April 8, 2020

Export-Import Bank (EXIM) Senior Vice President and General Counsel David Slade may have violated his ethics pledge or conflict of interest rules during his time in this government position, serving as yet another example of a Trump appointee with potential conflicts related to former employers.

On April 8, 2020, the Office of Government Ethics released a partial ethics waiver that authorized Slade to engage in certain activities related to his former employer Allen & Overy, an international law firm, and the clients he had while working there. Without the waiver, the ethics pledge he’d signed upon assuming this position on May 13, 2019 would completely bar him from doing so. 

However, while the waiver lacks a date, the document’s file is named “2019.8.15 Slade Waiver.pdf,” which suggests that it may have been issued three months after Slade began working at EXIM. If it had been issued to Slade retroactively, after potentially engaging in prohibited activities, it would be automatically invalidated by OGE.

CREW has requested all EXIM records of Slade’s scheduled meetings and events since May 13, 2019, as well as records of all communications between him and Allen & Overy employees or any of his former clients at Allen & Overy since the same date. CREW has also requested a copy of Slade’s ethics pledge.

This potential conflict only adds to the pattern of Trump’s appointees keeping questionable relations with former employers or former lobbying clients. Rick Perry rejoined the board of a pipeline company a mere month after leaving his position as Energy Secretary. Mark Esper, who is now in charge of the Pentagon, has refused to commit to not returning to work with Raytheon after leaving his position in government. 

These records will help determine the time at which Slade received the ethics waiver in relation to his engagement with contacts related to Allen & Overy, in turn shedding light on whether he violated his ethics pledge or conflict of interest regulations while working at EXIM.

Read the request here.