Last month, Kellyanne Conway famously turned an interview from the White House into an infomercial for Ivanka Trump. “This is just a wonderful line,” the presidential adviser said of the clothing brand that bears the name of the president’s eldest daughter. “I own some of it. I fully—I’m going to just give it a free commercial here: Go buy it today, everybody. You can find it online.”

Ethics watchdogs and good-government types were aghast with this blatant violation of federal ethics rules. Even Republicans who had repeatedly ignored concerns about the many glaring conflicts of interest posed by the president’s business empire felt compelled to weigh in. “That was wrong, wrong, wrong, over the line, [and] unacceptable,” House Oversight Chairman Jason Chaffetz said.

Chaffetz joined his Democratic counterpart on the oversight panel, Maryland Rep. Elijah Cummings, in asking the Office of Government Ethics to investigate. Agency Director Walter Shaub Jr. concluded that Conway’s actions appeared so outrageous as to warrant formal punishment from the president. To the surprise of no one, the Trump administration shrugged.

Conway ultimately got away with openly flouting federal ethics rules on national television without so much as a slap on the wrist. But as remarkably brazen as her actions were, they may be dwarfed by a much larger and more serious conflict of interest: The available evidence suggests that more than two months since starting work at the White House, Conway still hasn’t sold the D.C. consulting firm she founded in 1995—named, plainly, the Polling Company—that boasts of such high-profile past clients as Boeing, the National Rifle Association, and even the federal government. If Conway is taking an active role in White House decision-making that directly impacts the fortunes of her firm’s clients, it would pose a far larger problem than her unapologetic Ivanka endorsement did: It could be a federal crime punishable with prison time.

That if is worth considering given the stakes, the available facts, and the Trump administration’s silence on the matter. Conway appears to be in a position to use her public office to directly advance the interests of her private business. A company or advocacy group would be able to pay the Polling Company for consulting advice while knowing the firm’s owner is in turn giving her own advice to the president. Quid meet Quo. That would be more than just a violation of the type of federal rule blatantly ignored during the Ivanka episode, which is supposed to come with professional consequences ranging from a reprimand to removal; it would be a violation of federal law. Under the basic criminal conflict of interest statute (18 U.S.C. § 208)—which doesn’t apply to the president but does apply to his staff—it is illegal for an executive branch employee to participate “personally and substantially” in any government matter that will affect his or her own financial interests. If a court were to find Conway willingly violated that law, she could face up to five years in prison and $50,000 in fines for each offense. Prosecutions under the law are relatively rare though that can be explained, at least in part, by the reality that most executive branch employees at least pretend to follow it.

According the Polling Company’s website, Conway “resigned” as president and CEO “effective January 20th, 2017,” and was replaced by Brett Loyd, who had previously served as the firm’s director of political services. “We wish Kellyanne the best of luck in all of her future endeavors,” the company’s statement at the time read. After struggling to find public information on the firm, Slate reached out to the Polling Company to find out where the business was incorporated. Loyd responded to Slate’s initial query three weeks ago, telling us it is a Virginia company. But then he suddenly stopped answering emails and phone calls when asked about Conway’s current connection to the firm he now runs.

The White House was helpful only in comparison. In a statement provided to Slate in response to repeated questions about Conway and her company, a White House spokeswoman appeared to confirm that Conway does indeed still own the company but went on to suggest that she is waiting to sell it until the Office of Government Ethics grants her what is known as a certificate of divestiture:

Kellyanne Conway resigned from the company and has had no management responsibility since before she was sworn in as Counselor to The President. Mrs. Conway, who has signed the Ethics Pledge, has been working with the Office of the White House Counsel to ensure she is fully compliant with her legal and ethical obligations in connection with her former company and her duties in the White House. While she is in the process of divesting her assets, like all White House employees in a similar situation, this process requires submission of ethics documentation to the Office of Government Ethics to obtain a Certificate of Divestiture from OGE prior to selling the asset. As is the case for many other employees, this process is still underway.

The White House declined to discuss the matter further, responding to a detailed set of follow-up questions with a one-line email last week: “The statement sufficiently covers these areas.”

The problem, however, is that it doesn’t. For starters, there is no current record of Conway or the White House even beginning what can be a months-long process of obtaining a certificate from OGE. (The certificates provide recipients with a tax break on the profits they make from such sales, which can ease the financial pain of playing by the rules.) “OGE is at liberty to speak on what is available and received at OGE and we have not received any documents regarding Kellyanne Conway,” a representative for the agency’s compliance division told Slate on Wednesday in response to a formal request, as allowed under federal law, to review any certificates of divestiture or ethics waivers issued to Conway.

The absence of paperwork matters: A government employee seeking a certificate of divestiture must first commit in writing to sell the asset even if his or her request is denied. Until Conway puts pen to paper, she won’t be bound to follow through and sell her company. (On Thursday, Slate asked the White House why Conway hadn’t submitted the paperwork yet, but there was no response as of publication time.)

Furthermore, remarks Conway has made since taking her job as counselor to the president raise additional questions about her intentions. In an interview with Politico last month, Conway explicitly cited her declining to sell the company for a big sum as evidence of her loyalty to President Trump. “He knows I had a huge offer to sell my firm,” she said then. “He knows I walked away from millions.” It’s unclear why such a sale would preclude Conway from taking her new job. The White House declined to elaborate, but one reading might be that the big-dollar offer Conway received was contingent on her remaining with the firm full-time instead of following Trump to the West Wing. Counterfactuals aside, though, that still wouldn’t explain whether or not she actually intends to sell it now for a smaller sum, or the current delay in beginning that potential process.

Conway, then, appears to be taking a page out of her boss’s book. Trump made a big show of stepping away from the day-to-day operations of the Trump Organization before taking office, but he nonetheless maintains his ownership stake in the for-profit company he built. The difference is that there is a federal criminal statute that would make it illegal for Conway to exert influence on issues that impact her private clients. (Trump is likely violating the Emoluments Clause of the Constitution, but that’s another story.)

Robert Weissman, president of the D.C. watchdog nonprofit Public Citizen, told Slate that if Conway does actually still own the Polling Company, it would be incredibly problematic. “On its face,” he said, “it is an invitation for profound corruption.” The law, he explained, is clear: An administration employee either needs to sell her business or recuse herself from policy matters that directly impact that business. “But the latter can’t really even apply here since you have a senior adviser to the president who has input on effectively everything,” Weissman said. (The White House declined multiple times to say whether Conway has recused herself from any policy decisions since Trump took office.)

This wouldn’t be the first time that Conway’s ownership of the Polling Company has raised legal questions, either. During the 2016 campaign, while Conway was serving as both the head of her polling firm and as Trump’s campaign manager, her company received roughly one-quarter of $1 million from a Trump-friendly super PAC run by Rebekah Mercer. According to a formal complaint filed by the Campaign Legal Center currently pending before the Federal Election Commission, that was a violation of the election law that bars coordination between campaigns and super PACs. The CLC argues that the cash represented an illegal in-kind contribution to Trump since, in effect, Mercer’s PAC was paying part of Conway’s campaign salary.

The Polling Company is privately held, which will make it difficult if not impossible to independently confirm if Conway ultimately sells her business or not, and the firm appears happy to have it that way. Paperwork filed in Virginia currently lists the company’s registered agent—essentially its point of contact for any legal issues—as the CT Corporation, a third-party company that fills the same role for thousands of other businesses in the United States. (Disclosure: CT Corp. serves the same function for The Slate Group.) The corporation, which is the subsidiary of a multinational company based in the Netherlands, told Slate that it was not authorized to discuss the ownership of the Polling Company or provide any related information.

Meanwhile, Conway’s firm is required to submit annual reports to the Virginia State Corporation Commission, but those filings mandate only a list of the company’s principal officers and directors, not its owners. As part of its most recent report, the company informed the commission on Feb. 14, 2017 that Loyd had indeed taken over for Conway as CEO, but the form still named Conway as its director. As far as the commission is concerned, the information was current as of the date they received it, which was more than three weeks after Conway joined Trump in the White House. (“It would be considered to be accurate as of the time of signing/submitting the document,” an agency representative confirmed to Slate.)

The Polling Company declined to provide Slate with a list of its current clients, but a quick look at past ones touted on its website makes it easy to see the problem: Boeing, for example, is one of the largest defense contractors in the nation—and learned early just how important it is to stay on Trump’s good side after the president took to Twitter to complain about the costs of a new Air Force One. Altria and American Express operate in two of the more heavily regulated industries in the country, giving them added incentive to find a friend with the president’s ear such as Conway. And Major League Baseball enjoys an antitrust exemption that it is desperate to preserve.

Slate contacted each of the roughly two-dozen companies listed on the Polling Company’s website as clients it has done business with in the past two decades. Roughly half of them including Boeing, American Express, MLB, and the NRA, did not respond to questions about past and current dealings with the firm. Among those that did respond, most described their relationship with the firm as fleeting. A representative for the North Carolina–based supermarket chain Harris Teeter, for example, said it worked with Conway’s company “back in 2006 or 2007” but that it is not a current client.

Other groups described longer relationships with Conway’s company. An Altria spokesperson said the tobacco giant worked with the firm “during the late 1990s to 2001” but no longer does. The Susan B. Anthony List said the anti-abortion group has “frequently” worked with the Polling Company, most recently in January shortly before Trump was sworn in, but has no current projects with the firm. And a spokesperson for the American Road and Transportation Builders Association, which voiced support for Trump’s campaign promise to spend billions on the nation’s roads, told Slate that the firm has “done some good work for us” but did not respond to a follow-up about whether they’re currently working with the company now that Conway is in the White House.

Compared to the big-dollar conflicts created by President Trump’s own business empire—or those of his wealthy son-in-law, Jared Kushner, who also serves as a White House adviser—those that might be posed by Conway retaining ownership of her firm seem almost quaint. According to a copy of the firm’s contract with the U.S. Consumer Product Safety Commission reviewed by Slate, for instance, the government paid the firm $22,610 to conduct a total of four focus groups a decade ago.

It might be hard to imagine a five-figure consulting deal shaping federal policy. But we don’t know who is paying the Polling Company, or how much. The point of the bribery, graft, and conflicts of interest statute in question is to police any potential conflict. The president is said to have a tendency to make decisions based on the last person he talked to. Conway’s office is right in the West Wing. A major corporation wouldn’t need to pay the Polling Company to explicitly deliver its message to the president; simply knowing where your money is coming from could be enough to influence your thinking, which is why the laws are clear on this topic.

It’s also why Conway and the White House need to be clear as well. If she plans to sell her company, she should commit publicly to doing so. Step one would be for Conway to actually request a certificate of divestiture from OGE as the White House implied she was in the process of doing. If she isn’t going to sell, the White House should explain how she could possibly retain ownership of the company and avoid breaking the law, offer a running disclosure on all of the Polling Company’s clients, and all of the issues from which she is recusing herself. Anything short of that and Conway might as well reprise her role as a pitchwoman for Trump goods and services—that, at least, she was doing out in the open.

Know anything about the Polling Company or any other potential conflicts of interest in the Trump administration? DM Josh Voorhees on Twitter or email him at josh.voorhees@slate.com.