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Who They Are
Holland & Knight is a full-service BigLaw firm whose Public Policy & Regulation Group ranks as the third-largest lobbying practice in the United States by revenue. Founded in 1968 and headquartered in Tampa with its lobbying operation based in Washington D.C., the firm operates a rare hybrid model: it functions simultaneously as a major corporate law firm and a top-ten K Street lobbying shop, allowing it to bundle legal and regulatory strategy for the same client roster.
In 2024, Holland & Knight billed $49.7 million in lobbying income across 318 clients — ranking it among the four most lucrative lobbying shops in the country. By 2025, the firm reported $54.9 million in lobbying revenues, another record. Rich Gold has led the Public Policy and Regulation Group since 1999, after joining from the Clinton administration in 1994, and is consistently ranked among Washington’s top lobbyists by The Hill, National Journal, and Washingtonian Magazine.
The firm has been active in legislation spanning chemical safety, telecommunications, healthcare, defense procurement, energy, transportation, cannabis banking, semiconductor subsidies, foreign trade, and federal appropriations. It formed a dedicated National Security & Defense Industry Group in January 2025, signaling expansion into that sector.
Money
At $49.7M in 2024 revenue from 318 clients, Holland & Knight averages roughly $156,000 per client per year. The firm’s top clients pay substantially more: American Chemistry Council ($520K), Alibaba Group ($320K), and Alphabet’s Waymo and Wing Aviation ($320K each, $640K combined). These clients are not buying legal services — they are purchasing sustained legislative and regulatory access through former government officials who maintain active relationships with the offices that oversee them.
Client List
Organized by sector, based on 2024 OpenSecrets lobbying disclosure data:
Chemicals / Environment
- American Chemistry Council — $520,000 (chemicals industry’s primary DC trade group)
- Chemours Co — disclosed (PFAS/forever chemicals manufacturer, DuPont spinoff)
- Corteva Agriscience — disclosed (agricultural chemicals, Dow spinoff)
- Ecolab Inc — disclosed (industrial chemicals and water treatment)
- Portland Harbor Common Interest Group — disclosed (Superfund cleanup coordination)
- National Mining Assn — disclosed (mining industry trade group)
Technology / Autonomous Vehicles / AI
- Alphabet Inc / Waymo — $320,000 (autonomous vehicle regulation, FAA/NHTSA)
- Alphabet Inc / Wing Aviation — $320,000 (drone delivery, FAA beyond-visual-line-of-sight rules)
- Alibaba Group — $320,000 (Chinese e-commerce; US trade and regulatory matters)
- Abridge AI — disclosed (healthcare AI)
- Applied Intuition — disclosed (autonomous vehicle software, DoD adjacent)
- Oklo Inc — disclosed (advanced nuclear, energy)
Defense / National Security
- ACP Technologies (Michigan) — $250,000 (defense manufacturing)
- Advent International / Maxar Space — $200,000 (satellite intelligence/space)
- TransDigm Group — disclosed (aerospace components; sole-source defense contracts)
- ViaSat Inc — disclosed (satellite communications, DoD contractor)
- Veritas Capital / GuideHouse, Chromalloy — disclosed (private equity defense portfolio)
- OSI Systems / Rapiscan — disclosed (security scanning systems, DHS contracts)
- Intelligent Waves — disclosed (IT/cybersecurity, DoD)
- Kratos Defense & Security — disclosed (drone warfare systems)
Healthcare / Pharma
- American Hospital Assn — disclosed (hospital trade group)
- American Cancer Society / ACS Cancer Action Network — $200,000
- Front Line Hospital Alliance — disclosed
- Denver Health & Hospital Authority — disclosed
- Lurie Children’s Hospital — disclosed
- Novo Nordisk — disclosed (GLP-1/diabetes drugs)
- Viatris Inc — disclosed (generic pharmaceuticals)
- Alkermes — disclosed (addiction/psychiatric drugs)
- Alliance for Regenerative Medicine — $120,000
Financial Services / Real Estate
- Amscot Financial — $360,000 (payday lending/financial services, FL-based)
- American Land Title Assn — $320,000 (title insurance industry)
- Akridge — $200,000 (DC real estate development)
- AGNC Investment — $70,000 (mortgage REIT)
- American Factoring Assn — $120,000
Energy / Environment
- Occidental Petroleum — disclosed (oil and gas)
- Advanced Biofuels Assn — $270,000
- Aetherflux Inc — $100,000 (space-based solar energy)
- Gulf Energy Alliance — disclosed
Cannabis
- National Cannabis Roundtable — disclosed (via Ed Perlmutter; SAFER Banking Act)
Municipal / Tribal / Other
- Multiple city governments (Philadelphia, Seattle, Phoenix, Buffalo, Tampa, Sacramento, etc.) — transportation/infrastructure grant lobbying
- Multiple tribal nations (Choctaw Nation, Mille Lacs Band of Ojibwe, Red Lake Band, etc.) — federal appropriations, gaming regulation
- Financial Oversight/Management Board for Puerto Rico — disclosed
The Revolving Door
Holland & Knight’s lobbying practice is built on what the firm openly calls its “relationships throughout Congress, the White House and the executive branch.” Those relationships have a specific origin: they are purchased by hiring former government officials at the moment their government access peaks — typically as they exit after a key administration or committee position.
Rich Gold — Group leader since 1999. Joined Holland & Knight in 1994 directly from the Clinton administration, where he held environmental and regulatory positions. Has led the firm’s top-line lobbying operation for 30+ years, becoming one of the longest-serving and highest-profile lobbyists in Washington. Clients include American Chemistry Council, Occidental Petroleum, Keurig Dr Pepper, National Mining Assn, and Corteva Agriscience — a portfolio that precisely mirrors the industries most affected by EPA, USDA, and FDA rulemaking.
Christopher Armstrong — Former Senate Finance Committee general counsel and chief oversight counsel under Chairman Orrin Hatch (R-UT). Handles tax, finance, education, and appropriations lobbying. His clients include Case Western Reserve University, University of Southern California, Washington & Lee University — institutions directly affected by the Senate Finance Committee’s jurisdiction over nonprofit tax status and student lending.
Tom Davis — Former U.S. Representative (R-VA, 11th district, 1995–2008). Chair of the House Committee on Oversight and Government Reform. Joined Holland & Knight in January 2019. Lobbies primarily for defense contractors and government IT firms: TransDigm Group (aerospace components sole-source contractor), ViaSat (satellite communications and defense), Veritas Capital portfolio companies (GuideHouse government consulting, Chromalloy aircraft components), Arlington Capital Partners/Systems Planning & Analysis. His committee chairmanship oversaw the exact federal contractors he now lobbies for.
Nasim Fussell — Former Senate Finance Committee Chief International Trade Counsel, advising Chairman Chuck Grassley (R-UT) on USMCA, US-Japan Trade Agreement, China Phase One Agreement, and WTO reform. Joined Holland & Knight in September 2020 to lobby on trade, international, and customs policy. Left Holland & Knight in April 2023 for Lot Sixteen (PR/lobbying firm). The 3-year window she spent at H&K directly monetized her committee relationships during the most consequential trade policy period in decades.
Yasmin Nelson — Former senior aide to three Senate Democrats: Senate Finance Committee (under Ranking Member Ron Wyden), Sen. Debbie Stabenow, and Sen. Cory Booker. Named top lobbyist in 2022 by The Hill and the National Institute for Lobbying & Ethics. Joined Holland & Knight in September 2023. Provides direct Senate Finance Democratic access — complementing Armstrong’s Republican access — allowing H&K to work both sides of tax and healthcare legislation simultaneously.
Ed Perlmutter — Former U.S. Representative (D-CO, 7th district, 8 terms, 2007–2023). Original sponsor of the SAFE Banking Act. Joined Holland & Knight in 2023 upon retirement and immediately took the National Cannabis Roundtable as his primary client — lobbying the Senate to pass the SAFER Banking Act, a bill he spent his entire congressional career championing. The revolving door completed: Perlmutter spent 8 terms building the relationships and expertise to pass cannabis banking reform, then monetized that expertise the year he left Congress.
Michal Freedhoff — Former EPA Assistant Administrator for the Office of Chemical Safety and Pollution Prevention (OCSPP), January 2021–January 2025. The Biden administration’s top chemical safety regulator, overseeing 1,100 employees and regulating the safety of chemicals, pesticides, and PFAS under TSCA and FIFRA. Before EPA, she spent 20+ years in Congress as the Senate Environment and Public Works Committee’s minority director of oversight — and was one of the key architects of the 2016 Lautenberg TSCA reform amendments. Joined Holland & Knight in April 2025, three months after the Biden administration ended. Her primary landing spot: a firm whose top-billing client is the American Chemistry Council — the chemical industry’s primary DC trade group, which spent four years fighting EPA chemical safety rules she oversaw.
By May 2025, Holland & Knight was publishing detailed client advisories on “TSCA Roundup: Existing Chemical Regulation Under the Second Trump Administration’s EPA” — guidance documents that walked the chemical industry through exactly how to exploit the regulatory gaps opening under Trump’s EPA. Freedhoff, who oversaw the original Biden TSCA enforcement regime, is now positioned as an internal expert on the same rules she wrote and enforced — helping industry clients understand their enforcement exposure as those rules are dismantled.
The Regulatory Shuttle in motion (2025–2026): Within months of Freedhoff joining, the Trump EPA began rolling back the chemical safety infrastructure she built:
- June 2025: EPA extends TSCA reporting submission deadline for 16 substances
- September 2025: EPA initiates “Take 3” on the TSCA Risk Evaluation Framework Rule — a third attempt to weaken risk evaluation standards that Freedhoff’s office had strengthened
- November 2025: EPA proposes major shift in TSCA PFAS reporting policy — rolling back Biden-era one-time reporting requirements by exempting PFAS in mixtures at concentrations below 0.1%, exempting article importers, and narrowing R&D reporting
- February 2026: EPA proposes rescinding the SCCAP rule (Chemical Safety and Security) — eliminating requirements Freedhoff’s office introduced under TSCA and scaling back public information provisions
- March 4, 2026: Senate Environment and Public Works Committee holds hearing on the Toxic Substances Control Act Fee Reauthorization and Improvement Act of 2026 — a Senate Republican draft bill that would create tiered reviews, reduce the evidence burden for chemical manufacturers, and give accredited third-party assessors (industry-funded) expanded roles in safety determinations
H&K published client analysis on each of these changes. Freedhoff — one of TSCA’s principal architects — is now advising the clients who spent years trying to roll back those same rules.
Money
The Freedhoff hire is the sharpest illustration of Holland & Knight’s chemical industry machine. The firm now possesses: (1) the principal Senate Republican TSCA negotiator (Armstrong), (2) one of the longest-serving chemical industry lobbyists in Washington (Gold), and (3) the Biden EPA official who oversaw TSCA enforcement for four years (Freedhoff). Holland & Knight bills American Chemistry Council $520,000 per year. Freedhoff spent her last four government years attempting to strengthen TSCA rules that ACC was simultaneously paying H&K to weaken. She joined the firm in April 2025. By November 2025, those TSCA rules were being formally rolled back by the Trump EPA. Holland & Knight published client guidance on each rollback. That is the Regulatory Shuttle pattern in its purest form: the regulator becomes the lobbyist, then watches the government dismantle the regulations she wrote, then advises industry on how to profit from the dismantlement. The institutional memory of enforcement becomes a commodity for sale to the regulated industry — in real time.
Lobbying-to-Policy Timeline
| Date | Recipient/Target | Amount | Policy Return | Time Gap |
|---|---|---|---|---|
| 2016 | Senate EPW / House E&C | Career tenure | Frank R. Lautenberg Chemical Safety Act passed — TSCA’s first major revision in 40 years; H&K had both Republican negotiator and Dem architect on staff | Long-term |
| Jan 2019 | House Oversight / Defense procurement | H&K hire cost | Tom Davis joins; TransDigm, ViaSat, Veritas Capital win defense appropriations; H&K gains former House Oversight chair for contractor clients | Ongoing |
| Sep 2020 | Senate Finance / USTR | H&K hire cost | Fussell joins from Senate Finance; USMCA ratification complete; US-China Phase One entered into; H&K trade clients gain Senate Finance access | 6 months |
| 2022 | Congress (multiple) | $43M+ (firm revenue) | CHIPS & Science Act passes ($52B semiconductor subsidies); Inflation Reduction Act passes (clean energy, chemical provisions); H&K worked both | 12-18 months |
| 2024 | FAA / NHTSA | $640K (Alphabet) | FAA expands drone beyond-visual-line-of-sight authorization; autonomous vehicle federal framework advanced; Waymo/Wing commercial expansion enabled | 12-24 months |
| 2024 | Senate Banking Committee | Undisclosed (NCR) | SAFER Banking Act advanced in Senate Banking Committee for first time; Perlmutter’s 10-year legislative goal nearly achieved year of hire | 1 year |
| 2024 | Congress / EPA | $520K (ACC) | TSCA enforcement priorities shift in final Biden year; chemical industry maintains preferred status quo on PFAS exemptions | Ongoing |
| Apr 2025 | EPA OCSPP / Congress | $520K (ACC ongoing) | Freedhoff hired; H&K now has former chief TSCA enforcer advising chemical industry clients on compliance strategy and regulatory rollback | 3 months post-admin |
| May–Nov 2025 | Trump EPA / OCSPP / OMB | $520K (ACC annual) | EPA rolls back TSCA sequentially: deadlines extended (Jun), Risk Eval Framework weakened (Sep), PFAS reporting requirements stripped (Nov); H&K publishes client guidance on each change | 1–7 months post-hire |
| Feb–Mar 2026 | Senate EPW / House E&C | $520K+ (ACC annual) | EPA proposes SCCAP rescission (Feb 2026); Senate GOP releases TSCA reform draft reducing evidence burden for chemical manufacturers; H&K publishes analysis on TSCA rollback (Mar 2026) | 10–11 months post-hire |
Money
The timeline reveals Holland & Knight’s core business model: hire the government official at peak access, immediately deploy their relationships for paying clients. Tom Davis joined in January 2019 and defense contractor clients were disclosed that year. Nasim Fussell joined in September 2020 mid-USMCA ratification. Yasmin Nelson joined in September 2023 while Senate Finance was drafting major healthcare and tax provisions. Ed Perlmutter joined in 2023 and the SAFER Banking Act moved farther than it ever had in the Senate within 12 months. Michal Freedhoff joined in April 2025, three months after leaving the top chemical regulatory job in the country, to advise the clients who were trying to undo her own regulatory work. The pattern is not incidental. It is the product.
The Bipartisan Model
Holland & Knight explicitly markets its ability to work both sides of the aisle — and structures its revolving door hires to deliver this capacity systematically.
On the Republican side: Tom Davis (former R-VA congressman, House Oversight chair), Christopher Armstrong (Senate Finance under Orrin Hatch), Christopher DeLacy (counsel to Republican Sen. John Warner, Senate Rules Committee), Nasim Fussell (Senate Finance under Chuck Grassley).
On the Democratic side: Rich Gold (Clinton administration), Yasmin Nelson (Senate Finance under Ron Wyden; aides to Stabenow and Booker), Ed Perlmutter (8-term Democratic congressman), Michal Freedhoff (Biden EPA, Senate EPW Democratic oversight).
The result is a firm that can simultaneously lobby Republican appropriators and Democratic committee chairs — sometimes on behalf of the same client in the same legislative cycle. When a piece of legislation like TSCA reform, the CHIPS Act, or the Inflation Reduction Act requires bipartisan support, Holland & Knight can work both leadership offices, both party whip operations, and both committee staffs.
Contradiction
Holland & Knight publicly positions its bipartisanship as a public service — bringing both sides together, finding workable solutions, advancing good policy. But the bipartisan access is not a civic gift. It is a premium product sold to corporations. American Chemistry Council pays $520,000 per year to have access to both the Republican TSCA negotiator and Biden’s TSCA enforcer. Alibaba Group pays $320,000 to have a former Republican technology counsel working its regulatory strategy. TransDigm Group pays an undisclosed amount for a former House Oversight Committee chairman working defense appropriators. The bipartisan model is not about consensus — it is about charging more for covering more targets simultaneously.
Billing vs. Outcomes
American Chemistry Council / Chemical Industry ($520,000/year, 2024–2025)
Investment: $520,000/year to Holland & Knight, plus separate lobbying operations Return: The ACC investment in Holland & Knight produced the most documented regulatory return in the 2025–2026 TSCA cycle. In sequence: Freedhoff hired (April 2025) → H&K publishes TSCA industry guidance (May 2025) → EPA extends TSCA deadlines (June 2025) → EPA weakens Risk Evaluation Framework (September 2025) → EPA proposes PFAS reporting rollback (November 2025) → EPA proposes SCCAP rescission (February 2026) → Senate GOP TSCA reform bill targeting evidence burden reduction (March 2026). The firm that had the Biden-era TSCA architect AND the Republican TSCA negotiator on staff is now publishing client guidance on how to exploit each rollback. The $520,000 annual retainer is purchasing not just access but institutional expertise applied in real time against the regulatory framework Holland & Knight’s own staff helped write.
Alphabet/Waymo + Wing Aviation ($640,000/year, 2024)
Investment: $640,000 in 2024 lobbying fees Return: FAA advanced beyond-visual-line-of-sight authorization for commercial drones; autonomous vehicle federal regulatory framework developed without restrictive legislation; Waymo’s commercial robotaxi expansion enabled in multiple cities without new federal oversight requirements.
National Cannabis Roundtable / Ed Perlmutter (undisclosed)
Investment: Lobbying fees + Perlmutter hire Return: SAFER Banking Act cleared Senate Banking Committee in 2023 — the furthest the bill had advanced in 10 years of Perlmutter advocacy. The former sponsor of the bill now lobbying for it is, structurally, the fastest possible policy path.
TransDigm Group / Defense Portfolio (undisclosed)
Investment: Lobbying fees via Tom Davis Return: Defense appropriations continued. TransDigm historically cited for sole-source contracting and excess profit-taking from DoD — its continued defense business requires sustained congressional relationship management, which Davis provides via his House Oversight relationships.
Class Analysis
Holland & Knight operates the BigLaw revolving door model at institutional scale. Unlike pure lobbying shops (BGR, Brownstein), it pairs government-access lobbying with full-service legal representation — creating a one-stop capture shop where the same firm that lobbies for a chemical company also defends it in EPA enforcement actions, advises it on mergers, and monitors its congressional exposure.
The firm’s value proposition is structural rather than ideological. Holland & Knight is not conservative or liberal. It is institutional. It serves whoever pays the most, regardless of policy position — and its bipartisan roster means it can be deployed against any legislative or regulatory threat regardless of which party controls the government.
The Freedhoff hire crystallizes the logic: a career public servant who spent 20+ years in Congress and 4 years as EPA’s top chemical regulator is now advising the regulated industry. Her expertise — in TSCA enforcement gaps, regulatory priorities, interagency relationships, and the specific technical arguments that moved Biden EPA policy — is now a commodity. The chemical industry paid $520,000/year to Holland & Knight while she was regulating them. They continue paying after she joined. The revolving door does not require corruption. It requires only the transformation of public service into private credential.
The firm’s 318-client roster in 2024 also reveals the breadth of the Donor Map’s targets. American Chemistry Council, Occidental Petroleum, Alibaba Group, TransDigm Group, and the National Cannabis Roundtable are not natural allies. They share one thing: they have business before the federal government, and they need professionals who understand how that government works from the inside. Holland & Knight sells that understanding. That is K Street’s structural function — converting institutional knowledge of the public interest into billable access for private clients.
Sources
- OpenSecrets: Holland & Knight Lobbying Profile 2024 (Tier 1)
- OpenSecrets: Holland & Knight Lobbyists 2024-2025 (Tier 1)
- E&E News: Biden’s EPA chemicals chief lands new job (Freedhoff) (Tier 2)
- Holland & Knight: Former EPA Chemical Safety AA Michal Freedhoff Joins (Tier 3)
- Holland & Knight: Former Congressman Tom Davis Joins Holland & Knight (2019) (Tier 3)
- Holland & Knight: Yasmin Nelson, Former Advisor to Kamala Harris, Joins (2023) (Tier 3)
- Holland & Knight: BigLaw Firms Report Record Lobbying Revenues for 2024 (Tier 3)
- Holland & Knight: Forms National Security & Defense Industry Group (2025) (Tier 3)
- Holland & Knight: Rich Gold Professional Profile (Tier 3)
- Marijuana Moment: Former Congressman Behind Marijuana Banking Bill Discusses New Lobbying Work (Perlmutter) (Tier 2)
- Wikipedia: Holland & Knight (Tier 3)
- Kinney Recruiting: Senate Finance Committee Chief International Trade Counsel Nasim Fussell Joins Holland & Knight (Tier 3)
- Holland & Knight: TSCA Roundup — Existing Chemical Regulation Under the Second Trump Administration’s EPA (May 2025) (Tier 3)
- Holland & Knight: EPA Proposes Major Shift in TSCA PFAS Reporting Policy (November 2025) (Tier 3)
- Holland & Knight: EPA’s Proposed Rule Signals Rollback of Chemical Safety Requirements as Key Questions Remain (March 2026) (Tier 3)
- The New Lede: Senate GOP backs speedier chemical reviews; Dems cite health risks — Senate TSCA reform bill, March 4 hearing (March 2026) (Tier 2)
- The New Lede: House Republicans move to roll back key protections in US chemical safety law (January 2026) (Tier 2)
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