Pyne told me that at all times he has "complied with the requirements of the Ministerial Code of Conduct". It's likely he came to the attention of the Attorney-General's Department only by dint of his high profile because otherwise management of the government's code of conduct for lobbyists has been, to put it delicately, a farce.
The department had not been checking the end dates of government employees, had never conducted a "compliance risk assessment" and had "no method" to determine if lobbyists were abiding by the rules, or even declaring "whose interests they are representing". The department says it has now fixed these issues, and several months ago the audit office signed off on the reforms it has implemented.
The former US Ambassador's final day in the public service was not until January 31, the following year. Joe Hockey's DFAT-employed American advisor, Alex Tureman, filed the papers in DC while both men were still being paid by Australian taxpayers.
A spokeswoman for Hockey said he was "not involved in any US business registrations prior to March 2020", and that he complies with "all relevant codes of conduct and legislation in Australia, the US and the UK". It seems clear, though, that by at least the beginning of November 2019, the men had developed a plan to launch Bondi Partners, a US-Australia firm which now boasts of "navigating the critical intersection of policy, politics and the private sector", and that timing raises an obvious quandary.