper access-buying.

Complete ban on individual stock, options, and cryptocurrency trading for Members of Congress, senior staff, and federal judges while in office and for six months after separation

This rule completely bans members of Congress, senior staff, and federal judges from trading individual stocks, options, and cryptocurrency while in office and for six months after leaving. It prevents insider trading.

Members of Congress, their senior staff at GS-15 equivalent and above, all Senate-confirmed executive branch officials, and all Article III federal judges are prohibited from purchasing, selling, or otherwise trading individual equities, equity options, commodity futures, cryptocurrency, non-fungible tokens, and any other speculative financial instrument while in covered service. The prohibition extends for six months following separation. Covered persons must, within 60 days of entering covered service, fully divest all prohibited holdings or place them in a qualifying blind trust meeting OGE standards. Violations carry civil penalties and mandatory referral to the relevant ethics or disciplinary body for removal proceedings.

The STOCK Act (2012) requires disclosure but does not ban trading. Multiple independent studies have found that Members of Congress systematically outperform market benchmarks at rates inconsistent with random selection, suggesting material nonpublic information derived from government service. The ETHICS Act and similar bans have not been enacted despite repeated introduction. Cryptocurrency must be covered because it presents the same conflict-of-interest risk as equity trading and has been subject to documented congressional conflicts.

Stock trading ban extended to spouses and dependent children of all covered officials — no household-member evasion permitted

This rule extends the stock trading ban to spouses and dependent children of covered officials. It prevents officials from evading the ban through family members.

The trading prohibitions in CRPT-STCK-0001 apply in full to the spouse, domestic partner, and dependent children of every covered official. Covered officials must certify annually, under penalty of perjury, that no household member has engaged in any prohibited transaction during the reporting period. Any transaction in a prohibited instrument by a household member within 30 days before or after any legislative or regulatory action by the covered official that could affect the value of that instrument must be presumed a knowing circumvention of the ban. Violations carry the same penalties as direct violations by the covered official, with enhanced criminal penalties for intentional evasion through household accounts.

Spouses of Members of Congress have been among the most active traders in congressional households that systematically outperform market benchmarks. Multiple documented cases show family trading patterns that closely track official legislative activity on committees with direct oversight of the traded sectors. Excluding family members creates an obvious and judicially recognized evasion vector. No current statute closes this gap for congressional households.

Mandatory blind trust for financial assets over $1 million — genuinely independent trustee, no communication of holdings to the official

This rule requires covered officials with more than $1 million in financial assets to put them in a truly independent blind trust. The official cannot communicate with the trustee about holdings.

Any covered official holding total financial assets exceeding $1,000,000 — other than a primary residence, federally-insured deposit accounts, U.S. government obligations, and broadly-diversified index funds with no individual equity holdings — must place those assets in an OGE-qualifying independent blind trust within 90 days of entering covered service. The blind trust must be administered by an independent trustee with no existing business, professional, or personal relationship with the covered official; the trustee may not communicate the trust's holdings or transactions to the official at any time during covered service; and the official may not direct or influence the trustee in any manner. Failure to comply within the required period is grounds for removal from office.

Existing OGE blind trust guidance is voluntary for most officials below the President and VP. "Diversified portfolio" claims by officials retaining individually selected holdings are unverifiable as actual independence from potential conflicts. Genuine blind trust administration — where the official truly does not know what they own — is the only structural remedy for equity-based conflicts that cannot be addressed through divestiture alone.

Real-time 24-hour transaction disclosure for all covered officials and household members — replace the STOCK Act's 45-day window

This rule requires covered officials and their household members to publicly disclose any financial transaction within 24 hours. It replaces the current 45-day window that allows secret trading.

Any financial transaction by a covered official or covered household member in any financial instrument must be publicly disclosed in machine-readable format within 24 hours of execution. The STOCK Act's 45-day disclosure window must be repealed and replaced with this real-time standard. Disclosures must be filed in a centralized, publicly searchable federal database maintained by the Office of Government Ethics and accessible at no cost. Late filings carry a civil penalty of $1,000 per day of delay with no maximum cap, and three or more late filings within a two-year period trigger automatic ethics referral and a mandatory public hearing before the relevant ethics committee.

A 45-day disclosure window provides no meaningful protection against insider trading: a trade made on material nonpublic information from government service generates its financial benefit immediately, not 45 days later. Real-time disclosure creates the possibility of timely public scrutiny and investigative accountability. Current STOCK Act minimum fines of $200 have no deterrent effect; studies have documented hundreds of late STOCK Act filings by Members without meaningful consequence.

Mandatory public filing of presidential and vice-presidential tax returns for every year of service — IRS must publish within 30 days of filing

This rule requires the president and vice president to publicly file their tax returns every year they serve. The IRS must publish them within 30 days.

The President and Vice President must publicly file their complete individual, joint, and business entity federal income tax returns — including all schedules, K-1 forms, and related filings — for every year during which they hold office. Returns must be published on a government-maintained public website in machine-readable format within 30 days of filing. The IRS must complete mandatory audit of presidential tax returns and must release audit findings and any criminal referrals to the public within 90 days of completion. No executive privilege, confidentiality claim, or privacy interest may be invoked to withhold returns from Congress or from the required public filing.

President Trump's refusal to disclose tax returns from 2017 through 2022 exposed the absence of any legal compulsion for presidential disclosure. Voluntary norms followed by every president since 1974 were never codified. The Ways and Means Act mechanism eventually obtained Trump's returns, but years of litigation delayed disclosure until after his terms. A statutory requirement with immediate public filing eliminates this delay and closes the voluntary-norm gap permanently.

No federal contracts or procurement awards to companies in which a sitting President, VP, or cabinet officer holds a financial interest

This rule prohibits the federal government from awarding contracts to companies where the president, vice president, or cabinet officers have a financial interest. It prevents self-dealing.

No federal contract, grant, subcontract, cooperative agreement, or other federal procurement above $25,000 may be awarded to any company, LLC, partnership, trust, or other legal entity in which the President, Vice President, any cabinet officer, or any Senate-confirmed official holds a direct or beneficial financial interest exceeding $5,000. Violations must be treated as a civil False Claims Act violation and referred to DOJ for criminal investigation. The General Services Administration must screen all procurement awards against OGE financial disclosure records before award and flag all potential conflicts for independent review before execution. Covered officials must certify the absence of any financial conflicts as a condition of participation in any procurement, regulatory, or enforcement decision affecting a specific company or industry sector.

Trump Organization properties received payments from federal agencies, foreign governments, and officials seeking presidential access during the Trump administration, none of which was subject to any legal prohibition. The existing conflict-of-interest statute (18 U.S.C. § 208) is excluded from application to the President and VP by longstanding OLC interpretation. A procurement-linked prohibition creates both a structural remedy and a False Claims Act enforcement mechanism that does not depend on executive branch self-enforcement.

Pardon abuse prevention — self-pardon explicitly prohibited; Congress must have authority to refer co-conspirator pardons for judicial review

This rule explicitly prohibits presidents from pardoning themselves and allows Congress to refer co-conspirator pardons for judicial review. It prevents abuse of the pardon power.

Congress must enact a statute providing that: (a) the President may not pardon himself or herself, and any purported self-pardon is void as a matter of law and must be so declared by a federal court on petition by any Member of Congress; (b) any presidential pardon issued to a person charged with or convicted of conduct arising from the same criminal scheme or conspiracy as the pardoning official is subject to mandatory congressional review and referral for judicial review of constitutional authority; and (c) use of the pardon power to obstruct or terminate an ongoing criminal investigation of the pardoning official constitutes obstruction of justice and must be prosecuted independently of the pardon's validity. Persons directly harmed by a corrupt pardon must have a civil private right of action against any person who procured the pardon through fraud or bribery.

The constitutional question of presidential self-pardons was never definitively resolved in any court before Trump's 2024 conviction and subsequent election. Presidential pardons of co-conspirators — including Roger Stone, Paul Manafort, and others whose charges arose from Trump campaign conduct — demonstrate the potential for abuse when accountability of the pardoning official is directly at stake. No current statute addresses pardon abuse or provides any judicial review mechanism for plainly self-interested pardons.

Binding Supreme Court code of conduct enacted by Congress with an independent enforcement body — voluntary self-policing is not sufficient

This rule requires Congress to enact a binding code of conduct for all federal judges including Supreme Court justices. An independent body would enforce it, not the judges themselves.

Congress must enact a binding, statutory code of conduct applicable to all Article III federal judges including Supreme Court Justices. Enforcement must be vested in an independent Judicial Ethics Enforcement Body whose members are appointed jointly by the Judicial Conference, the Inspector General for the Federal Judiciary (to be established), and a bipartisan panel of retired federal appellate judges not currently in federal employment. The enforcement body must have authority to investigate complaints filed by any person, compel production of financial records and disclosure filings, and recommend sanctions including public censure, recusal mandates, and referral for impeachment to Congress. The Supreme Court's voluntary 2023 code is explicitly superseded by this statutory requirement.

The Supreme Court adopted a voluntary code of conduct in November 2023, but the code has no enforcement body, no binding recusal standards, and no consequences for non-compliance. ProPublica's 2023–2024 reporting documented that Justice Clarence Thomas accepted undisclosed gifts, travel, real property transfers, and tuition payments from Republican mega-donor Harlan Crow over two decades without any legal consequence. Justice Samuel Alito similarly accepted undisclosed travel from a party with ideological interests before the Court without recusal.

Statutory financial and hospitality disclosure for all federal judges; recusal standards codified and enforced by an independent body — no self-recusal decisions

This rule requires all federal judges to file detailed annual financial disclosures and codifies when they must recuse themselves from cases. An independent body enforces the rules, not the judges.

All federal judges including Supreme Court Justices must file annual financial disclosures in a publicly searchable, machine-readable format covering all income, investments, gifts, travel, lodging, meals, and hospitality received. Recusal standards must be codified in statute: a federal judge must recuse from any matter in which (a) the judge or an immediate family member holds a financial interest in any party or entity that has filed an amicus brief; (b) any party, party's counsel, litigation funder, or litigation sponsor has provided the judge with gifts, travel, meals, or hospitality exceeding $50 in aggregate in the prior five years; or (c) a reasonable observer with full knowledge of the relevant facts would question the judge's impartiality. Judges may not unilaterally decide their own recusal — disputes must be resolved by the Chief Judge of the relevant circuit, or for the Supreme Court, by the full enforcement body established under CRPT-JUDL-0001.

Existing financial disclosure requirements for federal judges under the Ethics in Government Act have been inconsistently followed and disclosures are not publicly searchable. The recusal standard in 28 U.S.C. § 455 exists but is self-enforced; Supreme Court Justices have historically decided their own recusal questions unilaterally and without review. Third-party litigation funders — increasingly common in ideological cases — are not covered by any current disclosure requirement for presiding judges.

Zero-tolerance prohibition on gifts and travel from case-adjacent donors; mandatory automatic recusal for any judge who has received benefits from a donor whose interests are before the court

This rule prohibits federal judges from accepting gifts or travel from anyone whose interests may come before the court. It requires automatic recusal when a judge has received benefits from a party in a case.

No federal judge may accept any gift, travel, lodging, meal, tuition, real property interest, or financial benefit of any kind from any person, organization, foundation, or law firm that has a case pending before that court, has filed or is likely to file an amicus brief in any matter before that court, or has an ideological or financial stake in pending litigation before that court. Any violation requires immediate recusal from all matters involving the benefiting party. Any judge who has received benefits totaling more than $500 in aggregate from any individual or affiliated organization in the preceding five years must automatically recuse from any case in which that individual, their company, or any party substantially controlled by them appears or has filed an amicus brief.

ProPublica's investigation documented that Justice Thomas received gifts, travel, and real property-adjacent transfers from Harlan Crow, whose organizations financed conservative litigation at the Supreme Court level and whose business partners had matters before the Court. No enforcement mechanism currently compels recusal or sanctions non-disclosure. The $500 aggregate threshold over five years is intentionally low to prevent structured giving designed to stay below any single-gift limit.

Expand False Claims Act qui tam provisions to all federal fraud — not limited to procurement contracts

This rule expands the False Claims Act to cover all types of federal fraud, not just procurement contracts. It allows whistleblowers to sue on behalf of the government and share in recoveries.

The qui tam relator provisions of the False Claims Act (31 U.S.C. §§ 3729–3733) must be amended to cover all fraud against any federal program, fund, or revenue stream, not only fraud in government procurement and contracts. Any person with direct knowledge of fraud against a federal tax, subsidy, grant, benefit, regulatory, or appropriations program must be eligible to file a qui tam complaint and receive a statutory relator's share of any government recovery. The FCA's anti-retaliation provisions must apply to all qui tam relators regardless of the underlying federal program. Federal contractor employees reporting fraud by their employer must receive the same whistleblower protections as direct federal employees, including the private right of action for reinstatement.

The False Claims Act's qui tam mechanism has recovered over $75 billion for the federal government since 1986, overwhelmingly through private whistleblower actions rather than government initiative. Current FCA coverage is limited to procurement and government-funded contracts, leaving tax fraud, regulatory fraud, and other federal program fraud without an equivalent enforcement mechanism. Expanding qui tam provisions creates a private enforcement incentive that supplements chronically underfunded federal enforcement agencies.

Universal private right of action for retaliation against any whistleblower reporting federal wrongdoing to Congress, an IG, law enforcement, or the press

This rule creates a universal right for whistleblowers to sue if they face retaliation for reporting wrongdoing. It covers reports to Congress, inspectors general, law enforcement, or the press.

Any federal employee, federal contractor employee, grantee employee, or private sector employee who reports information about federal government wrongdoing to any Member of Congress, congressional committee, federal Inspector General, federal law enforcement agency, or journalist must have a private right of action in federal court against any person or entity that retaliates through termination, demotion, harassment, civil litigation, criminal referral, blacklisting, or any other adverse action. Successful plaintiffs must be entitled to reinstatement, back pay, compensatory damages, punitive damages of at least three times actual damages, and mandatory attorney's fee awards. No non-disclosure agreement, severance agreement, contractor term, or other private arrangement may waive or limit this private right of action, and any such clause is void as against public policy.

Existing whistleblower protections are fragmented by sector: the Whistleblower Protection Act covers direct federal employees but not contractors; the FCA covers procurement fraud reporters; securities, tax, and environmental whistleblowers have separate statutes. Contractors performing substantial government functions are particularly vulnerable. A universal private right of action with robust remedies creates a floor that applies regardless of employment status and cannot be contracted away by the entity being reported on.

Federal anti-SLAPP statute — automatic dismissal of meritless suits targeting whistleblowers with mandatory triple-fee-shifting and judicial sanctions for abusive plaintiffs

This rule creates a federal anti-SLAPP law that automatically dismisses meritless lawsuits targeting whistleblowers. It requires abusive plaintiffs to pay triple the whistleblower's legal fees.

Congress must enact a federal anti-SLAPP (Strategic Lawsuit Against Public Participation) statute applicable in all federal courts and in all state court proceedings arising from whistleblowing activity on any matter of federal public concern. A defendant whistleblower who prevails on an anti-SLAPP motion must receive mandatory attorney's fees and costs. Courts must prioritize anti-SLAPP motions and must stay all discovery while the motion is pending. Any plaintiff found to have filed a meritless SLAPP suit must be liable for the defendant's attorney's fees multiplied by three, and presiding judges must refer abusive plaintiff attorneys for bar disciplinary proceedings. The statute applies to suits by private parties and government entities alike and may not be waived by contract.

SLAPP suits — civil litigation designed to punish and silence whistleblowers through litigation costs rather than merit — are among the most effective tools for suppressing government accountability. Twenty-nine states have anti-SLAPP statutes but there is no federal equivalent, leaving federal court whistleblowers and those in states without protection undefended. Federal legislation would create a uniform floor that cannot be avoided by strategic choice of forum.

IGs may only be removed for cause stated in writing to Congress 30 days in advance — private right of action for wrongful removal with reinstatement remedy

This rule allows Inspectors General to be removed only for cause stated in writing to Congress 30 days in advance. Wrongfully removed IGs can sue to get their jobs back.

Any Inspector General established under the Inspector General Act (5 U.S.C. App.) may be removed from office only for inefficiency, neglect of duty, or malfeasance in office. The President must provide written notice to Congress specifying the stated cause not fewer than 30 days before the removal takes effect, and this notice must be publicly released. An IG whose removal is found by a federal court to lack adequate stated cause must have a private right of action for reinstatement, back pay, and compensatory damages. The President may not install any acting IG, agency official, or political appointee to exercise IG functions while a legal removal challenge is pending in federal court. Any removal of an IG during an active investigation of the removing official is rebuttably presumed to lack cause and must be reviewed by a three-judge panel within 30 days.

In April 2020, President Trump fired multiple IGs without stated cause, including the Intelligence Community IG who had transmitted the Ukraine whistleblower complaint to Congress. In 2025, the Trump administration again fired IGs at multiple agencies simultaneously. Prior legislation required 30 days' notice but provided no judicial enforcement or reinstatement remedy. Without a private right of action with reinstatement as an available remedy, cause requirements remain aspirational rather than legally binding.

IG reports must be publicly released within 30 days of completion; Congress must receive unredacted copies; suppression of IG findings is a criminal offense

This rule requires all Inspector General reports to be publicly released within 30 days. Suppressing IG findings becomes a criminal offense.

Every report, audit, inspection, and completed investigation by a federal Inspector General must be publicly released within 30 days of completion. Redactions are permitted only for classified national security information specifically identified in a written classification determination, or information about an ongoing law enforcement proceeding where disclosure would compromise a specifically identified investigation. Congress must receive unredacted copies of all IG reports including those containing classified information, subject to applicable security procedures. Any executive branch official who delays, suppresses, modifies, orders the modification of, or prevents the release of a final IG report commits a criminal offense. Any official who directs an IG to alter investigative findings commits obstruction of a congressional function and must be prosecuted.

Multiple IG reports have been delayed, classified after completion, modified under agency pressure, or not released by the agencies being investigated. Without a mandatory release timeline with criminal penalties for suppression, IG independence is functionally limited by the willingness of agency heads to permit publication of findings that implicate them or their political superiors. Congress must receive unredacted copies because partial releases have been used to conceal the most significant findings from oversight committees.

IG budgets may not be reduced by the investigated agency — independent funding floor of 1% of agency discretionary spending, enforced by private right of action

This rule prevents agency heads from cutting Inspector General budgets. IGs get guaranteed funding of at least 1% of their agency's discretionary spending.

No federal agency head may propose, recommend, implement, or cause a reduction in the budget of that agency's Inspector General without the prior written concurrence of the IG Council and a two-thirds vote of the relevant congressional oversight committee. Each IG office must receive an annual appropriation equal to at least 1% of the investigated agency's total discretionary spending, indexed annually for inflation and agency workforce growth. IG appropriations must be enacted as independent line items separate from the agency's operational budget and may not be rescinded, reprogrammed, or transferred by the agency head. Any agency head who attempts to reduce IG resources in violation of this section must notify Congress within 72 hours, and the IG must have a private right of action to enforce the minimum funding requirement in federal court.

Budget control is a primary mechanism through which agencies suppress IG independence without directly removing the IG. An underfunded IG cannot conduct audits of adequate scope, hire qualified investigators, or maintain institutional capacity to challenge powerful agencies. Budget cutting targeting IG offices during 2025 DOGE-era reorganizations demonstrated the acute vulnerability of IG funding to unilateral executive action. Financial independence requires a statutory funding floor just as much as personnel protection does.

Mandatory Conflict Disclosure for Federal Consulting Contracts

This rule requires consulting firms with federal contracts to disclose all private clients that might create conflicts of interest. It prevents consultants from serving conflicting interests.

Any consulting firm awarded a federal contract must disclose, at the time of proposal submission and annually throughout contract performance, all private-sector clients in the same industry or regulatory sector as the contracting agency. A contract is void ab initio if the contractor knowingly concealed a material conflict; the firm is debarred from federal contracting for 5 years and subject to disgorgement of all fees received under the conflicted contract. The inspector general of each agency must review all consulting contracts above $1 million annually for undisclosed conflicts. Structural remedy: mandatory debarment and disgorgement are automatic upon a finding of concealment, not discretionary. Criminal enforcement: knowing concealment of a material conflict is a federal criminal offense. Private right of action: any competing bidder harmed by a concealed conflict may bring a civil action for damages.

Major consulting firms including McKinsey & Co. have simultaneously advised governments and private corporations in the same industries, including pharmaceutical companies and their regulators. McKinsey paid $573 million to settle claims related to its opioid consulting work.

Consulting Firms Employing Former Agency Officials May Not Contract With Those Agencies

This rule prohibits consulting firms that employ former agency officials from getting contracts with those agencies. It prevents the revolving door between government and consulting.

A consulting firm that employs, or enters into a compensated advisory arrangement with, a former federal official may not receive a contract from any agency that official led or in which that official held a position of Senior Executive Service rank, for a period of 3 years following the official's departure. This restriction applies to the entire firm, not merely to the former official's practice area. Structural remedy: any contract awarded in violation is void ab initio and all fees paid must be disgorged. Criminal enforcement: violations trigger mandatory referral to DOJ; the former official is subject to criminal liability under 18 U.S.C. § 207. Private right of action: any competing bidder who was passed over for a contract later voided under this section has a civil cause of action for damages and attorney's fees.

Full Public Disclosure of All Federal Consulting Contract Work Products

This rule requires all work products from federal consulting contracts over $500,000 to be published online. It ensures taxpayers can see what they paid for.

All work products — reports, analyses, recommendations, and presentations — produced under federal consulting contracts above $500,000 must be published on a public government portal within 90 days of delivery to the agency, unless the agency head certifies in writing that specific portions contain classified national security information. Blanket confidentiality agreements covering entire consulting engagements are void as against public policy. Congress must be notified of all consulting contracts above $5 million within 30 days of award. Structural remedy: confidentiality clauses purporting to cover non-classified work are unenforceable as against public policy and void. Criminal enforcement: willful suppression of a required disclosure by an agency official is a criminal obstruction offense. Private right of action: any person denied access to a required disclosure may bring an action in federal court for release of the work product and attorney's fees.

Full Disclosure of All Employer Payments for Union Avoidance Activity

This rule requires employers to publicly disclose all payments to union-busting consultants and law firms. It ensures workers know when their employer is paying someone to fight their union.

The Labor-Management Reporting and Disclosure Act must be amended to require employers to report all payments to labor relations consultants, law firms, and third parties engaged to persuade employees not to organize or bargain collectively, including indirect payments through trade associations and law firm retainers; the "advice exemption" to LMRDA reporting is eliminated. All consultant persuader agreements must be filed with the Department of Labor within 30 days; noncompliance is a federal misdemeanor. Reports must be publicly accessible in a searchable database. Structural remedy: elimination of the advice exemption is a structural change to the reporting framework that closes a statutory loophole; no discretion is granted to the Department of Labor to reinstate the exemption by rule. Criminal enforcement: noncompliance with mandatory filing is a federal misdemeanor. Private right of action: any employee whose organizing rights were impaired by an undisclosed persuader engagement may bring a civil action against the employer and the consultant.

Employers spend an estimated $340 million annually on union avoidance consultants.^[13] The LMRDA advice exemption has shielded most of this spending from public disclosure.

Workers Must Be Notified When Employer Has Hired Union-Busting Consultants

This rule requires employers to notify workers in writing within 48 hours when they hire union-busting consultants. It gives workers transparency about anti-union campaigns.

When an employer engages a labor relations consultant for union avoidance purposes, the employer must notify all affected employees in writing within 5 business days, identifying the consultant and the nature of the engagement. Employees have the right to know the identity and compensation of any individual who addresses them on the subject of unionization on behalf of the employer. Structural remedy: failure to notify is an unfair labor practice and the NLRB must treat it as evidence of bad faith in any concurrent organizing campaign. Criminal enforcement: a pattern of willful non-notification may be referred to DOJ as obstruction of the right to organize. Private right of action: any employee who received persuader communications without the required prior notification has a private right of action against the employer for statutory damages and injunctive relief.

Sponsored Content Must Be Labeled with Prominent "Paid Advertisement" Disclosure

This rule requires all sponsored content and native advertising to be labeled with a prominent "Paid Advertisement" notice. It prevents deceptive advertising disguised as news or editorial content.

All native advertising, sponsored content, and paid editorial placements — whether in print, digital, broadcast, or social media — must bear a disclosure label reading "PAID ADVERTISEMENT" in font size and prominence equal to or greater than the headline of the content. Disclosure must appear at the top of the content before any substantive text; end-of-article disclosures do not satisfy this requirement. Structural remedy: any publication, platform, or broadcaster that systematically fails to comply must be subject to mandatory corrective disclosure campaigns at the violator's expense, and the FTC must revoke safe-harbor status under any applicable platform liability provision. Criminal enforcement: willful concealment of paid placement that causes material consumer harm is a criminal fraud offense. Private right of action: any consumer who relied on undisclosed sponsored content to their material detriment has a private right of action for actual damages, treble damages for knowing violations, and attorney's fees. The FTC must enforce this requirement through civil monetary penalties of up to $50,000 per violation.

Native advertising is a $400 billion global industry.^[14] Studies show the majority of readers cannot distinguish native advertising from editorial content.^[15]

Digital Platforms Bear Secondary Liability for Undisclosed Sponsored Content

This rule makes large digital platforms responsible for enforcing disclosure rules on sponsored content. It ensures platforms cannot profit from deceptive advertising.

Digital platforms with more than 10 million monthly active users must maintain and enforce policies requiring disclosure of all sponsored, promoted, or paid content; platforms that knowingly host undisclosed native advertising after receiving notice of a violation are jointly liable with the advertiser for FTC civil penalties. Platforms must maintain a publicly accessible, searchable archive of all paid placements for a minimum of 4 years. Political advertising on digital platforms must be disclosed under the same rules as broadcast political advertising. Structural remedy: platform failure to maintain a compliant disclosure archive triggers mandatory audit by the FTC and suspension of new paid placement sales until compliance is certified. Criminal enforcement: platform executives who direct or ratify a policy of systematic non-disclosure after notice may be personally liable under federal fraud statutes. Private right of action: any person harmed by undisclosed political advertising on a non-compliant platform may bring a civil action against the platform for damages and injunctive relief.

Concentration in agricultural processing—including meatpacking, poultry processing, grain trading, and food di...

This rule subjects concentration in agricultural processing like meatpacking and grain trading to strict antitrust scrutiny. It prevents monopolies from controlling food production and prices.

Concentration in agricultural processing—including meatpacking, poultry processing, grain trading, and food distribution—must be subject to active antitrust enforcement, including review

Source: DB entry COR-AGF-001, status: PROPOSED. Pending editorial review.

Algorithmic systems may not be used to coordinate prices, rents, fees, or other market behavior in ways that function...

This rule prohibits using computer algorithms to coordinate prices or rents between competitors. It bans algorithmic collusion that functions like illegal price-fixing.

Algorithmic systems may not be used to coordinate prices, rents, fees, or other market behavior in ways that function as collusion or anti-competitive alignment.

Source: DB entry COR-ALG-001, status: PROPOSED. Pending editorial review.

Anti-monopoly law must be strengthened to prevent excessive concentration in essential consumer, infrastructure, tech...

This rule strengthens antitrust law to prevent excessive concentration in essential industries. It addresses monopoly power in technology, healthcare, housing, food, and other critical sectors.

Anti-monopoly law must be strengthened to prevent excessive concentration in essential consumer, infrastructure, technology, healthcare, housing, food, and communications markets.

Source: DB entry COR-ANT-001, status: PROPOSED. Pending editorial review.

Corporate audits must follow standardized formats and regulatory frameworks similar to tax filings

This rule requires corporate audits to follow standardized formats similar to tax filings. It makes audits more consistent and easier to verify.

Corporate audits must follow standardized formats and regulatory frameworks similar to tax filings.

Source: DB entry COR-AUD-001, status: PROPOSED. Pending editorial review.

Industry may not dominate the bodies that regulate, score, audit, or oversee its own conduct

This rule prohibits industries from dominating the bodies that regulate or oversee their own conduct. It prevents regulatory capture where regulators serve industry instead of the public.

Industry may not dominate the bodies that regulate, score, audit, or oversee its own conduct.

Source: DB entry COR-CAP-001, status: PROPOSED. Pending editorial review.

Concentration of economic power that undermines competition, public access, democratic accountability, or system inte...

This rule prohibits concentration of economic power that undermines competition, public access, or democratic accountability. It must be prevented or broken up when it occurs.

Concentration of economic power that undermines competition, public access, democratic accountability, or system integrity is prohibited and must be prevented or corrected.

Source: DB entry COR-CON-001, status: PROPOSED. Pending editorial review.

Antitrust and consumer-protection enforcement agencies must have sufficient staffing, technical expertise, funding, a...

This rule ensures antitrust enforcement agencies have sufficient staff, funding, and independence to police concentrated markets. It strengthens their ability to challenge monopolies.

Antitrust and consumer-protection enforcement agencies must have sufficient staffing, technical expertise, funding, and independence to police concentrated and technologically complex markets.

Source: DB entry COR-ENF-001, status: PROPOSED. Pending editorial review.

Corporate officers, executives, and responsible individuals may be held criminally liable for violations, including n...

This rule allows corporate officers and executives to be held criminally liable for violations, including negligence and failure to oversee. It ensures individuals face consequences, not just companies.

Corporate officers, executives, and responsible individuals may be held criminally liable for violations, including negligence and failure of oversight.

Source: DB entry COR-LAW-001, status: PROPOSED. Pending editorial review.

Markets must serve the public interest and may not be structured primarily to maximize extraction, lock-in, or concen...

This rule requires markets to serve the public interest, not just maximize profits for dominant firms. It prohibits market structures designed for extraction, lock-in, or concentration of private power.

Markets must serve the public interest and may not be structured primarily to maximize extraction, lock-in, or concentration of private power.

Source: DB entry COR-MKT-001, status: PROPOSED. Pending editorial review.

Concentration of employer power in geographic or occupational labor markets that demonstrably suppresses wages, limit...

This rule addresses concentration of employer power in labor markets that suppresses wages and limits job choices. It prevents monopoly employers from dominating local job markets.

Concentration of employer power in geographic or occupational labor markets that demonstrably suppresses wages, limits job choices, or prevents effective collective bargaining constitutes an antitrust

Source: DB entry COR-MPY-001, status: PROPOSED. Pending editorial review.

Further consolidation of local newspaper, broadcast, and digital news media ownership must be prohibited or restricte...

This rule prohibits further consolidation of local newspaper and broadcast media ownership. It prevents any entity from controlling too much of the news in a single market.

Further consolidation of local newspaper, broadcast, and digital news media ownership must be prohibited or restricted by FCC and DOJ to prevent any entity from achieving dominant control over the loc

Source: DB entry COR-NMD-001, status: PROPOSED. Pending editorial review.

Private-equity and other highly leveraged ownership models may not be used to strip assets, degrade quality, extract ...

This rule restricts private equity and highly leveraged ownership models that strip assets and degrade quality for short-term profit. It protects consumers and workers from predatory financial engineering.

Private-equity and other highly leveraged ownership models may not be used to strip assets, degrade quality, extract short-term gains, and leave consumers workers or communities with the harm.

Source: DB entry COR-PEQ-001, status: PROPOSED. Pending editorial review.

Firms operating in essential sectors including housing, healthcare, food, communications, utilities, education techno...

This rule subjects firms in essential sectors like housing, healthcare, and food to heightened antitrust scrutiny. It recognizes that monopolies in essential services cause unique harm.

Firms operating in essential sectors including housing, healthcare, food, communications, utilities, education technology, and transportation are subject to heightened public-interest obligations.

Source: DB entry COR-PIS-001, status: PROPOSED. Pending editorial review.

Dominant firms in essential sectors must disclose key metrics related to concentration, support windows, warranty den...

This rule requires dominant firms in essential sectors to publicly disclose key metrics about concentration, warranty denials, repair restrictions, and anti-competitive practices. It gives regulators and the public the information needed to identify problems.

Dominant firms in essential sectors must disclose key metrics related to concentration, support windows, warranty denial rates, repair restrictions, and pricing structure.

Source: DB entry COR-TRN-001, status: PROPOSED. Pending editorial review.