However, the restrictions set out by the Advisory Committee on Business Appointments (ACOBA), which prevent Jonathan Luff from lobbying the Government on behalf of his new employer for two years, will come as little surprise to Wonga, nor will they stifle his strategic value to the company.
Public affairs is increasingly viewed by companies as a business-critical function. To be effective in this endeavour, public affairs should be underpinned by what you know, rather than just who you know. As such, the restrictions do little to stem any commercial advantage of employing senior ex-government advisers, as the modern profession's functions are now more akin to business strategy than introductions and operational support.
The blustering assurances of 'unrestricted access' made by the 'generals' for hire' in the recent Sunday Times sting demonstrated not only their contempt for the ACOBA rules that were supposed to prevent this kind of activity, but also their own ineffectiveness as modern lobbyists.
Gone are the days of a 'quiet word in the ear' - if a personal favour is required to secure a ministerial meeting that would otherwise be refused, the likelihood is it fails the public interest test and will be a waste of time. This kind of approach is destined to fail in the long term, along with the very relationship that is being abused to sustain it.
So, whether bound by ACOBA rules or not, one thing's for sure; if a former official feels at any point they are acting to influence decisions made by officials in government, then by definition they are a 'lobbyist' and should register as one.