If Donald Trump wasn’t the US president, his push to hold the 2020 G7 summit at his Trump National Doral golf resort in Florida would be a federal crime.

It’s just one of several takeaways from a letter sent by Citizens for Responsibility and Ethics in Washington (CREW) to the State Department’s inspector general, urging him to monitor and investigate the procurement process surrounding the event. The president’s “corrupting influence” makes it crucial that the State Department “prevent and detect impropriety” before it occurs, the letter says.

With his refusal to divest his personal business holdings after his election, Trump has accumulated more than 2,300 known conflicts of interest during his first three years in office. Holding the G7 summit at his Doral resort would add to that total. And any payments by the US government to Doral would potentially violate the US Constitution’s Domestic Emoluments Clause. Payments by the six other government delegations attending would potentially contravene the Foreign Emoluments Clause.

But the president’s “unprecedented attempt” to insert himself into the bidding process and steer next year’s G7 to a property he owns—to the possible detriment of other companies vying for the business—would not only look bad from an ethical and Constitutional perspective, it would in fact be grounds for prosecution if he held almost any other position in the executive branch.

“To be sure, if he were any executive branch official other than the President or Vice President, his participation in a procurement for which his own company was competing would be a crime under two conflict of interest laws—sections 205 and 208 of title 18, United States Code,” CREW’s letter explains. “Though the president is exempt from these two laws, his exemption was never intended as a perk of high office.”

Violations of both statutes carry sentences of up to five years in prison. CREW has identified three federal solicitations for G7 2020 hotel space currently out for bids.

Past US presidents have willingly adhered to well-established ethical norms. Swearing the oath of office, along with concern for public perception, has always been enough to stave off obvious impropriety.

“We’re researching things that hadn’t even been considered before,” Danielle Brian, executive director of the nonprofit Project on Government Oversight, told the Associated Press shortly after Trump was elected.

A salesman in the Oval Office

The most recent G7, in Biarritz, France, reportedly cost about $40 million—far less than past G7 summits, a French government spokesperson told reporters. The 2018 G7, held in Quebec, Canada, cost close to $600 million. Trump stands to make tens of millions of dollars if the next G7 is in fact held at Trump National Doral, a “severely underperforming” property that has seen its net operating income drop by 69% over the past two years.

“In a presidency defined by profiteering and conflicts of interest, this is a new low,” CREW executive director and former federal prosecutor Noah Bookbinder said in a statement. “It’s almost unimaginable that the president would use a vitally important international summit to prop up his struggling business, but that truly appears to be what’s happening.”

Trump’s wish to have the G7 at Doral was first reported in June by the Washington Post. At a news conference in Biarritz, Trump said he doesn’t “care about making money,” after touting the features of his Miami resort like a seasoned time-share pitchman.

“It’s set up so—and, by the way, my people looked at 12 sites,” Trump said during another appearance at the summit. “All good, but some were two hours from an airport. Some were four hours from—I mean, they were so far away. Some didn’t allow this, or they didn’t allow that. With Doral, we have a series of magnificent buildings; we call them bungalows. They each hold from 50 to 70 very luxurious rooms with magnificent views. We have incredible conference rooms, incredible restaurants. It’s like—it’s like such a natural.”

Trump continued, explaining that Doral has ample parking and ballrooms that are “among the biggest in Florida and the best.”

“It’s brand new,” he said. “And they want—my people wanted it.”

A tweet issued later by the official White House account appeared to support Trump’s proposition:

“There can be no doubting that President Trump’s remarks in connection with his announcement of Trump National Doral’s consideration as the site for the G7 Summit, as well as the White House’s tweet, have put extraordinary pressure on the State Department’s procurement officials,” says CREW’s letter.

CREW wants to know if Trump managed to obtain secret information about bids submitted by competing companies, or inside knowledge about source selection. Giving his own businesses a leg up would violate the Procurement Integrity Act. And participating in such a scheme could also expose State Department employees to criminal charges, the group maintains.

“This all could have been avoided, had the president followed decades of precedent and divested from his business,” Bookbinder said. “Instead we’re left with a situation where every presidential action is under a cloud of suspicion for corruption, and that suspicion increasingly seems justified.”

A situation unprecedented

The Trump administration is the most scandal-ridden administration in American history, according to Craig Holman, a government ethics expert at nonprofit watchdog Public Citizen. The emerging G7 affair marks another in what he calls “a long and growing list of self-dealing business ventures by the president of the United States.”

REUTERS/Joe Skipper Trump campaigning at Doral in 2015.

“Over and over again, Trump has laundered tax dollars and government resources, as well as money from lobbyists and foreign agents, into his own pocket,” Holman told Quartz. “Sometimes the money laundering is very direct, as in federal payments to Trump properties for official visits and the cost of hosting an army of security officials. Other times the self-dealing is indirect, such as government contracts to a Scottish airport to facilitate more paying visitors to another of Trump’s properties.”

Although Trump is technically insulated from prosecution over any interference in next year’s G7 contracts, CREW’s letter notes that the Supreme Court has described such a conflict of interest as “an evil which endangers the very fabric of a democratic society. A democracy is effective only if the people have faith in those who govern, and that faith is bound to be shattered when high officials and their appointees engage in activities which arouse suspicions of malfeasance and corruption.”

Of course, there’s another reason altogether not to hold the 2020 G7 at Doral. As Quartz reported recently, the pools and spas at Trump’s Florida properties have been shut down by state health inspectors far more frequently than other comparable properties in the area. And Doral’s pools, according to public records, haven’t been inspected in over a year.