the revolving
door

The graph below maps each senior SEC official, their post-government landing, and whether their new employer had matters pending before or regulated by the SEC at the time of departure. Red edges are flagged conflicts.

Each transition below is sourced from primary SEC filings (DEF14A proxy statements, S-1 registration statements, Form 3/4 insider transactions) or official SEC press releases. All gaps are calculated from departure announcement or last filing date to new employer announcement or first private-sector filing appearance.

18 U.S.C. § 207 imposes post-employment restrictions on former federal officials. Senior officials face a one-year cooling-off period; "very senior" officials face two years. The restrictions are narrower than most people assume.

The result: the same official who wrote the ETF regulatory framework can, five months later, become the chief lobbyist of the world's largest ETF company — and this is fully legal. The law prevents them from walking into the SEC building as a representative. It does not prevent them from sitting across the table from their former colleagues at industry events, serving on industry working groups, or shaping the positions their new employer takes before the SEC through counsel.

The peak SPAC years — 2020 and 2021 — coincided with a period when the SEC's most senior officials were in transition. The Chair, the Corp Finance Director, and the Investment Management Director all departed within weeks of each other (Dec 2020 – Jan 2021). The number of SPAC enforcement actions during the boom years was negligible.

The first SPAC-specific enforcement action was brought in July 2021 — against Momentus Inc., a space technology SPAC, for alleged misleading statements — 14 months after the SPAC boom began. By the time enforcement activity increased (late 2022–2023), most senior SPAC sponsors had already exited their positions.

The structural issue: The officials who oversaw the 860-SPAC wave left the SEC during or immediately after the boom. Their replacements then discovered the problems and proposed rules. Those rules were adopted in January 2024 — four years after the boom began and two years after it ended. When the next administration arrived, it signaled the rules would not be enforced.

William Hinman served as Director of the SEC's Division of Corporation Finance from May 2017 to December 2020. Before joining the SEC, he was a senior partner at Simpson Thacher & Bartlett LLP. While at the SEC, he continued to receive deferred compensation payments from Simpson Thacher — a firm that actively advised SPAC sponsors, blockchain companies, and financial firms regulated by the Division Hinman directed.

On June 14, 2018, at the Yahoo Finance All Markets Summit, Hinman stated: "Based on my understanding of the present state of Ether, the Ethereum network and its decentralized structure, current offers and sales of Ether are not securities transactions."

This speech — now known as the "Hinman speech" — had immediate and lasting market impact. It provided regulatory clarity that Ethereum (ETH) would not be treated as a security, a determination that benefited the entire Ethereum ecosystem.

The conflict: Simpson Thacher had worked with the Enterprise Ethereum Alliance, an organization promoting Ethereum, prior to and during Hinman's tenure. The SEC's own Ethics Committee warned Hinman to recuse himself from matters involving Simpson Thacher clients. According to documents produced in the Ripple litigation, Hinman met with a partner at Simpson Thacher at least three times while serving as Director of Corporation Finance.

The SEC's internal investigation, confirmed publicly in 2024, concluded that Hinman had properly disclosed his interests — a conclusion disputed by Ripple's legal team and several members of Congress who wrote to the SEC requesting further review.

Hinman left the SEC in December 2020 and rejoined Simpson Thacher in approximately May 2021. He subsequently joined &vest, an investment advisory firm, as a partner in May 2021. Simpson Thacher continued to be named in EDGAR filings for Applied Blockchain, Inc. (S-1 2021–2022) and crypto-related companies.

Paul Atkins served as SEC Commissioner from August 2002 to August 2008. Upon departure, he founded Patomak Global Partners, a regulatory advisory firm whose clients included Goldman Sachs, Fidelity Investments, the U.S. Chamber of Commerce, and multiple cryptocurrency firms and exchanges.

For 16 years, Patomak advised clients on how to navigate SEC regulations — regulations Atkins had helped write. Atkins was also co-chair of the Token Alliance, a cryptocurrency advocacy group under the Chamber of Digital Commerce, and served on the advisory board of Securitize, Inc., a digital securities platform.

Trump nominated Atkins as SEC Chair on December 4, 2024. He was confirmed by the Senate and sworn in on April 21, 2025. The same crypto ETF S-1 filings that mention Atkins (CoinShares XRP ETF, Kraneshares Crypto Trust) were under SEC review during his confirmation process. CoinShares' XRP ETF S-1 lists activities directly affected by the regulatory posture of the SEC Chair reviewing it.

The structural anomaly: The confirmed SEC Chair had, for 16 years, been paid by firms he now regulates. His personal net worth — over $327 million, substantially in digital assets — is directly affected by the regulatory positions his agency takes on cryptocurrency. The statute of limitations on the cooling-off period had expired more than a decade before his re-nomination. No federal law restricted Atkins from holding these assets while serving as Chair.

Dalia Blass served as Director of the SEC's Division of Investment Management from September 2017 to January 2021. The Division of Investment Management regulates investment companies — including all exchange-traded funds (ETFs).

Under Blass, the Division finalized Rule 6c-11, the first standardized regulatory framework for ETFs, in September 2019. This rule governs the operations, disclosures, and fee structures of ETFs — including those run by BlackRock's iShares platform, the world's largest ETF business with more than $3 trillion in AUM.

Blass joined BlackRock as Senior Managing Director and Head of External Affairs on June 7, 2021 — exactly five months after leaving the SEC. As Head of External Affairs, she leads BlackRock's government relations, regulatory policy, and public affairs globally: the firm's chief interface with the very agency and Division she previously led.

The cooling-off period under § 207(c) prevented Blass from appearing before the SEC or contacting SEC staff on specific matters for two years. It did not prevent her from advising BlackRock on regulatory strategy, participating in industry comment letter processes, attending industry conferences alongside current SEC staff, or directing the team that files comments on SEC proposed rules. BlackRock submitted comments on multiple SEC rulemaking proceedings during Blass's tenure as its chief policy officer.

Annette Nazareth served as a Commissioner of the SEC from 2005 to 2008 and was Director of Market Regulation from 1999 to 2005. She joined Davis Polk & Wardwell as a partner in September 2008, heading the firm's Trading and Markets practice — advising the same financial firms and securities industry that her former division regulated.

In February 2021, while serving as Senior Counsel at Davis Polk — which advises financial firms on SEC regulations and submitted comment letters opposing the SEC's proposed SPAC disclosure rules — Nazareth was simultaneously named as a director of Athena Technology Acquisition Corp. (CIK 0001840292), a blank-check SPAC that filed its S-1 on February 5, 2021.

In the same period, Nazareth was also named as a director in Figure Acquisition Corp. I (CIK 0001839550, S-1 filed February 3, 2021) — a second SPAC. Both SPACs were subject to the SEC registration and review process managed by the Division of Corporation Finance, the same division she helped lead and now advises clients to navigate.

Davis Polk, where Nazareth works, subsequently published detailed client guidance on how to comply with (and structure transactions around) the SEC's final SPAC rules — rules that directly affected the SPACs on whose boards Nazareth served.

The SEC's regulatory response to the SPAC boom followed a predictable arc: the rules were proposed well after the peak, adopted years later, and immediately threatened with rollback when the next administration arrived with a former SPAC industry advisor as its appointed Chair.