Every year, a small federal office most have never heard of sends a questionnaire to more than 140 agencies across the executive branch. It’s called the Office of Government Ethics, and the questionnaire is essentially a report card.

How many ethics officials do you have on staff?
How many of your senior people filed their financial disclosure forms?
How many times did you let someone off the hook for a conflict of interest?
How many possible crimes did you send to the Justice Department, and what happened to them?

The answers for 2025 are in, and our strategic litigation partner Campaign Legal Center (CLC) spent the summer reading them. What they found was quieter than a scandal and yet, I think, more worrying. The federal government’s system for catching corruption is slowly being turned into an honor system, one missing form at a time.

Follow the money… unless you can’t

Start with the forms, because the forms are where the money hides.

When someone takes a senior job in the federal government, they have to disclose to the public what they own, what they owe, and who has been paying them. That document is called a public financial disclosure report, and while it is often quite dull paperwork, it’s also the single best tool the public has for spotting an official who is making decisions that help their own bank account. If the person overseeing a drug approval owns a pile of stock in the drug company, the form is how we find out. If the person writing a defense contract just left the contractor’s payroll, the form is how we find out.

In 2024, 110 of those reports were never filed. By contrast, in 2025, that number quadrupled to 418. Why would four times as many senior officials in the Trump Administration choose to simply ignore the law and fail to disclose their finances? Among a group of part-time advisers the government calls “special government employees,” compliance dropped from 100 percent to 82 percent in a single year. These are often the outside experts and business people brought in to advise on policy, which makes them exactly the group most likely to have a personal stake in the outcome.

I want to be fair about this. A missing form does not prove that anyone did anything wrong. It does prove that nobody could have caught them if they had, and catching them is the entire reason the form exists.

Riding the Waiver

Then there are the waivers. Federal law makes it a crime for an official to work on a matter where they have a personal financial interest. Agencies are allowed to waive that rule in narrow cases, when the interest is so small or so far removed that it could not realistically sway anyone. Those waivers are supposed to be rare. From 2021 through 2024, agencies issued about 120 of them a year, and in 2025 they issued 249. Roughly twice as many people were told, in writing, that the conflict-of-interest law would not apply to them this time.

And when agencies do find something that looks like a crime, the law requires them to refer it to the Justice Department. In 2025, agencies referred 141 possible criminal ethics violations, and the Justice Department declined to prosecute 94% of them. The Treasury Department alone sent 81 cases, and prosecutors passed on all but six.

Put those three numbers together and you can see the shape of the problem. Fewer people are telling us what they own. More people are getting permission to act on their conflicts anyway. And the rare cases that do get flagged as crimes are mostly going nowhere.

None of that happens by accident, because somebody has to chase the missing forms, review the waivers, and make the referrals. Those somebodies are the agency ethics officials, and there are 274 fewer of them than there were a year ago. The Department of Education lost 60 percent of its ethics staff, Treasury lost 44 percent, and the White House went from 18 ethics officials to four. Forty percent of ethics offices told the government they no longer have the resources to do the job.

At the top of each agency’s ethics program sits a person with the clunky title of Designated Agency Ethics Official. For decades, that job went to career civil servants, people who had spent years learning a thick body of law that confuses even the lawyers. But in 2025, one in five of those jobs was held by a political appointee, up from about one in seven the year before. At Homeland Security, Education, Energy, and the Office of the U.S. Trade Representative, the new ethics chiefs appear to have no prior federal ethics experience at all. At the CIA, Health and Human Services, Labor, and Treasury, the position was simply empty.

If you want a sports metaphor, this is a game where most of the referees have been sent home, and many of the refs still on the field were hired by one of the teams. The rulebook is still sitting on the table, and fewer and fewer people are bothering to open it.

I think people sometimes hear the word “ethics” and picture something soft, like the training video you click through on your first day at a new job. The federal ethics program is a much harder thing than that. It is the part of government that stands between your tax dollars and the people who would like to help themselves to them. It is what sends a contract to the best bidder rather than the bidder who golfs with the agency director. It is what keeps a reviewer from waving through a product they happen to own shares in. When that program weakens, the losses rarely show up as a headline. They show up as a slightly worse deal, a slightly slower approval, a slightly more expensive project, repeated thousands of times across the government, with no way to trace any of it back.

That is what an honor system costs. It works beautifully as long as everyone involved is honorable, and it costs nothing to run, which is exactly its appeal to the people who benefit from it.

CLC is leading our movement in asking Congress for two things:

1) An independent ethics body for the executive branch, with real investigators, real enforcement power, and leaders who cannot be fired for doing their jobs. Right now the Office of Government Ethics can write the rules and collect the questionnaire, but it has very little power to investigate anyone or punish them for breaking those rules.
2) Close the revolving door, so a lobbyist cannot walk straight from an industry into the office that regulates it.

Neither idea is new, and neither is partisan. Every administration eventually leaves, and whatever rules we let slide now will be waiting for the next one, whoever that turns out to be. The question underneath all these numbers is a simple one. Do we want to know what the people running our government own and owe, or would we rather take their word for it?

I would rather know, and the forms are sitting right there just waiting to be filled out.

Nobody’s counting the chickens