Decision

Advice Letter: Rishi Sunak, Member of the Group of Senior Advisers, The Goldman Sachs Group, Inc

Updated 8 July 2025

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Rishi Sunak MP, former Prime Minister of the United Kingdom. Paid appointment with The Goldman Sachs Group, Inc.

You approached the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for Former Ministers (the Rules) seeking advice on taking up an appointment as a Member of the Group of Senior Advisers with The Goldman Sachs Group, Inc (Goldman Sachs).

The purpose of the Rules is to protect the integrity of the government. The Committee has considered the risks associated with the actions taken and decisions made during your time in office, alongside the information and influence you may offer Goldman Sachs, as the former Prime Minister. The material information taken into consideration by the Committee is set out in the annex below.

The Committee’s advice is not an endorsement of the appointment. The advice imposes a number of conditions to mitigate the potential risks to the government associated with this appointment under the Rules – including a limitation to the role and a waiting period before taking up the post.

The Ministerial Code sets out that ministers must abide by the Committee’s advice. It is an applicant’s personal responsibility to manage the propriety of any appointment. Former ministers of the Crown, and Members of Parliament, are expected to uphold the highest standards of propriety and act in accordance with the 7 Principles of Public Life.

2. The Committee’s consideration of the risks presented

2.1 Context

Goldman Sachs is a leading global investment bank and financial services firm. The company’s Asset Management division offers a broad range of investment solutions for institutions, financial advisers, and individual investors, including ETFs focused on specific markets – such as UK government bonds (gilts). Its Private Wealth Management group specialises in providing tailored investment strategies, wealth planning, and lending services to ultra-high-net-worth clients. Goldman Sachs Bank USA is its direct bank which trades on behalf of itself and its clients in America.

Goldman Sachs is a stakeholder of the UK government as a major financial institution operating in the UK. It has advised and interacted with the UK government on various economic and financial matters – including working with various UK government departments on specific contracts. It is also a registered client of a firm providing lobbying services on its behalf, as recorded on the Register of Consultant Lobbyists.

It was relevant to the Committee’s consideration that your career prior to entering politics for around 14 years was in financial services, including a period of employment with Goldman Sachs some time ago – between 2001 and 2004. You then entered politics and subsequently government in 2018. You became a minister for the Ministry of Housing, Communities and Local Government, before joining HM Treasury as Chief Secretary to the Treasury, then as Chancellor of the Exchequer, before becoming Prime Minister in 2022. You therefore have deep experience in financial services gained in both the private sector and government.

2.2 The risks associated with your official dealings with the sector

As Prime Minister, you were responsible for the government’s policies and decisions, and for overseeing all ministers, the Civil Service and government agencies. Whilst you were not, and could not be, involved in all detail, you were responsible for government decision-making. The Committee^{[footnote 1]} agreed with the Cabinet Office it is likely there were numerous decisions you made that had an impact on financial services, alongside other sectors. The Cabinet Office informed us that they were not aware of any decisions you made that were specific to Goldman Sachs.

During your time as Prime Minister, the Edinburgh Reforms were announced. These introduced 30 regulatory and tax reforms aimed at driving growth and enhancing competitiveness in the UK’s financial services sector following its departure from the European Union. These reforms were built on the Financial Services and Markets Bill, which has since been enacted via the Financial Services and Markets Act 2023. Goldman Sachs, alongside other financial institutions arguably benefited from such reforms, with Goldman Sachs becoming the first to remove its cap on bankers’ bonuses.

Your personal dealings with the company were limited. You met with the company only once as part of a roundtable discussion. There is no suggestion any decisions were made or actions were taken in office in expectation of this role^{[footnote 2]}. The Committee therefore does not consider this role could reasonably be considered as a reward. Nonetheless your closeness to the sector is relevant to the Committee’s consideration, including that you were leading the government when significant reforms were introduced that could be seen as beneficial to financial institutions such as Goldman Sachs.

2.3 The risks associated with your access to information and your potential to offer unfair access to the company

This role is likely to have a broad overlap with your access to information in office – a risk that would undoubtedly arise with almost any outside role. As the former Prime Minister, you will have been privy to a range of high-level sensitive information on more or less all government-related matters.

There are factors which considerably reduce the risks associated with your access to information both broadly and that specifically related to financial services, geopolitics and economic policy. Since you left office there has been a change in government and significant shifts in the economic and geopolitical climate that the current government has had to respond to. It has now been 10 months since you last had access to information, creating a significant gap and reducing its currency. In particular, numerous decisions have been made under the current Prime Minister and Chancellor which you have had no involvement in, for example in the Autumn Budget 2024 and the Spring Statement 2025. The Cabinet Office is not aware of any specific information from your time as Prime Minister that would now offer Goldman Sachs or its clients an unfair advantage – though it is hard to argue that all information available to you as Prime Minister is now obsolete.

There is also the unknown risk around potential clients Goldman Sachs may ask you to work with and advise. Specifically, the Committee cannot rule out that you may be asked to advise on matters which either overlap with your responsibilities in office, or where you had official dealings with the client during your time in office. Goldman Sachs advises sovereign wealth funds around the world. Given your role in representing His Majesty’s Government on the international stage, the Committee did not consider that it would be appropriate for you to advise other governments (via their sovereign wealth funds) in this role on behalf of Goldman Sachs. To do so raises the risk that you could be seen to offer unfair insight, or be making use of contacts and influence gained as Prime Minister to the financial benefit of Goldman Sachs.

Without knowing which clients you will work with, the risks are hard to mitigate. Therefore, whilst it is entirely proper for you to make use of your skills and non- privileged insight from your time in office to advise Goldman Sachs and its clients, there remains a risk that the work could conflict with your time in office.

Goldman Sachs has a significant interest in UK government policy. As the former Prime Minister, there is a reasonable concern that your appointment could be seen to offer unfair access and influence within the UK government. You and Goldman Sachs have confirmed to the Committee that the role will not involve lobbying the government, which all former ministers are prevented from doing for two years on leaving office. The Committee considered that it would be difficult to mitigate the risk of perceived lobbying if you initiated engagement of any kind with the UK government in this role, noting this is not your stated intention.

3. The Committee’s advice

As the former Prime Minister with overall responsibility for the UK government, your privileged position granted you power to influence decisions and unique access to high-level information.

While acknowledging that the risks associated with your access to information are limited due to the passage of time and political and economic changes, the Committee noted a potential conflict of interest risk could arise given the end clients are unknown. Consequently, a condition has been imposed to limit your role and reduce the scope for risks under government Rules.

Further, considering your leadership during significant reforms that likely benefited financial institutions like Goldman Sachs, along with your seniority, access to information, and potential for significant insight and influence, the Committee determined a substantial gap between leaving office and this appointment was necessary. A 12 month gap from your last day in ministerial office has been imposed, along with a ban on engaging with the UK government on behalf of Goldman Sachs or its clients.

The Committee advises, under the government’s Business Appointment Rules, that your appointment with The Goldman Sachs Group, Inc be subject to the following conditions:

• a waiting period of 12 months from your last day in ministerial office;

• you should not draw on (disclose or use for the benefit of yourself or the persons or organisations to which this advice refers) any privileged information available to you from your time in ministerial office;

• for two years from your last day in ministerial office, you should not become personally involved in lobbying the UK government or its arm’s length bodies on behalf of The Goldman Sachs Group, Inc (including parent companies, subsidiaries, partners and clients); nor should you make use, directly or indirectly, of your contacts in the government and/or ministerial contacts to influence policy, secure business/funding or otherwise unfairly advantage The Goldman Sachs Group, Inc (including parent companies, subsidiaries, partners and clients);

• for two years from your last day in ministerial office, you should not provide advice to The Goldman Sachs Group, Inc, on the terms of, or with regard to the subject matter of, a bid or contract with, or relating directly to the work of the UK government or its arm’s length bodies;

• for two years from your last day in ministerial office, your role with The Goldman Sachs Group, Inc, should be limited to providing advice on strategy, macro- economic and geopolitical matters that do not conflict with your time as Prime Minister (including where you are working with parent companies, subsidiaries, partners and clients of Goldman Sachs). In doing so, you must not advise:

• on matters in which you were involved as Prime Minister which have not yet been determined or have not yet been made public;

• on matters specific to investment by a foreign government and its sovereign wealth funds for which The Goldman Sachs Group, Inc has an advisory mandate; and

• clients/investors with whom you had material dealings in your role as Prime Minister; and

• for two years from your last day in ministerial office, you must not initiate any engagement with the UK government or its arm’s length bodies on behalf of The Goldman Sachs, Group Inc (or parent companies, subsidiaries, partners and clients).

The advice and the conditions under the government’s Business Appointment Rules relate to your previous role in government only; they are separate from rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists, the Parliamentary Commissioner for Standards and the Registrar of Lords’ Interests.^{[footnote 3]} You are reminded that as a Member of Parliament you have a separate ban on paid lobbying under the Parliamentary Code of Conduct. It is an applicant’s personal responsibility to understand any other rules and regulations they may be subject to in parallel with this Committee’s advice.

By ‘privileged information’ we mean official information to which a minister or Crown servant has had access as a consequence of his or her office or employment and which has not been made publicly available. Applicants are also reminded that they may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Civil Service Code or otherwise.

The Business Appointment Rules explain that the restriction on lobbying means that the former Crown servant/minister ‘should not engage in communication with government (ministers, civil servants, including special advisers, and other relevant officials/public office holders) – wherever it takes place – with a view to influencing a government decision, policy or contract award/grant in relation to their own interests or the interests of the organisation by which they are employed, or to whom they are contracted or with which they hold office.’

You must inform us as soon as your appointment is live or announced. You must also inform us if you propose to extend or otherwise change the nature of your role as, depending on the circumstances, it may be necessary for you to make a fresh application.

Once the appointment has been publicly announced or taken up, we will publish this letter on the Committee’s website, and where appropriate, refer to it in the relevant annual report.

4. Annex – material information

4.1 The company

The Goldman Sachs Group, Inc (Goldman Sachs) is an American multinational investment bank and financial services company.

Goldman Sachs Asset Management is the investment management arm of Goldman Sachs that serves a broad range of clients on investment banking, mergers and acquisitions and restructuring, securities underwriting and prime brokerage. Its clients include:

• Institutional investors: pension funds, sovereign wealth funds, central banks, insurance companies, endowments, and foundations.

• Financial intermediaries: investment advisors, wealth managers, private banks, and broker-dealers.

• Individual investors: through mutual funds, ETFs^{[footnote 4]}, and other investment products.

Goldman Sachs Private Wealth Management caters to ultra-high-net-worth individuals and families, as well as select institutions like foundations and endowments. The typical client has substantial investable assets (often millions of pounds’ worth as a minimum). Its services include:

• customised investment strategy
• wealth planning
• private banking and lending
• access to alternative investments
• trust and estate administration.

Goldman Sachs Bank USA is a direct bank, and trades both on behalf of its clients (flow trading) and on its own account (proprietary trading). It serves as the primary lending and deposit entity for Goldman Sachs in the United States.

Goldman Sachs is also a stakeholder of the UK government as a major financial institution operating in the UK. It has advised and interacted with the UK government on various economic and financial matters – including through various UK government departments. It is also a registered client of a firm providing lobbying services on its behalf as recorded on the Register of Consultant Lobbyists^{[footnote 5]}.

4.2 The role

You described this as a paid part time role as a Member of the Group of Senior Advisers with Goldman Sachs.

You said you will provide strategic global advisory services – engaging with Goldman Sachs’ senior leadership and its key clients globally offering your perspectives and advice on strategy, macro-economic and geopolitical issues. The advice will not be UK centric but focussed on global issues. In doing so, you will attend meetings, conferences, speaker events and roundtables. You will have no contact with the UK government in this role.

Another key part of your role will be engaging with employees of Goldman Sachs in leadership and mentoring capacities to foster a culture of growth and development within the organisation.

You confirmed that your payment(s) from this engagement will be donated to charity, specifically The Richmond Project. When the Committee advises on your role as a Trustee you said you would contribute to this charity, which was set up by you and your wife. It will focus on identifying and supporting innovative initiatives that drive social mobility by helping families break down barriers to numeracy. The Richmond Project is regulated by the Charity Commission.

4.3 Previous experience in financial services

Before entering politics, you worked in the financial services sector for 14 years and previously worked with the same company, Goldman Sachs between 2001 and 2004. You noted that Goldman Sachs reached out to you as a former employee of the firm, after you stepped down as leader of the opposition. You told the Committee that, rather than your time in office, it is your professional background in finance and your time at the firm during the start of your career that makes this part-time role at Goldman Sachs a natural fit for you, now that you are no longer in office.

4.4 Correspondence from Goldman Sachs

Goldman Sachs proactively wrote to the Committee to make it clear that, in this role, you will not:

• draw on privileged information from your time as Prime Minister in any discussion or forum

• be involved in lobbying the UK government

• make use, directly or indirectly, of your contacts to influence policy or secure business/funding from the UK government

• provide advice on the terms or subject matter of bids or contracts with the UK government.

4.5 Dealings in office

You said you were not aware of, or involved in, any specific regulatory decisions involving Goldman Sachs. In December 2022, the then Chancellor announced a series of reforms to financial services regulation – the Edinburgh Reforms^{[footnote 6]}. As Prime Minister, you were not involved in the detail of the policy development.

You noted that you would see leading figures in finance on occasion, given the importance of the industry to the UK. You confirmed you had no personal meetings with Goldman Sachs during your time as Prime Minister. In June 2023, as part of a roundtable event with business in Washington DC, you met a range of leading US business people, including David Solomon – the CEO of Goldman Sachs.

You told the Committee that there is a clear distinction between your time in office (as Chancellor, now three years ago, and 10 months ago as Prime Minister) and the landscape now. In particular, you said that, since the election, the new government has announced significant new policy in the Financial Services sector, including:

• Listings Regime (July 2024)^{[footnote 7]}

• Pensions Review (July 2024)^{[footnote 8]}

• Bank Capital Requirements (Sept 2024)^{[footnote 9]}

• International Investment Summit (Oct 2024)^{[footnote 10]}

• Mansion House Speech (Nov 2024) including changes to the pension industry with new legislation announced, changes to Senior Managers Regime and new remits for all financial regulators: the FCA, PRA and Bank of England^{[footnote 11]}

• Financial Services Growth and Competitiveness Strategy (Nov 2024)^{[footnote 12]}

4.6 The Edinburgh reforms

The Edinburgh Reforms introduced over 30 regulatory and tax reforms aimed at driving growth and enhancing the competitiveness of the UK’s financial services sector following its departure from the European Union. These:

• followed the Financial Services and Markets Bill, since enacted via the Financial Services and Markets Act 2023;

• were aimed at changing the UK’s financial regulatory framework, post Brexit, to create a more agile, competitive, and innovative sector while maintaining stability and protecting consumers;

• provided an opportunity for more flexible regulation and included the removal of the cap on bankers’ bonuses^{[footnote 13]}.

4.7 Departmental assessment

The Cabinet Office confirmed the details provided by you, including that you made no decisions specific to Goldman Sachs and did not meet with the company on a one-to-one basis. It also provided the following context:

• as Prime Minister, you had oversight of all government business;

• some government business would have had an impact on the financial sector in which Goldman Sachs operates;

• you met representatives of the company alongside other leading US business people at a roundtable event; and

• as a former Prime Minister, you were privy to a wide range of information – however, given the change in political leadership and the length of time since you were in office, this knowledge will have changed significantly in terms of salience and currency.

The Cabinet Office considered any risk this role could be perceived as a reward to be limited, given that you are returning to a previous employer in financial services. In its view, the risks associated with this appointment could be appropriately mitigated by standard conditions and a ban on advising on relevant matters from his time as Prime Minister.

1. This application for advice was considered by Isabel Doverty; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CBE DL; Michael Prescott; and The Baroness Thornton. Andrew Cumpsty was not available. ↩

2. The Committee also took into consideration that you have chosen to donate your earnings from this work to your charity – The Richmond Project. ↩

3. All Peers and Members of Parliament are prevented from paid lobbying under the the House of Commons Code of Conduct and the Code of Conduct for Members of the House of Lords. Advice on your obligations under the Code can be sought from the Parliamentary Commissioners for Standards, in the case of MPs, or the Registrar of Lords’ Interests, in the case of peers. ↩

4. ETFs (Exchange Traded Funds) are a type of investment fund that is traded on stock exchanges. ↩

5. Goldman Sachs: Client Profile – Office of the Registrar of Consultant Lobbyists ↩

6. Financial Services: The Edinburgh Reforms – GOV.UK ↩

7. FCA overhauls listing rules to boost growth and innovation on UK stock markets ↩

8. Pensions Investment Review: interim report, consultations and evidence – GOV.UK ↩

9. New rules for banks to deliver financial stability and investment – GOV.UK ↩

10. Britain set for growth with International Investment Summit – GOV.UK ↩

11. Mansion House 2024 speech – GOV.UK ↩

12. Financial Services Growth and Competitiveness Strategy – GOV.UK ↩

13. Goldman Sachs removes bankers’ bonus limit – BBC News ↩