(https://www.citizensforethics.

org)

A DISGRACEFUL  

MILESTONE:
 (HTTP://WWW.FACEBOOK.COM/CITIZENSFORETHICS)  (HTTP://WWW.TWITTER.COM/CREWCREW)

TRUMP’S 3,000
CONFLICTS OF
A NEW MILESTONE INTEREST (https:

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President Trump’s unprecedented decision to retain his business interests while serving in the White House set the stage for a work-
deluge of conflicts of interests between the government and the Trump Organization. From the beginning of President Trump’s 2018?
administration, CREW has endeavored to track these conflicts (https://www.citizensforethics.org/trump-conflicts-of-
interest-tracking/), which pit President Trump’s personal and financial interests against those of the nation as a whole, and
this week, President Trump reached a new, disgraceful milestone: He has racked up 3,000 conflicts of interest during his time
in office.

Throughout his three years as president, Trump has used his office to praise and promote his resorts and golf courses.
Foreign governments have granted long sought-after trademarks to his businesses, opening up new avenues of profit for his
company. And by showing up at lavish fundraisers and political events, President Trump has also granted unparalleled access
to his administration for wealthy political donors and special interest groups that spend hundreds of thousands of dollars a
year to hold events at his properties. These examples, and many others, are all included in Trump’s growing tally of conflicts.

In contrast to his promise that a strict separation would be enforced, President Trump has established his private businesses
as an extension of his White House—by visiting them and rewarding their customers with access to, and sometimes jobs
within, his administration. Meanwhile, the Trump Organization has embraced the image, and as a result, patronizing the
president’s businesses has become an unregulated and unaccountable tool of influence for special interests and foreign
governments seeking to influence the White House.

CREW defines a conflict as any interaction between the Trump Organization and the government and between the Trump
Organization and those trying to influence the Trump administration. Additional information about our methodology is
available here (https://www.citizensforethics.org/conflicts-tracker-methodology/).
 POLITICAL ALLIES FREQUENT TRUMP PROPERTIES
(https://www.citizensforethics.org)
 
In recent months, Republican officials have stepped up their support (https://www.citizensforethics.org/members-of-
congress-trump-properties/) for Trump in the way 
 (HTTP://WWW.FACEBOOK.COM/CITIZENSFORETHICS) he (HTTP://WWW.TWITTER.COM/CREWCREW)
likes best: by flocking to his eponymous properties, often for lavish
events that boost the president’s businesses. Through frequent visits and relentless promotion, Trump has made it very clear
that the best way to curry favor with him is by visiting one of the many properties that he still owns and profits from as
president.

Even during President Trump’s impeachment, when members of Congress were supposed to be acting as impartial
investigators and jurors in his trial, visits to Trump’s properties actually spiked compared to prior months.  Fifty-five members
(https:
of Congress visited Trump properties 78 times in between House Speaker Nancy Pelosi’s opening of the impeachment inquiry

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Seouse
ate Sep , 0
Hearings
Trial 2018?
Impeachment Inquiry Announce

Overall, since President Trump took office, Lindsey Graham has been Trump’s most loyal patron in Congress with 21 visits,
followed by Kevin McCarthy and Rand Paul at 16, Mark Meadows at 13, and Jim Jordan and Matt Gaetz with 10 each.
(https://www.citizensforethics.org)
Top Congressional Visitors to Trump Properties
 

 (HTTP://WWW.FACEBOOK.COM/CITIZENSFORETHICS)  (HTTP://WWW.TWITTER.COM/CREWCREW)

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Many visits from members of Congress occurred during political fundraising events. Three significant political events took
place in the midst of the impeachment debates: the Take Back the House 2020 fundraiser, attended by 15 Representatives
(including a couple of members from House committees involved in impeachment), Senate Leadership Fund’s private dinner
event, and the National Republican Senatorial Committee’s Save the Senate retreat, attended by nine Senators.

In addition to making visits, some members of Congress have taken to social media to express support for Trump and
compliment his properties. Representatives Jody Hice and Paul Gosar fawned over Trump’s Mar-a-Lago Club with a series of
tweets where they called the club “amazing (https://twitter.com/JodyHice/status/1198649065636007936)” and “off the
hook (https://twitter.com/DrPaulGosar/status/1198667786089684992).” Representative Thomas Massie has similarly
gushed (https://twitter.com/OConnellPostbiz/status/1227340501189300224) over
(https://twitter.com/RepThomasMassie/status/1174719173781532672) the president’s D.C. hotel.

It’s no secret that the Trump hotel in D.C. is a sanctuary for conservative politicians and professionals who have or who seek
ties to the administration. On the night that Senate Republicans acquitted Trump of charges of abuse of power and
obstruction of Congress, his supporters converged at the hotel to celebrate. CREW tracked 15 members of Congress and
administration officials present that night. 

White House and executive branch officials are also frequent visitors. Several have even hosted personal events at the D.C.
hotel. Most recently, the wedding of White House officials Stephen Miller and  Katie Waldman brought 22 other Trump
administration officials—including the President and Vice President Mike Pence—to the Trump hotel. Together, the newlyweds
were the fifth and sixth (https://twitter.com/Z_Everson/status/1229911223602483202) Trump officials who are known to
have gotten married there since 2017. 

Departing administration officials Tony Sayegh (https://www.politico.com/newsletters/playbook/2019/06/14/and-the-next-

white-house-press-secretary-is-447180?nname=playbook&nid=0000014f-1646-d88f-a1cf-5f46b7bd0000&nrid=00000150-
c953-d0d8-a5f2-cb5796dc0001&nlid=630318) and Sarah Huckabee Sanders
(https://www.politico.com/newsletters/playbook/2019/06/26/will-trump-overshadow-the-democrats-first-debate-night-
450659) both had their going away parties at the hotel last year. Sanders’ party in particular brought a whopping 38 officials to
the President’s prized property. In August, the Washington Post reported
(https://www.citizensforethics.org)
(https://www.washingtonpost.com/business/2019/12/09/attorney-general-reschedules-trump-hotel-holiday-party-doj-
wont-disclose-date/)that Attorney General Bill Barr booked the hotel for his annual holiday party, though he was forced to  
reschedule due to negative press coverage. While it is unclear whether the party actually occurred, Barr put down a $10,000
deposit to book the venue—putting money right intohis
 (HTTP://WWW.FACEBOOK.COM/CITIZENSFORETHICS) boss’s pocket.
(HTTP://WWW.TWITTER.COM/CREWCREW)

Of course, the most frequent visitor is Trump himself. During his campaign for office he criticized Obama for making golf
outings and told the press (https://thehill.com/blogs/in-the-know/245884-trump-i-would-rarely-leave-the-white-house) that
if elected, he would “rarely leave the White House because there’s so much work to be done.” In December of 2015, Trump
blasted President Obama for reports suggesting (https://www.washingtonpost.com/news/early-
lead/wp/2015/12/22/donald-trump-rips-obama-for-playing-more-golf-last-year-than-tiger-woods/) he had played 250
(https:
rounds of golf during nearly seven years in office, but since his inauguration just three years ago, President Trump has made

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267 visits to the golf courses that he owns and profits from. 
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Trump has made it clear that while traveling he prefers to stay at his own properties, regardless of his destination. On his 2018?
recent trip out to the west coast (https://www.nytimes.com/2020/02/19/us/politics/trump-phoenix-rally.html), the
president insisted on staying at his Las Vegas hotel each night of his trip, despite having speaking engagements in California,
Colorado, and Arizona. This is not the first time that Trump has derailed his travel plans to stop at one of his properties. Trump
made a pit stop at his Hawaii resort in 2017 before traveling to Asia, and in 2019 he stayed at his Doonbeg golf course,
hundreds of miles out of the way of meetings in the U.K. and France. 

SPECIAL INTERESTS AND POLITICAL GROUPS PAY TRUMP FOR

LAVISH EVENTS 
Political groups and special interests have held 78 and 117 events, respectively, at Trump properties since the president took
office. These often afford the hosts and attendees something that other venues don’t have: Access to top Trump
administration officials, and even the President. Trump himself has attended 30 events at his own properties. 

While the Trump hotel in Washington is far and away the most frequently booked venue out of all of Trump’s businesses,
political groups and special interests have held events at 12 different Trump properties. In the last four months alone, Trump
Victory, a political group that raises money for the RNC and the Trump campaign, has held political events at four different
Trump properties, and the RNC held one at a fifth. Over the same period, political groups linked to Republican House and
Senate leadership gathered members of Congress for events at the Trump hotel in Washington. 

Two April 2018 recordings (https://www.nytimes.com/2020/01/26/us/politics/trump-recording-donors.html) released

(https://www.washingtonpost.com/politics/new-recording-shows-access-lev-parnas-and-igor-fruman-had-to-trump-at-
mar-a-lago-donor-event/2020/01/30/a11cb354-437e-11ea-abff-5ab1ba98b405_story.html) last month by the lawyer
representing an indicted Giuliani associate provided a rare look behind the scenes of these events. In one recording from a
dinner held by a pro-Trump super PAC called America First Action at the Trump D.C. hotel, donors representing natural gas,
steel, and other interests are heard lobbying Trump directly for their personal business interests during a dinner at the Trump
hotel in Washington. That same super PAC held its seventh event at a Trump property this month. Naturally, President Trump
stopped by.

President Trump’s visit to the hotel was a stroke of luck for another group there that night. The Texas Trucking Association
was in Washington for a lobbying event, and staying at the president’s hotel. The group posted a video
(https://twitter.com/TX_TA/status/1227967863488733184) of Trump passing through the lobby and shaking hands with
hotel customers on Twitter, adding that the encounter “made our members day” as well as an open invitation to the president
to “talk trucking.” 

In addition to President Trump himself, no private event venue in Washington can offer access to Trump administration
officials like the Trump hotel can. Cabinet members have visited the hotel to attend events with special interests or wealthy
political donors no fewer than 28 times—in essence, giving special interests and major donors access to powerful people in
(https://www.citizensforethics.org)
the president’s orbit, while the president himself personally profits from the event.  
 
The federal government and government-linked groups have hosted events at the Trump hotel in Washington, bolstering the
appearance that the president’s properties are an extension
 (HTTP://WWW.FACEBOOK.COM/CITIZENSFORETHICS) of his administration. The Commerce Department
 (HTTP://WWW.TWITTER.COM/CREWCREW)
(https://www.americanoversight.org/document/foia-to-the-commerce-department-seeking-records-on-agency-resources-
towards-agency-2017-holiday-party-at-the-trump-hotel) held a holiday party at the Trump hotel in 2017, and an Army
Battalion (https://www.citizensforethics.org/army-contract-us-government-spending-trump-properties/) gathered there for
an event last year. According to documents obtained by CREW, government funds were used to pay a deposit to the hotel for
that event, although they were reimbursed through ticket sales and private fundraisers. 

(https:
In November, The 45 Alliance, a pro-Trump dark money nonprofit, hosted (https://www.citizensforethics.org/trump-

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transition-150k-45-alliance/) a reception for Trump officials “to connect with fellow President Trump appointees and
celebrate your continued dedication and service.” Housing and Urban Development Secretary Ben Carson is reported to have
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addressed attendees (https://1100pennsylvania.substack.com/p/hotels-revenue-from-army-ball-exceeded)—from behind a 2018?

Trump Hotel podium no less. 

TRUMP CUSTOMERS GET SPECIAL TREATMENT FROM HIS

ADMINISTRATION
What do Trump customers get from all of their patronage? Nominations
(https://www.usatoday.com/story/news/investigations/2019/02/08/donald-trump-picks-ambassadors-golf-club-mar-lago-
members/2748260002/) to federal positions and promotions (https://www.washingtonpost.com/national-security/trump-
to-name-richard-grenell-us-ambassador-to-germany-as-acting-head-of-intelligence/2020/02/19/640a0716-536c-11ea-
929a-64efa7482a77_story.html) to higher ones, the chance to “shadow rule (https://www.propublica.org/article/ike-
perlmutter-bruce-moskowitz-marc-sherman-shadow-rulers-of-the-va)” a federal agency, and opportunities
(https://www.citizensforethics.org/customer-care-at-mar-a-lago-president-trump-consults-members-of-his-elite-club-
about-policy-and-staffing/) to weigh in to President Trump on myriad official questions by just hanging around. An
anonymous former White House official told (https://www.washingtonpost.com/politics/time-at-mar-a-lago-is-a-respite-
for-trump--and-a-headache-for-his-staff/2017/12/29/c1c3764a-ecb1-11e7-b698-91d4e35920a3_story.html) the
Washington Post that “anyone who can get within eyesight changes the game” at Mar-a-Lago, Trump’s private club that costs
$200,000 to join. Even club guests out of Trump’s sight are given “listening time
(https://www.nytimes.com/2019/01/31/us/politics/mar-a-lago-trump.html)” from White House aides, per President Trump’s
orders. In spite of their access to the president and his administration, the White House has insisted that the names of club
members should be kept secret. 
 Considered or Nominated for Ambassadorships
Icons made by Freepik at www.flaticon.com
(https://www.citizensforethics.org)
 

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(https:

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About Tableau
© 2020 Mapbox © OpenStreetMap
Undo

Members of President Trump’s clubs have also been given sneak previews of upcoming administration action. In December,
he hinted (https://www.thedailybeast.com/trump-told-mar-a-lago-pals-to-expect-big-iran-action-days-before-soleimanis-
death) to guests at Mar-a-Lago that he would be taking a “big” action involving Iran “soon.” Days later, his administration
announced that Iranian military official Qassem Soleimani had been killed. Last year, Mar-a-Lago patrons overheard President
Trump grumbling (https://www.nytimes.com/2019/05/28/us/politics/trump-john-bolton-north-korea-iran.html) about his
then-national security advisor John Bolton, a few months before his ouster from the White House. 

Prospective Trump officials have also appealed to President Trump through his businesses. Earlier this year, the Wall Street
Journal reported (https://www.wsj.com/articles/a-reversal-by-trump-revives-agency-that-aids-exporters-11578565800)
that President Trump’s nominee to lead the Export-Import Bank, Kimberly Reed, saw the president at his Trump National Golf
Club near Washington, D.C. and approached him about not having been confirmed yet. She was confirmed soon after. As Judy
Shelton sought Trump’s nomination to the Federal Reserve board, she conducted (https://www.citizensforethics.org/trumps-
nominee-to-the-federal-reserve-board-is-another-trump-customer/) a series of high-profile interviews from the lobby of his
D.C. hotel and even booked an expensive suite there. On (https://www.ft.com/content/c253d1b8-84cf-11e6-8897-
2359a58ac7a5) multiple (https://www.ft.com/content/46c4b186-8308-11e9-b592-5fe435b57a3b) occasions
(https://fortune.com/2016/08/18/trump-gold-standard-economic-advisor-woman-judy-shelton/), she has expressed being
open to having an international conference at Mar-a-Lago.

TAXPAYER MONEY FLOWS TO THE PRESIDENT’S PROPERTIES 

In August, President Trump used his platform at the G-7 conference in France to announce that his administration would likely
hold the next year’s summit at his own Trump Doral resort near Miami. In October, the administration made the announcement
official. The Trump Organization released a statement saying that it would be “honored
(https://www.washingtonpost.com/politics/trump-has-awarded-next-years-g-7-summit-of-world-leaders-to-his-miami-
area-resort-the-white-house-said/2019/10/17/221b32d6-ef52-11e9-89eb-ec56cd414732_story.html)” to host the meeting.
Days later, President Trump caved to pressure from the public, lawmakers, and watchdog groups who objected to the conflict
of interest and announced the G-7 would take place elsewhere. 
(https://www.citizensforethics.org)
While originally floating the idea of hosting the G-7 at his own property, President Trump claimed that the choice was based
largely on other members of the government, including the Secret Service, expressing a preference for his Doral resort.  
Records obtained by CREW contradicted that claim, showing (https://www.citizensforethics.org/secret-service-docs-
contradict-trump-doral-g-7/) that the Trump resort
 (HTTP://WWW.FACEBOOK.COM/CITIZENSFORETHICS) was added for consideration at the last minute and the Secret Service
(HTTP://WWW.TWITTER.COM/CREWCREW)
expressed hesitation about “challenges” the location would present. 

During an interview after the President first teased having the G-7 at his own resort, Eric Trump objected to conflicts of interest
concerns by claiming having it there would be less expensive for taxpayers than any other venue. “We’d be doing it for nothing,”
he told (https://finance.yahoo.com/news/g-7-at-trump-golf-resort-saves-the-us-money-eric-trump-192655739.html)Yahoo
News. That’s consistent with other statements he’s made about how the Trump Organization bills the government where he’s
(https:
claimed that the Trump Organization doesn’t make any money from government business.

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Contrary to Eric Trump’s claims that the Trump Organization bills the government “at cost,” documents obtained by the
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Washington Post show (https://www.washingtonpost.com/politics/secret-service-has-paid-rates-as-high-as-650-a-night- 2018?

for-rooms-at-trumps-properties/2020/02/06/7f27a7c6-3ec5-11ea-8872-5df698785a4e_story.html) the Trump Organization
charging the Secret Service far more. The documents show the Trump Organization has billed the government up to $650 per
night to stay at Mar-a-Lago, and that the government paid Trump’s private businesses nearly half a million dollars between
January 2017 and April 2018.

NO BORDER WALLS FOR TRUMP CONFLICTS 

Trump’s presidency has not stopped the Trump Organization from continuing to do business in foreign countries. Those ties
call into question whose interests—the American people’s interests or Trump’s personal financial interests—drive the Trump
administration’s foreign policy.
 Trademarks
2019
2018
2017
Icons Granted
made by Freepik from www.flaticon.com
(https://www.citizensforethics.org)
to Trump Businesses While Trump in Office
 

 (HTTP://WWW.FACEBOOK.COM/CITIZENSFORETHICS)  (HTTP://WWW.TWITTER.COM/CREWCREW)

(https:

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About Tableau
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Late last year, CREW discovered that one of Trump’s companies applied for two trademarks
(https://www.citizensforethics.org/trump-argentina-trademarks/) in Argentina for “real estate affairs” and building
construction, suggesting that plans for a Trump Tower Buenos Aires might be moving forward. These were the first
trademarks that Trump has applied for in the country since his election.

A closer look showed that the timing of the applications closely coincided (https://www.citizensforethics.org/trump-tower-
argentina-trademarks/) with Trump administration action on tariffs in Argentina. After the trademark opposition period ended,
Trump lifted tariffs on steel and aluminum from Argentina and a few other Latin American countries. Soon after the
application was granted Trump reinstated the tariffs, defending his actions on Twitter by claiming that Argentina had
manipulated their currency.

Trump’s international conflicts of interest span the globe to Indonesia, where the daughter of one of his business partners has
assumed a high ranking role (https://www.citizensforethics.org/indonesia-trump-angela-tanoesoedibjo/) in the Indonesian
government, thus directly linking Trump’s business to a foreign government. Angela Tanoesoedibjo was appointed in October
to a position which gives her power over tourism in the country. Tanoesoedibjo’s father owns and operates one of Indonesia’s
largest real estate conglomerates, MNC Group, which is building two Trump-branded developments in the country. In one
meeting between government officials and her father’s Trump-connected company, an official brought up a property MNC
Group is developing that will have Trump-branded aspects.
 CONCLUSION
(https://www.citizensforethics.org)
 
President Trump’s time in office has been an ethical disaster. While previous administrations have taken every precaution
(https://www.washingtonpost.com/news/national/wp/2018/08/17/feature/the-un-celebrity-president-jimmy-carter-shuns-
 (HTTP://WWW.FACEBOOK.COM/CITIZENSFORETHICS)  (HTTP://WWW.TWITTER.COM/CREWCREW)
riches-lives-modestly-in-his-georgia-hometown/) to avoid the appearance that the president’s official actions could be
tainted by their private business interests, President Trump has instead done the exact opposite, blatantly and regularly using
his office for his own financial gain. Three-thousand conflicts of interest later, President Trump has sent a clear message to
special interests, foreign governments, and others trying to influence the federal government that his presidency is effectively
for sale.

(https:
Instead of providing oversight or enforcing a higher standard, members of his administration and Republicans in Congress

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have condoned President Trump’s ethical abuses by taking their business to his properties and rewarding special interests
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who do the same with official access. Some have gone so far as to use their official platforms to give Trump businesses free
advertising. Their abdication of responsibility has served to embolden President Trump, whose presidency is devolving into a
2018?

cash grab that erodes ethical norms every time he visits his properties, promotes the Trump Organization, or bills the Secret
Service top-dollar to stay at his foundering resorts.

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