Short answer: the rules are personal, so get written advice before you introduce a company you dealt with
Whether you may refer a contractor depends on your former role, grade, agency guidance and any written advice you hold. Federal post-employment rules, including 18 U.S.C. 207, restrict some activity by former officials, and this page does not summarize them. An introduction to a commercial data-licensing program is not a government contact, but do not rely on that distinction without your ethics office confirming it for your situation.
This is general information, not legal, tax or financial advice. Confirm with your former agency's ethics office or your own counsel before acting. Read the current statute and agency guidance yourself.
What should you ask your ethics office about?
Think in buckets rather than one rule. The table lists questions to put to the office, not conclusions.
| Area to ask about | Question to put in writing | Why it matters to a referral |
|---|---|---|
| Contacts with the government | Do any limits apply to communicating with my former agency for someone else? | The risk appears if the introduction later involves you speaking to your old agency for the company |
| Waiting periods | Does any post-employment limit apply to my grade and position, and is it still running? | Senior and procurement-related roles may be treated differently, so check yours |
| Contractor relationships | Do any limits apply to a company I oversaw, evaluated or awarded work to? | The risk rises if the company you refer was a contractor on matters you handled |
| Non-federal obligations | What do my clearance, NDA, retirement agreement or licensing rules require? | These can bind you even if federal ethics rules do not |
Military retirees face the same style of question, plus rules tied to retirement status and service-specific guidance.
Why GovCon connections are the natural pipeline and the risky one
Retired officers, former program managers and former agency officials know contractors well. Many GovCon firms have 50+ full-time employees at peak (contractors excluded), years of documented operations and records across proposal, finance, program and engineering systems.
That same relationship is the risk. If you once oversaw, evaluated or awarded work to a company, an introduction to it deserves extra care even though SourceX is a commercial data-licensing program and not a government customer.
The 5-question self-check before you introduce anyone
- Did I personally work on, oversee, award or evaluate anything involving this company while in government?
- Is my cooling-off period still running, based on my grade and position?
- Will I ever speak or write to my former agency on this company's behalf as part of this?
- Do I hold clearance, NDA or retirement-agreement obligations that limit what I may say about the company?
- Have I asked my former agency's ethics counselor in writing and kept the answer?
If any answer is "yes" or "not sure," pause and get written guidance first.
Where classified and controlled records fit
Government contractors often hold records the company cannot license at all: classified material, export-controlled technical data and information marked as controlled by the customer. Those are rights problems, not partner problems. The company decides what it can license, and SourceX reviews rights before anything moves. A partner should never ask about, describe or request such material.
Contracts matter too. A prime contractor's records may include its government customer's data or subcontractors' proprietary information, both of which can require consent.
How to approach the company
Keep it commercial and short. Do not use your former title to press for a decision, and do not mention any government matter.
How the introduction works
- You register as a partner and share your referral link or use the referral form.
- SourceX checks size, history, data breadth and rights with the company's authorized sponsor.
- The company completes its inventory and agrees price and terms before buyers see anything.
- You do not export, upload or describe records at any point.
For related eligibility questions, see referring a supplier your own employer buys from, referring a division, retirement plan advisors and companies under an FTC consent order. Investor networks that bring GovCon portfolio companies together can start from the venture platform teams page. The company fit checker runs a preliminary, non-binding screen, and who qualifies lists the baseline.
Rewards and tax
Partners earn 25% of the eligible platform fees SourceX actually collects from the referred company's licensing deals, capped at $100,000 per referred company, payable only after the buyer pays and SourceX receives its fee. No reward is guaranteed. Expect to provide tax details; the IRS explains Form W-9, and a tax adviser can say how the income is reported for you.
When to say no
Decline if you worked directly on the company's contracts and have no written ethics advice, if the plan requires you to contact your old agency, or if the company's records are mainly classified or customer-owned.
Next step
Send your ethics office one email describing the activity. When the answer is clear, register as a partner and introduce your first company.