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 ac