Trump’s Interests vs. America’s, Dubai Edition

Despite its pledge to avoid new foreign deals, the Trump Organization is moving forward with expansion plans in the United Arab Emirates.

On August 5, the Trump Organization announced a new venture via Twitter: the Trump Estates Park Residences, “a collection of luxury villas with exclusive access to” the Trump International Golf Course in Dubai. The Trump-branded (though not Trump-owned) development is part of the company’s ongoing partnership with the Dubai-based real-estate firm Damac, which has previously made news due to its president Hussain Sajwani’s relationship to the Trump family. Individual units are expected to sell for 2.6 million Emirati dirhams, or roughly $800,000.

As with all of the properties with which the Trump Organization is involved, whether as owner or as licensor, the Trump Estates Park Residences creates a number of conflicts of interest. Whether the Trump Organization receives a portion of the property’s revenues or a flat annual fee in exchange for use of the Trump name (and in this case, that detail isn’t known), the company will be profiting from the villas—which means anyone looking to influence the president can try to do so by purchasing one of them.

The project also further entangles the Trump Organization, and by extension Trump himself, with a foreign government, creating the possibility that unscrupulous officials could attempt to gain some degree of leverage with the president by, say, issuing the property environmental violations or, alternately, turning a blind eye to irregularities in sales proceedings, in the hopes of receiving political favors. And the Trump Estates Park Residences certainly seem to go against the president’s pledge that his company would pursue “no new foreign deals” while he is in office, though the Trump Organization has justified similar projects by arguing that they represented merely the fruition of existing deals.

Trump’s relationship with Sajwani certainly creates the impression that this venture could give special benefits to the Emirati businessman and, by extension, other investors who have Sajwani’s ear. At a New Year’s Eve celebration at Mar-a-Lago, a guest recorded Trump publicly praising Sajwani. Trump later noted that, after the election, he spoke with the Emirati billionaire about a potential deal but ultimately decided not to pursue it, saying, “It’s a nice thing to have, but I don’t want to take advantage of something”—a statement that suggests that, even though Trump turned the deal down, the offer was memorable enough to leave a positive impression. Sajwani also met with Donald Trump Jr. in May, demonstrating enviable access to the president’s family that potential investors may hope to capitalize on.

Moreover, even though the United Arab Emirates features in the news less frequently than many of its neighbors in the Middle East, it is nevertheless an important American ally in the region. For example, the UAE was one of four Middle Eastern countries to sever ties with Qatar recently, creating a diplomatic crisis that, as of early August, remains unresolved. The nation has at times appeared on lists of state sponsors of terrorist groups, and, according to Human Rights Watch, “often uses its affluence to mask the government’s serious human rights problems” such as forced detention, torture, discrimination against women and gay people, and labor abuses. That the president will be profiting from business interests there could jeopardize his ability to make objective and effective decisions about policy that will affect the U.S., the UAE, and the Middle East overall.

The Background

President Donald Trump still has not taken the necessary steps to distance himself from his businesses while in office. In accordance with a plan that he and one of his lawyers, Sheri Dillon, laid out at a press conference on January 11, Trump has filed paperwork to remove himself from the day-to-day operation of his eponymous organization. However, numerous ethics experts have voiced strenuous objections to the plan, which they say does very little to resolve the issue: As long as Trump continues to profit from his business empire—which he does whether or not he is nominally in charge—they say, the possibility that outside actors will attempt to affect his policies by plumping up his pocketbook will remain very much in play.

Several of Trump’s critics have moved forward with legal action. The watchdog group Citizens for Responsibility and Ethics in Washington, or CREW, filed a lawsuit alleging that Trump’s business holdings violate the emoluments clause of the Constitution, which makes it illegal for government officials to “accept of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.” CREW’s bipartisan legal team includes, among others, Norm Eisen and Richard Painter, who served as ethics lawyers under Presidents Obama and George W. Bush, respectively; Laurence Tribe, a constitutional law professor at Harvard University; and Zephyr Teachout, a professor at Fordham University (and former congressional candidate) who is considered an authority on the emoluments clause. All have been vocally critical of Trump’s continued refusal to sell off his business, and are now taking their case to court to argue that several of Trump’s businesses present avenues by which foreign governments could seek to influence the president by, for example, booking stays at one of his hotels or renting space at one of his properties. Additionally, the lawsuit seeks to force Trump to reveal his tax returns, something every president has done since Gerald Ford but which Trump has refused to do, significantly limiting the public’s ability to understand the president’s finances. When asked about the lawsuit, Trump described it as “totally without merit.” Eisen was quick to respond on Twitter, offering to “debate Trump (or his chosen champion) on the merits of our case anytime,” making it clear that CREW intends to continue to pursue its case. (CREW has also filed a separate complaint to the General Services Administration arguing that Trump has violated the lease on his Washington, D.C. hotel, which states that “no ... elected official of the Government of the United States … shall be admitted to any share or part of this Lease, or to any benefit that may arise therefrom.”)

Though CREW is the first group to bring a lawsuit against President Trump, it may soon have company. According to The New York Times, Anthony Romero, the executive director of the American Civil Liberties Union, has said that his organization is looking for a plaintiff to sue Trump for violating the emoluments clause, although with a different claim to legal standing: While CREW intends to demonstrate that the group itself has suffered financial harm because the need to focus on the emoluments clause has diverted its resources away from other worthy causes, the ACLU is hoping to find a hotel or bed-and-breakfast owner that can prove he or she has lost business to one of Trump’s hotels during his presidency.

CREW’s lawsuit is just the latest development in what promises to be a continuing saga regarding Trump’s many conflicts of interest that began almost as soon as he won the presidency. Along with his unprecedented wealth, Trump brings to the office unique and gravely concerning entanglements that, whether he recognizes their effects or not, threaten to undermine his decision-making as president. The plan Trump and Dillon announced on January 11 would do very little to resolve the conflicts: It places control of his assets in the hands of his two adult sons and a longtime associate of their father’s with what so far amounts to a pinky-swear assurance that, despite their proximity to the president, they will not discuss any aspect of the business with him. On top of that, the plan supposedly would terminate several of the Trump Organization’s pending deals and place a ban on new foreign deals, two conditions undermined by the announcement that the organization would be moving forward with expanding its golf course in Aberdeen, Scotland.

Even before his most recent plan was laid out, Trump has attempted to deflect criticism by repeatedly asserting that the law barring executive-branch officials from maintaining financial holdings or business ties that overlap with their duties does not apply to the president or vice president. In this, he is correct; the law, passed in 1989, exempts the two chief executives from conflict-of-interest rules on the understanding that their purview is so broad that it would be impossible for them to completely disentangle themselves.

Regardless, legality does not imply propriety. Unless Trump acts to put actual distance between himself and his business ventures, these questions are likely to continue throughout his time in the Oval Office. On top of the aforementioned legal actions, the director of the Office of Government Ethics, Walter Shaub, has declared Trump’s efforts insufficient, remarking, “I don’t think divestiture is too high of a price to pay to be the president of the United States,” and a number of Senate Democrats have introduced legislation that would force Trump to divest or face impeachment. Below is an attempt to catalogue the more clear-cut examples of conflicts of interest that have emerged so far. The most recent entries appear at the top:

That Secret Service Detail

President Donald Trump’s decision to retain ownership of his business while in office means that he can profit from government entities that are obligated to patronize his properties. For the Secret Service, which sets up a protective perimeter around the president and vice president’s non-White House residences, this means paying the president’s company, and by extension the president, to rent space in Trump Tower in New York. It also, apparently, makes it possible for the Secret Service to get into a dispute with the Trump Organization over the lease.

For the past few decades, setting up such details, and occasionally paying rent to the officeholder, has been common practice. Vice President Joe Biden, for example, reportedly received $2,200 per month when the agency rented a cottage he owned near his home in Delaware.

But Trump Tower, a hybrid residential and commercial building in the middle of Manhattan, is a unique case. Within days of the election, pedestrians and tourists were chafing at the increased security around the building, which Trump used as the headquarters for his transition team and where his wife Melania and youngest son Barron stayed for the first few months of his presidency. Though Trump himself has not yet stayed in the building since taking office, the Secret Service has, at a potentially unprecedented cost: The New York Post estimated in November 2016 that renting out two of the building’s floors, as the Secret Service intended to do, could cost as much as $3 million per year, meaning Trump could be profiting substantially off of the security detail. Meanwhile, according to Politico, just five days after the election, a prominent New York real-estate firm presented the heightened security as a selling point for a $2.1 million condominium in the building, illustrating yet another way the president could stand to profit from the security presence.

According to The Washington Post, the arrangement has also created tension between the Secret Service and the president’s company. In July, amid a dispute over the conditions of the lease, the Secret Service moved out of the building and into an adjacent trailer. Whether the Trump Organization and the Secret Service remain in negotiations over the lease is currently unclear.

The situation demonstrates how the president’s decision to retain his business interests conflicts with his duties as president. National-security experts have noted that even if Trump is not physically present, Trump-branded properties around the world are in increased danger precisely because of their association with the president. The Trump Organization and the Secret Service’s inability to work out a deal for Trump’s detail to stay in Trump Tower potentially puts not only the president but also the residents, employees, and customers of the business in increased danger. And if, as two anonymous sources said, price was one of the sticking points in the negotiation, that would mean the president’s business interest—that is, making as much money from renting out his properties as possible—has come into direct conflict with national security.

Another way Trump could profit from his protective detail is by having family members travel in his two planes and three helicopters. Over the course of the campaign, the Secret Service, which traditionally pays for its own travel during elections, spent $2.74 million to fly on a plane owned by one of Trump’s own companies. While in office, Trump flies on Air Force One, while Mike Pence rides Air Force Two. However, their families might still be flying on Trump’s private planes, along with their protective details, which would effectively direct even more money to Trump. (Previous first families have flown with a detail, whose legal purview covers “the immediate family members,” but none have done so on planes they themselves own.)

This system creates a set of conflicting interests for Trump regarding his own travel and residences. Though presidents as different as Dwight Eisenhower and Barack Obama have evoked partisan ire over time spent away from the White House, whether on golf courses or on vacation in Hawaii, only Donald Trump will actually have made money from his and his family’s travels. And if, while in office, Trump visits properties he owns other than Trump Tower—his buildings in other U.S. cities like Chicago and Miami, for example, or his golf course and resort in Scotland, or one of the many international hotels bearing his name—he stands to gain from the stays for which his security detail (and, by extension, taxpayers) may be paying. Moreover, the more his family members fly on his planes, whether they are running his business on his behalf or running interference with foreign leaders, the more the Secret Service will end up paying for seats alongside them.

During the election, the Trump campaign put no small portion of its funds toward paying for use of the candidate’s own properties; perhaps the most notable of these expenditures was the nearly $170,000 the campaign spent in July 2016 on rent for its headquarters in Trump Tower. These expenses raised the possibility that, as Trump predicted in 2000, he “could be the first presidential candidate to run and make money on it.”

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That Golf Course in Aberdeen

In January, The Guardian reported that President Donald Trump’s company, the Trump Organization, is looking to move forward with a multimillion dollar plan to expand its Aberdeen resort, including a new 450-room, five-star hotel and a second 18-hole golf course. Six months later, the project is creating an additional conflict of interest for the president as it puts his company at odds with Scottish regulators, who are concerned about the expansion’s impact on the surrounding environment.

When it was announced in January, the expansion drew criticism almost immediately, especially coming as it did only three days after the press conference at which Trump unveiled his half-hearted plan to resolve his conflicts of interest. At the conference, the president and one of his lawyers, Sheri Dillon, announced that the Trump Organization would cease pursuing new foreign investments. Additionally, though neither Trump nor Dillon articulated the promise at the event, a press release detailing the steps Trump would be taking also states that he has “directed the Trump Organization to terminate all pending deals—over 30 in number.”

A representative soon clarified the grounds on which the Trump Organization deemed the Aberdeen expansion permissible in light of these vows. She argued that “implementing future phasing of existing properties does not constitute a new transaction, so we intend to proceed.” In other words, plans for the expansion had been drawn up and agreed upon before Trump made his pledge; simply moving forward with the project does not, in their view, breach their commitments to avoid pursuing new foreign investments or moving forward on pending deals.

As with so many of the defenses of Trump’s behavior when it comes to conflicts of interest, the Trump Organization representative’s justification overlooks the actual concerns regarding conflicts of interest: that Trump’s relationship with the British government and other foreign-policy questions may be colored by his expectations of what a policy will do to his property values, for instance, or whether wealthy guests will pay for a stay in the interest of currying favor with him. Instead, the argument seems to hinge on revising the pledge to create a more vague, and therefore more permissive, stance. As Richard Painter, who served as the chief ethics adviser for President George W. Bush, put it, the policy “clearly illustrates that around the world, he will just simply expand around the various holdings and as they continue to expand, the conflicts of interest expand.”

The expansion plans also demonstrate how the Trump Organization’s properties create the potential for the president’s business to come into conflict with foreign governments. As of July 28, the Scottish Environmental Protection Agency has put the development of the Aberdeen property on hold due to concerns over how the golf course will handle groundwater conservation and sewage pollution. Scottish National Heritage, the government’s conservation agency,  has also warned the Aberdeen council, the planning authority with jurisdiction over the resort, that the Trump Organization’s proposal doesn’t provide sufficient protection for the region’s dunes.

Though the Scottish government’s concerns appear to be genuine and unrelated to the property’s owner, its action exacerbates yet another situation in which Trump’s business interests could influence his relationship with a foreign government while he is president. Though he is not involved in the Trump Organization’s day-to-day operations, he still owns, profits from, and, according to his son Eric, receives periodic updates about the company. The knowledge that the Scottish government is holding up one of his investments could impact his dealings with the country (especially considering that, according to his disclosure documents, Trump has been losing money on the properties for years). With Scotland considering a second referendum on independence from the United Kingdom in the near future, the relationship between Scotland and the United States could become significantly more complicated, making it even more important that the U.S. be able to approach diplomacy without unnecessary distractions from the president’s business.

Moreover, the Scottish regulators’ decision suggests a template for how a less scrupulous government could attempt to use the president’s business interests to influence his behavior. Large real-estate ventures like golf courses, hotels, and office buildings are subject to all kinds of regulations, ranging from environmental considerations to zoning laws to workplace-safety standards. Officials in countries where the Trump Organization operates, or has plans to operate in the near future, could easily use such rules to attempt to strike political deals, explicitly or implicitly, with the president in exchange for allowing his businesses to continue to profit. Though this may not become a problem with Scotland specifically—the United Kingdom typically scores well with international ethics-watchdog groups like Transparency International—the president also owns or has his name on properties in countries with longer track records of corruption; in some, such as Azerbaijan and Indonesia, the specific partners with which the Trump Organization has worked have questionable track records. If such a group tried to use one of Trump’s moneymaking endeavors as a bargaining chip, the president’s business interests would come into conflict with his political responsibilities.

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Those Pension Funds

Though much of the focus on President Donald Trump’s conflicts of interest has gone to whether his hotels around the world violate the Constitution’s foreign emoluments clause, there is an additional clause that the president’s ownership of the Trump Organization may violate: the domestic emoluments clause, which holds that the president “shall not receive ... any other Emolument from the United States, or any of them,” aside from his official salary. Though Trump has renounced that official salary, there appear to be ways he could make money from sources through his business empire; for example, multiple federal agencies are renting space in Trump Tower in New York and other properties in order to keep the president and his family safe when they travel.

Now, two advocacy organizations, Free Speech for People and the Courage Campaign, are trying to bring attention to another potential violation of the domestic emoluments clause. The two groups are circulating petitions about public pension funds in several states, including California, New York, and Texas, that invest in CIM Fund III, a real-estate company that owns the Trump SoHo Hotel and Condominium in New York City. Though the details of most of the Trump Organization’s licensing agreements are private, the licensing deal for Trump SoHo, according to The New York Times, gives the Trump Organization equity in the property, meaning that the president’s company profits based on how well Trump SoHo performs. That means that the pension funds, which are drawn from mandatory deductions from the paychecks of more than 5 million public-sector employees across seven states, are therefore indirectly paying the Trump Organization to operate Trump SoHo.

These pension funds create a conflict of interest that corrupts the relationship between state and federal governments. Jed Shugerman, a law professor at Fordham University, says the domestic emoluments clause was written to avoid such a scenario:

The reason why the framers put the domestic emoluments clause in the Constitution is because they were concerned about the relationships of states vs. other states. Could big states, could rich states, wield more influence over the federal governments? One way that they worried rich states could wield more influence is by paying presidents directly. To avoid even the appearance of improper influence, they created a blanket rule: no emoluments from states.

So, the pension funds create exactly the possibility the framers feared. According to Reuters, California alone paid CIM $1,722,418 over the first three months of 2017, an unknown portion of which ended up in the pocket of the Trump Organization and, by extension, the president. Whether the states intend it or not, and whether Trump recognizes it or not, that financial relationship and the feelings of good will and reciprocity it may create could very well lead the president to favor one state or a collection of states over others—or to lash out if one of the states’ funds were to divest from a company linked to his business.

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Those Republican Fundraisers

By now, the myriad ways President Donald Trump may have profited from his presidential campaign, and could further profit from a 2020 reelection bid, are well-established. Holding rallies, fundraisers, and other election-related events at his hotels generated both publicity and paying guests, flying around the country meant that the Secret Service paid the president’s company for seats on his private plane every time he traveled, and housing his campaign headquarters in Trump Tower—and nearly quintupling the rent after becoming the Republican Party’s official nominee—guaranteed that some portion of his campaign expenditures would go back into his own pocket.

Now that he’s taken office, Trump is profiting from other Republicans’ campaigns too. According to Buzzfeed, Republican Party financial-disclosure documents show at least $293,000 spent at Trump properties during the first half of 2017. While the majority of that sum came from Trump’s already-underway reelection bid, roughly $72,000 came from the Republican National Committee, the National Republican Congressional Committee, and fundraising groups affiliated with other elected GOP officials, including Republican congressmen. The overall spending represents a significant increase over the first half of 2016, during which the party and its affiliated committees spent roughly $100,000 at Trump-branded properties, almost all of which was related to Trump’s presidential bid.

The gap between last year and this one on individual expenditures is even more striking: According to Buzzfeed, only one member of Congress spent money at a Trump property in 2016, putting down $200 for food and drinks. In the first half of 2017, on the other hand, the fundraising committees for Congressmen Tom MacArthur, Dana Rohrabacher, and Bill Shuster spent $15,000, $11,000, and $7,000, respectively, for events held at golf clubs and hotels owned by the president and operated by his company. The Republican Governors Association (RGA), meanwhile, spent more than $400,000 to hold a two-day policy summit at the Trump National Doral Miami golf club in May of this year; in 2016, the RGA’s largest expense for an event venue was roughly $285,000 at the Ritz Carlton in Half Moon Bay, California.

The fact that Trump is making money from other politicians’ campaigns threatens to undermine the relationship between the president and the legislative branch. While factors other than policy and legislative acumen often color interactions between members of different branches—they probably wouldn’t play as much golf together if interpersonal relationships didn’t matter—there has never before been a situation in which legislators were openly paying the president. The added financial component creates the new possibility that a congressperson may attempt to pay the president to influence his decision on a topic the congressperson finds important—if not explicitly, then by implicitly inspiring goodwill and an obligation to reciprocate. The longer the situation persists, the more likely it becomes that such payments would affect the president’s approach to policy.

Trump’s unprecedented willingness to attack members of his own party and the willingness of pro-Trump media to pile on compound this problem. The president has responded harshly toward Republican congresspeople whom he considers insufficiently supportive of his agenda, even going so far as to meet with their primary challengers, while a pro-Trump political action committee at one point purchased, then withdrew, campaign ads against a senator who was wavering on the Senate GOP’s health-care bill. And the alt-right website Breitbart, which was formerly run by Trump’s chief strategist, Steve Bannon, and has associated itself with Trump since he began his campaign, continually ascribes political failures to congressional leaders like Speaker of the House Paul Ryan rather than to Trump.

Those tendencies, and the recognition that Trump supporters don’t necessarily go along with the Republican Party, only reinforce the notion that GOP elected officials must tread carefully to retain the president’s support. As long as patronizing Trump’s businesses remains a plausible means of currying favor with the commander-in-chief, there will remain the unprecedented incentive for Republican Party officials to turn their relationship with the president into a financial one in the hope of gaining his support.

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That Estate in Palm Beach

To many of President Donald Trump’s critics, his decision to turn Mar-a-Lago, his Florida estate, into a “Southern White House” epitomizes the way he’s mixing his business interests with his duties as president. With each visit to the property, he boosts the resort’s visibility and may very well prompt more people to enroll as members in attempts to get a glimpse of the commander-in-chief. That the club doubled its initiation fees in January, from $100,000 to $200,000, only adds to the impression that Trump—or, at least his namesake company—is banking on his presidency as a means of boosting revenues. And without a publicly available guest list and no word on what security protocols are in place, the possibility that somebody could be using a club membership to gain access to the president has led Democratic members of Congress to draft a bill specifically to mandate better disclosure of the goings-on at the venue.

On Monday, July 18, the ethics watchdog organization Citizens for Responsibility and Ethics in Washington, or CREW, won a major victory on that front when the Department of Homeland Security agreed to provide CREW with Mar-a-Lago’s guest logs, starting in early September. CREW, which counts among its leadership ethics counsellors from the administrations of both Barack Obama and George W. Bush and is currently suing the Trump administration over multiple issues related to the president’s conflicts of interest, announced that it would be publishing the lists as soon as it receives them. What exactly they will receive, however, remains unclear: The private club’s screening protocols appear to be significantly less strict than those at the White House, and Politico reported in March that the resort may not actually be keeping track of the comings and goings of its frequent guests.

The possibility that Mar-a-Lago may not even have visitor logs to provide comports with both the Trump administration and the Trump Organization’s poor records when it comes to transparency. The administration has, for instance, ceased to provide a guest list for the White House and challenged the Office of Government Ethics’s requests for information about Trump’s finances and those of the lobbyists he has brought into the government. The president’s company, meanwhile, has asserted that keeping track of foreign payments at the Trump International Hotel in Washington, D.C., which Trump and his lawyer Sheri Dillon pledged the company would do in January, would be “impractical ... and diminish the guest experience of our brand.”

Since May, Trump has largely shifted his weekend trips from Mar-a-Lago to his company’s golf club in Bedminster, New Jersey. However, two stories from the months he spent frequenting his resort in Palm Beach, sometimes with high-profile diplomatic guests in tow, demonstrate the importance of making visitor logs public. In February, when Trump brought Japanese Prime Minister Shinzo Abe to Florida, the trip made news in part because it resulted in an apparent breach of security protocol: When their dinner was interrupted by news of a North Korean nuclear-missile test, the two heads of state read over briefing materials by the light of cellphones, in full view of paying dinner guests, at least one of whom took pictures.

Besides the guest who posted his pictures on Facebook, it remains unknown who was in attendance that night and may have had access to the two leaders and their meeting. Indeed, posts to social media have served as the public’s best window into the president’s interactions with the public during his weekends at his property. Pictures and videos taken by paying guests showing the president golfing, hobnobbing with attendees at meals, and crashing parties have proven vital to attempts to keep track of Trump’s comings and goings. That footage reinforces the suggestion that paying to attend a Trump property offers a good chance to meet the president, in turn suggesting that doing so could create an opportunity to speak with him and influence his decisions.

Then, in April, as Trump prepared to return to Palm Beach with Chinese President Xi Jinping, The New York Times reported on a frequent Mar-a-Lago guest who could have created friction between Trump and Xi: the billionaire real-estate mogul Guo Wengui, an outspoken critic who has accused China’s ruling Communist Party of rampant corruption. Guo himself is no stranger to charges of corruption: He left China in 2008 amid allegations that he had exploited his ties with one of the country’s top security officials to enhance his businesses. Guo maintains that the reporter who implicated him in the scandal was the tool of a government plot to undermine him, and has in turn pointed the finger at multiple party officials he says have engaged in various forms of graft, although he’s pointedly stopped short of criticizing Xi. He also claims that the Chinese government has seized more than $17 billion of his assets since he left the country.

And, the Times says, Guo is a frequent attendee at Mar-a-Lago. In March, he tweeted a picture of himself with the resort’s managing director. It is unknown whether Guo attended Mar-a-Lago, or even was in Palm Beach, at the time of Trump’s meeting with Xi. Indeed, without a guest list, it may be hard to ever know who’s there at the same time as the president except via social-media posts. But Guo’s possible presence, and even the fact that Trump is—via the membership fees Guo is paying to his company—profiting from Guo, would have cast a shadow over the president’s meeting there with Xi. Trump’s relationship with his Chinese counterpart got off to a rocky start when, about a month after the election, Trump broke decades of protocol by calling the president of Taiwan, something no president has done since the 1970s. Given China’s harsh treatment of dissidents in the past, Trump’s holding a meeting with Xi at a club with Guo in attendance could be interpreted as another slight, intentional or not, toward the Chinese government and further undermine one of the world’s most important bilateral relationships.

The problem, then, is twofold: First, it’s that Trump directly profits from spending his weekends at Mar-a-Lago and bringing high-profile guests with him, although only he knows for certain the extent to which his visits to Florida are motivated by this. Second, by paying the president to be a member at the resort, Guo gains a chance at brushing shoulders with and possibly even influencing the president, although, again, only he knows if that’s his reason for doing so.

Guo is also far from the only Mar-a-Lago member who might have a stake in rubbing elbows with the president, nor is he the only controversial foreign oligarch with whom Trump has financial ties of some kind. As such, Guo is indicative of the larger problem with the president’s maintenance of his business interests, both in general and with regard to his estate in Palm Beach.

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That Temporary-Visa Program

On Monday, the federal government announced that it would be expanding its H-2B temporary-visa program. Citing a lack of Americans willing and qualified to do seasonal, non-agricultural jobs, the Department of Homeland Security (DHS) expanded the H-2B program to allow 15,000 additional foreign workers into the country for the summer to meet demand at such seasonal businesses as landscaping services, hotels, and amusement parks. The move roughly mirrors last year’s, when DHS allowed 13,382 workers to come in under the program, although it came later in the summer than usual because it took longer than usual for Congress to authorize the expansion.

Even though the decision came from the executive branch, it seems to be directly at odds with President Donald Trump’s well-known anti-immigrant stances. After spending the campaign arguing that immigrants were taking Americans’ jobs and calling for a wall along the border with Mexico, Trump’s anti-immigration rhetoric has continued during his time in office. Though many of his proposals have faced obstacles that may prove insurmountable, he has, for instance, restricted H-1B visas for low-skilled immigrant laborers, and under DHS Secretary John Kelly, the government has significantly stepped up enforcement actions against illegal immigrants, including those previously protected under the Deferred Action for Childhood Arrivals (DACA) program. Additionally, the expansion was announced on the first day of the White House’s “Made in America” Week, intended to promote American companies, workers, and products.

Though the allowance of more foreign workers may appear to conflict with Trump’s “America First” rhetoric, it clearly aligns with his business interests. The Trump Organization, which the president still owns, uses H-2B workers at many of its golf courses, hotels, and vineyards. According to CNN, the Trump Organization has received 1,024 H-2B visas since 2000 for workers at such properties as Mar-a-Lago and the Trump National Golf Club in Washington, D.C., along with other types of foreign visas. Mar-a-Lago in particular has benefited from temporary foreign labor: The property has requested at least 787 employment visas since 2006. The Trump Organization has continued to apply for temporary visas since Trump was elected president; for example, in December 2016, the Trump Vineyard Estates and Winery in Charlottesville, Virginia, applied for six additional H-2A visas to fit its seasonal demands, then added 23 more in February. And on July 20, only three days after the DHS announced it would be increasing the number of visas available, Mar-a-Lago and the nearby Trump National Golf Club together requested an additional 76 H-2B visas for cooks, servers, and housekeepers.

The Trump administration has justified the increase by asserting that many of the companies that will benefit “are at risk of suffering irreparable harm if they don’t get additional H-2B workers.” However, the Trump Organization’s own record seems to contradict this statement: Mar-a-Lago has requested hundreds of foreign visas, including 70 in 2015 alone, while reportedly rejecting 283 of 300 domestic applicants since 2010. This arguably affirms one of the major criticisms of the program, which holds that companies don’t always sufficiently attempt to fill open positions using domestic labor before applying for temporary foreign visas.

The Trump administration’s decision to expand the H-2B program is yet another example of a fairly conventional government action complicated by the president’s continued ownership of his real-estate empire. The debate about the role of immigrants in the U.S. economy means that the decision would likely have been controversial regardless of who was in office. However, that the president himself will likely financially benefit from the program means that it also raises the question of whether Trump and his administration are looking out for the needs of the country or the needs of the Trump Organization.

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Those State Department Expenses

As the first (and, so far, only) Trump-branded property to open since the election, the Trump International Hotel and Tower in Vancouver has prompted significant scrutiny. When it opened just five days after President Donald Trump’s inauguration, ethics experts questioned whether the property presented an opportunity for anyone to attempt to influence the president by booking a stay there—a suspicion that seemed to be confirmed when a pro-business lobbying group relocated a meeting from a diplomat’s house to the new hotel the day after it opened.

As with all of Trump’s foreign properties, the property arguably violates the Constitution’s foreign emoluments clause, which says that federal officials can’t receive “any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.” But the first known government expenditure at the Vancouver hotel came not from a foreign entity—it came from the State Department. According to documents obtained by The Washington Post, the State Department spent more than $15,000 to book 19 rooms at the new hotel when the president’s adult sons, Donald Jr. and Eric, and his younger daughter, Tiffany, visited the property for its grand opening in February.

While the Trump Organization both owns and operates some of its flagship properties in the United States, such as Trump Tower in New York, the hotel in Vancouver is one of many licensing deals through which third-party companies pay to operate their hotels under the Trump brand. Though the president’s name appears in large gold letters on the building’s facade, the property is actually owned and managed by a Canadian company called The Holborn Group, which is in turn owned by the Malaysian billionaire Joo Kim Tiah. And, because the Trump Organization is a privately held company, the actual structure of the deal remains unknown: Though Trump declared more than $5 million in revenue from the property on his most recent financial-disclosure forms, it’s unclear whether that sum represents a flat fee or a percent of the hotel’s revenue. However, Slate noted that previous court filings show that some similar Trump properties operate on the latter model, suggesting that what Trump earns from the hotel hinges on its success.

If that is indeed the case, the State Department’s expenditures represent a conflict of interest for him. As I wrote in February, when the Secret Service spent more than $97,000 to accompany Eric Trump on a business trip to Uruguay, it’s first and foremost improper that the Trump Organization appears to be directly profiting from taxpayer money because of the increased security necessary when its leaders visit their holdings.

Moreover, the State Department’s expenditure arguably violates the Constitution’s domestic emoluments clause, which states that the president “shall not receive ... any other Emolument from the United States, or any of them” during his time in office aside from his official salary. Already, the Trump Organization is receiving taxpayer money from multiple federal agencies, including the Secret Service, which not only effectively subsidized Eric Trump’s business trip to Uruguay but also pays to accompany the president’s family on their private airplanes, and the Department of Defense, which CNN revealed in February would be renting space in Trump Tower. These expenditures raise the possibility that groups within the U.S. government as well as those outside of it may influence the president, intentionally or not, by patronizing his businesses. Because even small payments can change a person’s behavior, these payments may warm the president to one department over others, potentially shading his assessments of the advice and intelligence he receives from them.

Even if the Trump Organization doesn’t profit directly from the hotel’s success—that is, if the company makes a flat annual fee instead of a percentage of the property’s revenue—the State Department’s expenditure demonstrates the problems Trump’s continued intermingling of business and government continues to create. As of now, because Trump has disclosed only the minimum financial details he is required to by law, it's impossible to determine how exactly he makes money from properties like the hotel in Vancouver. That in turn makes it impossible to determine the precise nature of his conflict of interest—an epistemological problem that has arisen with several other business endeavors of his.

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That Clean-Water Rule

In February, President Donald Trump signed an executive order directing the Environmental Protection Agency to review the Obama administration’s Waters of the United States, or WOTUS, rule. The regulation, which was created in 2015 but was put on hold by a court later that year, aims to expand the federal government’s ability to apply anti-pollution statutes to a variety of bodies of water. This week, the Environmental Protection Agency announced that it would be acting on the president’s order and rolling back the regulation.

When he first called upon the EPA to review WOTUS, Trump cited its economic cost, calling it “a disaster” and “a massive power grab” that was “putting people out of jobs by the hundreds of thousands” (a claim The Washington Post gave its lowest fact-checking rating). And while pro-business groups such as the U.S. Chamber of Commerce lauded the EPA’s decision, environmental groups criticized the move, arguing that WOTUS represented a significant step forward in protecting the drinking water of more than one-third of Americans.

The decision also appears to represent a conflict of interest for the president. Along with increasing federal oversight of large bodies of water, WOTUS would have expanded the EPA’s authority to include regulation of smaller streams and ponds. As such, some of the business benefits of rolling back the rule will redound to the golf industry, which has been a major opponent of the regulation since before it was signed in the summer of 2015. The Golf Course Superintendents Association of America, a 17,000-member lobby, spent $30,000 to fight WOTUS in the quarter it was finalized, arguing that the rule would make it excessively costly to maintain golf courses without running afoul of new regulations on water use and polluted runoff. According to the association’s chief executive officer, Rhett Evans, under an earlier, somewhat more expansive, version of the rule, golf courses “would find themselves economically burdened, if not unable to operate profitably.”

Trump, of course, owns 12 golf courses in the United States, all of which would likely be impacted by WOTUS, meaning that he has a significant financial stake in ensuring that it does not ultimately go into effect. And though the decision to fully scrap the regulation was technically made by the EPA and its chairman Scott Pruitt, it was ultimately Trump who called for its review in his February Executive Order—not to mention that he was the one who appointed the notoriously anti-regulation Pruitt in the first place.

The executive branch’s decision to scale back enforcement of WOTUS specifically and clean-water regulation in general is also an example of how Trump’s broader anti-regulatory agenda often overlaps with his personal financial interests. Through his first few months in office, Trump’s domestic agenda has involved chipping away at the regulations his predecessor put in place, following a self-imposed rule that federal agencies must cut two regulations for each they implement. This will likely frequently result in policy decisions that will at least tangentially benefit Trump; for example, many of the tax cuts that Trump seems to favor, such as repealing the estate tax, would reduce his own tax burden as well as those of others in his income bracket. The result is that it’s often difficult to separate Trump’s conflicts of interest from what very well may be a genuine pro-business, anti-regulatory agenda.

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That Development Outside of New Delhi

President Donald Trump’s international real-estate empire continues to grow. According to The Washington Post, two new Trump-branded buildings—one residential development and one office tower—will soon be going up in Gurgaon, a suburb of New Delhi, India, “known for rapacious development and poor planning.”

As with many of the company’s other international projects, the deals create new conflicts of interest as they bring the Trump Organization into contact with more investors, partners, and governments that may seek to influence the president’s decisions. The nature of the real-estate business means that the company and its international partners will have all sorts of interactions with local and national governments, ranging from acquiring permits for construction to health and safety inspections once a project is complete. That creates opportunities to attempt to curry favor withTrump, whether intentionally or not, by creating favorable conditions in which he can do business.

To complicate matters, these deals in India find Trump in partnerships with less-than-savory companies. The companies involved, IREO and M3M India, have both been frequent targets of anti-corruption actions by the Indian government, which is currently investigating the former for illegal land purchases and money laundering and the latter for bribing officials to speed along construction. And Gurgaon is widely seen as a hotbed of corruption, where poor citizens and small landowners are often pushed out by developers through bribery or bullying.

As has been the case with some of the Trump Organization’s other international projects—the tower in Baku, Azerbaijan, that The New Yorker deemed “Donald Trump’s Worst Deal” springs to mind, along with his ongoing developments in Indonesia—the company’s involvement with potentially corrupt officials and companies could create problems going forward. For instance, if someone found demonstrably illegal labor practices at the sites in Gurgaon, he or she could use that information to blackmail the president’s company and its owner (that is, the president himself) into pushing for a particular policy. And to reverse that example, Indian officials seeking a favorable outcome on an issue of international concern from the American government could, explicitly or implicitly, turn a blind eye to any ethical concerns in Gurgaon in return for the president’s good graces, which could end up creating unsafe conditions that hurt the laborers working on the building. Meanwhile, the developments’ investors—currently unknown for the deal with IREO, according to The Washington Post, as the money flowed through banks in Mauritius and Cyprus—have substantial leverage over the president that they could wield by cutting off the flow of funds to the projects.

On top of the concerns regarding the specific details of the projects, the developments in Gurgaon demonstrate how little the Trump Organization’s pledge not to pursue any new foreign deals, which the president announced shortly before taking office, actually means in practice. Technically speaking, the projects in Gurgaon aren’t new deals, as the Trump Organization agreed to the partnerships before Trump became president. However, at a press conference held in January, Trump and one of his lawyers, Sheri Dillon, announced not only that “no new foreign deals will be made whatsoever” but also that the Trump Organization had already terminated “all pending deals.” That these projects in India are moving forward regardless seems to demonstrate that the Trump Organization’s definition of “new foreign deals” is so narrow that the guidelines will do little to prevent the company from continuing to expand while Trump is in office, thus creating new conflicts of interest.

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That Golf Course in Westchester

According to a report by ABC News, the Trump Organization is looking for a tax break for the Trump National Golf Club Westchester in Briarcliff Manor, New York. The company is attempting to halve its tax bill on the golf course by arguing that the tax assessor’s $15 million valuation of the property is twice what the course is actually worth. If the appeal succeeds, the Trump Organization could see the property taxes it owes on the 143-acre club reduced by as much as a quarter of a million dollars.

Contesting a tax assessor’s valuation of a property in the hopes of getting a tax break is a fairly common move for large property owners generally and the Trump Organization specifically. In 2016, after the town’s tax assessor valued the property at $15 million, the Trump Organization tried to assert that the course was only worth $1.35 million, but ultimately relented and paid the bill.

The difference this year is, of course, that the property’s owner is now president, which means that suddenly, Briarcliff Manor is one of many local governments that must weigh the consequences of how they deal with Trump’s businesses. It must decide if giving the Trump Organization a sweet deal is worth the loss in tax revenues, whether because doing so will create a positive affinity that could spill over into preferential treatment from the federal government or because not doing so would mean crossing the famously temperamental president and potentially facing consequences down the line.

The situation demonstrates how the president’s decision to hold onto his business while in office could have ramifications for everyday Americans. While Briarcliff Manor isn’t exactly struggling—according to the latest figures from the U.S. Census Bureau, median household income for the town’s 6,300 adult residents is roughly $141,000, and the poverty rate of 4.3 percent is 10 points lower than the national level—the local government nevertheless relies in part on property taxes for funding. If the town does give the Trump National Golf Club the tax break it has requested, that would mean less money for the town’s schools, police department, and other civic services.

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Those Russian Trademarks

One of the questions underlying the ongoing investigation into the Trump campaign’s interactions with Russian officials is whether the president himself is in debt to the country’s government or state-run banks. Though Trump has insisted recently that he does not do business in Russia, that assertion conflicts with 20 years of his (and his sons’) statements to the contrary.

This weekend, The New York Times reported on details that underline his past dealings in the country: On the night of the 2016 presidential election, the Russian government granted extensions to six expiring trademarks that Trump had received between 1996 and 2007. The trademarks cover branding for a variety of products, including one for Trump Vodka, which debuted in 2007 and folded shortly thereafter, and one for the name “Trump Tower,” for a real-estate deal that the president began exploring in 1996 but that ultimately fell through.

By all appearances, the renewals in November were fairly routine and don’t indicate that the Trump Organization has any actual plans for pursuing business opportunities in Russia in the near future. As was the case with the trademarks the company received in China in February, it’s likely that registering the Trump name is more defensive than anything else, a means of securing the name to ward off potential knockoffs or patent trolls, who in some cases register well-known brand names so that, should a corporation try to expand overseas, they will have to pay to wrest the trademark back.

Even if the renewals were a mere formality, they point to the ongoing complications the president’s decision to retain his business while in office creates. Trademarks certainly aren’t direct financial compensation, but they have distinct monetary value as a means of protecting a company’s business interests, especially for a corporation like the Trump Organization, which relies so heavily on its brand appeal that the Trump name is arguably among the family’s most valuable assets. That leaves open the possibility that the president may be inclined to think more highly of a country because it has recently helped his company by approving a trademark request—which in turn opens the possibility that a foreign government seeking to influence the president might seek to curry favor with him by expediting the process or granting trademarks they wouldn’t for a less important person.

Other trademarks that Trump has received in foreign countries since taking office are not only ethically questionable but arguably violate the Constitution. Though part of the ethics arrangement the president and his lawyer laid out before the inauguration was that the Trump Organization would cease pursuing new deals in foreign countries during Trump’s presidency, the company has continued to register trademarks around the world. China granted him not only the trademark on his name in February but also 38 others in March, on everything from hotels to insurance to escort services, followed by six more last week; his eldest daughter Ivanka, who serves as an adviser within the administration, has also received trademarks there since her father took office. Mexico, too, approved Trump trademarks in March. These developments, which all came about after Trump took office, arguably violate the Constitution’s foreign emoluments clause, which bars federal officials from “accept[ing] of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.”

Moreover, as has frequently been the case with the Trump Organization’s dealings in recent months, the timing of the renewals The New York Times reported on raises additional questions about whether Russia may have been trying to influence the president. Since November 8, the Trump Organization has seen unexpected progress on projects in multiple countries, including not only China but also Argentina and Georgia, where long-stalled developments both began moving forward in November. Though it remains unclear whether any of these actions were specifically meant to influence Trump, the cumulative effect suggests that international offshoots of the Trump brand are benefiting from the Trump presidency.

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That Trump Organization Event Planner

Much has been written about how few high-level government positions President Donald Trump has filled compared to his predecessors; still more has been written about the unusual qualifications of those he has appointed. This week, the president named another appointee whose background doesn’t really comport with her new position: Lynne Patton, who will head the U.S. Department of Housing and Urban Development’s Region II, which comprises New York and New Jersey.

Like Secretary of Housing and Urban Development Ben Carson, to whom she will soon report, Patton has little-to-no directly relevant background in urban planning or housing. According to the New York Daily News, which first reported Patton’s nomination on Thursday, though, Patton has plenty of experience with the Trumps. Patton’s LinkedIn account indicates that since 2009, she has planned and run events for the Trump Organization, including “various marketing projects, philanthropic events & golf tournaments.” From 2011 until January of this year, she was also the vice president of the now-defunct Eric Trump Foundation, which is currently under investigation by the attorney general of New York after a report in Forbes alleged that the family had used the foundation to siphon more than $1.2 billion in charitable donations to the Trump Organization.

Patton’s appointment once again demonstrates how Trump continues to mix his presidency with his business interests. In her new office, Patton will oversee the disbursement of billions of dollars in federal housing funds to the states in which the president’s company owns the most property. Though the Trump brand and federal housing would seem to occupy significantly different sectors, there’s actually significant overlap between the two. As was documented by The American Prospect in April, the Trump Organization has repeatedly benefited from federal funding; for example, Trump owns part of a low-income housing development in Brooklyn that has received numerous grants from HUD (and that the president once called “one of the best investments I ever made”). Trump even came into conflict with the agency over the property in 2007 when he attempted to sell his stake, only to have the transaction blocked. That he has chosen a loyal business associate to administer a position that will have oversight over his own company seems to indicate how, rather than putting the best interests of the American people above all else, the president can make decisions that stack the regulatory deck in his own favor.

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That Saudi Arabian Lobbying Effort

Less than five months into President Donald Trump’s administration, Saudi Arabia has created a template for foreign governments looking to influence the president through his businesses. On Monday, The Daily Caller reported that the country’s government spent nearly $270,000 on lodgings and catering at the Trump International Hotel in Washington, D.C., between November 2016 and February 2017. The expenditures were part of a lobbying campaign in which the Saudi government paid for U.S. veterans to travel to D.C. to advocate against the Justice Against Sponsors of Terrorism Act. The law, which passed in September despite a veto from President Barack Obama, allows American citizens to sue foreign governments that allegedly sponsor terrorist attacks and organizations.

The payment clearly demonstrates the problems with the arrangements Trump has made to prevent ethics violations, which he and his lawyer Sheri Dillon described in January before he took office. Among other steps meant to resolve the president’s conflicts of interest, one measure was specifically designed to address concerns that foreign governments might attempt to influence Trump by paying to stay at his hotel in Washington, D.C. To head off such a possibility, Dillon said in January, the Trump Organization would “voluntarily donate all profits from foreign government payments to his hotels to the United States Treasury.”

In the four months since the inauguration, the Trump Organization itself has demonstrated the insufficiency of this pledge on multiple occasions. First, in March, the company admitted that it hadn’t yet made the payments it had promised, and said it would not be doing so until the end of the calendar year. Then, in May, the organization sent Congress a pamphlet outlining the relatively meager steps it would take to uphold its commitment, stating that it wouldn’t actively attempt to identify foreign agents staying at the hotel because doing so would be “impractical.” Instead, the document suggested, the company would be relying on the foreign governments to identify themselves. After The Daily Caller’s report, the Trump Organization announced that it would indeed be transferring profits from the Saudi payments to the Treasury at the end of the calendar year.

However, it’s unclear whether, under the Trump Organization’s guidelines, they would have done so if not for the attention the story received from the media. The Saudi government didn’t technically pay for the hotel rooms; instead, they paid the American lobbying firm Qorvis MSLGroup, which hired a subcontractor. Qorvis was then required to disclose the source of the funds to the Justice Department under the Foreign Agents Registration Act, and a Daily Caller reporter then reported the story based on those disclosures. Given that the Trump Organization has effectively abdicated the responsibility of tracking payments that aren’t “direct billings from the Property to a foreign government,” it’s entirely possible that the company would not have done the due diligence required to follow the money; as it is, the story didn’t emerge for several months. Moreover, the Trump Organization still hasn’t answered the question of how it will determine what portion of the revenues constitute profits that it will pass along to the treasury.

Theoretically, the Trump Organization may have legitimately not been aware that the money Qorvis spent at the hotel came from the Saudi government, in which case Trump himself also wouldn’t have known about it, either. However, Saudi Arabia has hired Qorvis to carry out PR campaigns twice in the past, once shortly after 9/11 and once after the country invaded Yemen in 2015; both efforts were highly controversial, with the former resulting in a probe by the Justice Department in 2004. Besides, given that the Saudi government would likely have been spending that money on the campaign regardless, the mere possibility that the president would know where the payments came from and think more favorably of the country may very well have been enough of an incentive to make bookings at Trump’s hotel over its competition. Finally, even without the Saudi connection, the situation still constitutes an organization effectively paying the president while lobbying on a controversial issue.

It’s hardly hyperbolic to say that Saudi Arabia’s payment at the Trump International Hotel is exactly what ethics experts worried about when they first raised concerns about the president’s decision to retain ownership of his businesses while in office. As part of an active campaign to lobby the U.S. government, the Saudi government was effectively paying the president, who very well could end up significantly influencing how the policy plays out. In doing so, they demonstrated the inadequacy of Trump’s plan to avoid conflicts of interest: If the disclosure paperwork hadn’t surfaced, all it would have taken to skirt the rules Trump and his company set up was to funnel money through a lobbying firm.

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That Golf Course in New Jersey

During his first few months in office, President Donald Trump spent many of his weekends at Mar-a-Lago, which some have called his “Winter White House,” in Palm Beach, Florida. His trips there were subject to criticism on the grounds of both symbolism and substance. Symbolically, his visits both conflicted with his campaign promise to rarely leave Washington, D.C., and undermined his frequent criticisms of his predecessor for traveling while in office. Substantively, Trump’s trips to Mar-a-Lago make manifest one of the major problems with his decision to retain ownership of his businesses while in office: Anybody seeking to influence Trump could theoretically pay for a membership, putting money in his pocket while potentially gaining direct access to him. In this way, the president’s mere presence serves as an advertisement for the resort.

Many of the same concerns apply to Trump’s “Summer White House,” his golf club in Bedminster, New Jersey. It’s historically been his summer getaway, and, given his penchant for visiting his own properties, it’s expected he will be spending more time there in coming months.

But whereas the problems with Mar-a-Lago have mainly been implicit—neither Trump nor his company, the Trump Organization, has acknowledged any link between the election and, say, the decision to double the club’s initiation fees in January—the intermingling of the presidency and the Trump Organization is on more explicit display in Bedminster. While there’s plenty of evidence (especially on social media) that visiting Mar-a-Lago could lead to an encounter with the president, Bedminster appears to have been actively advertising the possibility. According to Laura Holson of The New York Times, who toured the property with Trump’s son Eric,

Mr. Trump is a selling point for prospective brides and grooms considering holding their weddings at the club. When I was there, I was given a marketing brochure that made the following pledge: “If he is on-site for your big day, he will likely stop in & congratulate the happy couple. He may take some photos with you but we ask you and your guests to be respectful of his time & privacy.”

In a remarkable piece of advertising synergy, Trump made good on the promise in the brochure the weekend after Holson published her article. Between June 9 and June 11, Trump’s second weekend visiting the property since taking office, numerous photos posted on Instagram show the president posing for pictures with his paying guests at the resort, including not only a bride and groom but also a group of eighth-graders at their middle-school graduation party.

Though Holson notes that “a spokeswoman for the club said that the specific brochure has been discontinued,” the fact that it was present after Trump took office in the first place demonstrates the conflict of interest the resort creates. Trump himself has even acknowledged that his presence is a draw for the property: In November, shortly after the election, Trump told paying guests that he would be interviewing prospective members of his cabinet at the golf club and that members might be able to “come along” to the meetings.

Bedminster offers a prime opportunity for anybody with deep enough pockets—the initiation fee reportedly runs $350,000—to attempt to buy his or her way into a meeting with the president, a fact that marketers at the Trump Organization appear to have recognized. And scientific studies show that even minuscule financial transactions can be enough to significantly influence the recipient, meaning that, if and when such a meeting happens, the fact that such visitors are paying Trump to be there will almost certainly hang over the encounter—and make him more inclined to do something in return.

The situation demonstrates how Trump’s continual choice to shirk longstanding ethical procedures threatens to compromise his decisionmaking as president. As Trump himself has noted, the president is technically exempt from federal conflict-of-interest laws (although not, as has been frequently noted, the Constitution’s emoluments clause). But by retaining ownership of his businesses, Trump creates the exact situation those laws were designed to prevent: On issues both large and small, it’s an open question whether Trump is prioritizing the well-being of the country or whether he’s allowing his financial interests to dictate his behavior.

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That Meeting in Brussels

On the European leg of his first foreign trip, President Donald Trump elucidated the relationship between his business and his presidency, although in a way that only further complicates the already-difficult task of understanding how his financial interests might impact his decisions in office. According to the Belgian newspaper Le Soir, in a meeting with Belgian Prime Minister Charles Michel, Trump discussed his skepticism toward the European Union through the lens of his experiences as a real-estate mogul. Per a translation in The Guardian, an anonymous source told the paper, “Every time we talk about a country, [Trump] remembered the things he had done. Scotland? He said he opened a club. Ireland? He said it took him two and a half years to get a license and that did not give him a very good image of the European Union.”

The meeting isn’t the first time the president has discussed the Trump Organization—which he still owns, but no longer operates—with other world leaders: In a phone call with Turkish President Recep Erdogan, one of the first Trump made after his election, he relayed praise from a business partner on the company’s towers in Istanbul; on the line with Mauricio Macri, the president of Argentina, Trump mentioned a long-stalled project in Buenos Aires (which suspiciously began moving forward after the exchange).

His conversation with Michel, though, is different, for one key reason: Trump has no hotels in Belgium—and, unless his company is willing to violate a pledge meant to mitigate conflicts of interest, it won’t be pursuing deals there until Trump is out of office. That doesn’t definitively preclude the possibility that he meant to boost his businesses by venting to Michel, but it certainly reduces its likelihood.

What the conversation does do, though, is demonstrate how inextricable Trump’s businesses are from his behavior as president. It’s not just that Trump has ample knowledge of his holdings to act in his own financial interests and little reason to fear that a Republican-controlled Congress might try to stop him. It’s also that Trump seems to approach every issue with a mind toward how it’s impacted his company in the past—and how it will impact his company in the future. As the aforementioned anonymous source in Le Soir described it, “One feels that he wants a system where everything can be realized very quickly and without formality”—a broad pro-business stance that would just so happen to make it significantly easier for the Trump Organization to operate in Europe as well.

As long as the president retains ownership of his company, it’s possible to impute the Trump Organization’s footprint in a variety of the administration’s policy stances. For instance, the notion that Trump favors leaders of countries where he has property is arguably the least concerning explanation for his affinity for noted authoritarians like Erdogan and Filipino President Rodrigo Duterte. On economic issues as well, the president has supported numerous policies over the years that would mainly help wealthy businesspeople in general and the Trump Organization in particular; for example, he’s in favor of weakening the Foreign Corrupt Practices Act, which would make it significantly easier for his company to move forward on deals in countries like Azerbaijan where bribery of public officials is more common than it is in the U.S. These questions of where genuine policy positions end and self-interest begins will continue—unless, of course, Trump does what ethics experts have urged him to do and actually sells his business.

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That Tower in Toronto

President Donald Trump’s properties around the world bring with them business partners from around the world. Several of these ties have already come under scrutiny: A Trump-branded tower in Baku, Azerbaijan, put him in business with allegedly corrupt officials who are themselves connected with the Iranian Revolutionary Guard, for example, while two properties in Indonesia link him to officials implicated in a bribery scandal and a racially-motivated attempt to oust a sitting governor.

Now, The Wall Street Journal has reported an additional source of a conflict of interest along these lines: Trump International Tower and Hotel in Toronto. According to the Journal, one of Trump’s partners in the project, Alexander Shnaider, received millions of dollars from the Russian bank Vnesheconombank, or VEB, shortly before investing in the project. Shnaider, who is Russian American and was the main developer on the Trump-branded property, sold his own company’s share in a Ukrainian steelmaker to VEB for $850 million in 2010. Shnaider’s lawyer said in April that $15 million from the sale went into the Toronto tower, although he walked back his statement the next day, writing that he is “not able to confirm that any funds” from the sale went into the project.

VEB is owned by the Russian government; according to its website, its mandate is “to enhance [the] competitiveness of the Russian economy, diversify it, and stimulate investment activity,” and the bank’s supervisory board is chaired by the country’s prime minister, Dmitry Medvedev. At the time of the deal with Shnaider’s company, though, its chairman was the current Russian President Vladimir Putin, who, according to a Russian government official and multiple experts, would have had to sign off on such an exchange.

As with many of Trump’s business holdings, the property represents a conflict of interest because it brings him revenue that’s made possible by money from a bank owned and operated by a foreign government. Though Trump doesn’t own the tower—he merely licenses his name to Shnaider, who owns the building through his company Talon International Development Inc.—the Trump Organization nevertheless profits off of the building and, by extension, from VEB’s deal with Shnaider. This potentially gives the Russian government leverage that it could use should it want to influence Trump’s policies. That means that the Trump Organization’s continued involvement with the tower may represent a violation of the Constitution’s emoluments clause, which precludes elected officials from “accept[ing] of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.”

The Journal’s report highlights the inadequacy of the financial disclosures the president has so far offered. Last week, Trump insisted that his company does not have business ties to Russian “persons or entities.” As my colleague David Graham wrote, the letter from Trump’s lawyers that Trump proffered on the subject last week “doesn’t define several key terms,” leaving open the possibility that one of Trump’s projects benefited from Russian funding through a pass-through corporation or another intermediary. VEB’s role in the financing of the Trump-branded property in Toronto is a perfect example: Because money from VEB went toward enriching Trump (through Shnaider), one can reasonably argue that Trump didn’t do enough to eliminate the conflict of interest that the hotel creates for him in office.

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That Caribbean Villa

President Donald Trump has another property on the market: Le Château des Palmiers, his estate on the Caribbean island of St. Maarten. The president’s company bought the 11-bedroom beachfront compound in 2013, and the Trump Organization has been using it as a rental property ever since. It’s listed at $6,000 per night on TripAdvisor; according to specialty sites such as Luxury Retreats, which lists the price as between $6,000 and $20,000, and Mansion Global, which places the upper limit at $28,000, the price increases substantially during the winter, when the Caribbean offers an escape from cold weather. According to the disclosure forms Trump submitted to the Federal Election Commission (which remain the only public documentation of his finances), he derived between $100,001 and $1 million from the property in the year leading up to May 2016.

The asking price for Le Château des Palmiers remains unknown. The Trump Organization is selling the property through the real-estate agency and auction house Sotheby’s; according to the listing for the complex, the price is available only upon request. However, there are some clues available. On his FEC disclosure forms, Trump lists the property as worth between $5 million and $25 million, which does correspond with the $19.7 million he paid for it four years ago. According to Mansion Global, 7th Heaven, a real-estate brokerage in St. Maarten, has identified the asking price as $28 million, although 7th Heaven’s current page for the property lists the price as “PoA,” or Price on Application.

Though Trump no longer runs the Trump Organization, he still owns the company and, by extension, the property, meaning that he will profit from its sale. That means that Le Château des Palmiers offers yet another avenue by which somebody could attempt to influence the president’s decisions by putting a large sum of money in his pocket. It would even be possible for somebody to make an offer well above the currently unknown asking price to curry favor with him (and, possibly, through the artful use of a shell company, hide their identity).

As NPR noted, the Trump Organization’s decision to sell Le Château des Palmiers is “the first known major divestiture of a Trump property since he became president.” As such, it demonstrates the insufficiency of the steps the president has taken to eliminate his conflicts of interest. Trump has put the leadership of his company in the hands of his adult sons and a longtime Trump Organization executive with relatively few—and, based on Donald Jr. and Eric’s frequent presence at administration events and Eric’s statement that he will share some business-related data with his father, relatively permeable—barriers blinding him from knowledge of his financial interests.

Had Trump taken the measures suggested repeatedly by ethics experts on both sides of the political aisle, he would by now have put his assets in what’s called a blind trust, which would entail turning over his empire to a third party with whom he will have no contact, who would sell off the properties and reinvest the resulting money in other assets without providing the president any information about the sales or the purchases. Instead, Trump has set up a system under which, even if he does proceed to sell off his business, one property at a time, he will simply create new conflicts of interest as he takes payments from those who are purchasing the Trump Organization’s real estate.

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Those Condos for Sale

President Donald Trump’s finances are infamously opaque. Since he has not followed the long-standing presidential custom of releasing his tax returns to the public, the only publicly available records of where he derives his income are his two filings with the Federal Elections Commission. Even those are difficult to parse: Much of his business empire comprises limited-liability companies (or LLCs), which face very few disclosure requirements, and shell and pass-through corporations, which can obscure ownership and make money trails harder to follow.

Much the same can be said for whoever has been buying up Trump Organization condominiums. A lengthy investigation published in USA Today found that, “since launching his White House bid, Trump’s companies have sold at least 58 units nationwide”—out of a total of more than 400 currently on the market—”for about $90 million. Almost half of those sold to LLCs.” One of those LLCs, a financial firm created shortly before the Republican National Convention named Milan Investment Limited, spent $3.1 million to buy 11 condominiums in the building the president co-owns in Las Vegas.

Normally, such a story would then identify who is behind the purchase and whether they may have some ulterior motive in buying something from the president. In this case, though, repeated efforts by the USA Today to ascertain who exactly is behind Milan apparently came up empty. The company’s headquarters in a strip mall the outskirts of Las Vegas are registered to two individuals named Jun Xu and Qi Huang; however, the reporters were unable to reach Xu and Huang through either their listed addresses and phone numbers or through business associates. A third individual associated with Milan, Chen Huang, also apparently could not be reached for comment, nor did the Trump Organization respond to inquiries about the identities of the buyers. The newspaper’s attempts to find the buyers of other Trump Organization condos met with mixed results: Though reporters were able to track down the real people behind some of the purchases, including a couple who said they bought the property because they’re fans of Trump’s, others proved just as elusive as whoever is behind Milan.

As the USA Today notes, the story highlights one of the major problems underlying Trump’s decision to retain his businesses while in office. There is no law requiring a shell company like Milan to disclose the identities of its owner(s) or the source of its money while purchasing real estate. The Trump Organization still owns hundreds of condominiums, the sales of which will directly profit it and, by extension, the president; this offers plenty of chances for any individual or corporation to purchase a unit to attempt to curry favor with Trump without having to disclose their own identity to the public.

So far, the Republican-controlled Congress has shown little interest in investigating the constitutionality of Trump’s decision to hold onto his businesses. That means that the only real disincentive for those attempting to influence the president by patronizing his businesses is the bad publicity that might ensue. But Milan Investment Limited’s secretive investment in Trump’s properties shows how easy it would be for an individual or a corporation to stay anonymous and avoid that scrutiny.

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Those Reelection-Campaign Funds

For President Donald Trump, it pays to be in constant campaign mode.

Metaphorically, at least, this isn’t unusual; the idea of the “permanent campaign,” a reference to how politicians consider their reelection chances from almost the moment they take office, has been around for decades. Such is the case for Trump, who filed a letter with the Federal Election Commission establishing his eligibility to run for a second term in 2020 just hours after taking the oath of office. Though the letter declares only that he can run, not necessarily that he will run, it gives broad coverage for the president to begin fundraising and holding campaign events, and to do so far earlier in his first term than have previous presidents.

Since doing so, Trump has held several events that, while officially presented as part of his “thank-you tour,” have seemed an awful lot like his campaign rallies. Meanwhile, between merchandise sales and an already-active fundraising effort, he has raised more than $7.1 million, and the Republican National Committee has raised an additional $23 million. That’s not necessarily noteworthy by itself; by this time, President Obama and the Democratic National Committee had raised $15 million. (Obama had not yet filed for eligibility in 2012 three months into his first term, although he had held events to promote his economic-stimulus package.) What does make Trump unusual is that he has already spent $6.3 million of his reelection campaign funds—and, according to reports he recently filed with the FEC, he is paying some of that money to his own personal businesses—for instance, renting space at his hotels or golfing on his courses—thereby literally profiting off of his permanent campaign.

This practice is nothing new for Trump. As early as 2000, he was speculating that he “could be the first presidential candidate to run and make money on it” by patronizing his own businesses and running the campaign out of one of his properties. During his 2016 bid, he did exactly that, establishing his political headquarters in Trump Tower (and quintupling the rent as soon as he became the Republican nominee and began drawing funds from the party rather than his personal war chest). Shortly before his victory, The Wall Street Journal reported that Trump’s campaign had paid out the unprecedented sum of more than $14 million to his family and companies for such services as flights on his personal airplanes, rent at Trump Tower, and meals and hotel rooms at other Trump buildings.

Similarly, since taking office, Trump has profited off of the federal government’s newfound need to patronize his properties. Both the Secret Service and Department of Defense are renting out space in Trump Tower, for example, with the former believed to be paying at least $3 million per year to do so. This has led to rumblings that Trump may be violating the Constitution’s domestic emoluments clause, which holds that the president “shall not receive ... any other Emolument from the United States, or any of them,” beyond his official salary.

The amount Trump’s reelection campaign has spent at his businesses is comparatively small: According to The Wall Street Journal, more than 6 percent of the $6.3 million it’s spent so far, or almost $500,000, went to Trump’s hotels, golf courses, and restaurants. But that’s a higher rate than when his campaign money was going to his own businesses for the 2016 campaign ($14 million out of a total of $322 million, or about 4.3 percent). At his current rate, if he spends a similar amount over the next election cycle—and given that he’s already started spending, he could easily far outdo himself—he would be directing nearly $20 million to his own businesses.

On top of the arguable impropriety of personally profiting off of his donors’ and his party’s largesse, the situation presents perverse incentives for Trump. Already, elected officials, up to and including the president, to an extent base their behavior in office on what they believe will play well with voters rather than (or, in the best-case scenario, on top of) what is best for America. This is certainly true of Trump, whose every decision seems to prompt discussion of how it plays into the tension between his nationalist base and traditional Republican voters.

The personal financial benefits of campaigning mean that Trump has a little more motivation to delve into his reelection efforts than most politicians in his position. Because he is personally profiting, he has another reason to aim his politics toward his base so that they will continue donating to him and buying his merchandise in the downtime between election years. Moreover, rather than stockpile for 2020, he has an incentive to keep up the campaign rallies—and keep charging for them, as he did in 2016—so that he can continue funneling money from his donors and voters into his personal businesses.

Moreover, that the president is redirecting donors’ money into his own businesses only further highlights the inadequacy of the trust arrangement he has set up to supposedly prevent him from conflicts of interest. Trump and his lawyers have claimed that, by resigning from his positions within the Trump Organization and handing over control to his two adult sons and a long-time business associate, the president has distanced himself from his businesses enough that he will no longer be tempted to act in his own financial interests. Ethics experts (and common sense) immediately disagreed: Unless the president actually sells his businesses, many have said, and has the funds reinvested without his knowledge, he still knows more than enough about his sources of profit to put his own personal gain above that of the country. The almost $500,000 he’s channeled into the Trump Organization via his reelection campaign demonstrates this: Trump doesn’t need to be in charge of his businesses to know how to direct money their way; all he needs to know is where they are.

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That Second Hotel in Washington, D.C.

There may soon be more than one Trump Hotel in Washington D.C. According to The Washington Post, the Trump Organization is considering purchasing another property in the nation’s capital to develop for its recently created Scion brand, which aims to offer a more affordable alternative to the upscale properties bearing the president’s name.

Unlike the Trump International Hotel—the upscale property that opened in September 2016 and has become something of a synecdoche for the president’s conflicts of interest—a new Scion hotel in D.C. would likely be a licensing deal. That means that, rather than the Trump Organization owning and operating the property itself, a third-party hotelier will be paying the president’s company for the right to use the Scion name; candidates identified by the Post include Foxhall Partners, which has two properties in the city and a third under development, and the Beacon Hotel in downtown D.C.

But even if it isn’t actually owned or operated by the Trump Organization, the new hotel would likely attract scrutiny along the same lines as the Trump International. A licensing agreement means that the president will not be profiting off of the building directly; payments from individuals or organizations booking rooms or events there will not go straight to the Trump Organization, but to the hotelier. But Trump will still have a financial stake in the hotel’s viability: The longer it stays in business and the more successful it is, the more (and longer) the licensee will pay to use the Scion name, and the more likely other owners may be to commit to similar partnerships with the fledgling brand. Trump has resigned from his positions with the Trump Organization and transferred control of his assets to his two adult sons and a long-time business partner. But he still owns the company, which means he will still profit from his properties. According to his son Eric, the president will even continue to receive quarterly reports on how his real-estate empire is faring financially. The pathway to Trump’s pocketbook may be slightly more complicated, but it still exists.

The proposed new property also engenders some of the same concerns as the broader round of expansions the Trump Organization announced in February. Developing a hotel, even in an existing building, means working with local government bureaucracies, such as zoning offices that sign off on structural changes or licensing boards. In any city, this would create  conflicting incentives for government officials who are suddenly being asked to rule on the president’s businesses. On the one hand, Washington, D.C., like many of the cities into which the Trump Organization is looking to expand, voted strongly against the president in the 2016 election; city officials, especially those elected by D.C.’s denizens, may feel a need to factor his unpopularity into their decisions with regard to the newly proposed hotel. On the other hand, the federal government still controls D.C.’s budget, placing additional pressure to green-light a proposal from the infamously mercurial commander-in-chief.

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That Property in Azerbaijan

When it comes to President Donald Trump’s constellation of foreign investments, properties, and companies, much of the attention so far has been on his business’s apparent violation of the Constitution’s emoluments clause, which bars officeholders from taking gifts from foreign leaders. According to numerous ethics experts, the clause takes an expansive definition of gifts, encompassing everything from a direct bribe to a foreign official’s approval of construction of a new Trump property. But some of the Trump Organization’s properties raise additional red flags due to the specific partners involved. That’s true in Indonesia, for example, where Trump’s affiliates have been involved in bribery scandals and radical Islamic nationalist parties, and Brazil, where the company pulled out of a branding agreement amid a criminal investigation of a local business partner.

Such is the case in Azerbaijan, which Transparency International ranks as among the most corrupt countries in the world, where the Trump International Hotel and Tower in Baku remains unopened. Though the long-stalled development has generated a steady drip of news and rumors for years, an overview by Adam Davidson in The New Yorker, entitled “Donald Trump’s Worst Deal,” puts into perspective just how convoluted the situation is, and just how much the project has led Trump and his company into a partnership with numerous corrupt officials in the Middle East. The details suggest that, on top of the continual underlying breach of the emoluments clause, the Trump Organization’s involvement may also violate the Foreign Corrupt Practices Act, or FCPA, which forbids American companies from participating, even unknowingly, in bribery schemes in other countries, with a penalty of up to $2 million and up to five years in jail.

According to Davidson, though the project originated in 2008 as a high-end apartment building, the Trump Organization has had a licensing deal with the building’s Azerbaijani developers to turn the property into a hotel since 2012. Though the Trump Organization presented the deal as a straightforward licensing agreement, it was in fact a much more involved agreement granting the company—specifically, Trump’s daughter Ivanka—extensive oversight over the project. Based on his FEC disclosures in 2016, which as of this moment remain the only official record of Trump’s finances, the president has so far made $2.8 million from the partnership.

But what makes this story unique among the dozens of ethical questions surrounding the president is the Trump Organization’s partners on the project. Ostensibly, the main developer behind the property is Anar Mammadov. He is in turn the son of Azerbaijan’s transportation minister Ziya Mammadov, who was once described in a leaked diplomatic cable as “notoriously corrupt even for Azerbaijan.” Also in on the deal, though not initially publicly disclosed, is Ziya’s brother Elton, who founded the company that currently owns the property in Baku while serving in Azerbaijan’s parliament. Then there’s the Mammadovs’ relationships with Iranian oligarchs. For years, the Mammadovs have been closely linked with the Darvishis, whose members include the head of a  construction firm implicated in the Iranian Revolutionary Guard’s possibly illicit financial operations and the former leader of a company that was sanctioned by the United States for its role in Iran’s attempts to develop an arsenal of nuclear missiles. As the Mammadovs’ influence within Azerbaijan has begun to weaken in recent years, they have  increased both their wealth and their mutually profitable relationship with the Darvishis, green-lighting a number of deals that will prove lucrative for both families.

Alan Garten, the chief legal officer for the Trump Organization, asserted to The New Yorker that, as the company has never worked directly with Ziya or Elton Mammadov, it has not engaged in any behavior that should trip ethical alarms. He has additionally claimed that the company did “extensive due diligence” in making the deal, which did not raise “any red flags,” although the actual employees who carried out the process are no longer with the company.

Still, merely by partnering with the Mammadov family, the Trump Organization may have violated the FCPA. The law explicitly covers cases in which an American company claims not to have known it was working with corrupt officials; jurisprudence since its 1977 passage has further expanded the law’s definition to include “conscious avoidance,” or active efforts by an American company to not learn of a foreign partner’s corruption. So though Garten claims that, since the Trump Organization did not have enough control over the project and has not itself engaged in bribery, its hands are essentially clean, experts on the law say that the Trump Organization may be legally liable if its foreign partners engaged in corrupt practices.

Adding to all this is the fact that Trump is on the record as opposing the FCPA in May 2012, right when it would have become relevant to his company’s engagement in Azerbaijan. Trump called the law “absolutely horrible” and argued that, since other countries do not have the same provision, American corporations are at a major disadvantage in which bribery is the norm. Trump’s appointee to the Securities and Exchange Commission (which enforces the statute), Jay Clayton, similarly considers the FCPA an obstacle to U.S. companies seeking to expand abroad. A dissenting voice on the topic is Attorney General Jeff Sessions, who stated in his confirmation hearings that he intends to continue enforcing the statute. Which of these voices will end up winning out on the topic remains an open question.

This, then, is the situation in which the Trump Organization—and, by extension, the president, who has stepped down from his position within the business but who retains ownership—finds itself in Azerbaijan: The company’s direct partner on Trump Tower Baku is the scion of a wealthy and notoriously corrupt family that appears to have only stepped up its self-dealing as its political power wanes. That family is engaged in what appears to be a relationship of mutual graft with Iranian oligarchs with deep connections to their country’s Revolutionary Guard, the ideological militia widely suspected by the international community of gross corruption and sponsoring terror at home and abroad.

These families can be added to the ever-growing list of international partners whose relationships with the Trump Organization could create conflicts of interest for the president. The Mammadovs’ arrangement with Trump’s company may not only violate the emoluments clause but could also feasibly put the president and his family in legal trouble should the SEC choose to actively pursue enforcement of the FCPA in Azerbaijan. And the Darvishis could in turn use their relationship to influence the Mammadovs, which could have significant implications should Trump attempt, as he has said he will, to take hard-line stances that could affect the Iranian Revolutionary Guard’s activities. And if Trump so chooses, he could direct the Justice Department to curtail its enforcement of the FCPA or even use his bully pulpit to lead a legislative push to undo it, essentially condoning unethical behavior that in many countries enables leaders to personally profit at the expense of their own citizens—which, of course, could be a fair way to characterize the current situation with Trump’s business holdings.

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That Trump Tower Penthouse

With President Trump in office and still refusing to distance himself from his businesses, every new tenant in one of his buildings creates another possibility of a conflict of interest. Such is the case with Xiao Yan Chen, who also goes by Angela Chen, a business executive who, according to documents filed with the New York City Department of Finance, purchased a $15.8 million penthouse apartment at Trump Tower in New York on February 21. Chen’s transaction is the first notable real-estate deal involving one of Trump’s properties since the election, although it should be noted that she has lived in a different unit in Trump Tower since 2004. And though Trump has officially removed himself from the board of directors of Trump Park Avenue LLC, the corporation that runs Trump Tower, he remains the company’s owner, meaning that he profits from its dealings.

Chen’s purchase represents the exact kind of entanglement that has fueled concerns that Trump’s financial interests could influence his decision-making as president. Chen is the founder and managing director of Global Alliance Associates, a consulting firm that, according to its website, “facilitates the right strategic relationships with the most prominent public and private decision makers in China.” The firm is explicit about what it sells: access. Though the page listing its partnerships is currently empty, the firm’s “affiliates” page includes a number of international organizations promoting relationships between private corporations and the governments of the United States and China, including the USA-China Chamber of Commerce, the Asia Society, and the China Institute. Notably, Global Alliance Associates also consults for the U.S. Department of Commerce and the U.S. Trade & Development Agency, meaning that Trump is accepting money from the founder and managing director of a firm that works with the U.S. government.

Because Trump is holding onto his businesses, he has created a situation in which some of his earnings include money from the leader of a company whose sole goal is to help its clients curry favor with the Chinese government; it’s no stretch to believe that her move to Trump Tower and the money it puts in Trump’s pocket may help her gain access to the United States government. (Reached for comment by the New York Post, Chen said she was “not comfortable” discussing the purchase and its possible ramifications for her company.) Even if it wasn’t Chen’s intention, the transaction still could influence the president. As the president’s conflicts of interest continually accumulate, the likelihood that one or more will eventually impact his decision-making continually grows—as does the appearance that he is ethically compromised by the many people, organizations, and governments from which he is receiving money while in office.

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That Resort in the Dominican Republic

The Trump Organization’s January 11 pledge that it would no longer be pursuing new deals in foreign countries is looking increasingly toothless. Shortly after President Donald Trump took office, The Guardian reported that the president’s business would be moving forward with a planned expansion of its golf course in Aberdeen. Now, the Associated Press has reported that the company is working on a licensing deal in the Dominican Republic.

As was true with the Aberdeen plans, the Trump Organization has provided a narrow justification under which it argues that the news does not violate its promise. Technically, it argues, the deal is not new: The Trump Organization has had a contract with Ricardo and Fernando Hazoury, the brothers who own the Cap Cana Resort in the Dominican Republic, since 2007. But the financial crisis and disagreements between the Trump family and the Hazoury brothers, which climaxed with Eric Trump accusing the pair of “textbook fraud” in a 2012 lawsuit, had stalled the arrangement for nearly a decade, and the two parties haven’t written a new contract since the 2007 deal was struck. Even other real-estate developers have said that the resumption of the relationship between the Trumps and Hazourys caught them by surprise. For their part, the Hazourys have said that the relationship with the Trumps “remains incredibly strong, especially with Eric, who has led this project since its conception.”

The development in the Dominican Republic epitomizes the way the Trump Organization seems intent to violate the spirit of their “no new foreign deals” pledge, and arguably even the letter. Asked about the Organization’s justification for the deal, Richard Painter, who served as the ethics lawyer for President George W. Bush, noted that the company “can take the tiniest little past involvement in something and then extend it into an enormous new deal” and hasn’t presented a meaningful way “to distinguish between new business and old business.” Already, the Trump Organization has provided excuses for moving forward with two projects based on an interpretation of its own pledge that seems predicated on the idea that a deal can only be described as “new” if there had never been any relationship whatsoever between the Trump family and the property in question. As the company finds more explanations to broaden what initially seemed to be a clear-cut policy to reduce conflicts of interest—arguably, the only step in Trump’s plan that actually would have helped him do so—the pledge will likely become increasingly meaningless.

The Cap Cana story is yet another conflict of interest that only became public because of reporting from local media—and because of the nonchalance with which the Trump family handles the relationship between their business and the presidency. The first outlet to report on Eric’s trip was the Dominican newspaper Diario Libre, shortly after Cap Cana posted a picture of the Hazourys with Eric on its website. This follows stories like the president’s phone call with the president of Argentina and his company’s plans to expand into Taiwan, both of which were similarly broken by local newspapers before getting picked up by American press outlets. Further, like the president’s post-election meeting with business partners from India and Eric’s trip to Uruguay, the Trump family’s propensity for photo ops played a role: Even amid intensifying scrutiny of the Trump Organization’s actions, Eric seems unworried about having not only taken the trip but also taken pictures with his business partners.

The president’s putative pick for his ambassador to the Dominican Republic only adds to the perception that Trump will intermingle business and politics in the country. Trump has picked Robin Bernstein, a campaign donor, business partner, and founding member of Trump’s Mar-a-Lago Club, to be his administration’s representative in the country. Bernstein and her husband Richard have been in business with the president and his company for decades through The Americas Group, a consulting and marketing firm focused on construction projects in Latin America and the Caribbean. Choosing personal friends and supporters to be ambassadors is relatively common, especially in countries with which the United States has relatively uncomplicated relations. However, Trump’s decision to appoint somebody with whom he has long maintained a financial relationship—his second such appointment, after having named fellow billionaire real-estate developer and business partner Steven Roth to head his infrastructure program—suggests a continued willingness to blur the lines between his endeavors as a businessman and his duties as president, all while contributing to the perception that the president is willing to reward those who have done business with him in the past.

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That Chinese Trademark

On February 15, President Trump scored a long-sought-after victory when a Chinese court ruled in his favor in a trademark dispute. In the case, which dragged on for more than a decade, the Trump Organization won sole rights to use the president’s name on products in the country, which would help prevent a bevy of unrelated entrepreneurs from applying it to a wide range of products, from toilets to clothing to condoms to explosives.

Almost immediately, Trump’s critics pointed out that the ruling poses a clear conflict of interest. Senator Dianne Feinstein of California called the trademark decision “deeply troubling,” adding, “If this isn’t a violation of the emoluments clause, I don’t know what is.” Some, including Feinstein, went further in their assertions: Only days before, Trump had apparently reversed one of his stances toward China by offering a full-throated endorsement of the “One China Policy” (under which countries officially recognize the mainland Chinese government but not Taiwan), leading to the suggestion that the court’s decision was part of a quid-pro-quo deal between the two governments.

Additional context, though, complicates this picture. The case, it turns out, was largely resolved in November 2016, before there was any indication that the president would waffle on the One China Policy by calling the president of Taiwan, and was the culmination of more than a decade of litigation that largely predates Trump’s involvement in politics. Conflicts of this kind over trademarks are fairly common in China, and, though resolving such cases often costs companies significant time and money, the Trump Organization’s victory is one of several that have gone in favor of American corporations in recent years. None of this rules out the possibility of a quid-pro-quo arrangement, but in sum it suggests that there is more to the case than what Feinstein alleges.

Whether or not the Chinese government tried to curry favor with the president by seeing to it that the court ruled in his favor, Trump’s newly awarded trademark poses a conflict of interest that could impact his future interactions with China. On top of the questions around his adherence, or lack thereof, to the One China Policy, Trump has taken a number of controversial stands when it comes to China, from accusing the country of currency manipulation to threatening to take hard-line trade positions that experts worry could lead to a trade war. Over all of these questions will loom the president’s knowledge that, with its trademark now secured, his company has an ongoing profitable relationship with the Chinese government—which, even if Trump does not proactively consider it in approaching the negotiating table, could provide his Chinese counterparts with leverage to influence the president’s decisions.

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That Meeting at Mar-a-Lago

Of his first three weekends in office, President Donald Trump spent two of them away from Washington, D.C., at his Mar-a-Lago Club in Palm Beach, Florida. On his first trip to the resort, which he has dubbed his “Winter White House,” Trump spent time on the golf course, attended a ball held by the Red Cross—a federally chartered organization over which he will likely be tasked to wield authority while in office—and held a Super Bowl party at which he hobnobbed with wealthy patrons.

His third weekend in office, Trump brought a guest of honor along with him: the prime minister of Japan, Shinzo Abe. After first meeting with Abe at the real White House, Trump took his Japanese counterpart to Florida for a weekend on the links. The biggest controversy out of the weekend was over the president’s handling of a situation that developed on Saturday, February 11: As news of a North Korean missile test broke during dinner, Trump and Abe discussed the situation in public, using light from phones of gathered onlookers to read briefing documents, an incredibly lax approach to information security, particularly ironic given that Trump won in part because of his opponent’s own lapses in information security.

The situation perfectly encapsulates the way the president’s business interests are coming up against those of the country. Already, the Trump Organization’s decision to double Mar-a-Lago’s initiation fees led to accusations of profiteering, premised on the notion that people would be willing to pony up in the hopes of earning an audience with the commander-in-chief.

The events of Saturday, February 11 took the problem to a whole new level. By discussing the recently obtained intelligence with Abe without leaving the table, the president committed a breach of international-security protocol in a very public setting. Even had the meeting been taking place in the White House, Trump’s lackadaisical approach to information security would have been cause for concern; for self-evident reasons, briefings on urgent security situations do not typically happen in somewhat open settings around civilians. But on the patio at Mar-a-Lago, the situation becomes much more dangerous, because the patio is not a secure setting, and the administration does not appear to have taken measures to make it one. This is a perfect example of a conflict of interest in practice: Trump has an incentive to host an event at Mar-a-Lago (personal financial gain) that runs directly counter to what would be best for the country’s security (hosting the event at the White House or an otherwise secure location). Not only that, part of the appeal of Mar-a-Lago is that guests will have a front-row ticket to see Trump at work. Previous presidents like Barack Obama, meanwhile, took a more conventional, and far more secure, approach, setting up a mobile security perimeter known as a sensitive compartmented information facility, or SCIF, to ensure that nobody in the area could look in on or overhear the president’s dealings.

According to the president’s Press Secretary Sean Spicer, Mar-a-Lago does, in fact, have a SCIF on site that they used for the remainder of the Trump’s conversation about North Korea with Abe. That they apparently began their discussion at the dinner table before deploying the SCIF underscores the problem of the situation at Mar-a-Lago: Trump has a financial incentive to hold an open-air meeting like Saturday night’s to keep up the appearance that, by paying to be a member of his exclusive club, anyone can have access to the most powerful man in the world.

Who could have been present? The club’s membership list is private, meaning that the American public has no way of knowing who was around to overhear the conversation. (Two Democratic senators, Tom Udall and Sheldon Whitehouse, have introduced a bill to change this fact, but there is little evidence suggesting it has any hopes of passing through the Republican-held Congress.) Nor have the Trump Organization and White House been forthcoming as to how they intend to screen club members and employees for security clearance; though Udall and Whitehouse reached out to the administration to ask how Mar-a-Lago vets guests for security risks, but received no response. In such a public place, and without protective measures like a SCIF, there may not be anything to stop an agent of a foreign government or other malicious actor from paying the $200,000 initiation fee to stay at the club, effectively paying to be near to the president when he receives sensitive information. Unless Trump takes significant steps either to erect barriers between himself and the guests at Mar-a-Lago—which he certainly didn’t do this time, and which could reduce his ability to profit from the property—there is a real possibility that he will continue to compromise his country’s interests when he travels to his resort in Palm Beach.

One patron of the club, Richard DeAgazio, demonstrated just how much of a breakdown the situation represents. DeAgazio, who, according to a photo he posted on Facebook, joined the club in December after Trump’s election, snapped several pictures of the president and prime minister’s conversation, which helped corroborate a CNN report on the public nature of the ad-hoc meeting and details such as the use of cellphone flashlights to illuminate documents; he also took pictures with Trump’s chief strategist Steve Bannon and the president’s “body man,” whose job is in part to carry the “nuclear football” containing missile-launch codes (and who was initially identified by name in the photo’s caption). As if to reinforce impression that Mar-a-Lago members gain unprecedented access to the the president, even in the middle of a crisis situation, another patron was able to film Trump giving a toast at a wedding shortly after his press conference with Abe.

There is no reason to believe that DeAgazio had any intention of compromising international security with his pictures; he appears to simply be a wealthy Trump supporter who was excited at the chance to see his commander-in-chief in action and wanted photographs with which to remember the occasion. (He has since apparently either deleted his Facebook profile or increased his privacy settings so that it is no longer publicly accessible.) Nevertheless, he demonstrated just how Trump’s continued commingling of his business interests and his presidency places not just Americans but the entire global community in jeopardy.

In a way, the sheer enormity of the situation at Mar-a-Lago briefly crowded out the fact that merely bringing Abe to Mar-a-Lago demonstrates Trump’s conflicts of interest neatly. Though diplomatic meetings outside the White House are not unprecedented, Trump’s trip with Abe is likely the first instance of the president actually making money from such a meeting. Though Trump said that he was footing Abe’s bill, with both increased Secret Service presence and Abe’s retinue on hand, there’s a distinct possibility that, at some point in the weekend, somebody from the U.S. or Japanese government made a payment that ended up in Trump’s pocket. On top of that, the visit generated an inordinate amount of free publicity for Mar-a-Lago, which Trump repeatedly mentioned (and posted photos of) on his social media accounts and was continually noted in coverage of the weekend.

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That Defense Department Trump Tower Rental

President Donald Trump’s most iconic property is about to get a new tenant: the Department of Defense. According to CNN, the Pentagon, hewing to a longstanding policy of establishing an offshoot headquarters near the president’s private, non-White House residence, is planning to lease space in Trump Tower in New York City to maintain close proximity to Trump should he choose to spend time there instead of Washington, D.C..

The Department of Defense’s decision is yet another example of how Trump’s decision to hold onto his business interests is rewriting norms surrounding the presidency and creating problems in what were once uncontroversial procedures. As mentioned above, the Department of Defense’s decision is not unique to Trump’s presidency: They took up residence in Chicago, for example, during Barack Obama’s two terms for the exact same reason.

The difference, as is true in so many of the stories surrounding Trump and his family’s conflicts of interest—the Red Cross’s decision to hold its annual ball at Mar-a-Lago, for example, or Eric Trump’s business trip to Uruguay—is that the president himself is now making money off of routine governmental functions. According to The Wall Street Journal, the Department of Defense is spending roughly $130,000 per month to stay at the property, although, according to the Journal, “a Pentagon official wrote in a letter seen by the Journal that the space is owned privately by someone unaffiliated with the Trump Organization and that the department sees no way in which Mr. Trump can benefit from the rent money.”

Nevertheless, the situation points to one of the possible ramifications of the president’s decision to hold onto his real-estate empire while in office. Trump’s protestations to the contrary aside, scientific evidence shows that the mere knowledge that one has profited from a relationship in the past often leads to preferential behavior. As a result, the fact that government agencies—if not the Department of Defense, then the Secret Service and the State Department—may be paying the president himself large sums of money to stay in Trump properties could have significant ramifications for how Trump’s White House operates.

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That Red Cross Ball

The web of President Donald Trump’s conflicts of interest has grown to encompass the American Red Cross, which held its annual ball on Saturday, February 4, at Trump’s Mar-a-Lago Club in Palm Beach, Florida. By hosting the ball, the Trump Organization accepted money from an organization that, while not a federal agency per se, is subject to federal oversight that at some point in the next four years will likely involve President Trump.

Unlike a number of the events at Trump properties that have been featured in this list of Trump’s conflicts of interest, the Red Cross Ball, which celebrated the organization’s centennial anniversary, appears to have been scheduled before Trump even received the Republican nomination for president; a calendar listing on the website of the Coastal Star, a local newspaper covering events in the Palm Beach area, is recorded as having been placed in April 2016. Additionally, though the event has been held elsewhere in the past, this was not the first time it has taken place at Mar-a-Lago: Not only was last year’s ball held there, but the very first Red Cross Ball was hosted there by the property’s prior owner, the famous socialite Marjorie Merriweather Post.

Given all that, there is no indication that the decision to hold the event at Mar-a-Lago had anything to do with Trump’s election, and the fact that Trump will likely be attending the event is not unusual—President Barack Obama also attended as the honorary chairman of the organization while in office. Nevertheless, the ball perfectly encapsulates why Trump’s continued refusal to relinquish his business interests complicates even situations that would have taken place had he not become president.

Thanks in part to the makeup of the Red Cross’s leadership and its unique relationship with the federal government, the ball creates a particularly complicated situation. According to its website, the Red Cross “is not a federal agency, nor [does it] receive federal funding on a regular basis to carry out our services and programs,” instead relying on donations and fees for services like health-and-safety training courses. However, the organization operates under a federal charter as a “federal instrumentality … to carry out responsibilities delegated to [it] by the federal government.” The best-known of these duties include overseeing blood-donation drives and disaster-relief efforts; according to its website, it is also the Red Cross’s duty “to fulfill the provisions of the Geneva Convention” and “provide family communications and other forms of support to the U.S. military.” Further, the organization has a chairperson appointed by the president; currently, the chairwoman is Bonnie McElveen-Hunter, who was appointed by President George W. Bush in 2004. The charter also periodically comes before Congress for review and amendments to be signed into effect by the president.

On multiple occasions in recent years, the Red Cross has come under scrutiny for how it handles its multi-billion-dollar budget, most of which comprises donations from the American public. Prompted in part by reporting on the organization’s inadequate response to Hurricane Sandy, misleading statements about how it uses its money, and a September 2015 report by the Governmental Accountability Office, two congresspeople—one Democrat and one Republican—have independently introduced measures to increase the organization’s transparency. Neither has been enacted, but there will likely be another push to improve the relationship between the federal government and the Red Cross during Trump’s presidency, whether via a review of the Red Cross’s charter, the need to appoint a new chairperson, or the introduction of reform-minded legislation. If and when Trump is called upon to weigh in on these decisions, he will be asked to do so having directly profited from the organization while in office, which could limit his ability to act in the best interests of the American people.

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That D.C. Labor Dispute

One month before he took office, President Donald Trump managed to sidestep a potential conflict of interest at his hotel in Las Vegas. In the fall of 2015, several hundred employees at the city’s Trump International Hotel had voted to join the local branch of the Culinary Workers Union, only to find their efforts stalled by Trump and the hotel’s co-owner, Phil Ruffin. The case languished for more than a year until, after the National Labor Relations Board found Trump and Ruffin in violation of federal law, the workers successfully negotiated their first collectively-bargained contract. If this hadn’t been resolved, a conflict of interest would have arisen: The case would have gone to the U.S. Court of Appeals for the District of Columbia, to which Trump will soon be able to appoint members.

Now, the same issue is cropping up at the Trump International Hotel in Washington, D.C. Already a centerpiece of the controversy over the likely violation of the Constitution’s emoluments clause, the property may soon be the site of another legal tussle: According to The Washington Post, 40 workers at the hotel have also voted to unionize, the first group to do so at a Trump-owned establishment since his election.

As was true in Las Vegas, the push for unionization in D.C., if it’s met with resistance from the hotel, would create an opportunity for the president to place his own financial interests above those of the hotel’s workers. In Las Vegas, the dispute appears to have been resolved partly because of the NLRB’s intercession; if the Trump Organization similarly contests the case in D.C., the NLRB may once again be asked to weigh in. And now that Trump is president, he will be appointing new board members to fill two vacancies on the agency’s five-seat panel, which could very well tip it from its current left-leaning, labor-friendly composition to a more conservative, pro-owner bent. If, as in Las Vegas, the NLRB finds in favor of the workers, but the Trump Organization chooses to continue its opposition, there is a possibility that the case could come before a federal appeals court, where judges who Trump himself may have appointed will be asked to review the NLRB’s decision. And if the conflict continues even beyond the Court of Appeals, it will fall to the Supreme Court, to which Trump recently nominated Judge Neil Gorsuch, to render a final verdict. (It should be added that each appointee will be faced with the possibility of ruling against the financial interests of the infamously vindictive man to whom they owe their position.)

Appointing labor-unfriendly officials and justices might fairly be said to be in keeping with Trump’s long history of questionable labor practices, but this does not mean that the conflict-of-interest question will dissipate. It’s difficult, if not impossible, to determine how much his pro-business stances are dictated by a sincere belief in their efficacy rather than an understanding that he himself has benefited from them in the past and will likely continue to do so in the future. As such, Trump’s motivations will continue to occupy an ethical and legal gray area until he eliminates the overlap between his roles as a businessman and as president.

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Those Expansion Plans

Of the measures that President Donald Trump and his lawyer Sheri Dillon laid out at his January 11 press conference to address conflicts of interest, only two actually ameliorate any of the concerns critics have raised: the cancellation of all of the Trump Organization’s pending deals and the promise not to pursue expansion in other countries (although developments since the announcement suggest that those pledges leave plenty of wiggle room). Conveniently left out of the plan, however, is any prohibition on expanding holdings within the United States—which is apparently something that Trump Hotels plans on doing while Trump is in office.

On January 25, Bloomberg reported that Eric Danziger, the CEO of Trump Hotels, said after a panel discussion in Los Angeles that the company is considering tripling the number of Trump-branded properties within the U.S. According to Danziger, “There are 26 major metropolitan areas in the U.S., and we’re in five. I don’t see any reason that we couldn’t be in all of them eventually.” Danziger listed Dallas, Seattle, Denver, and San Francisco as among the cities where the Trump Organization is looking to build in the near future.

As the Trump Organization’s holdings expand, so too does the potential that business considerations will have undue effects on the president’s behavior in office, or at least appear to. Each location presents another opportunity for businesspeople or foreign dignitaries to choose to stay in a hotel in an attempt to burnish Trump’s opinion of them, their company, and/or their country. Each location increases the number of municipal governments with whom Trump will be interacting both as president and as the owner of a real-estate empire.

Trump Hotels’ expansion plans could put not only Trump but also the cities where new properties may be built in a difficult situation. San Francisco, for example, is currently experiencing a housing crisis, one possible solution to which would be to increase the pace of new home-construction projects, some of which could be funded by federal grants. On the one hand, it is almost certain that the residents of San Francisco, a city that voted against the president by roughly a 9-to-1 margin in November, would strenuously object to a new Trump-branded property in the city. But there is also an incentive for the city government to work with the Trump Organization in finding a suitable expansion plan. With plenty of evidence to suggest that collaborating with Trump’s businesses could influence the president, there’s added pressure for city officials to pursue a potentially costly project residents may otherwise not want in hopes of reaping the benefits down the road. Meanwhile, the officials in charge of doling out federal largesse such as housing grants may similarly feel pressure based on the knowledge that Trump’s feelings toward particular cities may change based on how receptive the locale was of his business’s expansion plans.

Finally, the Trump Organization’s announcement that it would be pursuing expansion further attests to just how little the president’s plan to mitigate his conflicts of interest actually accomplishes its goal. For the Trump Organization to not just expand but do so on such a large scale violates the professed spirit of the measures laid out on January 11 and defies any argument that the company will cease to act in a way that jeopardizes the president’s ability to do his job.

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That Hotel in Vancouver

Less than a week into his administration, President Trump has a new property opening for business: the Trump International Hotel & Tower in Vancouver. According to The Washington Post, construction on the hotel finished shortly before Trump assumed office, with the building’s finishing touch—the president’s name spelled out in giant letters—revealed on January 19 (the day before the inauguration), and the first guests and permanent residents checking in on January 25.

As with many buildings bearing the president’s name, the new hotel in Vancouver is a licensing deal, with the Trump Organization leasing its branding to a third party—in this case, a real-estate company called the Holborn Group, which operates several luxury hotels throughout Canada. The Holborn Group is run by Joo Kim Tiah, the eldest son of one of the wealthiest families in Malaysia; several members of Tiah’s family are expected to fly in from Kuala Lumpur to attend the opening with the president’s two adult sons, Donald Jr. and Eric.

The building is yet another manifestation of the running problem posed by Trump’s extensive foreign real-estate holdings. Unless the president actually rids himself of his financial stake in his company, every Trump property influences his incentives when it comes to making policy, foreign or domestic: Should he act in the manner that best serves the country, or the one that will protect his profits? Every building provides the opportunity for third parties to curry favor with the infamously capricious president: If he knows that he has taken money from somebody, be it a company, a private individual, or agents of a foreign government, that knowledge, and the goodwill it creates, is likely to color Trump’s decision-making. Moreover, every businessperson who has a licensing deal with Trump now has leverage: If Tiah, or any of the other businesspeople around the world with a Trump-branded property, disagrees with a decision the president makes, he can threaten to pull out of the partnership and jeopardize some of Trump’s cash-flow in an attempt to change his mind.

Hardly a day had passed between the new hotel in Vancouver opening for business and the first report of an organization choosing to host an event at the site, possibly for political reasons. On January 26, The Washington Post reported that The American Chamber of Commerce in Canada, a business organization affiliated with the conservative U.S. Chamber of Commerce, had scrapped longstanding plans to hold a meeting about trade relations at the home of a diplomatic official and would instead be booking space in the new Trump Hotel for the equivalent of roughly $1,900—a relatively small sum, to be sure, but even small sums have been shown to substantially influence decision making. The change initially prompted at least one planned speaker, the University of British Columbia professor Matilde Bombardini, to back out of the event; however, according to the Vancouver Sun, she has since changed her mind after being told that the change of location was due to a leak at the previous site.

As with so many of the instances chronicled here, the venue change demonstrates how Trump’s conflicts of interest often operate in shades of grey. If the Chamber of Commerce did make its decision solely based on logistics, booking a spot in a Trump-branded building still makes possible the appearance of paying for play. In a marked departure from the Chamber’s copacetic relationship with the Republican nominee Mitt Romney in 2012, the aggressively free-market, pro-trade group clashed with the president on multiple occasions during the 2016 campaign over Trump’s protectionist trade policies, but has already made public overtures since the election to reconcile with the president. If it did, in fact, choose to move the event even in part because of the giant name on the new location’s facade, the decision represents another chapter in the ongoing saga of the business community’s desire to both please and sway a president whose ideology is not that of a typical Republican. Additionally, though nearly all of Trump’s rhetoric about NAFTA centers on Mexico, Canada actually trades more with the U.S. than not just Mexico but any other country in the world. As such, there is plenty incentive for the Canadian branch of the American Chamber of Commerce to do whatever it can to reach out to Trump.

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That Reality-Television Show

Though President Donald Trump has been a well-known figure in American public life for decades, perhaps the single biggest contributor to his stardom has been NBC’s The Apprentice. Trump himself is no longer the star of the show—former California Governor Arnold Schwarzenegger has taken over as host in 2017—but the president remains an executive producer on the series for at least the coming year, including receiving a low five-figure salary for the position, according to Variety. Shortly after the news of that income broke, Kellyanne Conway, a counselor to Trump, clarified that he would be taking on his producing duties in his spare time, comparing the situation to previous presidents playing golf or pursuing other leisure activities.

Norm Eisen and Richard Painter, who served as the chief ethics lawyers under Presidents Obama and George W. Bush, respectively, pointed out on NPR’s Fresh Air that Trump’s ongoing involvement with The Apprentice presents yet another conflict of interest. According to AdWeek, 11 companies, including the television-shopping network QVC and Carnival Company (which operates the eponymous cruise line), are providing on-air sponsorships for the newest season of The Apprentice; a twelfth, the Japanese motorcycle company Kawasaki, withdrew from a previously reported deal after customers threatened a boycott because of its sponsorship of the show. All of these companies—plus the numerous companies that run ads during the show’s commercial breaks—are effectively putting money into the pockets of the president, not to mention supporting one of his products.

Trump apparently believes himself immune to such conflicts of interest, both in terms of legal impunity and his ability to ignore them, despite a good deal of research indicating that even minuscule financial incentives (minuscule for a billionaire, that is) can be enough to significantly influence behavior. Additionally, there is little doubt that Trump cares deeply about the ongoing success of The Apprentice: The weekend after the new Schwarzenegger-led season debuted, the then president-elect took to Twitter to voice his thoughts on the new season’s ratings. So when one of the companies that sponsors the show interacts with the executive branch—as when Carnival reached a $40 million settlement with the U.S. government over pollution in the Atlantic Ocean, for example, or when QVC settled a $7.5 million suit regarding deceptive advertising in 2009—the question will necessarily arise how their contributions to Trump’s pocketbook and beloved TV show will affect the outcome.

Even if Trump were able to fully blind himself to the conflicts described above, the president’s role would remain a problem because it provides an unprecedented bargaining chip for both the companies currently sponsoring in the show and those that could seek to use it to attempt to manipulate the president. Consider, for a moment, the potential negotiations between one of Trump’s sponsors and a government agency that finds it in violation of federal regulations. That company, though, has a trump card the likes of which has never been seen in American politics: Should it become apparent that the case is going awry, they can threaten to pull their support of the president’s television show. The move would inevitably make waves on cable news of the kind that Trump has repeatedly demonstrated himself to be susceptible to. Any decision, whether in favor of the company or against it, immediately loses credibility: If the company is found guilty, the decision is easily framed as retaliatory, a vindictive manifestation of the president’s ego and narcissism; if the company is let off the hook, it will appear that the company has manipulated his venality for its own gain. A formerly uninvolved company facing federal investigation could essentially pull the same gambit in reverse: By publicly committing to sponsor The Apprentice, a company could create a situation in which any decision appears to reflect not the facts of the case but the sticky situation created by its involvement with the show. In this sense, then, Trump’s decision to stay on as executive producer, and the conflicts of interest the position creates, jeopardizes not only the president’s ability to carry out his job but also the fundamental legitimacy of the rule of law for any company that currently is or in the future may become involved with the show.

Additionally, the president’s continued involvement with the show creates a strange and tricky situation for NBC. Trump’s reputation is inextricably intertwined with that of the show, meaning that NBC will to some extent be caught between promoting Trump as a successful businessman and doing its journalistic work. The network will likely also be advertising The Apprentice during its other programs, not only through commercials but also possibly in-studio promotions on other shows, creating conflicting incentives for NBC journalists who will be trying simultaneously to talk about the Trump administration fairly while their own network markets one of his products.

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That Pipeline

The Dakota Access Pipeline, or DAPL, was the subject of continual controversy during the presidential campaign, drawing months of protests because of the perceived environmental impact it would create by crossing the Missouri River in close proximity to a Standing Rock Sioux reservation. Shortly before the election, the Army Corps of Engineers announced that it would be halting progress on the pipeline for further environmental review and to study potential routes that might avoid crossing both the river and Native American territory. On January 24, however, only four days after President Trump took office, he decided to move forward with both DAPL and the Keystone XL pipeline, which the Obama administration likewise blocked because of environmental and tribal-sovereignty concerns; the Army Corps of Engineers finalized the easement on the project on February 7. Trump has been vocally supportive of the pipelines for months, claiming that they would create new jobs in construction and the oil industry.

Trump’s FEC filings, which remain the only public record of his finances, suggest that he may have had an additional incentive to greenlight the projects: According to financial-disclosure forms he filed in June 2015 and May 2016, Trump has owned stock in Energy Transfer Partners, the company seeking to build DAPL. The stock was worth between $500,001 and $1,000,000 in 2015 and between $15,001 and $50,000 in 2016.

The president and one of his spokesmen, Jason Miller, have both stated, without offering evidence, that Trump’s stock-related conflicts of interest have been resolved. According to Trump and Miller, the president sold off his stocks in June of last year specifically to head off concerns that they may influence his decision-making in office. However, they have offered no meaningful evidence to back up their claims—evidence which, in this case, would likely be fairly easy to provide. They could, for example, offer more details on when exactly the stocks were sold beyond simply “back in June,” or explain why they did not mention the sale until December, just after the election, if the intention was to proactively address conflict-of-interest questions.

Given Trump’s penchant for dissembling about his personal finances and the lack of evidence that he has sold off his stocks, Trump’s decision to push ahead on DAPL and Keystone XL simply underscores the need for him to take larger, and more public, steps to distance himself from his financial interests. Moving forward with the pipelines is not the first instance of Trump making a significant decision that benefits a company whose stock is listed in his financial disclosures. For example, when Trump announced his intention to intervene at the factory of the air-conditioner manufacturer Carrier in Indianapolis, the Indianapolis Star noted that Trump’s filings list stock in Carrier’s parent company, United Technologies.

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Those HUD Grants

As has been noted on several previous occasions, one of the overarching questions about America’s first businessman presidency is just how President Trump’s vast empire will interact with federal agencies that answer to him. One of these potentially sticky situations became something of a flashpoint at the hearing for Dr. Ben Carson, Trump’s appointee to lead the Department of Housing and Urban Development. At the hearing, Senator Elizabeth Warren pressed Carson over the fact that, as the head of the department, he would be in charge of numerous programs that the president could manipulate to profit his real estate empire, asking Carson, “Can you assure me that not a single taxpayer dollar that you give out will financially benefit the president-elect or his family?” Though Carson did not respond to the question with regard to Trump specifically, he responded that he “will absolutely not play favorites for anyone” or act with an “intention to do anything to benefit any American, particularly.” (Warren went on to expound on how Trump’s lack of financial transparency makes it borderline impossible to know if a policy will benefit him.)

Warrens’s line of questioning was not entirely hypothetical: Trump does, in fact, own properties the maintenance of which falls under HUD’s purview. Thanks to an inheritance from his father, the president holds an ownership stake in—and has made millions from—Starrett City, a 153-acre, 5,881-unit low-income housing development in Brooklyn. The development, according to ABC News, receives substantial federal funding via HUD’s many programs designed to support low-income renters and homeowners. Trump could easily press for policies that would increase his profits from Starrett, most notably allowing for the sale of the complex, an action HUD blocked in 2007—and, potentially, to other properties from which he may profit in ways that, without more complete financial information, the American public may not even know.

The potential for a profitable relationship with HUD underscores a central problem with Trump’s refusal to fully divest from his holdings before entering office. It’s not just high-ranking officials who will possess the ability to act in a manner that benefits the president’s pocketbook—it’s ordinary civil servants as well. Shortly before his inauguration, The Washington Post noted several additional ways employees in Trump’s executive branch could do so: Trademark disputes, for instance, will be adjudicated by judges appointed by his Commerce secretary, while the EPA could roll back environmental regulations that reduce profits at his golf courses.

Meanwhile, lower-level officials tasked with the day-to-day work of regulating Trump’s properties are likely to face pressure as well—if not explicit from superiors, then from the implicit, inescapable knowledge that enforcement decisions will impact the president personally. Federal Aviation Administration inspectors, for instance, are in charge of on-the-spot, random inspections of aircraft, including Trump’s, and at one point during the campaign grounded one of his planes after its registration expired; the Occupational Safety and Health Administration oversees construction sites, and has fined the Trump Organization on multiple occasions for workplace-safety violations. Only 10 years ago, politically motivated firings within the Justice Department became one of the many enduring scandals of George W. Bush’s administration; with so many executive-branch employees interacting with the president’s properties in so many different ways, some will inevitably face difficult decisions between proper enforcement at his expense or looking the other way to stay in the boss’s good graces.

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That Other Billionaire New York Real-Estate Developer

President Trump’s promise to erect a big, beautiful wall between himself and his business lasted slightly more than 48 hours.

Almost exactly two days after the January 11 press conference at which Trump announced plans purported to disentangle himself from his namesake business, the Huffington Post reported that the president had scheduled a meeting with Steven Roth. Roth, a fellow New York-based billionaire real-estate developer, is in charge of Vornado Realty Trust, an investment firm that co-owns two of Trump’s most valuable properties, one in Manhattan and one in San Francisco, and served as an economic adviser during the campaign. What Trump and Roth discussed at their meeting remains unknown, nor is it clear when exactly the meeting was scheduled. Regardless, that the meeting came directly on the heels of the press conference at which Trump and his lawyer laid out a plan supposedly meant to resolve conflicts of interest, throws the reality of the problems that come from having a businessman as president—and one who seems completely uninterested in taking steps that would actually distance him from his business—into sharp relief.

Shortly thereafter, The Wall Street Journal reported that Roth may soon become involved with the Trump administration beyond just his pre-existing friendship and partnership with the president. Trump, it seems, will soon be naming Roth and Richard LeFrak, yet another New York-based billionaire real-estate developer, to oversee a council of 15 to 20 builders and engineers who will be carrying out the president’s $1 trillion infrastructure proposal, a situation which itself provides ripe opportunities for the pair to direct federal dollars toward projects from which they will financially benefit. This news comes on top of a December report in The Washington Post that Roth’s firm had put in a bid to rebuild the FBI’s headquarters, a deal that could be worth as much as $2 billion. In other words, Trump, mere days after promising to remove himself from his businesses, is instead ushering a longtime partner into his administration.

The move could also end up providing yet another avenue by which Trump could enrich himself in office and by which others could attempt to curry favor. Whether or not he intended to do so, the president’s decision to place Roth at the head of such a large pool of money sends a signal to other companies about the continued intermingling of his business and his presidency: that working with the Trump Organization can be a path to increased influence or even appointment. And though Trump claims that he will no longer be in involved in day-to-day operations, he will be actively profiting off from the company, meaning that he will be personally making money off of the attempts of others to gain influence over American public policy.

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Those Indonesian Politicians

Despite President Trump’s assurance that he has stopped pursuing deals since the election, his namesake organization apparently moved forward with a pair of projects in Indonesia. According to The New York Times, the two properties that will bear the Trump name, one overlooking a Hindu temple in Bali and the other abutting a theme park in West Java, presented ethical problems even before the election.

To begin with, through his Indonesian partner on the projects, the billionaire media mogul Hary Tanoesoedibjo (known in Indonesia as Hary Tanoe), Trump has forged relationships with several top Indonesian politicians. One such leader is Setya Novanto, the speaker of the country’s House of Representatives who temporarily lost his post for trying to extort $4 billion from the American mining company Freeport-McMoRan (a company which counts Carl Icahn, who will be serving as a special adviser in Trump’s administration, among its largest shareholders, and which has been frequently criticized by labor advocates and environmentalists). Trump had lunch with Novanto and several other Indonesian politicians during the campaign in September 2015 to discuss the Trump Organization’s planned expansion into Indonesia. At a post-luncheon press conference, Trump pulled Novanto in front of the cameras, calling him “an amazing man” and “one of the most powerful men” and asserting, “we will do great things for the United States.” (It is unclear exactly whom Trump meant when he used the word “we.”) Trump then asked Novanto to confirm that “they like me in Indonesia,” which Novanto did.

Another of the politicians who attended the lunch with Trump is Fadli Zon, the vice chairman of Indonesia’s House of Representatives, whose district includes one of the cities in which one of the Trump-branded properties will be built. According to the Australian Broadcasting Corporation, Zon is associated with a political movement seeking to unseat and jail the current governor of Jakarta, Basuki Tjahaja Purnama, also known by his nickname, Ahok, and has spoken at rallies against Ahok. The anti-Ahok movement is rooted partly in centuries of ethnic tension within the country: Ahok is both Christian, which has made him the target of attacks by hardline clerics claiming to represent Indonesia’s Muslim majority, and a member of the country’s historically oppressed Chinese minority, which was the target of a massacre in 1998. Aside from an interim governor appointed half a century ago, Ahok is the first governor of Jakarta to fall into either category, and is currently on trial for blasphemy for allegedly insulting the Koran, although Ahok’s supporters claim that it is Ahok’s accusers who are guilty of blasphemy for denigrating Ahok’s Christianity.

Both Trump’s question to Novanto and Zon’s presence at the meeting underscore another difficulty the president introduces into the United States’ relations with Indonesia. Indonesia is both the largest predominantly Muslim country in the world and the nation with the largest population of Muslims. Novanto received significant blowback for his statement that, yes, Indonesians do like Trump, because it turns out that, no, many Indonesians don’t like Trump, in large part because of his on-again, off-again proposal to ban Muslims from immigrating to the U.S.; in fact, faced with mounting criticism, Novanto’s party apologized not only for Novanto’s statement but also for his mere attendance at the luncheon. Since Trump’s victory, both Novanto and Zon have stood up for the president, arguing that Trump’s hardline stance toward Muslim immigration was merely campaign rhetoric and not actually reflective of the president’s own beliefs, something Novanto claimed Trump personally assured him was the case. Regardless, it is clear that the Trump Organization’s planned expansion into Indonesia—which, again, is the reason Trump met with Novanto and Zon in the first place—could introduce major complications into the relationship between the president and the political leaders of the world’s largest Muslim country, not to mention a significant trade partner and an important ally in the South China Sea region.

As if that weren’t enough, Tanoe himself has shown increasing interest in becoming involved in Indonesian politics. In 2014, Tanoe publicly supported the retired general Prabowo Subianto in the nation’s presidential election; Subianto lost to the country’s current leader, Joko Widodo. Then, in 2015, he helped found a new political party, the United Indonesia Party, or Partai Perindo, which intends to field candidates for national office in the near future, including Tanoe himself: Shortly after The New York Times reported on the project, Tanoe told the Australian Broadcasting Corporation that, “If there is no one I can believe who can fix the problems of the country, I may try to run for president.”

If Tanoe does so, it will create the possibility that Trump will be dealing with a head of state with whom he has shared business interests, which, as the ethics lawyer Richard Painter told The New York Times, “makes it impossible to conduct diplomacy in an evenhanded manner”—especially considering that, after Trump’s election, stock in Tanoe’s company rose significantly. Moreover, Tanoe, like Ahok, is both Christian and ethnically Chinese, which some insiders consider an obstacle to his electoral chances, although Tanoe argues that it is not Ahok’s religion but his lack of firm leadership that has led to the large-scale protests against the governor. Nevertheless, if Tanoe does choose to run for office, it is difficult to see how his race, religion, and business partnership with a president many see as blatantly Islamophobic could do anything other than create further difficulties both within Indonesia and in the country’s relationship with the U.S..

Tanoe remains close to Trump. He attended the inauguration as a guest of the Trump Organization; he and his wife posted several photos commemorating the occasion on their Instagram accounts, including pictures with Donald Jr. and Eric Trump and a video taken out the window of a car driving along the inaugural parade route. Then, in a February 7 interview with the Indonesian news magazine Tempo, Tanoe bragged about his access to the president. In the interview, he claimed to have seen Trump as recently as January 4 in New York, though he demurred when asked what they discussed, saying, “It wouldn’t be ethical, especially now that he is the president.” Tanoe also confirmed that “nothing has changed” regarding the branding deals in Indonesia, which he says will be moving forward with Trump’s sons in charge, a statement that would seem to contradict Trump and his lawyer’s January 11 announcement that the company would be suspending unfinished development projects.

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That Emirati Businessman

Though the biggest controversy over the New Year’s Eve celebration at Mar-a-Lago, Trump’s Florida estate, was apparently whether or not Joe Scarborough could accurately be described as having “partied” there, video footage taken by a guest and obtained by CNN the next day brought renewed scrutiny to President Trump’s own presence at the event. During a 10-minute speech given in front of the party’s 800-odd attendees, Trump praised his Emirati business partner Hussain Sajwani and Sajwani’s family, saying, “The most beautiful people from Dubai are here tonight, and they’re seeing it and they love it.” CNN identifies Sajwani as a “billionaire developer in Dubai” who has “paid Trump millions of dollars to license the Trump name for golf courses in Dubai.” Trump’s spokeswoman, Hope Hicks, defended the remarks by clarifying that the president and Sajwani “had no formal meetings of professional discussions. Their interactions were social.”

Whether or not Hicks’s statement was true, Trump’s commendation of Sajwani is part of a pattern in which the president praises his business partners in ways that suggest he has little interest in extricating himself from his company’s interests. Previously, he has name-dropped business partners in Turkey and Argentina while on official calls with the countries’ leaders; he also met, and took photos, with associates from India shortly after the election. Moreover, as with several of the countries in which Trump-branded buildings are located, the United Arab Emirates has a questionable record on human rights; Human Rights Watch specifically states that the nation “uses its affluence to mask the government’s human-rights problems.”

By singling out Sajwani, Trump also runs headlong into accusations that he and his family are selling access to his administration through their organization and family foundations. According to Politico, tickets to celebrate with the president at Mar-a-Lago, went for upwards of $500; the stated attendance of at least 800 people means that the Trump Organization made at least $400,000 off of ticket sales for the event. (There is no indication that the party was a fundraiser for any outside organization, such as a charity or campaign fund, as is often the case when politicians attend such an event.) Whether or not the president sees it as such, the event offered attendees the opportunity to be in the same room as Trump and bend his ear for a price. This follows consternation regarding an auction for a face-to-face meeting with Trump’s daughter, Ivanka, and a charity event that offered a reception with the president and a hunting trip with his two sons, both of which have since been cancelled, as well as ongoing speculation that foreign entities will attempt to curry favor with Trump by booking rooms and events at his hotel in Washington, D.C. That Trump singled out Sajwani at the New Year’s Eve party lends credence to these concerns—it’s an instance of someone receiving the president’s attention simply by buying a ticket to one of his events.

Since footage of Trump’s shout-out emerged in early January, Sajwani has continued to feature in coverage of the president’s business entanglements. At the January press conference where Trump and his lawyer, Sheri Dillon, laid out the president’s plan to ostensibly avoid conflicts of interest, Trump said that after the election, Sajwani offered him a $2 billion deal, which Trump turned down. Rather than acknowledge that being offered billions of dollars from a foreign businessman constitutes a conflict of interest, Trump presented his decision not to accept as an example of his magnanimity, saying, “I didn’t have to turn it down, because as you know, I have a no-conflict situation because I’m president. It’s a nice thing to have, but I don’t want to take advantage of something.” Later, Sajwani attended Trump’s inauguration, although it’s unclear if he interacted with the president while there.

Then, on Tuesday, Sajwani posted a picture of himself eating with Donald Trump Jr. in Dubai on Instagram with a caption reading, “It was great having my dear friend and business partner Donald Trump Jr. over for lunch. Discussing new ideas and innovation always make [sic] our meetings even more interesting.”

Donald Jr.’s meeting with Sajwani prompts concerns about the president’s conflicts of interest, for two main reasons. First, the meeting offers a reminder of the insufficiency of the steps Trump has taken to distance himself from his businesses. Though Trump and Dillon claimed that their plan resolved questions about conflicts of interest, ethics experts disagree: Because Trump still knows what his assets are and the identities of those with whom he does business, they say, Trump still knows more than enough to favor his company. Moreover, in an actual blind trust, Trump would have turned his assets over to a trustee with whom he would have no contact. Instead, he turned it over to a long-time executive within the Trump Organization and his sons, who he has long counted as among his closest advisers and with whom he has remained in contact during his presidency so far. Donald Jr.’s meeting with Sajwani is a reminder of these inadequacies, especially because Sajwani posted the picture to Instagram, thus increasing the lunch’s visibility and, along with it, the likelihood that the president will know about the ongoing interactions between his company and Sajwani’s (that is, if Donald Jr. hasn’t already made his father aware of them).

Second, Sajwani’s caption further undermines one of the few parts of the arrangement that actually would have meaningfully reduced the president’s conflicts of interest. In January, Dillon said that the Trump Organization would be canceling all of its pending deals and would stop pursuing foreign deals during Trump’s presidency. Since then, numerous developments have called those intentions into question: Projects appear to be moving forward in both Scotland and the Dominican Republic, with the Trump Organization offering narrow, legalistic explanations as to why the progress didn’t violate the terms of the trust. Though a spokeswoman for the Trump Organization has said that Donald Jr. was not seeking new deals while in Dubai, the previous stories, coupled with Sajwani’s Instagram caption, undermine that account.

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That Virginia Vineyard

Among the dozens of properties President Trump owns is Trump Vineyard Estates and Winery in Charlottesville, Virginia, the source of his namesake wine. On December 23, the property requested temporary H-2A visas for six foreign workers, according to The Washington Post; on February 17, BuzzFeed reported an additional request that upped the total to 29. The visas, which are administered by the Citizenship and Immigration Services wing of the Department of Homeland Security, allow businesses to temporarily hire foreign, unskilled workers provided that the employer proves that there are not enough domestic candidates to fulfill a one-time or seasonal shortage and that the hiring will not depress wages for U.S.-born employees. Trump, of course, appointed the current Secretary of Homeland Security, which gives Trump authority over the very department responsible for deciding whether to grant the visas that the vineyard has requested. His choice for the position, the retired general John Kelly has a relatively scant track record when it comes to immigration, leaving open the question of how much influence Trump himself will have over the DHS’s policy on the matter.

On top of the fact that Trump will soon be able to influence the outcome of the request, that his organization has continued to request visas after his election underscores a tension in the president’s stance on immigration. From the moment that he announced that he would be running for president, Trump made antagonism toward immigration the central aspect of his campaign, arguing that both legal and illegal immigrants are taking jobs that should be filled by native-born Americans and depressing wages for others. Though he did not specifically single out the H-2B visa, the president has on multiple occasions spoken critically about the H-1B program, which enables employers to temporarily hire foreign workers for skilled jobs like those in the tech industry.

But the Trump Organization has long been a beneficiary of immigrant labor. For example, according to a Reuters report from August 2015, nine companies of which Trump is the majority owner have requested at least 1,100 foreign visas since 2000. The majority of these requests were from Trump’s Mar-a-Lago Club in Florida, which has requested at least 787 foreign visas since 2006, including 70 applications in 2015. (Meanwhile, The New York Times reported that, since 2010, only 17 of the nearly 300 domestic applicants for positions at the Mar-a-Lago have been hired.) The Trump Organization also famously may have benefited from illegal immigration: There is significant evidence that many of the Polish construction workers at the Trump Tower construction site in New York in 1980 were in the country illegally. In other words, Trump’s track record includes not just taking advantage of the very visa process he claims to abhor but also actually subverting existing law for his own profit. Now, by applying for visas for his vineyard, Trump is signaling that he expects that his business will continue to be able to profit from one of the very immigration programs he continually denounces.

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That Las Vegas Labor Dispute

On top of owning various properties and enterprises, Trump and his company employ roughly 34,000 people, according to an analysis by CNN. On December 21, several hundred of those workers resolved a labor dispute against the president—one in which, had it continued for even a few weeks more, Trump would have had the unprecedented power to make appointments to affect its outcome.

Here’s the situation: In October 2015, several hundred employees, primarily housekeeping staff, at the Trump International Hotel in Las Vegas voted to join the local branch of the Culinary Workers Union. Trump Ruffin Commercial LLC, which owns the hotel and is itself owned by Trump and the casino magnate Phil Ruffin, contested the vote, first by enlisting an anti-union consulting firm (for whose services it paid $500,000) and then by filing complaints with the National Labor Relations Board (NLRB). Shortly before the election, the NLRB not only rejected Trump and Ruffin’s complaints but also found that, because the pair had refused to negotiate with the nascent union, they had violated federal law and their hotel was operating illegally. Trump and Ruffin have since appealed to the U.S. Court of Appeals for the District of Columbia.

On December 21, more than a year after the hotel’s workers first voted to join the union, the workers announced that they arrived at their first collectively-bargained contract, achieved, according to an employee quoted in ThinkProgress, despite significant pressure from ownership that attempting to unionize would cost workers their jobs. According to the union, the new agreement “will provide the employees with annual wage increases, a pension, family health care, and job security” comparable to that of other Las Vegas hotels. Moreover, the Culinary Workers Union’s parent organization, UNITE HERE, has reached an agreement to represent workers at Trump’s recently-opened hotel in Washington, D.C..

Although this dispute has been resolved, it is included here because it exemplifies the type of situation in which Trump’s business interests are likely to overlap with his duties as president. Trump will be tasked with appointing members to fill current openings on the NLRB, the very body that ruled against him shortly before the election and will be tasked with resolving any future disputes between the hotel’s owners and its employees. Moreover, as Slate noted, the chief justice of the D.C. Court of Appeals is none other than Merrick Garland, whose nomination to the Supreme Court has spent months languishing in the Republican-controlled Congress and was withdrawn once Trump became president. Finally, if disputes of this nature go beyond the Court of Appeals, the case would go to the Supreme Court, to which Trump will be appointing a justice, which is expected to tip the balance decisively in a more conservative (and likely anti-union) direction. In other words, no matter how far up the chain future disputes of this nature go, Trump’s presidency will give him new power to influence the results.

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That Kuwaiti Event

According to an anonymous source and documents obtained by ThinkProgress, representatives from the Trump Organization pressured the ambassador of Kuwait to hold its embassy’s annual celebration of the country’s independence at the Trump International Hotel in Washington, D.C. The event, held annually on February 25, was originally scheduled to take place at the Four Seasons Hotel in Georgetown; the location was allegedly changed after members of the Trump Organization contacted the country’s ambassador. ThinkProgress’s source “described the decision as political,” suggesting that the embassy chose to relocate the event in an effort to curry favor with the president. The Kuwaiti ambassador has since disputed the report, telling The Washington Post that he had not been contacted by the Trump Organization and that the move “was solely done with the intention of providing our guests with a new venue.”

If ThinkProgress’s account is correct, Kuwait’s decision represents an escalation of a situation that has been developing since Trump’s election. The Trump International Hotel has been the subject of continual scrutiny for the conflict of interest it poses, in part because its lease explicitly bars elected officials from holding it, but mainly because Trump’s ownership of the hotel will almost definitely result in a violation of the emoluments clause, which prohibits the president from receiving payments from foreign powers—something that will arguably be happening any time a foreign government books a room at the hotel. Already, the hotel has begun advertising itself as a destination for diplomats and dignitaries, and the embassies of Azerbaijan and Bahrain have both scheduled events in the building. However, before the ThinkProgress report, there was no evidence that the Trump Organization had individually reached out to a foreign government in hopes of getting it to relocate an event to the hotel.

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Those Certificates of Divestiture

In addition to the many possibilities for President Trump to pursue his financial interests in office, the unique makeup of his cabinet also creates a new set of financial motivations. While Trump’s own fortune automatically makes his administration the wealthiest in history, he has also surrounded himself with an unprecedented collection of billionaires and multi-millionaires whose investments are likely to also come under scrutiny.

Unlike the president himself, those who are up for Trump’s cabinet, such as his proposed Secretary of the Treasury Steven Mnuchin and Secretary of Education Betsy DeVos, will be legally obligated to divest from any holdings which may pose a conflict of interest. However, as The Washington Post noted, even selling off their holdings offers an opportunity for Trump’s cabinet members to enhance their fortunes. A federal program known as a “certificate of divestiture” allows executive-branch appointees and employees to avoid capital-gains taxes when selling their assets. The program has existed since 1989, and most recently received attention when President George W. Bush appointed Hank Paulson, then the chief executive of Goldman Sachs as his Treasury Secretary in 2006. Paulson was forced to sell off $700 million in shares of the bank; the certificate of divestiture enabled him to avoid a potential $200 million in capital-gains tax liability. According to The Washington Post, the Office of Government Ethics is currently researching whether the president himself would qualify for the tax break; even if he doesn’t, the unprecedented wealth of Trump’s cabinet promises to push this provision, and the financial incentives it creates, to the limit.

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That Carrier Deal

One of President Trump’s first major economic moves as president was the deal that he and Vice President Mike Pence struck with the air-conditioner manufacturer Carrier, which had planned to move 2,100 jobs from its Indiana plant to Mexico. Finalized on November 29, the compromise kept 730 of the plant’s jobs in Indiana in exchange for $7 million in tax breaks over 10 years. The deal immediately attracted praise and criticism on both sides of the aisle, with much of the scrutiny going toward the tradeoff between jobs and tax breaks and Trump’s idiosyncratic, ad-hoc negotiation techniques.

An additional detail soon emerged regarding the deal: According to his FEC filings (which, despite Trump and his spokesman Jason Miller’s unverified statements that the president sold off his stock in June, remain the most recent public record of the president’s finances), Trump holds stock in Carrier’s parent company, United Technologies. In 2014, his investment in the company was between $100,001 and $250,000, while in 2015, the stock is listed as worth less than $1,001, which could indicate that he sold some or most of the stock; each year, his holdings earned him between $2,500 and $5,000.

The paucity of information in the FEC filings makes it difficult to ascertain why his holdings appear to have decreased; regardless, the investment is not only one of several hundred but also a relatively minor one among Trump’s many holdings, some of which are worth over $5,000,000. As a result, it’s difficult to know how much, if at all, Trump may have considered the stock, particularly considering that he didn’t appear to remember his initial promise to save the Carrier plant. Additionally, Trump does not have stock in the next company he called out on Twitter, Rexnord Corporation (which is also based in Indiana), or its parent company, The Carlyle Group. Still, Trump’s deal with Carrier demonstrates the unprecedented challenge the president’s conflicts of interest create: Unless he either puts his holdings in a truly blind trust or divests completely, a significant number of the decisions he makes will involve some level of financial incentive for himself as well as for the country.

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That Blind-Trust Issue

Almost as soon as Donald Trump and a lawyer from the Trump Organization unveiled their plans to distance the president from his businesses on January 11, many ethics experts argued that the proposal didn’t do nearly enough to ward off concerns that Trump’s business involvements would produce conflicts of interest during his presidency.

Under that plan, Trump resigned from the positions he held at the many companies that make up his real-estate empire, ceding control to his two adult sons and a longtime business associate, with his assets placed in a trust run by his two adult sons and Allen Weisselberg, a longtime Trump Organization executive, for the duration of his presidency. In unveiling the plan, the president vowed to refrain from talking about his financial interests with Donald Jr. and Eric Trump and said that all future business decisions would be reviewed by a newly appointed compliance officer to prevent even accidental impropriety. However, critics said, as long as Trump still profits from his businesses, these measures do almost nothing to mitigate worries about conflicts of interest. Besides, with so much of his fortune derived from highly visible real-estate and branding deals, some lawyers note that no trust would fully blind him from knowing where his financial interests lie; they say the only way to fully protect against conflicts of interest would have been for him to have sold off his businesses before taking office.

Events since the election demonstrate that these experts’ doubts are well-founded. Trump and his sons have shown little interest in maintaining the appearance of separation, with Eric and Donald Jr. showing up at numerous political events for their father. Roughly two weeks before the election, Donald Jr. met with a pro-Russian group in Paris to discuss his father’s policy toward Syria and, according to Politico, was involved in his father’s search for a Secretary of the Interior; he was also spotted hunting in Turkey shortly after his father’s phone call with Turkish President Recep Erdogan in which the president praised a Turkish business partner. Eric, meanwhile, appeared in photos with his father and a group of Indian businessmen mere days after the election.  And both were present for the president’s announcement of his nominee for the Supreme Court.

Then, when asked about the blind trust in a March 24 interview with Forbes, Eric gave answers that seemed to contradict not only the arrangement to which he supposedly agreed but also his own statements on the topic. “I do not talk about the government with him, and he does not talk about the business with us. That’s kind of a steadfast pact we made, and it’s something that we honor,” he said, before telling the interviewer that he will be providing updates to his father “on the bottom line, profitability reports and stuff like that” on a quarterly basis. “My father and I are very close. I talk to him a lot. We’re pretty inseparable,” he concluded. If Trump is in constant contact with Eric and receiving updates on his businesses from his sons, it renders the trust they created effectively meaningless—and validates the concerns watchdog groups raised when Trump first unveiled his plan in January.

After Eric Trump made those comments to Forbes, other holes in Trump’s plan have come to light. On April 3, ProPublica discovered a previously unreported change to the trust arrangement that effectively allows the president to personally withdraw money from his businesses at virtually any time he chooses. On February 10, a clause was apparently added to a letter outlining the details of the trust stating that “the Trustees shall distribute net income or principal to Donald J. Trump at his request, as the Trustees deem necessary for his maintenance, support or uninsured medical expenses, or as the Trustees otherwise deem appropriate.” In other words, Trump will be able to draw profits from his businesses at any time during his presidency as long as he and the trustees—again, his two sons and his long-time business partner—agree that it is “appropriate,” and will not have to disclose when he does so. This goes directly against the purpose of a blind trust, which in this case would be to distance Trump from his sources of income in an attempt to get rid of his incentive—or even ability—to consciously act in his own financial interest. So far, the plan unveiled in January appears to be as inadequate as many ethics experts had feared.

Finally, removing himself from day-to-day operations will do little to change the fact that Trump will retain substantive knowledge of the illiquid assets involved in his business, such as the numerous buildings and other products that bear his name, especially if he remains in frequent contact with his children. Even assuming that Trump does separate himself from any consideration of his holdings, his children will still likely be major players in the family’s organization, which will still bear at least the Trump name—arguably one of their most valuable properties, as much of the family’s wealth derives from licensing the name to third-party companies. Given the family’s oft-touted brand-consciousness (Ivanka, for example, briefly appeared to be distancing herself from the campaign, and several properties considered rebranding under the name “Scion” when it appeared Trump would lose), the situation epitomizes the way Trump’s, and his family’s, business interests may very well prove inextricable from his actions as president.

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Those Fannie and Freddie Investments

After railing against elites during the campaign, Trump has so far stocked his prospective cabinet with an array of billionaires whose policy positions seem likely to significantly benefit those who are also doing very well. Trump’s putative treasury secretary, Steven Mnuchin, is no exception: His resume includes stints as a banker at Goldman Sachs, a Hollywood producer, and the operator of a bank that has been described as a “foreclosure machine” and once foreclosed on a homeowner over a 27-cent discrepancy.

One of Mnuchin’s apparent beliefs is that the government should cede control of the mortgage guarantors Fannie Mae and Freddie Mac, which the government acquired during the 2008 financial crisis. The two financial institutions’ stocks rose by more than 40 percent after Mnuchin stated that he believes the Trump administration “will get it done reasonably fast.”

Doing so would be broadly compatible with Trump’s general antipathy toward regulation of the banking industry. However, The Wall Street Journal identified an additional wrinkle to the story: When Fannie Mae and Freddie Mac’s stocks rose, one major beneficiary was John Paulson, an adviser to the Trump campaign and a business partner of Mnuchin’s. Paulson’s hedge funds include significant investments in both Fannie and Freddie. Trump himself has invested between $3 million and $5 million across three of Paulson’s funds, according to his filings with the Federal Election Commission (which remain the only available window into the president’s financial holdings). In other words, as Fannie Mae and Freddie Mac’s stock prices increase—and they have so far more than doubled since the election on the expectation that the incoming Trump administration will be more lenient toward the financial sector than Obama—Trump’s portfolio benefits.

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That Phone Call With Taiwan

When news first emerged that the president spoke on the phone with Taiwanese President Tsai Ing-wen on December 2, the immediate reaction was uproar over his apparently impetuous breach of decades of U.S. protocol toward China and Taiwan. As my colleague David Graham explained, since 1979, the United States has participated in the “artful diplomatic fiction” of officially recognizing the mainland People’s Republic of China as the only legitimate Chinese government while maintaining loose, unofficial recognition of—and significant economic and military ties to—Taiwan. That Trump would speak to the president of Taiwan, especially before doing the same with Xi Jinping, the president of the PRC, flies in the face of a diplomatic tradition that has undergirded almost 40 years of U.S.-China relations.

Amid the days of dissembling that followed the phone call, an additional worrisome detail came out: At the time, the Trump Organization was apparently exploring expansion into Taiwan. Soon afterwards, the Trump Organization denied that it planned to do so; however, even before the controversy arose, the mayor of Taoyuan, Taiwan, the municipality in which the Trump Organization allegedly wants to build, described in a televised interview a meeting with a representative of the Trump Organization in September to discuss prospective real-estate projects, and at least one Trump employee was found to have posted on Facebook that she was in Taiwan at the time on a business trip. Based on the January 11 announcement that the Trump Organization will be suspending its development plans and will not pursue foreign deals in office, it would appear that any movement on development in Taiwan is no longer on the table.

The phone call, and the many statements that have followed, are of particular interest because of the extent to which they dovetail with some of the biggest concerns about Trump’s approach toward governance. In the ensuing 48 hours, Republican officials offered several, sometimes entirely contradictory, explanations of what initially appeared to be an impulsive move by Trump; depending on who was speaking, the phone call was actually initiated by Ing-wen (which, if technically true, ignores that it was Trump’s staff who arranged the conversation), was just “a courtesy,” or manifested a policy shift weeks in the making—although, regardless, it was made without first consulting the White House or State Department. The defense of the move, and the questions it creates regarding conflicts of interest, have largely hinged on the belief that, since voters apparently don’t mind, the reaction was overblown.

On this issue, though, whether or not voters care is immaterial to the central question. The president of the United States breached decades of international protocol created to preserve a precarious balance of power. That decision raised not only the possibility that Trump was blundering into a potential international incident but also that he may have done so in part out of consideration for his business prospects.

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That Deutsche Bank Debt

Though he often brags about leveraging corporate-finance law to become “The King of Debt,” Trump’s numerous bankruptcy filings have left most large Wall Street banks reticent to lend to him, according to The Wall Street Journal. Among the few exceptions is Deutsche Bank, which “has led or participated in loans of at least $2.5 billion” to the president since 1996, with at least another $1 billion in loan commitments to Trump-affiliated companies; more than $300 million of those loans have come since 2012.

The president’s indebtedness does not itself pose a conflict of interest, but Deutsche Bank’s ongoing legal troubles very well might. The Justice Department is currently negotiating with Deutsche Bank regarding a preliminary settlement of $14 billion to resolve probes into allegedly misleading predatory lending practices in the leadup to the 2008 financial crisis; while it is believed that Deutsche Bank will push back against the sum, there has been no public news regarding negotiations since the initial figure was reported in September. Trump will soon be naming many of the officials with jurisdiction over this and other deals, prompting several House Democrats to send a letter to federal financial agencies calling for close scrutiny of how Trump may seek to influence the settlement through his appointments—although doing so would be just as in keeping with his general stance toward financial regulation as with active protection of his pocketbook. Other Democrats have called for the proactive appointment of independent prosecutors to avoid any appearance of conflict if the case is not resolved before Trump takes office.

Fears that Trump may unduly consider his indebtedness to Deutsche Bank in deciding his administration’s policy toward the financial sector go beyond general anxiety about deregulation. Deutsche Bank is undergoing a period of struggle that may have it on the verge of failure already. Its stock valuation has dropped by more than half since July 2015; in January, it posted its first full-year loss since 2008; and one of its many tranches of bonds—one specifically designed to be a high-risk, high-reward safety valve in times of trouble—has recently begun to crash. In June, the International Monetary Fund called Deutsche Bank “the most important net contributor to systemic risks” among globally important financial institutions. If the bank were to fail, it could have major consequences for not only Trump’s businesses, which would lose their sole remaining lender, but for the global economy as well.

Arguably, the $14 billion fine the Justice Department is seeking to impose has exacerbated rather than alleviated these struggles. Based the company’s market capitalization—the number of shares multiplied by their price— of roughly $16 billion, the sum would leave Deutsche Bank critically low in liquid assets with which to absorb future troubles, although the institution’s own self-valuation of $68 billion argues otherwise. But given the complexity and potential volatility of the situation, it is important for any decision to be free from outside influence, something Trump’s outstanding debt threatens to jeopardize.

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That Property in Georgia (the Country)

Trump’s election has had the effect of speeding up development on a number of his branded properties, even when the president appears not to be pulling any strings himself. As occurred with Trump Tower Buenos Aires, the completion of an embattled Trump-branded building in the former Soviet republic of Georgia is no longer on hold now that Trump has won. The project, which has been in the works in the seaside resort city of Batumi since 2010, was initially scheduled to break ground in 2013, but has been in stasis for several reasons, possibly including the 2013 electoral defeat of President Mikheil Saakashvili, a friend of Trump’s and a supporter of the deal.

According to a report in The Washington Post, the green-lighting of the Trump property in Batumi has not been linked to a specific conversation with Georgian leaders, and a U.S.-based partner on the project has suggested that it has moved forward without any nudging from the government. However, numerous public statements in the days since suggest that Trump’s election was a major factor, including an interview with a real-estate entrepreneur who said, “Cutting the ribbon on a new Trump Tower in Georgia will be a symbol of victory for all of the free world.”

That the property seems to be moving forward solely because Trump was elected suggests his various business interests around the world may play a role not only in his foreign policy but in how other countries seek to deal with the U.S. as well. America’s relationship with Georgia is largely shaped by concerns about Russian influence and potential aggression in the region, most recently manifested in Russia’s 2008 seizure of two regions of Georgia, South Ossetia and Abkhazia. With controversy already swirling over Trump’s admiration for Putin and Russia’s alleged role in the U.S. election, some in the foreign-policy community have expressed trepidation that Trump’s potential deferential attitude toward Russia would prove deleterious for the continued independence of former satellite nations like Georgia. So, if Georgia has an ulterior motive behind the approval of Trump’s property in Batumi, it would be to keep Russia at bay and maintain the status quo in the region.

According to Trump and his lawyer, as of January 11, the Trump Organization has suspended ongoing development projects and will no longer pursue deals in foreign countries. As the project in Batumi falls under both categories, the statement suggests that progress on the president’s property in the city is no longer moving forward. Still, it’s alarming that a country like Georgia may be giving Trump’s businesses favorable treatment (whether he asked for it or not) in an attempt to influence his foreign policy.

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That Phone Call With Erdogan

One of the worries regarding Trump’s many conflicts of interest is that they may influence policy towards countries whose relationships with the U.S. are currently strained. Such is the case with Turkey, whose president, Recep Erdogan, has been cracking down significantly on civil liberties and democratic institutions within the country after a failed coup last summer. Though Turkey has in the past been a vital U.S. ally as a bulwark against Islamic terror, Erdogan’s authoritarian turn and combative stance toward Europe have led to some reevaluation of that relationship.

Thus, it was troubling news that when Erdogan phoned Trump shortly after the election—it was one of the first calls Trump received after his victory—Trump used the opportunity to plug his business partners in Istanbul. According to the Huffington Post, while on the line with Erdogan, Trump relayed praise for the leader from Mehmet Ali Yalcindag, whose father-in-law, Aydin Dogan, owns the holding company that operates the Trump Towers in Istanbul. Dogan has previously drawn Erdogan’s ire by criticizing the leader; in recent years, however, Dogan’s companies, most notably CNN Turk, have shown support for Erdogan’s regime, including broadcasting his first message after the uprising in July.

Trump’s conversation with Erdogan is also worth noting because of a number of Trump’s previous statements regarding the Turkish president. Though Erdogan briefly called for Trump’s name to be removed from the Istanbul property due to his proposed ban on Muslim immigration, Erdogan dropped the demand when, after the overthrow attempt, Trump praised Erdogan for “turning it around” and essentially dismissed concerns over Erdogan’s crackdown on civil liberties by bringing up domestic problems. Michael Flynn, who was recently named Trump’s national security adviser, wrote an election-day op-ed in The Hill arguing against offering asylum to a Muslim cleric whom Erdogan has accused of orchestrating the uprising, which some have interpreted as a diplomatic overture. Erdogan has also bristled at post-election protests in the U.S. and the description of both himself and Trump as part of a “ring of autocrats.” That the two are now talking about their countries’ relationship as in the same conversation as Trump’s business interests further complicates Trump’s strangely effusive comments about Erdogan.

It’s worth noting that Trump himself considers his hotel in Istanbul a potential conflict of interest. In a December 2015 interview with Stephen Bannon, at the time the chairman of Breitbart News, Trump said as much, telling Bannon, “I have a little conflict of interest ‘cause I have a major, major building in Istanbul. It’s a tremendously successful job.” That he chose to discuss the towers with Erdogan, albeit obliquely, through his references to his business partners when he has already acknowledged the impropriety of doing so simply reinforces the perception that he may prove unable to separate his business from his official duties while in office.  

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That Hotel in Washington, D.C.

The White House is not the only Trump property in Washington, D.C.; there’s also the Trump International Hotel, which opened last October and is located just a few blocks away in what was formerly known as the Old Post Office Pavilion. Previously, the hotel played a role in the presidential campaign as the site of the event at which Trump halfheartedly recanted his belief that Barack Obama was not born in the United States. Now, the hotel is a symbol of how inextricable Trump’s presidential role is from his business interests.

Trump himself acknowledged that his presidency would likely increase traffic to his Washington property. Speaking to The New York Times shortly after the election, the then-president-elect noted that the property is “probably a more valuable asset than it was before” and that his brand is “hotter” since the election. The numbers certainly seem to bear that prediction out: After projecting that the hotel would lose $2.1 million in the first four months of 2017, the Trump Organization revealed in August that the property had instead made $1.9 million in profit. This beating of expectations reflects more than anything else the exorbitant prices the hotel is charging: Guests are on average paying more than $650 per night, an increase of more than $200 over the Trump Organization’s projections for what the market would bear—and $150 more than the average price for other similar luxury hotels in D.C.

The Trump International Hotel’s unexpected profits are also a worrisome indicator regarding the relationship between Trump’s businesses and his presidency, especially considering that, shortly after the election, the hotel hosted a promotional event aimed at enticing foreign diplomats to stay there while in town on official state business. Critics have argued that the hotel thus violates the Constitution’s emoluments clause, which makes it illegal for a federal official to “accept of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State” lest the payment influence his or her decisions.

Direct influence would likely be difficult to prove: The establishment is, after all, a five-star hotel that would have been likely to attract clientele even if Trump had lost the election, a fact to which Trump and those who surround him may well point in their defense. Still, the hotel’s unanticipated popularity and several events held by both foreign governments and other interest groups reinforce the notion that Trump may be inappropriately commingling his financial interests with his duties as president.

A string of post-election events have kept the Trump International Hotel a focal point in discussions of his conflicts of interest, including among Democrats in the House. On November 29, 2016, Bahrain—a country whose donations to the Clinton Foundation Trump decried during the campaign—announced it would be celebrating at the hotel the anniversary of its king’s ascension to the throne. Other events announced not long after the election included a Hannukah celebration co-hosted by the Embassy of Azerbaijan and the Conference of Presidents of Major American Jewish Organizations and a reception for the conservative think tank the Heritage Foundation featuring Vice President Mike Pence as its keynote speaker.

Nor did the string of bookings by international entities end after Trump’s inauguration: On February 9, Politico reported that a lobbying group with connections to the government of Saudi Arabia had booked a four-day stay at the hotel in Washington, D.C. And on March 13, The Daily Caller reported that the Turkish-American Business Council, whose chairman paid $530,000 to Trump’s former National Security Adviser Michael Flynn to lobby on behalf of the Turkish government, would be co-hosting its annual conference at the hotel after a seven-year run at the Ritz-Carlton.

Moreover, since the election, ethics groups and critics of the president have alleged that, since taking office, Trump has been in continual violation of the lease he holds on the Old Post Office, the government-owned building the Trump International Hotel inhabits. At issue is a clause in the lease stating that “no ... elected official of the Government of the United States shall be admitted to any share or part of this Lease, or to any benefit that may arise therefrom.” As such, watchdog organizations such as Citizens for Responsibility and Ethics in Washington (CREW) have repeatedly appealed to the Government Services Administration (GSA), the federal agency that administers the lease, to terminate the agreement with the Trump Organization.

On March 23, however, the GSA released a letter finding that Trump “is in full compliance” with the lease. According to Kevin Terry, the contract officer who oversaw the initial negotiations between the government and Trump, the president’s plan to turn over his businesses to his two adult sons and the long-time Trump Organization executive Alen Garten is sufficient to meet the terms of the agreement, as Trump is no longer “an officer, director, manager, employee, or other official in any of the entities” involved in operating the hotel. The letter immediately drew outcry from ethics organizations like CREW, which called the ruling “a disappointment” that failed to address the underlying problems of Trump’s businesses, and the left-leaning advocacy group Public Citizen, which described it as “an affront to the rule of law” based on “tortured and wholly uncompelling analysis” that “would get a first-year law student kicked out of law school.”

The GSA’s decision may also prove a blow to the more general argument that Trump has not done enough to distance himself from his namesake organization. Critics have strenuously objected to the plan Trump and his lawyer Sheri Dillon laid out on January 11 to mitigate conflicts of interest, under which the president has stepped down from, but retains ownership of, his numerous business interests, and placed his assets in a trust to be administered by his adult sons and a longtime Trump Organization executive. Trump’s opponents maintain that, because he still has significant knowledge of his business interests and will still be benefiting from them, and because he has put in place few real barriers to communication between himself and his sons, there is still ample opportunity for outside actors to seek to influence the president’s decisions by patronizing his companies. Though the letter from the GSA discusses only the Trump International Hotel and not the legality of the overall arrangement, it is nonetheless a decidedly favorable outcome for Trump in the first legal challenge over his conflicts of interest.

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That Argentinian Office Building

According to a report by the prominent Argentine journalist Jorge Lanata, the president’s first phone call with his Argentine counterpart Mauricio Macri included a discussion of the permit issues currently holding up construction of a new Trump-branded office building in Buenos Aires. Both Macri and Trump quickly denied the report; according to a statement from the Embassy of Argentina, “The subject both leaders talked about was the institutional relationship, and they briefly mentioned the personal relationship they have had for years.”

As summarized in a tweetstorm here, Trump’s relationship with Argentina’s government and business elites—and the story so far on his property there—is already long and convoluted. The phone call with Macri was apparently set up through Felipe Yaryura, one of Trump’s longtime associates whose company, YY Development Group, is in charge of Trump Tower Buenos Aires. The day after the phone call, the PanAm Post reported that YY Development Group had been approved to break ground in June 2017; evidence has since emerged that the permitting process is not, in fact, finished, although Trump’s business associates are moving ahead as though it is.

Based on the information at the president’s January 11 press conference, it appears that the properties in Argentina, as both ongoing development projects and deals in a foreign country, is no longer moving forward. Nevertheless, the questionable circumstances under which it did so in the immediate aftermath of the election demonstrates just how many avenues there are for Trump’s conflicts of interest to interfere with governance around the world.  

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Those Companies in Saudi Arabia

Even as Trump was running for president, his company was continuing to operate and open new properties. While the most memorable openings may have been that of his hotel in Washington, D.C., and his golf course in Turnberry, Scotland, the Trump Organization was continuing to work on projects in other countries, including, according to a report the Washington Post, registering eight new companies in Saudi Arabia during the 16-month campaign.

The organization’s endeavors in Saudi Arabia are notable not only because they may further complicate the shaky relationship between the U.S. and an oil-rich gulf state notorious for human-rights abuses but also because of how they relate to Trump’s campaign rhetoric. One of his criticisms of Hillary Clinton was that her charitable foundation had accepted donations from governments with questionable records on human rights, most notably Qatar and Saudi Arabia, always with the implication (or direct accusation) that they were doing so to curry favor with Clinton when she was secretary of state. That Trump was continuing to level this criticism while his namesake organization was actively pursuing new projects in Saudi Arabia not only bodes ill for his ability to separate his personal and presidential interests but also further calls into question the honesty and transparency of his campaign.

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That British Wind Farm

As he indicated when he stopped there during the campaign, President Trump takes enormous pride in his recently opened golf course in Turnberry, Scotland. The day after the British public voted for Brexit—over intense Scottish opposition—Trump spoke at the property’s opening, proudly touting how the decision’s deflationary effect on the pound would benefit his business.

However, Trump also has a second golf course in Aberdeen, where it appears Trump has attempted to intercede in the interest of his own pocketbook.* According to The New York Times, Trump had a post-election meeting with Nigel Farage in which he “encouraged Mr. Farage and his entourage to oppose the kind of offshore wind farms that Mr. Trump believes will mar the pristine view from one of his two Scottish golf courses.” Hope Hicks, a spokeswoman for the president, denied that the two had discussed the subject, only for Trump to later confirm that the topic had, in fact, come up in their conversation.

* This entry originally misstated that Trump intervened at Turnberry, his other golf course in Scotland. We regret the error.

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Those Indian Business Partners

It didn’t take long after the election for President Trump to be seen in public with international business partners. According to a November 19 article in The New York Times, Trump took a break from his transition schedule to meet with three Indian real-estate executives who are currently building a Trump-branded apartment complex in Mumbai. According to both Trump and the Indian businessmen, the meeting was essentially congratulatory in nature; a picture posted by one of the executives on Twitter shows the four men smiling broadly and giving a thumbs-up to the camera. However, that the meeting happened in the first place suggests that Trump does not currently have any qualms about forestalling official state business for personal business.

On top of that, the meeting raises questions in the blind-trust realm as well. The president himself was not the only member of his family there; two Facebook photos show that Ivanka and Eric Trump both attended the meeting as well. Their presence serves as a reminder that their father seems so far uninterested in maintaining even the nominal separation between himself and his assets that he repeatedly said he would create during the campaign.

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That Envoy From the Philippines

One leader with whom Trump already has an advantage over President Obama is Rodrigo Duterte, the similarly brash president of the Philippines. Duterte, who has threatened to “break up with America,” told Obama to “go to hell,” and called the president a “son of a whore,” expressed admiration for Trump, noting that, among other similarities, they both enjoy swearing.

Duterte’s affinity for Trump apparently goes beyond vulgar word choice. Late in October, Duterte appointed a longtime business associate of Trump’s as a special envoy to the United States, an announcement that became public shortly after the election. This appointment in particular raises questions because it is just as open to exploitation by Duterte as it is to Trump, as the Filipino president could intend to use his new envoy’s relationship with Trump to strengthen the Philippines’ hand. Whichever side the appointment does eventually benefit, however, the situation is nevertheless fraught with conflicts between the three men’s personal and political interests.

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