Championing Responsible National Security Policy

State Dept. Is Quietly Approving Former Servicemembers’ Work for Foreign Interests. That’s a Problem.

More than half of all waivers authorize ties with authoritarian regimes.
(Photos: Getty Images; Department of Defense; Illustration: Leslie Garvey / POGO)

Over 500 retired and reserve U.S. military personnel have received permission to receive awards or employment from foreign interests after they retire, according to documents obtained by the Project On Government Oversight (POGO). Over half of these waivers were granted so former military officials could work on behalf of United Arab Emirates interests, despite the Emirati government’s troubling record of human rights violations.

POGO acquired the waivers through a Freedom of Information Act (FOIA) lawsuit. The Washington Post filed a similar lawsuit, and the two organizations shared the documents that were obtained. Read the Washington Post's own investigation into the waivers here. While the identities of most waiver recipients remain redacted, the emoluments clause waiver program itself raises troubling questions about whether those receiving emoluments from foreign interests have previous professional relationships with foreign countries or plan to seek such relationships following their retirement. If so, can they be counted on to provide advice on national security issues that is in the best interest of the United States? In some cases, these are public figures working to sway public sentiment that do not identify their relationships with foreign interests.

Under current law, any retired or reserve members of the military wishing to work for a foreign government or receive emoluments (gifts, payments, reimbursements, or something of value from a foreign state) must first obtain approval from the secretary of their military service and then from the Secretary of State. In August 2017, POGO released an investigation revealing high-ranking former military officials — including then-Secretary of Defense James Mattis, former National Security Advisor James L. Jones, and then-White House Chief of Staff John Kelly — had previously requested and received waivers. While Kelly’s waiver allowed him to work with the Australian Defense Force, a close U.S. ally, Mattis’ and Jones’ waivers were to conduct work on behalf of the government of the United Arab Emirates and Saudi Arabian foreign interests, respectively.

At that time, it was unclear how many other retired or reserve members of the military received permission to receive emoluments from foreign interests. Now, for the first time, these documents provide a closer look at the size and scope of the waiver program.

Over 500 Waivers for More Than 50 Foreign Governments

Between April 2010 and August 2020, the State Department issued over 500 waivers to retiring servicemembers, allowing them to take emoluments to work on behalf of foreign interests. While many of these positions are not disclosed, some clearly support military operations, such as “battle trainer,” while others are far more general, including descriptions like “consultant” or “advisor.” 

Nearly half of all waivers issued went to former Army personnel (44%). Roughly a quarter of all waivers were issued to former members of the Navy (24%), while waivers were distributed fairly evenly between the Air Force (15%) and Coast Guard (10%). Waivers issued to retired members of the U.S. Public Health Service and Marine Corps made up less than 10% combined (7% and 1%, respectively).

We examined 517 ethics waivers, issued by the State Department, for former military officials to work on behalf of foreign interests.

Hover over or tap in the visualization to see some of the details provided in individual waivers.

These waivers authorized former members of the military to be paid to work on behalf of over 50 countries, including close allies like Australia, the U.K., Canada, Germany, South Korea, and Japan. However, waivers also approved work on behalf of countries the U.S. government has criticized for their record on human rights violations and authoritarianism, including Saudi Arabia and Azerbaijan. In fact, nearly 280 waivers (or a little over half of the waivers obtained under FOIA) granted approval for former military personnel to receive emoluments for work on behalf of United Arab Emirates interests. 

These waivers authorized former members of the military to be paid to work on behalf of over 50 countries.

Double-click or scroll to zoom in on the map. Click to drag the map.

And yet, even as the State Department issued hundreds of these waivers, they simultaneously listed a bevy of human rights abuses in their 2020 Country Report on human rights issues in the United Arab Emirates, including “arbitrary arrest and detention ... government interference with privacy rights ... undue restriction on free expression and the press ... and criminalization of same-sex sexual activity.” Despite this ideological divide, waivers to work on behalf of the United Arab Emirates far outpaced waivers for work on behalf of any other country. The next most frequently requested country for a waiver was Australia, with more than 30 waivers issued during the same period — a distant second to the United Arab Emirates’ nearly 280 waivers.

Of the nearly 280 waivers issued for work in the United Arab Emirates, over three quarters (around 77%) were issued for work on behalf of three Emirati companies: Global Aerospace Logistics (37%), the Advanced Military Maintenance Repair and Overhaul Center (26%), and Knowledge Point (14%). Research revealed that these three companies are subsidiaries of the state-owned Emirati defense conglomerate, EDGE Group. In a November 2019 press release, EDGE Group defined Global Aerospace Logistics as “a leading regional provider of integrated aircraft sustainment solutions for military and civilian customers.” According to the companies’ websites, the Advanced Military Maintenance Repair and Overhaul Center operates in aircraft manufacturing and repairs while Knowledge Point offers educational training.

Over half of the waivers were granted to work on behalf of the United Arab Emirates — and of those, most were to work for just one state-owned defense conglomerate.

Hover over or tap in the visualization to see some of the details provided in individual waivers.

The outsized presence of waivers to the United Arab Emirates means that EDGE Group’s subsidiaries attracted nearly half of all 500+ former servicemembers who appeared in the FOIA results for the waiver program. Another 12% of waivers issued for work on behalf of the United Arab Emirates were for direct work within the Emirati government, with over 7% for the United Arab Emirates Land Forces.

A 2017 POGO investigation revealed that then-Secretary of Defense James Mattis had received a waiver to work as a military advisor to the United Arab Emirates in 2015. Mattis became Secretary of Defense two years after receiving that waiver, meaning he oversaw the Defense Department when the United Arab Emirates reportedly convinced then-President Donald Trump to support a blockade on their regional rival, Qatar. Mattis did not list his work as military advisor for the United Arab Emirates in his public financial disclosure form, but according to a Defense Department spokesperson who discussed the matter with POGO, the information was included in Mattis’s security clearance review and he notified the Senate Armed Services Committee. Nevertheless, the lack of public knowledge about Mattis’s prior relationship with the United Arab Emirates highlights one of the risks inherent in this program: the potential for conflicts of interest.

Two Illustrative Examples

While the recipient names for most of the 500+ waivers POGO has been able to review were redacted, two high-ranking officials whose names were disclosed suggest that Mattis is not alone in having taken actions beneficial to a foreign government either before or after obtaining a waiver to conduct work on behalf of a foreign interest.

Charles Frank Bolden, who acted as the administrator of NASA for nearly 8 years between 2009 and 2017, was among the nearly 100 named officials to have received a waiver. On June 12, 2016, NASA issued a press release announcing Bolden’s signing and formalizing of a deal between the United States and the United Arab Emirates that aimed to operationalize collaborative efforts on space exploration and research between the two countries. Half a year later, Bolden retired from NASA. On April 26, 2018, the State Department approved Bolden to work in the United Arab Emirates as a member of the Emirati Space Advisory Committee.

Charles Frank Bolden
(Photo: Department of Defense)

Though the waiver does not list Bolden’s responsibilities while serving on the Emirati committee, or detail the recruitment process for the position, there is little doubt of a preexisting relationship between the former NASA chief and the United Arab Emirates before April 26, 2018. Bolden’s time as administrator of NASA during the Obama administration featured a heavy emphasis on bolstering a stronger scientific relationship between the U.S. and the United Arab Emirates. In a July 2010 interview with Al Jazeera, Bolden detailed how he and former President Barack Obama recognized the importance of reaching out to the Middle East for greater collaboration on scientific research in space development. Nevertheless, without more information regarding the nature of the relationship — specifically, whether Bolden received payments for this position and if so, how much (which was redacted by the State Department on the waivers) — we cannot discount the possibility that Bolden’s support for the U.S.-United Arab Emirates deal while at NASA may have been in part an effort to curry favor with a future patron.

While it may be challenging to assign motive to actions taken prior to working on behalf of a foreign government, certainly once a former servicemember has taken such a position it becomes critical to ask whether their advice and opinions on national security reflect the best interests of the United States.

Charles “Chuck” Wald
(Photo: Department of Defense)

Retired General Charles “Chuck” Wald served for over 35 years in the U.S. military and eventually assumed the role of deputy commander of the United States European Command from 2002 to July 2006. Wald then spent the next decade working for numerous international consulting firms, including the Middle East division of Jones Group International, a firm co-founded by President Obama’s former National Security Advisor, James L. Jones. Jones Group International boasts “unrivaled experience with numerous foreign governments” that allows the company to “[align] clients with opportunities, markets, and decision makers to maximize their chances for success.” On March 22, 2017, the State Department approved Wald’s request to work as an independent security consultant at Ironhand Security, LLC, from the firm’s Saudi Arabian office. According to reporting by the Daily Beast, Ironhand Security is a subsidiary of Jones Group International.

Within months of receiving approval to work for Ironhand, Wald regularly published op-eds for various media outlets such as Politico, The Hill, and The Wall Street Journal, opining on U.S. policy in the Middle East. It is unclear if Ironhand paid Wald, how much he was compensated, or whether he disclosed the Saudi Arabian business relationship to media outlets seeking his opinion on U.S. foreign policy, though a review of his publications seems to suggest Wald was not forthcoming to his readership about this professional relationship. POGO contacted The Wall Street Journal, Politico, and The Hill to ask if these outlets were aware of Wald's foreign ties, but none replied prior to our publication deadline.

A Need for Transparency

While the release of these State Department waivers allows further insight into the emoluments clause waiver program, two issues around the transparency of this program remain. First, the waivers do not always identify the country on whose behalf former members of the military plan to work. Rather, the waiver identifies the entity that the recipient will work for. In many cases, the recipient will work directly for a foreign government, but in dozens of other cases, the entity is a private firm that may contract with one or several different foreign governments.

The waivers revealed dozens of retired servicemembers working for unlisted foreign governments.

For example, on September 23, 2019, former National Security Advisor Lieutenant General H.R. McMaster received a waiver for employment with the Hudson Institute, a D.C-based think tank. The waiver is fully unredacted but does not disclose which foreign entity the Hudson Institute paid McMaster to support. In the case of McMaster, the answer is a matter of public record: He serves as the Japan Chair of the Hudson Institute. But McMaster’s situation isn’t unique; the waivers revealed dozens of retired servicemembers working for unlisted foreign governments. In these cases, it is difficult to determine which foreign entity ultimately benefits from a former U.S. military member’s paid work. Hopefully, the State Department had that information when they approved the request, but the waivers provided to POGO do not include it.   

Second, of the more than 500 waivers POGO reviewed, the State Department redacted the recipient’s name in the overwhelming majority (around 80%). For former military personnel working on behalf of the United Arab Emirates in particular, name redactions were even more common, with over 98% of those names withheld. During negotiations over POGO’s FOIA request, the State Department agreed to release the names of high-ranking miliary personnel, but continued to redact the names of lower-ranking servicemembers. As a result, the higher percentage of name redactions among waivers to work on behalf of the United Arab Emirates may reflect the larger number of waivers issued to lower-ranking military personnel. However, without knowing what specifically these waiver recipients did for the military before they retired, what they have done since receiving a waiver, or how much — if anything — they were paid, it is difficult to determine whether there is any evidence of divided loyalties.

How many former military personnel are receiving payments on behalf of foreign interests or working to benefit foreign interests and not reporting them?

Looking beyond concerns about transparency to problems of accountability, to what extent do these waivers reflect the full picture of foreign influence on former servicemembers? In other words, how many former military personnel are receiving payments on behalf of foreign interests or working to benefit foreign interests and not reporting them?

Here, the waivers issued by the State Department can provide few answers, as they are issued to individuals who properly disclosed and sought permission to receive awards or employment on behalf of foreign interests. However, recent news about Retired Army General and former National Security Advisor Michael Flynn substantiates these concerns. In July 2022, the Washington Post published a story revealing the findings of a Defense Department investigation into Flynn’s foreign financial involvement. According to Defense Department investigators, in 2015, Flynn failed to request prior approval before receiving almost $450,000 from Turkish and Russian interests. Included in documents obtained by the Washington Post was a letter from the Army dated May 2, requesting to recoup nearly $40,000 from Flynn’s unauthorized foreign payments. (It would also seem that Flynn did not obtain an emoluments clause waiver, as his name does not appear among the waivers acquired by POGO.) 

Similarly, consider the example of the Foreign Agents Registration Act (FARA). Under FARA, any American that intends to lobby on behalf of foreign governments or political parties, irrespective of any connection to government or military service, must register with the Justice Department and disclose any and all political activity engaged in on behalf of foreign clients.

In June 2022, news broke that the FBI was investigating retired four-star Marine General and then-Brookings Institution President John R. Allen for allegedly lobbying on behalf of the government of Qatar without registering with FARA years ago. Like Flynn, Allen’s name does not appear among the 500+ names in the waivers obtained by POGO.

The Justice Department’s probe alleges Allen lobbied White House officials in an attempt to improve Qatar’s image during their diplomatic crisis with neighboring countries, but he neglected to disclose this political relationship as required by law. In light of the probe’s allegations, on June 8, the Brookings Institution placed Allen on administrative leave before Allen himself resigned. Senator Elizabeth Warren sent letters to the Brookings Institution, the Secretary of Defense, and the Secretary of State requesting more information on Allen’s involvement with Qatar and advocating for greater regulation of retiring public officials. Indeed, the recent revelations about Flynn and Allen underscore concerns about public figures with undisclosed foreign financial influence who nonetheless continue to influence U.S. policymaking and public opinion. 


Currently, the State and Defense Departments may have limited tools to ensure retired military personnel seek the proper waivers to work on behalf of foreign interests. Even so, these retired and reserve military personnel continue to use their expertise to weigh in on matters of U.S. policy and sway public thought. The least these agencies can do for the sake of transparency and accountability is make sure the waivers they do issue are easily accessible to the public. Absent this knowledge, it is impossible for the people to know whether former military personnel are acting solely in the interest of the United States or if they also serve the interests of wealthy foreign clients, including those with questionable human rights records.

From January 1, 2020, to January 24, 2022, the State Department provided POGO with 517 waivers across 14 productions, all in PDF format. Relevant data fields including the waiver’s approval date, personnel name (where possible), service, rank, country, company/employer, and company position were extracted from these documents via manual review and recorded in a spreadsheet. In order to prepare this data for analysis and visualization, POGO researchers recoded several data fields into categorical variables, including rank, country, and company.

Rank: The U.S. military abbreviates the same rank differently depending on the branch of the military in which a member served. For example, the rank of “Brigadier General” is abbreviated as “BG” for the Army and “Brig Gen” for the Air Force. For the purposes of the visual, acronyms across different branches were standardized under one military acronym. In circumstances in which the rank of a servicemember was either redacted or otherwise illegible, we labeled the rank “Unclear.”

Waiver Recipient Name: Most waiver recipient names were redacted by the State Department. Other than the individuals named in the piece (McMaster, Mattis, Wald, Bolden, and Jones), those few that were not redacted by the State Department were labeled "Names Disclosed" in our graphics.

Company/Employer Name: Given that some waivers list the parent company as the employer while others list the subsidiary as the employer, we standardized the employer for both such instances as “[Parent company] and its subsidiaries.” Moreover, waivers that list the employer as an agency within a foreign government are standardized as “[X country] Government,” rather than the specified agency within “[X country] Government.” For example, the employer for a retired servicemember working within “Department for Environment, Food and Rural Affairs of the British Government” was recoded as “British Government” rather than the specific department of that foreign government. This decision was made for the purpose of capturing all retired servicemembers receiving a waiver for employment within a foreign government.

Country: In most cases, the country on whose behalf a former servicemember requested a waiver was clearly indicated in that waiver. However, there were a few exceptions that required recoding. If a retiring member of the military requested a waiver to work for a private employer operating in one or more international locations but the specific location where they would work was not disclosed, we recoded the location as “Multiple.” Waivers for speaking events or conferences at an undisclosed location were listed as “Unknown.” Waivers recoded as “Multiple” or “Unknown” – approximately 9% – were excluded from the map visual for clarity.