Cross-posted from the Global Anticorruption Blog

[Original version May 2, 2017; updated June 8, 2017]

The Trump Administration has been dogged by accusations that President Trump, as well as his family members and close associates, are seeking to use the presidency to advance their personal financial interests. While President Trump claims to have ceded control of the Trump Organization to his sons Eric and Donald Jr., the trust set up is porous at best and reports indicate that the president can withdraw money from his more than 400 business at any time without disclosure.

Just as President Trump will receive “quarterly” updates on the Trump Organization from his son Eric, we will track and report on instances in which there are credible allegations of President Trump, his family, and his close associates exploiting their public power for private gain. We will organize the issues into the following four categories, which capture four related but distinct ways that political leaders leverage the power of public office to enrich themselves, their families, and their cronies:

1. U.S. Government Payments to the Trump Organization
2. Use of the Power of the Presidency to Promote Trump Brands
3. U.S. Government Regulatory and Policy Decisions that Benefit Business Interests of the Trump Family and Senior Advisors
4. Private and Foreign Interests Seeking to Influence the Trump Administration Through Dealings with Trump Businesses

1.  U.S. Government Payments to the Trump Organization

One of the most direct ways that President Trump can profit from the presidency is by making decisions that effectively require U.S. government agencies to directly pay the Trump Organization. Though unseemly and costly to taxpayers, this is one of the less destructive forms of potential profiteering by President Trump, since it does not significantly distort U.S. policy. Illustrative examples that have been reported in the media include the following:

• Secret Service at Trump Tower: The Secret Service, charged with protecting the President and his family, must rent out two vacant floors of Trump Tower, where President Trump spends time and First Lady Melania Trump and son Barron Trump continue to reside. This is not the first time the Secret Service has rented space from the government officials they are protecting. For example, when the Secret Service needed to protect former Vice President Joe Biden, they rented a nearby cottage that he owned. However, the payments are several orders of magnitude larger in the case of Trump Tower: While the Secret Service rented Vice President Biden’s cottage for $2,200 per month, the Secret Service may have to pay as much as $3 million per year to rent out two floors of Trump Tower. To accommodate this cost, Congress allocated an additional $23 million specifically for rent at the Trump Tower and to outfit the Tower with the necessary equipment and personnel.
• Department of Defense at Trump Tower: The Department of Defense will follow its standard practice of setting up a separate headquarters near the President’s private residence—in this case also in Trump Tower. While the Department rented space near President Barack Obama’s Chicago home and rented a secure trailer near President George Bush’s ranch, it is unusual for the Department to rent space directly from the president’s own business organization for a (presumably) a substantial amount of money. (Neither the exact amount, nor the information required to estimate it, is public).
• Trips to Mar-a-Lago: In the first four months of his presidency, President Trump visited the Mar-a-Lago resort (owned by the Trump Organization) eight times—including on diplomatic visits by Japanese Prime Minister Shinto Abe and President Xi Jinping of China. On these visits, the Secret Service must pay the Trump Organization directly for any costs related to protecting the president. (This includes the $16,685 the Service spent at Mar-a-Lago on golf cart rentals alone.)
• Trump Properties Abroad: If President Trump or his immediately family travel abroad and choose to stay at a Trump property, the U.S. government will pay the Trump Organization to rent space for the Secret Service and any additional necessary support. For example, when Eric Trump visited Uruguay, he stayed at the Trump Tower Punta del Este. The Secret Service rooms cost $88,320, and the U.S. Embassy in Uruguay paid an additional $9,510 for its staff to stay in the hotel to support the visit. To accommodate these costs, Congress allocated about $60 million to the Secret Service for mostly the expenses of protecting the president while he is traveling and security in Trump Tower.
• Secret Service on Trump Jets: The President is required to travel on Air Force One or Marine One during his time in office, but the First Family can and does travel on private planes owned by the Trump Organization. When the Secret Service accompanies the Trump family on their private planes, they reimburse the Trump Organization directly. (In fact, during the presidential campaign the Service paid TAG Air, Inc.—a Trump company—$1.6 million.)

2. Use of the Power of the Presidency To Promote Trump Brands

Donald Trump and his family can also enrich themselves by taking advantage of the unique status and exposure of the President of the United States to promote Trump family brands. Indeed, Eric Trump noted that the Trump brand “is the hottest it has ever been,” and Melania Trump noted in her defamation lawsuit that she had lost a “once-in-a-lifetime opportunity [as First Lady] . . . to launch a broad-based commercial brand” worth millions of dollars. Moreover, in the first month of the Trump Administration, Ivanka Trump’s apparel line sales increased 346%. While some of this increase is “passive” and thus less problematic, there have been incidents that suggest efforts on the part of President Trump, his family, and members of his administration, to actively promote Trump brands.

While distasteful, this is also one of the less harmful ways in which the Trump Administration may seek to profit from the Presidency, as it also does not involve significantly distortions of U.S. policy. Nonetheless, the overt attempts to use the presidency as a marketing opportunity indicates a troubling underlying attitude, one revealed by a number of specific instances in which the Trump family has apparently taken more active steps to use the prestige and influence of the presidency to promote the Trump brand. Examples include:

• Melania Trump Jewelry: In response to criticism of the language used in the defamation suit mentioned above, Trump’s attorney clarified that the First Lady had no intention of profiting from her position. However, within minutes of President Trump’s inauguration, the White House website was updated to include details on Melania Trump’s jewelry line at QVC. After criticism of this endorsement of her products, the site was updated to drop any mention of specific brands.
• Nordstrom Tweet: After Nordstrom’s department stores made the business decision to drop Ivanka Trump’s clothing line, President Trump used Twitter to attack Nordstrom’s “unfair” treatment of his daughter. Shortly thereafter, White House senior advisor Kellyanne Conway explicitly endorsed the Ivanka Trump brand, saying from the White House briefing room, “I’m going to give a free commercial here: Go buy [Ivanka’s products] today, everybody.” This was a clear violation of a federal ethics regulation, codified at 5 C.F.R. § 2635.702(c), which states that a federal employee “shall not use or permit the use of his Government position or title or any authority associated with his public office to endorse any product, service, or enterprise[.]”
• Access and Influence at Trump Properties: President Trump has actively promoted that impression that staying at Trump properties—particularly at the Mar-a-Lago “winter White House,” where the membership applications have soared—comes with a front-row seat to the inner workings of the U.S. government. During the process of selecting Cabinet nominees, president-elect Trump invited members of his Bedminster Golf Club to join the excitement at the Mar-a-Lago resort. At this same resort, after news broke of a North Korean missile test, President Trump discussed intelligence and briefings with Prime Minister Shinzo Abe of Japan on an open patio in plain view of resort guests. In fact, briefly after giving a joint press conference with Prime Minister Abe, President Trump gave an impromptu speech at a wedding, claiming, “They’ve been members of this club for a long time. They’ve paid me a fortune.” Further promoting this idea that membership at Mar-a-Lago comes with a unique opportunity to be close to the excitement of presidential decision, retired investor Richard DeAgazio posted a Facebook picture of the Presidential Emergency Satchel (commonly known as the “nuclear football”). Presumably to capitalize on the reputation of Trump properties as unique places of access to the president, the Mar-a-Lago resort has doubled its initiation fee to $200,000 following the election.
• Advertisement for Mar-a-Lago on State Department Website: In April 2017, a U.S. State Department website called Share America–which, according to the site, is supposed to be a “platform for sharing compelling stories and images that spark discussion and debate on important topics like democracy, freedom of expression, innovation, entrepreneurship, education, and the role of civil society”–posted a feature on Trump’s Mar-a-Lago resort. After widespread criticism from lawmakers and ethics experts–who pointed out that the post was also a clear violation of 5 C.F.R. § 2635.702(c)–the State Department removed the posting.
• Ivanka Trump’s Book: Both Voice of America—a government funded news agency—and the State Department promoted Ivanka Trump’s new book, Women Who Work: Rewriting the Rules for Success. Voice of America published an Associated Press article review about the book and advertised the book on Twitter. The State Department’s Office of Global Women’s Issues retweeted Ms. Trump’s tweet promoting the book, but later deleted the tweet after criticism. Ms. Trump has pledged not to draw publicity through any promotional tour or media appearances, and she has also pledged to donate the advance and profits from the book to charity. Nonetheless, government agencies openly promoting the book raises serious ethics concerns.

3. U.S. Government Regulatory and Policy Decisions that Benefit the Business Interests of the Trump Family and Senior Advisors

Federal decisions—on regulation, law, enforcement, and discretionary spending—may be influenced or manipulated in ways that benefit the private commercial interests of the Trump Organization or other businesses closely tied to President Trump, his family, or his senior advisors. This is a much more serious concern, as it involves not only enrichment of the Trump family and associates at taxpayer expense, but also potential distortions of U.S. policy, with more far-reaching consequences.

The extent of the Trump Organization’s business interests makes it impossible to summarize all of the potential conflicts of interest that might arise. For example, the Trump Organization has been involved in labor disputes; Trump businesses regularly apply for visas for foreign workers; Trump businesses are subject to countless federal safety and environmental regulations; the Trump Organization owns properties that may be eligible for grants and subsidies from the Department of Housing and Urban Development (HUD). As head of the executive branch, President Trump might have influence over numerous decisions that affect the Trump Organization’s business interests. While the potential conflicts of interest are too extensive—and in most cases likely too indirect—to enumerate, here are a few examples of more specific reports that raise concerns about how the financial interests of the President and his advisors may distort regulatory or policy decisions:

• Dakota Access Pipeline (DAPL): In his first week in office, President Trump reversed a decision from the U.S. Army Corps of Engineers—which had announced it would not issue permits for building the controversial Dakota Access Pipeline—and directed the Corps to “review and approve [the construction] in an expedited manner.” President Trump’s filings with the Federal Election Commission in June 2015 and May 2016 indicate that he owned stock in Energy Transfer Partners, the company building the $3.7 billion pipeline. While the President has asserted that he sold his stock in the company in June 2016, resolving the possible conflict of interest, he has not provided any concrete, independently verifiable evidence for that claim.
• General Services Administration Lease: The Trump Organization leased the building that is now the Trump International Hotel in Washington D.C. from the Federal Government’s General Services Administration (GSA). The lease agreement explicitly 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.” The purpose of this clause seems quite clearly to be avoiding the conflict of interest that would arise if an elected federal official were, in effect, on both sides of the transaction (as both landlord and tenant). In March, the GSA decided that President Trump—who has the authority to appoint and potentially remove the head of the GSA—was fully compliant with the lease agreement as long as he does not receive profits while he serves as President. The GSA’s decision was roundly criticized by most experts as an implausible reading of the contract.
• Ivanka Trump and Jared Kushner’s Advisory Roles: Ivanka Trump serves as an assistant to her father, while Ms. Trump’s husband Jared Kushner serves as senior advisor to the president. Since Ms. Trump is not being paid a salary and was not sworn in, she is not an official government employee (although she maintains a West Wing office, security clearance, and White House communications equipment). While Ms. Trump stepped down from her management and operations role at the Trump Organization, she continues to receive fixed payments from the Organization and profits from her fashion brand and the Trump International Hotel in Washington, D.C. Similarly, although Mr. Kushner turned over his family’s real estate empire to family members, he still remains a beneficiary of his businesses through a series of trusts. Similar to the president himself, neither Ms. Trump nor Mr. Kushner divested from their assets or placed them in a blind trust—which means taht their financial interests could influence their counsel to President Trump.
• Infrastructure Plan: To oversee a council at the helm of President Trump’s proposed $1 trillion infrastructure plan, President Trump selected Steven Roth and Richard LeFrack, billionaire real-estate developers and former business partners of the President. The Trump Organization is currently invested in Mr. Roth’s real estate development company, Vornado Realty Trust, and receives $22.7 million annually from an ownership stake in two Vornado buildings. Not only has Mr. Roth entered bids to build new buildings for the Labor Department and the FBI, but, should the infrastructure plan be enacted, he will be in a position to influence billions of dollars in government spending in ways that benefit his company—and thus also directly benefit the Trump Organization.
• Deutsche Bank Investigation: The Department of Justice is investigating Deutsche Bank’s connection to a Russian money-laundering scheme. Justice Department officials appointed by President Trump, including Attorney General Jeff Sessions, are overseeing the investigation. Deutsche Bank has lent President Trump billions of dollars, and he currently still owes the Bank about $340 million. Senator Chris Van Hollen highlighted this potentially serious conflict of interest in a letter he sent to Deutsche Bank, asking for assurances that the president’s debt would not be used as leverage.
• Fannie Mae and Freddie Mac: John Paulson is the billionaire founder and manager of the hedge fund Paulson & Co. Mr. Paulson’s funds have a stake in Fannie Mae and Freddie Mac—both of which were taken over by the federal government in 2008. Since President Trump’s election, shares of Fannie Mae and Freddie Mac have soared, and Mr. Paulson has called for the government to relinquish control of the companies. President Trump himself has invested $3­­–5 million in Paulson’s funds, and thus would stand to gain immensely from a decision to end government control of the companies. Treasury Secretary Mnuchin—a former business partner of Mr. Paulson—has expressed interest in ending government control of the companies.
• Commerce Secretary Ross’s Shipping Interests: Commerce Secretary Wilbur Ross shed millions of dollars in assets to avoid conflicts of interest. However, he maintained passive investments in Diamond S Shipping Group Inc., one of the world’s largest operators of shipping vessels, despite stepping down from positions within the company. Secretary Ross will be at the forefront of the U.S. trade negotiations and will help shape U.S. trade policy, which will directly impact the financial interests of the Diamond S Shipping Group.
• Carl Icahn’s Mining Interests in Indonesia: Billionaire investor Carl Icahn serves as a special advisor to President Trump. Mr. Icahn is simultaneously a top shareholder in Freeport-McMoRan, a mining company that does so much business in Indonesia that it is the country’s largest taxpayer. Freeport has been trying to extend its mining contract with the Indonesian government, and Icahn has pushed Freeport to fight more aggressively against the government’s challenges to Freeport’s contracts. Mr. Icahn’s simultaneous business interest in Indonesia and the importance of U.S.-Indonesian relations create serious conflicts of interest.
• Carl Icahn’s Oil Refinery Bet: Mr. Icahn also owns an 82% stake in oil refining company CVR Energy Inc. In 2016, Mr. Icahn accumulated a large short position in biofuel blending credits. In February 2017, after Mr. Icahn began serving as a special advisor to the President, he proposed changing biofuel regulations by shifting the responsibility for blending ethanol and gasoline from refiners to terminal operators. When news of the proposal broke, the price for these blending credits dropped dramatically, and Mr. Icahn made over $50 million. Democratic lawmakers have asked the Securities and Exchange Commission, the Commodity Futures Trading Commission, and the Environmental Protection Agency to look into whether Mr. Icahn’s conduct amounted to insider trading or other illegal conduct.
• The Scope of the Proposed Travel Ban: In January 2017, President Trump signed a controversial executive order that barred entry into U.S. for individuals from seven Muslim-majority countries in the Middle East. Experts, courts, and the international community broadly denounced the effectiveness of a country-specific ban and the discriminatory purpose and intent of the executive order. Some critics went further, suggesting that the order itself may have been influenced by President Trump’s foreign business interests: The Trump Organization has no financial interests in any of the countries affected by the travel ban, but does have business interests in other predominantly Muslim countries that could have been included in the ban, such as Saudi Arabia, the United Arab Emirates, Turkey, and Egypt. This is admittedly pure speculation, as there are alternative explanations for the selection of the targeted countries.
• Rupert Murdoch’s 21st Century Fox: Media mogul Rupert Murdoch is a close friend, confidant, and adviser to President Trump. In fact, President Trump speaks with Mr. Murdoch on the phone every week for consultation and strategy. Mr. Murdoch has two important interests that President Trump could influence. First, President Trump could influence the proposed merger between AT&T and Time Warner, as he promised to on the campaign trail and stressed that it was, “a deal we will not approve in my administration.” Mr. Murdoch has a vested interest in the deal, as the merger would create a powerful rival to Mr. Murdoch’s company, 21st Century Fox. Secondly, the Justice Department is currently investigating Fox News for financial settlements related to sexual harassment lawsuits brought by female employees. The investigation will be overseen by Attorney General Jeff Sessions, who in turn reports to President Trump.
• Clean Water Act Rollback: In February 2017, the Trump administration issued Executive Order 13778, which directed the EPA to review and either rescind or revise the regulations pertaining to the scope and coverage of the Clean Water Act. The EPA sent a proposal to repeal the regulation to the White House Office of Management and Budget’s Office of Information and Regulatory Affairs (OIRA), which the office will review before publishing in the Federal Register. Though the proposed repeal would affect many constituencies, it is strongly supported by golf-course owners (among others); the Trump Organization owns numerous golf courses, and therefore stands to gain from the proposed repeal.

4. Private and Foreign Interests Seeking To Influence the Trump Administration Through Dealings with Trump Businesses

Another significant concern is that individuals, private firms, and foreign governments may believe—rightly or wrongly—that they can curry favor with the Administration and increase their odds of favorable policy decisions by engaging in private business transactions with companies owned by or connected to President Trump—or, in the case of foreign governments, granting favorable regulatory treatment to Trump business operations. This is one of the most serious concerns related to the Trump family’s interest in profiting from the presidency, as it gives rise both to the appearance of corruption and the risk of actual corruption. The range of possible problems is too broad to summarize, but here are some examples of the leading sources of concern:

• The Trump International Hotel in Washington, D.C.: A number of concerns center on the Trump International Hotel in Washington, D.C., and in particular on whether foreign governments, or agents of foreign governments, may seek to curry favor with the Trump Administration by booking rooms and events at the hotel. While the Trump Organization initially declared that it would donate profits earned from foreign officials to charity, recently the Organization noted that it would not donate profits until 2018 at the earliest. Moreover, in a pamphlet distributed to senior Trump employees, the Organization noted that it would be “impractical” to “fully and completely” identify all foreign guests staying at the Trump hotels. Shortly after the election, the Hotel hosted a promotional event aimed specifically at foreign diplomats and attended by almost 100 diplomats from Brazil to Turkey. Since then, there have been numerous reports of private companies and foreign governments paying for rooms and events there. Some illustrative examples include:
  • Bahrain: Shortly after President Trump’s election, the Embassy of Bahrain booked a reception at the Trump International Hotel in Washington, D.C., held on December 7, 2016.
  • Saudi Arabia: On January 23-26, 2017, a lobbying firm working on behalf of Saudi Arabia booked rooms at the hotel, which were paid for by the Saudi government. In fact, the firm has paid nearly $270,000 to the hotel, including $190,272 on lodging, $78,204 on catering, and $1,568 on parking.
  • Kuwait: The Embassy of Kuwait’s celebration of Kuwaiti independence on February 25, 2017 was originally to take place at the Four Seasons hotel but was moved to the Trump hotel. According to anonymous sources, the location changed because members of the Trump Organization pressured the Kuwaiti ambassador to move the event. The ambassador, however, has denied these reports. If the allegation is true, this suggests direct efforts by the Trump Organization to leverage the president’s position to steer foreign government business to the Trump hotel.
  • Oil Lobby: On March 23, 2017, Interior Secretary Ryan Zinke addressed the board of directors of the American Petroleum Institute (API)—an oil and gas industry trade group—at the hotel. While it is unclear how much money API spent on hosting their board of director’s meeting at the hotel, it likely cost hundreds of thousands of dollars. API spent $2.7 million lobbying in the first quarter of 2017, including lobbying the Interior Department and the Trump Administration.
  • Turkey: The American Turkish Council and the Turkey-U.S. Business Council (TAIK)—an arm of the Turkish government—will host their annual conference at the Trump hotel. Previous conferences have cost around $400,000, with about one-third of that going to the venue. (Also of note: TAIK is headed by Ekim Alptekin, who founded Inovo BV, the consulting company that paid former national security advisor Michael Flynn $530,000 for lobbying work.)
• Events at Other Trump Properties: Similar concerns have been raised with respect to other Trump properties, where domestic of foreign interests may seek to curry favor with the president by hosting events at Trump resorts. For example, the American Red Cross held its annual ball on February 4 at President Trump’s Mar-a-Lago Club. The ball has been held at the Mar-a-Lago resort before and was planned before the election. However, the event still raised concerns because the President will likely have to decide whether to appoint a new chairman and whether to review the Red Cross federal charter. Another example: The National Confectioners Association, which represents large candy companies, will be hosting several large meetings at the Trump National Doral Resort and other Trump properties. While these bookings were also made before President Trump was elected, it is nonetheless the case that a lobbying group is paying the Trump Organization while it is also advocating for changes in government policy. And in Canada, shortly after Trump’s election, the American Chamber of Commerce in Canada moved a planned meeting from the home of a diplomatic official to the newly-opened Trump International Hotel & Tower in Vancouver. The Chamber only paid $1,900 to rent the space for the event and asserted that the decision to move the event was due to a water leak at the original site, rather than any desire to influence the Trump Administration. While the explanation is plausible, events like this nonetheless contribute at least to the perception of an attempt to curry favor.
• Taiwan: On December 2, 2016, President Trump broke the nearly four decades of presidential precedent and communicated with the President of Taiwan. Since 1979, the United States has not officially recognized Taiwan, and the phone call between president-elect Trump and Taiwanese President Tsai Ing-wen could cause serious tension in U.S.-China relations. In the days after the call, news broke that the Trump Organization was considering expanding to Taiwan. While the Trump Organization has denied any such plans, the Mayor of Taoyuan—the city where the Organization supposedly wants to build—confirmed a September 8, 2016 visit from a representative of the Trump Organization to talk about expansion.
• Chinese Trademarks: Although President Trump’s phone call with the President of Taiwan caused tension in the U.S.-China relationship, in February 2017 President Trump reaffirmed the U.S. commitment to the so-called “One China Policy.” Within a week of this announcement, the Chinese government granted the Trump Organization a long-coveted Chinese trademark for the “Trump” brand. While there is no direct evidence of quid pro quo, and some commentators have suggested alternative explanations for the Chinese government’s decision, the suspicious timing, the unusual speed with which the trademarks were granted, and the mere fact that a foreign government has conferred on the President’s business a benefit worth millions of dollars, raises serious obvious and serious concerns. Similarly, Ivanka Trump’s company has over 40 trademark applications pending in China. On April 6, Ivanka—who remains an important adviser to her father on China related issues—dined with the Chinese President at Mar-a-Lago. That same day China granted her company three provisional trademarks (which had been filed with the Chinese authorities before President Trump was elected president).
• Chinese Real Estate Purchases:
  • On February 21, 2017, Chen Xiaoyan (who also goes by Angela Chen), purchased a penthouse apartment in Trump Tower in New York for $15.8 million. Ms. Chen is the founder and managing director of a consulting and lobbying firm that helps clients secure access to senior public and private decision-makers in the People’s Republic of China, and includes among its clients the U.S. Department of Commerce and U.S. Trade and Development Agency.
  • In March 2017, news outlets reported that a Chinese company, Anbang Insurance Group, planned a $4 billion transaction involving a property at 666 Fifth Avenue in Manhattan owned by the family of Jared Kushner, President Trump’s son-in-law and senior advisor. If the deal had gone through, it would have netted the Kushner family firm approximately $400 million. (Although Jared Kushner sold his ownership stake in the company when he assumed his White House role, he sold the stake to his family members, a move which many ethics experts considered inadequate.) However, within a few weeks of the initial reports, Anbang and the Kushner family ended talks about a possible deal. It is not clear how much public outcry over the potential conflict of interest issue may have played a role.
  • At a May 2017 investor event in Beijing, Nicole Kushner Meyer—Jared Kushner’s sister—made a pitch soliciting $150 million for a Jersey City housing development to over 100 Chinese investors. The pitch attracted criticism for two reasons. First, Ms. Meyer promoted the EB-5 visa, a program that allows a path to permanent residence for foreign investors who invest more than $500,000 in projects that create jobs in the US. (The brochure for the event included slogans such as, “Invest $500,000 and immigrate to the United States.”) The EB-5 program, however, long pre-dates President Trump’s election and has been supported by both Democrat and Republicans officials in the past, and so while the program has been persuasively criticized, Ms. Meyer’s remarks here are not unusual and do not raise specific concerns about leveraging the political influence into private gain. But Ms. Meyer’s attracted additional criticism because she stressed that the investment project “means a lot to me and my entire family,” and she made a point to highlight the important role of her brother in the White House. Indeed, Mr. Kushner previously oversaw the project until he left the company to be senior advisor to the President, and he remains the beneficiary of trusts that own his stakes in Kushner Companies. After the criticism, the Kushner Companies has apologized, “if that mention of [Jared Kushner] was in any way interpreted as an attempt to lure investors.”
• Jared Kushner’s Meeting with Russian Officials: In connection with the ongoing investigation into possible collusion between the Trump campaign and the Russian government during the 2016 election, the FBI and Special Counsel Robert Mueller are reportedly scrutinizing meetings in 2016 between Jared Kushner and two Russian officials, Ambassador Sergey Kislyak and Sergey Gorkov, the head of VEB, a Russian state-owned development bank (and a close associate of Vladamir Putin). The contents of those discussions are still unknown, and the parties have issued seemingly contradictory explanations. (Mr. Kushner, for example, asserted that he was discussing policy issues, while Mr. Gorkov asserted that in their meeting Mr. Kushner was acting in his private capacity as a representative of his business.) Some media reports have suggested that Mr. Kushner and Mr. Gorkov may have discussed the possibility that Mr. Gorkov’s bank might extend financing to the 666 Fifth Avenue property mentioned above, or other business ventures of the Kushner family, if the Trump Administration lifted the sanctions that the U.S. had imposed on Russia in response to Russia’s incursion into Ukraine. (Others, however, have questioned the plausibility of this speculation, given that the size of the loan required for the 666 Fifth Avenue property would be quite large relative to VEB’s assets.)
• Philippines: President Rodrigo Duterte of the Philippines named Jose E.B. Antonio, the chairman of the company that is building a Trump Tower in the Philippines, as an envoy to the United States for trade, investment, and economic affairs. Mr. Antonio, whose company paid the Trump Organization as much as $5 million to use the Trump name on the current Trump Tower project, has said he’s discussing additional projects in the Philippines with the Trump family. (Moreover, until recently those looking to buy a condo at the Tower were greeted by a video of President Trump, filmed several years ago, advocating for the Tower and project.) In other words, Mr. Antonio will be representing the Philippines in discussions with the U.S. government regarding policy issues, and will at the same time be discussing private business ventures with the Trump Organization.
• Turkey: The Turkish conglomerate Dogan Holding was instrumental in developing the Trump Towers Istanbul, and continues to pay millions to the Trump Organization. The Erdogan government, however, has previously imposed a $2.5 billion tax fine on Dogan Holding, and could put further pressure on the company in the future. According to some reports, this is a deliberate strategy to pressure the Trump Administration. According to a Newsweek report, President Erdogan “told associates he believes he must keep pressure on Trump’s business partner [in Turkey] to essentially blackmail the president.”
• United Arab Emirates: Just before President Trump’s first foreign trip, which he made to the Middle East, Donald Trump Jr. delivered the commencement address at American University Dubai. While his fee was not disclosed, previous speakers, including President Clinton, have been paid as much as $150,000 for a commencement address at the same university. The speaking fee might be used by Dubai’s leaders to curry favor with the Trump Administration, particularly since the United Arab Emirates holds a stake in the American University Dubai.
• Caribbean: In the first major divestiture of a Trump property since the election, the Trump Organization is selling Le Chateau des Palmiers—a five acre beachfront estate on the Caribbean island of St. Martin. President Trump bought the property in 2013 for an undisclosed amount, although the asking price at the time was $19.7 million. The property was initially listed for $28 million, although the price is officially listed as “price on application.” Given that any transaction would be a private property transaction, the Trump Organization would not need to reveal the identity of the buyer. This raises concerns that a buyer could overpay to curry favor with the Trump Administration and the President.
• State Public Pension Funds: Public pension funds in California, New York, Texas, Arizona, Montana, Michigan, and Missouri—with more than five million members—have millions of dollars invested in The CIM Group, a Los Angeles-based investment group that owns The Trump SoHo Hotel and Condominium. The CIM Group pays Trump International Hotels Management LLC 5.75% of Trump SoHo’s operating budget, resulting in millions of dollars in payments. Thus, these state pensions are paying millions of dollars almost directly to the Trump Organization through The CIM Group. Senator Patty Murray, the top Democrat on the Health, Education, Labor & Pension Committee, has written to the Office of Government Ethics urging them to investigate the payments.

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