October 19, 2018
Leonardo S.p.A.
Attn: General Counsel’s Office
Piazza Monte Grappa, 4
00195 Rome, Italy
Dear General Counsel of Leonardo S.p.A.:
The Project On Government Oversight (POGO) is creating a Department of Defense Revolving
Door Database on its website (pogo.org), which compiles information from public resources
regarding former senior Department of Defense officials and military officers who went on to
work for government contractors, including Leonardo S.p.A., from 2008 to the present. The
database is an attempt to track individuals when they leave the Department of Defense, and
inclusion in the database doesn’t represent anything illegal or a violation of ethics rules. I have
enclosed the findings relevant to Leonardo S.p.A. and am requesting verification or refutation of
the data from you.
Any response would be greatly appreciated, as the accuracy of this information is in the best
interest of all parties. When a precise start date was not publicly available POGO chose the first
day of the month the employee said they began working for Leonardo S.p.A. POGO is also
interested in any related ethics opinions issued for current or former Leonardo S.p.A. personnel
in compliance with the National Defense Authorization Act for Fiscal Year 2008, Public Law
110-181, Sec. 847 and certifications of compliance as required by Defense Federal Acquisition
Regulation Supplement (DFARS) subpart 252.203-7005; 41 U.S.C. § 2105(c). Out of fairness to
Leonardo S.p.A., please be assured that any response received by POGO will be posted on the
website along with the data if you so choose.
If you have any questions, I can be reached at (202) 347-1122 or msmithberger@pogo.org.
Thank you for your time and consideration.
Sincerely,
Mandy Smithberger
Director, Center for Defense Information

 Enclosure
Revolving Door Instances
1. Individual: Lieutenant General Michael W. Wooley (USAF Ret.)
Approximate Date Joined Leonardo S.p.A.: May 19, 2008
Synopsis: Lieutenant General Michael W. Wooley (USAF Ret.) was Commander, Air
Force Special Operations Command, Hurlburt Field in Florida, retiring in 2008. Later
that year he joined the board of Alenia North America, a subsidiary of Alenia
Aeronautica and part of the European defense contractor Finmeccanica Group (now
Leonardo S.p.A.). The year he joined the company they had received $292 million in
Department of Defense contracts. “The leadership experience General Wooley gained
from his roles as a pilot, special operations warrior, and Air Force Commander will
no doubt provide our Board with invaluable wisdom and direction as we seek to
expand the presence of Alenia in North America," the Chair of Alenia North
America's board said in an official press release.
Documents to Include:
http://www.af.mil/About-Us/Biographies/Display/Article/105208/lieutenant-generalmichael-w-wooley/
https://www.businesswire.com/news/home/20080519005953/en/Lieutenant-GeneralMichael-W.-Wooley-USAF-Ret.
https://www.businesswire.com/news/home/20080519005953/en/Lieutenant-GeneralMichael-W.-Wooley-USAF-Ret.
https://www.usaspending.gov/#/search/5b0f005a41f473ae430ee333a21da7ff
2. Individual: William J. Lynn III
Approximate Date Joined Leonardo S.p.A.: January 26, 2012
Synopsis: William J. Lynn III was Deputy Secretary of Defense, leaving in 2011. He
was the first President Obama nominee to receive an ethics waiver due to his previous
position as Vice President of Government Operations and Strategy at Raytheon. He
joined Pentagon contractor DRS Technologies, now a subsidiary of Leonardo S.p.A,
as Chief Executive in 2012. The year he joined the company DRS received $1.1
billion in Department of Defense contracts. "Bill’s responsibilities will be to develop
our business in North America," the Chairman and Chief Executive Officer of thenFinmeccanica said in an official press release.
Documents to Include:
https://defensesystems.com/articles/2011/08/03/ashton-carter-deputy-defensesecretary.aspx?admgarea=DS
https://www.pogo.org/press/release/2009/white-house-waiver-for-dod-appointeelynn-undermines-white-house-ethics-standards-and-sends-wrong-message/
https://www.cnas.org/people/william-j-lynn-iii
http://www.leonardocompany.com/en/chi-siamo-about-us/profilo-profile-chisiamoaboutus-2/nostra-struttura-our-structures
https://washingtontechnology.com/articles/2012/01/26/drs-lynn-new-ceo.aspx

2

 http://www.leonardocompany.com/en/-/drs-technologies-nomina-william-j-lynnpresidente-e-amministratore-delegato
https://www.usaspending.gov/#/search/139cca3baa2174fe3733a0c344eb6e71

3