Mixing Politics with Business

A Master List of Trump’s Conflicts of Interest

By Kate Brannen

 

This article comes from Just Security which is based at the Center for Human Rights and Global Justice at New York University School of Law. A warning to those with short attention spans – this is a long article, far exceeding 140 characters. However, the writing style is lively and readable. The information contained herein is vital for the challenges Americans now face.

Remember that giant pile of manila folders?

They were stacked high at Donald Trump’s press conference on Jan. 11. While no one was allowed to take a closer look at them, the unlabeled folders were said to contain the documents that Trump had signed in order to hand over control of his business to his two sons, Don Jr. and Eric.

The move was supposed to free Trump of any conflicts of of interest as he became president, or at least give the appearance that he’d done that. Sheri Dillon, of the law firm Morgan Lewis, said at the January press conference that Trump had asked her firm to design a structure that would “completely isolate him from the management of the company.” 

As part of this arrangement no new foreign deals would be made while Trump was president. New domestic deals would be allowed but would undergo vigorous vetting, according to Dillon. Trump would limit how much information about the business could be shared with him. And the Trump Organization, through its social media and marketing materials, would not refer to Trump as president.

Dillon also addressed the Emoluments Clause in the Constitution, which is meant at a minimum to protect the American public from a foreign government being able to bribe the president. Dillon argued that it could not be construed to cover fair value goods or services, for example, paying one’s bill at a Trump hotel. (Trump is now facing three Emoluments lawsuits that argue these kinds of payments represent exactly the kind of foreign payments that the Constitution sought to prohibit.) 

Despite asserting that foreign governments’ spending money at Trump properties could not be considered an emolument, Dillon said Trump would voluntarily donate all profits made from foreign government payments to his hotels to the U.S. Treasury.

This was the ethics plan that Trump laid out for himself and his family. It was meant to assure the public that Trump’s private business interests would never overlap or influence his duties as president. His daughter, Ivanka, and her husband, Jared Kushner, made somewhat similar arrangements for themselves and their companies as they got ready to work in the White House. 

While all three distanced themselves to some degree from the companies and brands that carry their names, their financial stakes in the Trump and Kushner business empires remain the same. As for Trump’s sons, they frequently attend White House events and remain very much a part of the political scene surrounding their father.

It has become difficult to track these conflicts of interest stories as they often get drowned out by competing headlines. To help keep up, below is an attempt at a master list. It’s not comprehensive, but it starts to paint a picture of the vast number of issues that require oversight and scrutiny during this presidency. 


If you see anything I’ve missed, please send it my way. 

Not Tracking Profits from Foreign Governments

To avoid the violating the Constitution’s Emoluments clause and the appearance of a conflict of interest, Trump pledged to donate any profits his hotels earned from foreign governments to the U.S. Treasury.

In May, NBC News reported the Trump Organization is not actually tracking these payments. According to a company pamphlet, Trump Hotels is not going to “attempt to identify individual travelers who have not specifically identified themselves as being a representative of a foreign government entity.”

Asking guests to identify themselves as working for a foreign government “would impede upon personal privacy and diminish the guest experience of our brand,” said another company document, the Guardian reported .

No Tax Returns, No Transparency

While we know a lot about Trump’s properties and sprawling business empire, it is still a mostly opaque picture. This is because, unlike his predecessors, Trump has not publicly released his tax returns, which would provide a much fuller picture of Trump’s financial information. 

The public is also unaware of which loopholes and tax provisions Trump personally benefits from, which is important information for the public to  gauge his motives and interests, for example, as his administration pursues tax reform.

New foreign deals

“Seeking global opportunities” As of June 28, Trump Hotels is “actively expanding its portfolio of award-winning luxury hotels and resorts and seeking global opportunities for the best developments in key destinations to add to our renowned portfolio,” according to its own website. The ethics plan laid out by Trump’s team in January promised no new foreign deals as long as Trump is president.

Resort in the Dominican Republic The Trump Organization is pursuing a licensing deal for a beachfront resort in the Dominican Republic.  The Trump Organization’s general counsel defended the project in February, saying it’s not a “new” deal, as the original agreement was signed in 2007. The project was stalled for years amidst the 2008 financial crisis and a dispute over Trump’s fees. The Trump family’s reengagement with the deal surfaced “unexpectedly” from published photos of Eric Trump visiting the property.

While in Dubai in May, Don Jr. discussed “new ideas” Trump Jr. “met a billionaire business partner in the city-state, discussing ‘new ideas’ as the Emirati’s real estate firm still lists possible plans for future joint projects while Trump’s father is in the White House,” reported the AP.

In his Instagram post documenting the meeting, Hussain Sajwani wrote, “Discussing new ideas and innovation always make our meetings even more interesting.”

DAMAC Properties, the Dubai-based developer owned by Sajwani, offered $2 billion in deals to Trump’s company after the election, but Trump turned them down.

Properties Opened After Jan. 20

Trump International Golf Club in Dubai In February, Don. Jr. and Eric Trump attended the opening of the Trump International Golf Club in Dubai, the largest city in the United Arab Emirates. “All services to the property — electricity, water, roads — come at the discretion of the government. The club’s bar will need government approvals to serve alcohol, not to mention other regulatory issues,” the AP reported.

Trump World Golf Club Dubai, a second golf project, is also in the works. According to the company, it “will be designed by the iconic golfing superstar Tiger Woods.”

Trump Vancouver opens Eric and Don Jr. also attended the opening of Trump International Tower and Hotel in Vancouver, Canada in February. The Trump Organization is licensing the name to the building and managing the hotel, but does not own it. The father of the tower’s Malaysian developer, Joo Kim Tiah, is one of Malaysia’s wealthiest businessmen. 

According to the New York Times, the new Trump tower in Vancouver has some interesting residents such as Sou Lam Fong, who founded a company that is majority-owned by a Chinese state-owned enterprise.

Toronto’s Trump International Hotel has been bought and will be rebranded the St. Regis Toronto.

Other Foreign Properties

UK wind farms and Trump’s golf course in Scotland Trump encouraged British politician Nigel Farage and other Brexit leaders to oppose offshore wind farms when he met with them in New York following the election, according to The New York Times. Trump is worried that the windmills will ruin the view at one of his golf courses in Scotland. At first the Trump team denied that such an exchange took place, but Trump then admitted he “might have brought it up.”

Business in India Three Indian real estate executives flew from India to congratulate Trump and meet with his children after the election, the Times reported. They are building a Trump-branded apartment complex south of Mumbai. During the meeting, Trump praised India’s Prime Minister Narendra Modi, The Economic Times reported. According to an investigation by The Times, Trump has five projects underway in India.

These include two new projects in the suburbs of New Delhi, both deals signed before Trump won the election in November. The Washington Post reported that the company’s Indian business partners are “already attracting the attention of law enforcement authorities.”

Trump Tower at Century City in Manila A new $150 million tower, branded with the Trump name, is set to open next year in the Philippines. Jose E.B. Antonio, chief executive and controlling stakeholder of Century Properties, the company behind the tower, was appointed last month to serve as a special government envoy to the U.S. for President Rodrigo Duterte, reports Bloomberg. Since taking office, Duterte has killed thousands of Filipinos as part of his “anti-drug” campaign. During a phone call in April, Trump reportedly told Duterte that he’s  doing an “unbelievable job on the drug problem,” and invited him to visit the Oval office anytime he wants to come.

Trump project in Buenos Aires The Trump camp and President of Argentina Mauricio Macri both denied that they discussed permits for Trump’s project in the country when they talked on the phone after the election. But three days after the phone call, Trump’s associates in Buenos Aires — the YY Development Group — announced Trump Tower in Buenos Aires would be moving ahead. Felipe Yaryura, an executive partner of YY Development Group, was with the Trump family at the New York Hilton on the night of the election and was   photographed celebrating with Eric Trump.

Taiwan Conflicting reports surfaced after Trump’s now infamous Dec. 2 phone call with Taiwanese President Tsai Ing-wen about whether the Trump Organization is looking to drum up business in the country. In November, the mayor of Taoyuan said Trump is interested in building luxury hotels in Taoyuan City, a suburb of Taipei, and that a female representative of the company visited Taiwan in September. The Trump team immediately pushed back on the report, saying, “There have been no authorized visits to Taiwan on behalf of Trump Hotels for the purposes of development, nor are there any active conversations.” But as The Wall Street Journal reported, it appears at least one informal meeting may have taken place.

Trump Towers Istanbul Opened in 2012, Trump Towers Istanbul is not owned by Trump, but like other properties around the world, a local company leases the Trump brand name. In June 2016, Turkish President Recep Tayyip Erdogan called for Trump’s name to be removed from the towers, citing the presidential candidate’s Islamophobia, the Wall Street Journal reported at the time. 

In his call with President Erdogan on Nov. 9, Trump mentioned one of his Turkish business partners, who is part of the company that owns Trump Towers in Istanbul and pays the Trump Organization to license the name and brand. On the call, Trump referred to his business partner as a “close friend” and passed on that he is “your great admirer.”

In April, Trump called Erdogan to congratulate him on his referendum victory that will “cement his autocratic rule over the country and, in the view of many experts, erode Turkey’s democratic institutions” according to the New York Times. 

While the White House has since claimed that the call was not intended as an endorsement of the outcome, or even an acceptance of the results, critics have pointed to Trump’s history of praising Erdogan’s anti-democratic policies. Trump then hosted Erdogan at the White House in May.

Investigation into Trump Hotel Rio de Janeiro In its exhaustive investigation on Trump’s business holdings and properties, the New York Times reported that this hotel in Brazil, which pays for the Trump brand, is under criminal investigation “by a federal prosecutor who is examining whether illicit commissions and bribes resulted in apparent favoritism by two pension funds that invested in the project.”

Trump International Golf Links in Ireland The New York Times investigation also showed that Trump is fighting to build a seawall to protect his golf course in County Clare, but has been stymied by environmentalists trying to protect a snail species and the sand dunes, as well European Union rules that protect the dunes. A national planning board is expected to decide on the issue soon.

Trump Tower, Batumi gets nixed The Trump Organization and Silk Road Group, a company in the former Soviet republic of Georgia, jointly announced on Jan. 6 that they were ending the development of Trump Tower, Batumi, a residential condominium. Trump wouldn’t own the tower, but similar to other arrangements, he would be paid for the use of his name. 

McClatchy reported that “Silk Road Group, had business ties and relationships that could have been problematic for a sitting U.S. president. Over the years it had oil trading and transport deals with companies in both Russia and Iran, countries currently facing varying degrees of U.S. and European financial sanctions.”

Trump International Hotel & Tower Baku The Trump Organization had some dubious business partners in a hotel deal in Baku, Azerbaijan, The New Yorker reported. While the Trump Organization says it conducted extensive background checks on its business partners for the hotel, the Azerbaijani business developers are relatives of the Mammadov family, linked to the Iranian Revolutionary Guard Corps. 

According to Jessica Tillipman, an assistant dean at George Washington University Law School, who specializes in the Foreign Corrupt Practices Act, “The entire Baku deal is a giant red flag—the direct involvement of foreign government officials and their relatives in Azerbaijan with ties to the Iranian Revolutionary Guard. Corruption warning signs are rarely more obvious.”

According to McClatchy, “The Trump Organization backed out of that relationship in mid-December, about a month before Trump took office and about three weeks before scrapping the Georgia deal.”

Chasing deals in Russia for years In January, Trump said, “I have no deals that could happen in Russia, because we’ve stayed away. And I have no loans with Russia.” It’s true Trump has no properties in Russia known to the public, but it’s not true that Trump has stayed away. 

As the New York Times reported, “Mr. Trump repeatedly sought business in Russia as far back as 1987, when he traveled there to explore building a hotel … As recently as 2013, Mr. Trump himself was in Moscow. He had sold Russian real estate developers the right to host his Miss Universe pageant that year, and he used the visit as a chance to discuss development deals, writing on Twitter at the time: ‘TRUMP TOWER-MOSCOW is next.’”

Trump International Hotel, Washington, D.C.

Lease Violations? In 2013, Trump signed a 60-year, $180 million lease with the federal government to take over the Old Post Office Pavilion in Washington, D.C., now the site of Trump International Hotel, which opened in September. 

This meant that when Trump became president in January, he essentially became both landlord and tenant, a situation that “presents unprecedented and intolerable conflicts of interest,” reported Government Executive. When he took office, he breached his contract, which reads, “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…”

In March, the General Services Administration (GSA), which oversees the lease, determined the lease was valid and that the Trump Organization was in full compliance with its terms. Stephen Schooner, an expert on government procurement law at George Washington University, told NPR that he thought the GSA decision was “unbelievable” and “unpersuasive, as a matter of law.”

Hosting foreign diplomats Following the election, the Trump International Hotel in Washington, D.C., hosted an event for the foreign diplomatic community that included Trump-branded champagne and a sales pitch on the new hotel, reported The Washington Post.

Foreign governments’ party POLITICO reported that the Kingdom of Bahrain planned to observe its 45th national day at the hotel after Trump won the election. Azerbaijan’s embassy hosted a Hanukkah party at the hotel, reported The Jerusalem Post in December. 

The Kuwaiti government could be fronting a $60,000 bill to Trump’s Washington, D.C. hotel for a party held by Kuwait’s embassy there Feb. 22 in celebration of their national day, Reuters reported. The event is traditionally held at the Four Seasons Hotel.

Lobbyists working on behalf of Saudi Arabia stay at Trump Hotel POLITICO reported in February that “Qorvis MSLGroup, a communications firm that lobbies for the Saudis, has been organizing veterans and other activists to come to Washington to urge Congress to repeal the law letting 9/11 victims’ families sue the kingdom. 

Between 20 and 40 veterans, with the assistance of the advocacy group NMLB, stayed at the Trump International Hotel on Pennsylvania Avenue in December and January.” A group of families of Sept. 11 victims called upon the Justice Department to investigate the situation.

The Wall Street Journal reported in June that the Saudis paid the Trump Hotel $270,000 through Qorvis.

Trump’s First Dinner Out: His Own Restaurant For his first meal outside of the White House, Trump dined out at his own restaurant in the Trump International Hotel.

Using the White House to Advertise the Trump Hotel Suites In an email advertisement for its Washington, D.C. hotel, the Trump Organization displayed an image where it appeared you could see the White House outside the hotel’s window, even though the Old Post Office building is about a half-mile away. But it wasn’t the White House, but a lightened photo of the EPA building, which is across the street, the Washington Post reported.

Ambassador tweets his praise In April, the Ambassador and Permanent Representative of Georgia to the UN, Kaha Imnadze, lavished Trump’s Washington hotel with praise on Twitter, saying, “Trump International Hotel Washington DC @TrumpDC – great #hotel and so far the best service I’ve seen in United States! Keep it up! #travel”

Trump hosted re-election fundraiser at Trump Hotel More than three years before the election, Trump launched his 2020 Trump re-election fundraising campaign with a $35,000-per-plate donor event on June 28 at Washington’s Trump International Hotel.

Anti-sharia group touts chance to access president’s business An anti-sharia group, ACT for America, offered sponsors “pre-conference cocktails” and a “private tour of the historic Trump Hotel” for $10,000 ahead of its upcoming Washington conference. The tour will take place before participants lobby lawmakers on national security issues. “The promotion represents a new twist in the story line of Trump’s luxury hotel,” reported the Washington Post. “Groups typically pay to book meeting space and food service at the Trump hotel like they would at any event venue, but ACT is touting the chance to enjoy access to a signature business owned by the president.”

Mar-a-Lago

Membership price doubles The initiation fee of the Mar-a-Lago resort, owned by the Trump Organization, doubled from $100,000 to $200,000, effective Jan. 1.

Who paid for Abe’s stay at Mar-a-Lago? Japanese Prime Minister Shinzo Abe Abe’s visit to the U.S. in February included a scheduled round of golf with Trump and a stay at the Mar-a-Lago resort. Before the visit, a senior White House official said “The visit to Mar-a-Lago is a personal gift of — I don’t know exactly how we’re phrasing it, but it’s something that the President is doing for the Prime Minister.”

Trump coordinated response to North Korean missile testing from Mar-a-Lago dining room President Trump and his aides coordinated a response to the North Korean ballistic missile test in the public dining room at the Mar-a-Lago resort during Abe’s visit. Club members, with front seats to an emerging national security crisis, posted photos of the entire event on Facebook. 

One guest posted a picture with the U.S. official charged with carrying the nuclear “football,” a briefcase that enables the president to authorize a nuclear attack.

After this, the club posted new regulations forbidding photos or videos of the president while he is on the resort premises, but even since then  The Palm Beach Post and others on social media have published photos of Trump mingling with guests.

Senators demand IG investigate Mar-a-Lago visits Sen. Tom Udall (D-N.M.) wrote a letter in February to the Department of Homeland Security Inspector General demanding an investigation as to whether Trump had violated the Emoluments Clause at Mar-a-Lago. Four other senators signed the letter, requesting a report within 90 days. The letter said that it was unclear whether the club is charging Trump’s staff, members of the Secret Service, or military aides for rooms or other services at the resort. If they were, it “directly benefits the President’s business and allows him to profit off of every vacation he takes to one of his properties.”

Trump Hosted Chinese President at Mar-a-Lago Trump hosted his first meeting with Chinese President Xi Jinping at Mar-a-Lago.

State Department promotes Mar-a-Lago In April, a handful of government websites promoted Trump’s Florida property. POLITICO reported: “The State Department and at least two U.S. embassies — the United Kingdom and Albania — earlier this month circulated a 400-word blog post detailing the long history of the president’s South Florida club, which has been open to dues-paying members since the mid-1990s and is now used by Trump for frequent weekend getaways. He has hosted foreign leaders there twice.”

Other U.S. properties

Trump Hotels eyes expansion in the U.S. In January, Trump Hotels CEO Eric Danziger said, “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.”

A Second Washington, D.C. Hotel? The Trump Organization is looking into opening a second hotel in Washington, D.C., potentially creating another opportunity for President Trump to “benefit financially from customers doing business in the nation’s capital,” reported the Washington Post in March. 

Representatives of the company have been looking into converting one of several medium-sized hotels in Washington into a Scion-brand hotel, a sub-brand the company launched last year. The plan for the four-star Scion hotels is for other developers to own the properties and pay the Trumps for licensing rights and management. The first publicly announced location for a Scion property is in Cleveland, Mississippi.

Trump Organization to debut “American Idea” hotel chain in Mississippi The Trump Organization is also planning to roll out a separate three-star hotel line called American Idea, evoking the “America First” theme of the Trump campaign. The New York Times reported in June that the Trump children were unimpressed with the budget-friendly hotels they encountered on the campaign trail. 

The Organization will debut the “patriotic” hotels in towns in Mississippi, a state which voted heavily in Trump’s favor. Similar to the new Scion chain of hotels, the Trumps won’t own the new hotels but will license the brand to business partners. Unlike with the Scion hotels, Trump’s company will not be responsible for management at the American Idea hotels.

The tenants at Trump Tower Manhattan The Industrial and Commercial Bank of China (ICBC), whose majority owner is the government of China, leases office space at Trump Tower in Manhattan.

The Department of Defense rents space A spokesman for the Pentagon, announced in February that the Defense Department was seeking to lease limited property space in Trump Tower. “The space is necessary for the personnel and equipment who will support the POTUS at his residence in the building,” the spokesman said. 

A leasing agent from Trump Tower, which is owned by the Trump Organization, told CNN that the rent for an available floor in the building is around $1.5 million a year. Based on a November estimate from the New York Post, the lease held by the Secret Service in Trump Towers could also be costing taxpayers up to $3 million a year, and a significant amount of that rent payment heads to the pockets of the Trump Organization.

The Next FBI Headquarters Vornado Realty Trust, which owns other buildings with Trump and the Kushners, is one of three finalists competing for the $2 billion contract to build the agency’s new headquarters. The Baltimore Sun reported that “Trump has never spoken about it publicly and did not include funding for the headquarters in his budget proposal. The General Services Administration announced in March that it would delay moving forward with the building until Congress sets aside more money for it.”

Trump’s Possible Ties to the Keystone and DAPL Pipelines Trump signed two orders in March clearing the path for the Keystone XL and Dakota Access Pipeline (DAPL)  — both oil pipeline projects, which President Barack Obama rejected in November. Trump’s recent financial disclosures, however, have spurred conflict-of-interest concerns surrounding the deals.

In December, Trump spokeswoman Hope Hicks told the press that Trump had sold off his original $15,00 to $50,000 worth of shares in Energy Transfer Partners, the owner of the nearly $4 billion DAPL project. As reported by CNBC, Hicks did not say if Trump had sold all his stocks in Phillips 66, which has a 25 percent share of DAPL. 

Trump’s federal disclosure forms for 2016 reported that he owned between $100,000 and $250,000 of Phillips 66. The Washington Post also reported that CEO of Energy Transfer Partners Kelcy Warren donated over $1.5 million to GOP super PACS during the campaign, and Warren donated $100,000 to the Trump Victory Fund this June.

Trump’s frequent visits to his own golf courses and restaurants When Trump leaves the White House on the weekends, it’s often to visit one of his golf courses. The Trump golf course in Sterling, Virginia hosted the PGA championship over Memorial Day Weekend. Eric Trump, promoting the event, said “I think our brand is the hottest it has ever been.”

Trump campaign paid $500K to Trump’s companies in 2017 Trump campaign filings show that the campaign and a joint fundraising committee have spent nearly $500,000 in 2017 for facility rental and lodging at Trump hotels, rent at the Trump Tower in New York and catering from Trump restaurants, according to the Washington Post.

Trump’s Caribbean estate listed for sale “If someone does pay anything close to the asking price, it will be because they are paying a premium to say they own a property that was once owned by President Trump,” a real estate agent familiar with the property told the Washington Post. Four St. Martin real estate agents told the Post that the $28 million price tag “far outstrips the amount that sellers are getting for the most exclusive properties on the island.”

Trademarks

Ivanka’s Chinese trademarks approved Since the inauguration, the Ivanka Trump brand, which is still owned by Ivanka, has secured approval for trademarks from the Chinese government. It secured three of them on the same day Ivanka sat next to the Chinese president for dinner at Mar-a-Lago in April, the AP reported. The company’s global sales have skyrocketed since the election, hitting record levels in 2017.

The AP also reported in April, “Globally, the company has more than 180 pending and registered trademarks in countries including Canada, India, Japan, Israel, Mexico, Turkey, Saudi Arabia, as well as the U.S. and Europe, public records show. 

In December, the company applied for five trademarks, covering handbags and wallets in Puerto Rico, and lingerie and other clothes in the U.S. After the inauguration, the company filed four more applications, for branded clothing and shoes in the Philippines, and perfume and other items in Canada.”

China patents for Trump In February, the Chinese government awarded Trump a 10-year trademark for construction services, a valuable foreign trademark he’d been seeking for more than a decade. On Friday, Feb. 17, Sen. Dianne Feinstein (D-Calif.) said, “If this isn’t a violation of the Emoluments Clause, I don’t know what is.”

China grants preliminary approval for 38 more trademarks In March, China granted preliminary approval for 38 additional Trump brand trademarks, which Trump applied for in April 2016 in the midst of his presidential campaign.

China overturns rejection of nine Trump trademarks The AP reported in early June that China has granted preliminary approval for nine Donald Trump trademarks it had previously rejected.

Mexico grants Trump brand-name trademarks The AP reported that Mexico approved a renewal of three Trump-branded trademarks on Feb. 21. The Mexican trademarks, which expired in 2015, are now valid again through 2026 and include a broad range of business operations from construction, hotels, real estate, financial services, and insurance.

Trump’s foreign trademark applications: 157 in 36 countries A peek into the global reach of the Trump Organization reveals that the president’s enterprises have 157 trademark applications pending in 36 countries, according to The New York Times after a review of 10 trademark databases. Prior to January, many trademarks were bogged down in legal bureaucracy for months or years, yet once Trump assumed office, it was suddenly smooth sailing for a number of formerly stalled applications.

Trump’s Sons

Using campaign connections to make new deals Trump’s sons Eric and Don Jr. are planning a nationwide expansion of the family’s business, going from their core market of large metropolises to a broader range of cities that the brothers visited during the course of their father’s campaign. 

Don Jr. said they would be leveraging relationships from the campaign, explaining, “I met people along the way that would be awesome partners.” The expansion strategy “illustrates how President Trump’s political rise has the potential to affect his business even as he and his sons promise to adhere to a strict ethical boundary between the company’s moves and the Trump administration,” wrote the Washington Post in March.

Don Jr. gave a commencement speech at American University in Dubai The Trump Organization would not say how much Trump Jr. was paid for the speech but past speakers have made over $50,000.

“While the university is private, sources tell CBS News that Dubai helped found and holds a continuing stake in the school. In his remarks, Trump Jr. thanked and conferred degrees alongside Sheikh Ahmed bin Mohammed bin Rashid Al Maktoum, the son of Dubai’s ruler.”

Front row seats at the White House Eric and Don Jr. were sitting in the front row of the audience for the big reveal of Trump’s nominee for the Supreme Court. CNN reported that during the event, Sen. Orrin Hatch (R-UT) congratulated Trump’s sons on the “great pick” for the Court.

Eric’s trip to Uruguay costs taxpayers $100K According to the Washington Post, Eric Trump’s business trip for the Trump Organization to Uruguay in early January cost taxpayers nearly $100,000 in hotel rooms for Secret Service and staff from the U.S. Embassy in Montevideo.

Maintaining close ties to White House Eric Trump, who runs the Trump Organization, gave an interview in April to Fox and Friends on the White House lawn about the administration’s foreign policy. And in another interview, Eric promoted the president’s use of  Mar-a-Lago as “a very effective tool” for diplomacy, and noted that he speaks to his father “several times a week.”

Ivanka and Jared

Ivanka’s role “I’m going to be a daughter,” Ivanka Trump told 60 Minutes when asked in November what her role would be in a Trump administration, but from the get-go, Ivanka’s role was always much more than this. She, along with her husband Jared Kushner, were with her father when he met with Prime Minister Shinzo Abe of Japan after the election.  

The New York Times later reported that her company “is nearing a licensing deal with the Japanese apparel giant Sanei International,” of which the Japanese government has a stake. She was also on her father’s phone call with Macri and Erdogan. Along with her brothers, she has also met with Antonio, the Philippine developer and special envoy to the U.S., since the election.

Marketing jewelry After appearing on 60 Minutes, Ivanka Trump Fine Jewelry sent a “style alert” to journalists drawing attention to the fact that Ivanka had been “wearing her favorite bangle from the Metropolis Collection on ‘60 Minutes’” the night before. Her company also promoted the dress she wore during her speech at the Republican National Convention in July.

Ivanka assumes official position in the White House The White House announced in March that Ivanka would assume a role in the administration as an official government employee, serving as assistant to the president. As she took on this official position, Ivanka prohibited her fashion label from using her image or any likeness in any campaigns or social media, the Huffington Post reported.

Ivanka frequently wears her own brand Ivanka did wear an Ivanka Trump dress to the Republican National Convention last July, but since moving to Washington, she generally eschews wearing clothes that carry her label. Still, she often wears shoes and other accessories from her eponymous clothing line. Ivanka is photographed daily leaving her Washington house, heading into work at the White House. Photographs of Ivanka are shared widely on social media and published in news outlets.

Nordstrom drops Ivanka – President responds After Nordstrom announced on Feb. 2 it was dropping Ivanka Trump’s label due to product performance, Trump lashed against the retailer on Twitter, blurring the line between the White House and the Trump business organization. 

The official POTUS twitter account retweeted Trump’s personal attack on Nordstrom. While Nordstrom insists that the decision was entirely based on product sales, White House Press Secretary Spicer argued that Nordstrom’s action was a “direct attack” on Trump’s policies, and that Trump should be able to defend her as her father.

Kellyanne Conway: Go buy Ivanka’s stuff Speaking to Fox News from the White House press briefing room, Kellyanne Conway, senior aide to Trump, told the public to “go buy Ivanka’s stuff.” 

Quite possibly violating a regulation from the Office of Government Ethics and a federal law barring the executive branch from endorsing any product or company, Conway declared, “I’m going to give a free commercial here. Go buy it today, everybody. You can find it online.”

Jason Chaffetz (R-UT), chairman of the House Oversight Committee, and Rep. Elijah Cummings (D-Md.), ranking democrat on the Oversight Committee, jointly wrote a letter to the Office of Government Ethics (OGE), recommending the agency take disciplinary measures against Conway, such as “reprimand, suspension, demotion or dismissal.”

OGE recommends disciplinary measures against Conway Walter Schaub, OGE’s director, wrote a letter to Deputy White House Counsel Stefan Passantino recommending disciplinary actions against Conway. The letter stated, “Under the present circumstances, there is strong reason to believe that Ms. Conway has violated the Standards of Conduct Act and that disciplinary action is warranted.” Schaub requested that the White House respond by Feb. 28.

White House rejects disciplinary action against Conway In response to OGE’s request for the White House to investigate and review Conway’s endorsement of Ivanka Trump products on television on Feb. 9, the White House’s deputy counsel wrote in a letter that Conway “acted inadvertently and is highly unlikely to do so again,” adding that she made her statement “in a light, off-hand manner while attempting to stand up for a person she believed had been unfairly treated and did so without nefarious motive or intent to benefit personally.” 

The letter also claimed that officials working in the president’s office are not subject to the same ethics rules that apply to other government officials.

OGE rejects White House claim that ethics regulations don’t apply Schaub slammed the White House’s choice not to discipline Conway. Schaub expressed concern about Conway’s “misuse of position,” but emphasized that he was even “more concerned about the extraordinary assertion that ‘many’ of OGE’s regulations are inapplicable to employees of the Executive Office of the President.”

U.S. pressures China to release activists arrested investigating Ivanka Trump factory In June, the U.S. called on China to release labor activists arrested for investigating conditions in a factory which produces Ivanka Trump-brand shoes. A spokeswoman for the Chinese Minister of Foreign Affairs said it was an internal Chinese matter. China recently released the activists.

Ivanka and Jared still profiting from sprawling business empires Ethics filings indicate that Ivanka Trump and her husband Jared Kushner “will remain the beneficiaries of a sprawling real estate and investment business still worth as much as $740 million, despite their new government responsibilities,” reported The New York Times in March.

Kushner is keeping parts of his family business, some of which are heavily dependent on “foreign investment from undisclosed sources.” Meanwhile, Ivanka has kept her stake in the Trump Washington, D.C. hotel, and has retained ownership of her brand-name line of international clothing and accessories. 

As federal employees, Kushner and Ivanka are now required to adhere to various ethics and transparency rules, and under federal law, they may not participate in government policy in areas that impact their individual financial holdings. While Kushner and Ivanka have resigned from all positions at their companies, and divested from 58 of the potentially most problematic investments, like the president, they have not ceded ownership.

The State Department promotes Ivanka’s book In May, the State Department Office of Global Women’s Issues retweeted Ivanka’s promotional post about her new book on working and motherhood. The U.S. government media outlet Voice of America also promoted her book on its website and Twitter feed. Ivanka said she wouldn’t promote her own book or participate in media appearances for it, but she does use her Instagram account to market it.

Ivanka’s role in new women entrepreneur fund World Bank President Jim Yong Kim announced in April the creation of the Women’s Empowerment Fund, thanking Ivanka and German Chancellor Angela Merkel for their support of the fund. Trump is not supposed to have a formal authority or fundraising role in the fund, but is considered a “strong advocate” of it. 

While essentially no one questions the cause or intentions behind it, the fund has raised ethical questions about whether it can be used in a way to buy favor with Ivanka or the Trump administration. Saudi Arabia and the United Arab Emirates announced they’d give a total of $100 million to the fund during an event Ivanka was attending during her father’s trip to Saudi Arabia.

Kushner and anti-nepotism laws On Jan. 9, Trump appointed Jared as senior adviser in the White House. The Federal Anti-Nepotism Statute, 5 U.S. Code § 3110, states that a public official may not appoint a relative to a position in the agency in which the official is serving. 

While the law establishes that the president is a public official and a son-in-law is included as a relative, the interpretation of “agency” as including the White House or the Executive Office of the President could be debated based on the reading of a circuit court case in 1993, reported Ailsa Chang at NPR in November.

Hours after Trump was sworn in as president, the Department of Justice issued an opinion concluding that Trump’s appointment of Kushner to a position in the White House did not violate federal anti-nepotism laws.

Kushner keeps stake in high-rise financed by visa-for-sale program White House financial disclosures revealed Kushner has retained his stake in Trump Bay Street, a luxury building in Jersey City, New Jersey. Kushner’s family developed the building, and the family pays royalties for the Trump brand-name on the property. 

The Kushners financed the high-rise through loans obtained via the EB-5 Immigrant Investor Program, a controversial government program offering expedited visas for foreign nationals who will pay a minimum of $500,000 for qualified investments in the U.S.

Kushner Companies, is looking for a $250 million loan to repay Chinese investors in the New Jersey tower. Bloomberg reports that major U.S. banks are wary of lending the money in light of the link to Kushner and the visa program.

Jared’s sister pitches visa program to Chinese investors Nicole Kushner Meyer, speaking to a ballroom of Chinese investors in May, urged the audience to “consider investing hundreds of thousands of dollars in a New Jersey luxury apartment complex that would help them secure what’s known as an investor visa,” reported the Washington Post. The presence of reporters at the event unnerved the organizers. “At one point, organizers grabbed a reporter’s phone and backpack to try to force that person to leave,” the Post reported.

A Chinese company is boasting it can guarantee American green cards thanks to Kushner connections “A Beijing immigration company called Qiaowai tells visa applicants of a secret weapon: It is working on behalf of a real estate firm owned by the family of President Trump’s son-in-law and adviser, Jared Kushner,” the New York Times reported May 19.

Kushner Failed to Disclose Major Investments Kushner didn’t disclose “that he is currently a part-owner of a real-estate finance startup and has a number of loans from banks on properties he co-owns” on his financial disclosure forms, the Wall Street Journal reported in May.

Kushner Companies and Israeli Financing The New York Times uncovered major financial ties between Kushner and one of Israel’s wealthiest families. Israel’s Steinmetz family, “which built a fortune as one of the world’s leading diamond traders,” invested roughly $50 million in New York City properties bought by the Kushner company in 2012. While Raz Steinmetz is said to be behind the deals, his uncle, billionaire Beny Steinmetz, is “under scrutiny by law enforcement authorities in four countries” for bribery and money laundering.

Fifth Avenue skyscraper owned by Kushners faces mounting debt In April, the Kushners announced that “talks had broken off with a Chinese financial conglomerate for a deal worth billions to redevelop the 41-story tower, at 666 Fifth Avenue, into a flashy 80-story ultraluxury skyscraper comprising a chic retail mall, a hotel and high-priced condominiums,” the New York Times reported.

According to the Times, if the Kushners want to hold onto the property, they need to “either to bring in a fresh infusion of cash or a well-heeled partner willing to foot the bill.”

Melania Trump

Melania’s multi-million dollar business opportunity as FLOTUS First Lady Melania Trump filed a lawsuit in February in New York state commercial court against the Daily Mail for publishing several “false, salacious, and highly damaging” statements. 

The complaint alleges that as a result of the statements, “Plaintiff’s brand has lost significant value, and major business opportunities that were otherwise available to her have been lost and/or substantially impacted.”

What exactly are these lost business opportunities? According to the complaint itself:

“Plaintiff had the unique, once-in-a-lifetime opportunity, as an extremely famous and well-known person…to launch a broad-based commercial brand in multiple product categories, each of which could have garnered multi-million dollar business relationships for a multi-year term during which plaintiff is one of the most photographed women in the world.”

Following press scrutiny, her complaint was amended, removing all references to her “once-in-a-lifetime opportunity” to market her products.

ABOUT THE AUTHOR

Kate Brannen is the deputy managing editor of Just Security and a nonresident senior fellow at the Brent Scowcroft Center on International Security at the Atlantic Council. Previously, she was a senior reporter covering the Pentagon for Foreign Policy. Follow her on Twitter (@K8brannen).