FBI: Ex-Air Force Officer Violated Lobbying Ban


IOWA CITY, Iowa -- An Air Force captain who oversaw a company's contracts to provide boots for Afghan soldiers switched sides after leaving government, taking a well-paying job representing the vendor in front of his former colleagues, according to a criminal complaint.

Adam J. Pudenz of Carroll, Iowa, repeatedly sought to expedite U.S. government contract payments to Kabul Milli Trading Company, which hired him as a $40,000-per-month consultant in 2011, the complaint alleges. Only months earlier, Pudenz was in charge of managing the same contracts for the Air Force and took official actions that benefited the company, it alleges.

Pudenz was arrested Wednesday in Carroll by FBI and Department of Defense agents, said Assistant U.S. Attorney Rich Murphy.

Pudenz is charged with violating a ban on representing companies that he oversaw in government and with violating a conflict of interest law. He's also accused of, but not charged with, making false statements in connection with a $1 billion no-bid contract he proposed before leaving the Air Force to benefit Kabul Milli and another firm he later represented.

Pudenz, 33, made an initial court appearance Wednesday in federal court in Sioux City. He did not enter a plea and was released with conditions.

His court-appointed federal defender didn't return a message Thursday. No phone listing was available for Pudenz in Carroll, where the FBI alleges he bought a house using some of his improper consulting payments.

The complaint filed by FBI special agent Kevin Kohler details the allegations against Pudenz, who worked in 2009 and 2010 at the Kabul Regional Contracting Center at Camp Eggers and was tasked with helping equip Afghan National Security Forces.

Pudenz was involved in managing three government contracts with Kabul Milli to supply boots to the Afghan military. Before he left the service, Pudenz exchanged emails with the owners of the company discussing his future employment, according to the complaint unsealed Wednesday.

In November 2010, Pudenz proposed a "blanket purchase agreement" for clothing and boots worth up to $1 billion for two unnamed companies, believed to be Kabul Milii and Afghan Vision Group. The contract was authorized and awarded to Afghan Vision Group in 2011.

A subsequent review by an Air Force officer concluded Pudenz made false statements in the proposal when he asserted no similar contracts for those items existed, and that those companies were the only ones capable of providing the supplies. The review also found the agreement had other deficiencies, including lacking the required specifications for the products.

In anticipation of leaving the Air Force, Pudenz sought guidance in December 2010 from the Office of the Staff Judge Advocate on any restrictions he would face on post-government employment. Pudenz said he was considering returning to Afghanistan as a consultant to help Afghani clothing and textile businesses become sustainable.

The office warned Pudenz in a letter that he would be barred for life from accepting compensation from Kabul Milli under a statute that bans a government official responsible for a particular matter from "later `switching sides' and representing someone else in the same matter."

Nonetheless, Pudenz left the Air Force in February 2011 and started a business in which he allegedly represented Kabul Milli and Afghan Vision Group in front of his former government colleagues. Kabul Milli paid Pudenz $247,000 in 2011 for six months of consulting work, according to the complaint.

Pudenz told investigators that payment was a retainer, and that he had an agreement to submit and track Kabul Milli's invoices for $500 apiece. Company owner Farhad Ahsan told investigators that Pudenz contacted him in March 2011 seeking a job, and he was hired to follow up on invoices to ensure payment.

Pudenz represented Kabul Milli during several meetings in 2011 to work out payment issues with the U.S. Air Force officer who had taken Pudenz's former job. He also represented the company during several meetings with another contract employee, including one in which he sought an outstanding payment of $780,000, and "repeatedly emailed U.S. government officials" seeking payments for its work, the complaint says.

Confronted by investigators in November 2011, Pudenz admitted that his Kabul Milli consulting violated the guidance he'd received, the complaint says.

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