Donald Trump’s Conflicts of Interest: A Crib Sheet

Authored by theatlantic.com and submitted by SallyYatesIsAHero

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.”)

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.

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.

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.

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:

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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 activities. And if Trump so chooses, he could direct the Justice Department to curtail its enforcement of the FCPA or even use his bully pulpit to lead a legislative push to undo it, essentially condoning unethical behavior that in many countries enables leaders to personally profit at the expense of their own citizens—which, of course, could be a fair way to characterize the current situation with Trump’s business holdings.

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.

Chen’s purchase represents the exact kind of entanglement that has fueled concerns that Trump’s financial interests could influence his decision-making as president. Chen is the founder and managing director of Global Alliance Associates, a consulting firm that, according to its website , “facilitates the right strategic relationships with the most prominent public and private decision makers in China.” The firm is explicit about what it sells: access . Though the page listing its partnerships is currently empty, the firm’s “ affiliates ” page includes a number of international organizations promoting relationships between private corporations and the governments of the United States and China, including the USA-China Chamber of Commerce , the Asia Society , and the China Institute . Notably, Global Alliance Associates also consults for the U.S. Department of Commerce and the U.S. Trade & Development Agency, meaning that Trump is accepting money from the founder and managing director of a firm that works with the U.S. government.

With President Trump in office and still refusing to distance himself from his businesses, every new tenant in one of his buildings creates another possibility of a conflict of interest. Such is the case with Xiao Yan Chen, who also goes by Angela Chen, a business executive who, according to documents filed with the New York City Department of Finance, purchased a $15.8 million penthouse apartment at Trump Tower in New York on February 21. Chen’s transaction is the first notable real-estate deal involving one of Trump’s properties since the election, although it should be noted that she has lived in a different unit in Trump Tower since 2004. And though Trump has officially removed himself from the board of directors of Trump Park Avenue LLC, the corporation that runs Trump Tower, he remains the company’s owner, meaning that he profits from its dealings.

The Trump Organization’s January 11 pledge that it would no longer be pursuing new deals in foreign countries is looking increasingly toothless. Shortly after President Donald Trump took office, The Guardian reported that the president’s business would be moving forward with a planned expansion of its golf course in Aberdeen. Now, the Associated Press has reported that the company is working on a licensing deal in the Dominican Republic.

Because Trump is holding onto his businesses, he has created a situation in which some of his earnings include money from the leader of a company whose sole goal is to help its clients curry favor with the Chinese government; it’s no stretch to believe that her move to Trump Tower and the money it puts in Trump’s pocket may help her gain access to the United States government. (Reached for comment by the New York Post , Chen said she was “not comfortable” discussing the purchase and its possible ramifications for her company.) Even if it wasn’t Chen’s intention, the transaction still could influence the president. As the president’s conflicts of interest continually accumulate, the likelihood that one or more will eventually impact his decision-making continually grows—as does the appearance that he is ethically compromised by the many people, organizations, and governments from which he is receiving money while in office.

The development in the Dominican Republic epitomizes the way the Trump Organization seems intent to violate the spirit of their “no new foreign deals” pledge, and arguably even the letter. Asked about the Organization’s justification for the deal, Richard Painter, who served as the ethics lawyer for President George W. Bush, noted that the company “can take the tiniest little past involvement in something and then extend it into an enormous new deal” and hasn’t presented a meaningful way “to distinguish between new business and old business.” Already, the Trump Organization has provided excuses for moving forward with two projects based on an interpretation of its own pledge that seems predicated on the idea that a deal can only be described as “new” if there had never been any relationship whatsoever between the Trump family and the property in question. As the company finds more explanations to broaden what initially seemed to be a clear-cut policy to reduce conflicts of interest—arguably, the only step in Trump’s plan that actually would have helped him do so—the pledge will likely become increasingly meaningless.

As was true with the Aberdeen plans, the Trump Organization has provided a narrow justification under which it argues that the news does not violate its promise. Technically, it argues, the deal is not new : The Trump Organization has had a contract with Ricardo and Fernando Hazoury, the brothers who own the Cap Cana Resort in the Dominican Republic, since 2007. But the financial crisis and disagreements between the Trump family and the Hazoury brothers, which climaxed with Eric Trump accusing the pair of “textbook fraud” in a 2012 lawsuit, had stalled the arrangement for nearly a decade, and the two parties haven’t written a new contract since the 2007 deal was struck. Even other real-estate developers have said that the resumption of the relationship between the Trumps and Hazourys caught them by surprise. For their part, the Hazourys have said that the relationship with the Trumps “remains incredibly strong, especially with Eric, who has led this project since its conception.”

The president’s putative pick for his ambassador to the Dominican Republic only adds to the perception that Trump will intermingle business and politics in the country. Trump has picked Robin Bernstein , a campaign donor, business partner, and founding member of Trump’s Mar-a-Lago Club, to be his administration’s representative in the country. Bernstein and her husband Richard have been in business with the president and his company for decades through The Americas Group , a consulting and marketing firm focused on construction projects in Latin America and the Caribbean. Choosing personal friends and supporters to be ambassadors is relatively common, especially in countries with which the United States has relatively uncomplicated relations. However, Trump’s decision to appoint somebody with whom he has long maintained a financial relationship— his second such appointment , after having named fellow billionaire real-estate developer and business partner Steven Roth to head his infrastructure program—suggests a continued willingness to blur the lines between his endeavors as a businessman and his duties as president, all while contributing to the perception that the president is willing to reward those who have done business with him in the past.

Almost immediately, Trump’s critics pointed out that the ruling poses a clear conflict of interest. Senator Dianne Feinstein of California called the trademark decision “deeply troubling,” adding, “If this isn’t a violation of the Emoluments Clause, I don’t know what is.” Some, including Feinstein, went further in their assertions: Only days before, Trump had apparently reversed one of his stances toward China by offering a full-throated endorsement of the “One China Policy” (under which countries officially recognize the mainland Chinese government but not Taiwan), leading to the suggestion that the court’s decision was part of a quid-pro-quo deal between the two governments.

On February 15, President Trump scored a long-sought-after victory when a Chinese court ruled in his favor in a trademark dispute . In the case, which dragged on for more than a decade, the Trump Organization won sole rights to use the president’s name on products in the country, which would help prevent a bevy of unrelated entrepreneurs from applying it to a wide range of products , from toilets to clothing to condoms to explosives.

The situation perfectly encapsulates the way the president’s business interests are coming up against those of the country. Already, the Trump Organization’s decision to double Mar-a-Lago’s initiation fees led to accusations of profiteering, premised on the notion that people would be willing to pony up in the hopes of earning an audience with the commander-in-chief.

His third weekend in office, Trump brought a guest of honor along with him: the prime minister of Japan, Shinzo Abe. After first meeting with Abe at the real White House, Trump took his Japanese counterpart to Florida for a weekend on the links. The biggest controversy out of the weekend was over the president’s handling of a situation that developed on Saturday, February 11: As news of a North Korean missile test broke during dinner, Trump and Abe discussed the situation in public , using light from phones of gathered onlookers to read briefing documents, an incredibly lax approach to information security, particularly ironic given that Trump won in part because of his opponent’s own lapses in information security .

Of his first three weekends in office, President Donald Trump spent two of them away from Washington, D.C., at his Mar-a-Lago Club in Palm Beach, Florida. On his first trip to the resort, which he has dubbed his “Winter White House,” Trump spent time on the golf course, attended a ball held by the Red Cross—a federally chartered organization over which he will likely be tasked to wield authority while in office—and held a Super Bowl party at which he hobnobbed with wealthy patrons.

Whether or not the Chinese government tried to curry favor with the president by seeing to it that the court ruled in his favor, Trump’s newly awarded trademark poses a conflict of interest that could impact his future interactions with China. On top of the questions around his adherence, or lack thereof, to the One China Policy, Trump has taken a number of controversial stands when it comes to China, from accusing the country of currency manipulation to threatening to take hard-line trade positions that experts worry could lead to a trade war . Over all of these questions will loom the president’s knowledge that, with its trademark now secured, his company has an ongoing profitable relationship with the Chinese government—which, even if Trump does not proactively consider it in approaching the negotiating table, could provide his Chinese counterparts with leverage to influence the president’s decisions.

The events of Saturday, February 11 took the problem to a whole new level. By discussing the recently obtained intelligence with Abe without leaving the table, the president committed a breach of international-security protocol in a very public setting. Even had the meeting been taking place in the White House, Trump’s lackadaisical approach to information security would have been cause for concern; for self-evident reasons, briefings on urgent security situations do not typically happen in somewhat open settings around civilians. But on the patio at Mar-a-Lago, the situation becomes much more dangerous, because the patio is not a secure setting, and the administration does not appear to have taken measures to make it one. This is a perfect example of a conflict of interest in practice: Trump has an incentive to host an event at Mar-a-Lago (personal financial gain) that runs directly counter to what would be best for the country’s security (hosting the event at the White House or an otherwise secure location). Not only that, part of the appeal of Mar-a-Lago is that guests will have a front-row ticket to see Trump at work. Previous presidents like Barack Obama, meanwhile, took a more conventional, and far more secure, approach, setting up a mobile security perimeter known as a sensitive compartmented information facility , or SCIF, to ensure that nobody in the area could look in on or overhear the president’s dealings.

Who could have been present? The club’s membership list is private, meaning that the American public has no way of knowing who was around to overhear the conversation. (Two Democratic senators, Tom Udall and Sheldon Whitehouse, have introduced a bill to change this fact, but there is little evidence suggesting it has any hopes of passing through the Republican-held Congress.) Nor have the Trump Organization and White House been forthcoming as to how they intend to screen club members and employees for security clearance; though Udall and Whitehouse reached out to the administration to ask how Mar-a-Lago vets guests for security risks, but received no response. In such a public place, and without protective measures like a SCIF, there may not be anything to stop an agent of a foreign government or other malicious actor from paying the $200,000 initiation fee to stay at the club, effectively paying to be near to the president when he receives sensitive information. Unless Trump takes significant steps either to erect barriers between himself and the guests at Mar-a-Lago—which he certainly didn’t do this time, and which could reduce his ability to profit from the property—there is a real possibility that he will continue to compromise his country’s interests when he travels to his resort in Palm Beach.

According to the president’s Press Secretary Sean Spicer, Mar-a-Lago does, in fact, have a SCIF on site that they used for the remainder of the Trump’s conversation about North Korea with Abe. That they apparently began their discussion at the dinner table before deploying the SCIF underscores the problem of the situation at Mar-a-Lago: Trump has a financial incentive to hold an open-air meeting like Saturday night’s to keep up the appearance that, by paying to be a member of his exclusive club, anyone can have access to the most powerful man in the world.

There is no reason to believe that DeAgazio had any intention of compromising international security with his pictures; he appears to simply be a wealthy Trump supporter who was excited at the chance to see his commander-in-chief in action and wanted photographs with which to remember the occasion. (He has since apparently either deleted his Facebook profile or increased his privacy settings so that it is no longer publicly accessible.) Nevertheless, he demonstrated just how Trump’s continued commingling of his business interests and his presidency places not just Americans but the entire global community in jeopardy.

The Department of Defense’s decision is yet another example of how Trump’s decision to hold onto his business interests is rewriting norms surrounding the presidency and creating problems in what were once uncontroversial procedures. As mentioned above, the Department of Defense’s decision is not unique to Trump’s presidency: They took up residence in Chicago , for example, during Barack Obama’s two terms for the exact same reason.

President Donald Trump’s most iconic property is about to get a new tenant: the Department of Defense. According to CNN , the Pentagon, hewing to a longstanding policy of establishing an offshoot headquarters near the president’s private, non-White House residence, is planning to lease space in Trump Tower in New York City to maintain close proximity to Trump should he choose to spend time there instead of Washington, D.C..

In a way, the sheer enormity of the situation at Mar-a-Lago briefly crowded out the fact that merely bringing Abe to Mar-a-Lago demonstrates Trump’s conflicts of interest neatly. Though diplomatic meetings outside the White House are not unprecedented, Trump’s trip with Abe is likely the first instance of the president actually making money from such a meeting. Though Trump said that he was footing Abe’s bill , with both increased Secret Service presence and Abe’s retinue on hand, there’s a distinct possibility that, at some point in the weekend, somebody from the U.S. or Japanese government made a payment that ended up in Trump’s pocket. On top of that, the visit generated an inordinate amount of free publicity for Mar-a-Lago, which Trump repeatedly mentioned (and posted photos of ) on his social media accounts and was continually noted in coverage of the weekend.

Just how much the DoD will be paying the Trump Organization for the privilege of working out of the president’s property is not the only outstanding question. Trump’s protestations to the contrary aside, scientific evidence shows that the mere knowledge that one has profited from a relationship in the past often leads to preferential behavior, which could lead Trump to favor the Pentagon in his decision-making. As a result, beyond the overarching problem of a government agency paying the president himself a large sum of money to set up shop in the president’s property, the Department of Defense’s decision to rent space in Trump Tower could have significant ramifications for how the Trump White House operates.

The difference, as is true in so many of the stories surrounding Trump and his family’s conflicts of interest— the Red Cross’s decision to hold its annual ball at Mar-a-Lago , for example, or Eric Trump’s business trip to Uruguay —is that the president himself is now making money off of routine governmental functions. Exactly how much money remains unknown, as the Department of Defense has yet to publicly state how much space they will be renting and for how long. However, details of the Secret Service’s decision to do the same are instructive as to the general scope of the bill. When that news first broke back in November 2016, the New York Post used publicly available information regarding rents at Trump Tower to deduce that , at a cost of up to $105 per square foot, the Secret Service’s decision to occupy two 3,000- to 5,000-square-foot floors of the building could cost taxpayers more than $3 million a year, a significant portion of which would be going to the Trump Organization, and, by extension, the president himself.

The web of President Donald Trump’s conflicts of interest has grown to encompass the American Red Cross, which held its annual ball on Saturday, February 4, at Trump’s Mar-a-Lago Club in Palm Beach, Florida. By hosting the ball, the Trump Organization accepted money from an organization that, while not a federal agency per se, is subject to federal oversight that at some point in the next four years will likely involve President Trump.

Unlike a number of the events at Trump properties that have been featured in this list of Trump’s conflicts of interest, the Red Cross Ball, which celebrated the organization’s centennial anniversary, appears to have been scheduled before Trump even received the Republican nomination for president; a calendar listing on the website of the Coastal Star, a local newspaper covering events in the Palm Beach area, is recorded as having been placed in April 2016. Additionally, though the event has been held elsewhere in the past, this was not the first time it has taken place at Mar-a-Lago: Not only was last year’s ball held there, but the very first Red Cross Ball was hosted there by the property’s prior owner, the famous socialite Marjorie Merriweather Post.

Given all that, there is no indication that the decision to hold the event at Mar-a-Lago had anything to do with Trump’s election, and the fact that Trump will likely be attending the event is not unusual—President Barack Obama also attended as the honorary chairman of the organization while in office. Nevertheless, the ball perfectly encapsulates why Trump’s continued refusal to relinquish his business interests complicates even situations that would have taken place had he not become president.

Thanks in part to the makeup of the Red Cross’s leadership and its unique relationship with the federal government, the ball creates a particularly complicated situation. According to its website, the Red Cross “is not a federal agency, nor [does it] receive federal funding on a regular basis to carry out our services and programs,” instead relying on donations and fees for services like health-and-safety training courses. However, the organization operates under a federal charter as a “federal instrumentality … to carry out responsibilities delegated to [it] by the federal government.” The best-known of these duties include overseeing blood-donation drives and disaster-relief efforts; according to its website, it is also the Red Cross’s duty “to fulfill the provisions of the Geneva Convention” and “provide family communications and other forms of support to the U.S. military.” Further, the organization has a chairperson appointed by the president; currently, the chairwoman is Bonnie McElveen-Hunter, who was appointed by President George W. Bush in 2004. The charter also periodically comes before Congress for review and amendments to be signed into effect by the president.

On multiple occasions in recent years, the Red Cross has come under scrutiny for how it handles its multi-billion-dollar budget, most of which comprises donations from the American public. Prompted in part by reporting on the organization’s inadequate response to Hurricane Sandy, misleading statements about how it uses its money, and a September 2015 report by the Governmental Accountability Office, two congresspeople—one Democrat and one Republican—have independently introduced measures to increase the organization’s transparency. Neither has been enacted, but there will likely be another push to improve the relationship between the federal government and the Red Cross during Trump’s presidency, whether via a review of the Red Cross’s charter, the need to appoint a new chairperson, or the introduction of reform-minded legislation. If and when Trump is called upon to weigh in on these decisions, he will be asked to do so having directly profited from the organization while in office, which could limit his ability to act in the best interests of the American people.

One month before he took office, President Donald Trump managed to sidestep a potential conflict of interest at his hotel in Las Vegas. In the fall of 2015, several hundred employees at the city’s Trump International Hotel had voted to join the local branch of the Culinary Workers Union, only to find their efforts stalled by Trump and the hotel’s co-owner, Phil Ruffin. The case languished for more than a year until, after the National Labor Relations Board found Trump and Ruffin in violation of federal law, the workers successfully negotiated their first collectively-bargained contract. If this hadn’t been resolved, a conflict of interest would have arisen: The case would have gone to the U.S. Court of Appeals for the District of Columbia, to which Trump will soon be able to appoint members.

Now, the same issue is cropping up at the Trump International Hotel in Washington, D.C. Already a centerpiece of the controversy over the likely violation of the Constitution’s Emoluments Clause, the property may soon be the site of another legal tussle: According to The Washington Post, 40 workers at the hotel have also voted to unionize, the first group to do so at a Trump-owned establishment since his election.

As was true in Las Vegas, the push for unionization in D.C., if it’s met with resistance from the hotel, would create an opportunity for the president to place his own financial interests above those of the hotel’s workers. In Las Vegas, the dispute appears to have been resolved partly because of the NLRB’s intercession; if the Trump Organization similarly contests the case in D.C., the NLRB may once again be asked to weigh in. And now that Trump is president, he will be appointing new board members to fill two vacancies on the agency’s five-seat panel, which could very well tip it from its current left-leaning, labor-friendly composition to a more conservative, pro-owner bent. If, as in Las Vegas, the NLRB finds in favor of the workers, but the Trump Organization chooses to continue its opposition, there is a possibility that the case could come before a federal appeals court, where judges who Trump himself may have appointed will be asked to review the NLRB’s decision. And if the conflict continues even beyond the Court of Appeals, it will fall to the Supreme Court, to which Trump recently nominated Judge Neil Gorsuch, to render a final verdict. (It should be added that each appointee will be faced with the possibility of ruling against the financial interests of the infamously vindictive man to whom they owe their position.)

Appointing labor-unfriendly officials and justices might fairly be said to be in keeping with Trump’s long history of questionable labor practices, but this does not mean that the conflict-of-interest question will dissipate. It’s difficult, if not impossible, to determine how much his pro-business stances are dictated by a sincere belief in their efficacy rather than an understanding that he himself has benefited from them in the past and will likely continue to do so in the future. As such, Trump’s motivations will continue to occupy an ethical and legal gray area until he eliminates the overlap between his roles as a businessman and as president.

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.

Still, the president apparently intends to continue not only going to Mar-a-Lago himself but also bringing high-profile diplomatic guests there for meetings. The first time he did so, in February, made news in part because it resulted in an apparent breach of security protocol: When Trump’s meeting with Japanese Prime Minister Shinzo Abe 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.

Now, Trump is returning to Palm Beach with another world leader in tow. But, as The New York Times reports, one frequent Mar-a-Lago guest may create friction between Trump and Chinese President Xi Jinping. In recent weeks, the billionaire real-estate mogul Guo Wengui has emerged as an outspoken critic of China’s ruling Communist Party, accusing it 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 will be at Mar-a-Lago, or even 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, could still cast a shadow over the president’s meeting there with Xi. Trump’s relationship with his Chinese counterpart already got off to a rocky start when 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 Guo belongs to 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. And second, it’s that 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. That exchange of money—Guo’s membership dues going into the president’s pocket—could in part end up being responsible for complicating U.S.-China relations as Trump and Xi hold their first meeting since the former became president.

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.

Of the measures that President Donald Trump and his lawyer Sheri Dillon laid out at his January 11 press conference to address conflicts of interest, only two actually ameliorate any of the concerns critics have raised: the cancellation of all of the Trump Organization’s pending deals and the promise not to pursue expansion in other countries (although developments since the announcement suggest that those pledges leave plenty of wiggle room). Conveniently left out of the plan, however, is any prohibition on expanding holdings within the United States—which is apparently something that Trump Hotels plans on doing while Trump is in office.

On January 25, Bloomberg reported that Eric Danziger, the CEO of Trump Hotels, said after a panel discussion in Los Angeles that the company is considering tripling the number of Trump-branded properties within the U.S. According to Danziger, “There are 26 major metropolitan areas in the U.S., and we’re in five. I don’t see any reason that we couldn’t be in all of them eventually.” Danziger listed Dallas, Seattle, Denver, and San Francisco as among the cities where the Trump Organization is looking to build in the near future.

As the Trump Organization’s holdings expand, so too does the potential that business considerations will have undue effects on the president’s behavior in office, or at least appear to. Each location presents another opportunity for businesspeople or foreign dignitaries to choose to stay in a hotel in an attempt to burnish Trump’s opinion of them, their company, and/or their country. Each location increases the number of municipal governments with whom Trump will be interacting both as president and as the owner of a real-estate empire.

Trump Hotels’ expansion plans could put not only Trump but also the cities where new properties may be built in a difficult situation. San Francisco, for example, is currently experiencing a housing crisis, one possible solution to which would be to increase the pace of new home-construction projects, some of which could be funded by federal grants. On the one hand, it is almost certain that the residents of San Francisco, a city that voted against the president by roughly a 9-to-1 margin in November, would strenuously object to a new Trump-branded property in the city. But there is also an incentive for the city government to work with the Trump Organization in finding a suitable expansion plan. With plenty of evidence to suggest that collaborating with Trump’s businesses could influence the president, there’s added pressure for city officials to pursue a potentially costly project residents may otherwise not want in hopes of reaping the benefits down the road. Meanwhile, the officials in charge of doling out federal largesse such as housing grants may similarly feel pressure based on the knowledge that Trump’s feelings toward particular cities may change based on how receptive the locale was of his business’s expansion plans.

Finally, the Trump Organization’s announcement that it would be pursuing expansion further attests to just how little the president’s plan to mitigate his conflicts of interest actually accomplishes its goal. For the Trump Organization to not just expand but do so on such a large scale violates the professed spirit of the measures laid out on January 11 and defies any argument that the company will cease to act in a way that jeopardizes the president’s ability to do his job.

Less than a week into his administration, President Trump has a new property opening for business: the Trump International Hotel & Tower in Vancouver. According to The Washington Post, construction on the hotel finished shortly before Trump assumed office, with the building’s finishing touch—the president’s name spelled out in giant letters—revealed on January 19 (the day before the inauguration), and the first guests and permanent residents checking in on January 25.

As with many buildings bearing the president’s name, the new hotel in Vancouver is a licensing deal, with the Trump Organization leasing its branding to a third party—in this case, a real-estate company called the Holborn Group, which operates several luxury hotels throughout Canada. The Holborn Group is run by Joo Kim Tiah, the eldest son of one of the wealthiest families in Malaysia; several members of Tiah’s family are expected to fly in from Kuala Lumpur to attend the opening with the president’s two adult sons, Donald Jr. and Eric.

The building is yet another manifestation of the running problem posed by Trump’s extensive foreign real-estate holdings. Unless the president actually rids himself of his financial stake in his company, every Trump property influences his incentives when it comes to making policy, foreign or domestic: Should he act in the manner that best serves the country, or the one that will protect his profits? Every building provides the opportunity for third parties to curry favor with the infamously capricious president: If he knows that he has taken money from somebody, be it a company, a private individual, or agents of a foreign government, that knowledge, and the goodwill it creates, is likely to color Trump’s decision-making. Moreover, every businessperson who has a licensing deal with Trump now has leverage: If Tiah, or any of the other businesspeople around the world with a Trump-branded property, disagrees with a decision the president makes, he can threaten to pull out of the partnership and jeopardize some of Trump’s cash-flow in an attempt to change his mind.

Hardly a day had passed between the new hotel in Vancouver opening for business and the first report of an organization choosing to host an event at the site, possibly for political reasons. On January 26, The Washington Post reported that The American Chamber of Commerce in Canada, a business organization affiliated with the conservative U.S. Chamber of Commerce, had scrapped longstanding plans to hold a meeting about trade relations at the home of a diplomatic official and would instead be booking space in the new Trump Hotel for the equivalent of roughly $1,900—a relatively small sum, to be sure, but even small sums have been shown to substantially influence decision making. The change initially prompted at least one planned speaker, the University of British Columbia professor Matilde Bombardini, to back out of the event; however, according to the Vancouver Sun, she has since changed her mind after being told that the change of location was due to a leak at the previous site.

As with so many of the instances chronicled here, the venue change demonstrates how Trump’s conflicts of interest often operate in shades of grey. If the Chamber of Commerce did make its decision solely based on logistics, booking a spot in a Trump-branded building still makes possible the appearance of paying for play. In a marked departure from the Chamber’s copacetic relationship with the Republican nominee Mitt Romney in 2012, the aggressively free-market, pro-trade group clashed with the president on multiple occasions during the 2016 campaign over Trump’s protectionist trade policies, but has already made public overtures since the election to reconcile with the president. If it did, in fact, choose to move the event even in part because of the giant name on the new location’s facade, the decision represents another chapter in the ongoing saga of the business community’s desire to both please and sway a president whose ideology is not that of a typical Republican. Additionally, though nearly all of Trump’s rhetoric about NAFTA centers on Mexico, Canada actually trades more with the U.S. than not just Mexico but any other country in the world. As such, there is plenty incentive for the Canadian branch of the American Chamber of Commerce to do whatever it can to reach out to Trump.

Though President Donald Trump has been a well-known figure in American public life for decades, perhaps the single biggest contributor to his stardom has been NBC’s The Apprentice. Trump himself is no longer the star of the show—former California Governor Arnold Schwarzenegger has taken over as host in 2017—but the president remains an executive producer on the series for at least the coming year, including receiving a low five-figure salary for the position, according to Variety. Shortly after the news of that income broke, Kellyanne Conway, a counselor to Trump, clarified that he would be taking on his producing duties in his spare time, comparing the situation to previous presidents playing golf or pursuing other leisure activities.

Norm Eisen and Richard Painter, who served as the chief ethics lawyers under Presidents Obama and George W. Bush, respectively, pointed out on NPR’s Fresh Air that Trump’s ongoing involvement with The Apprentice presents yet another conflict of interest. According to AdWeek, 11 companies, including the television-shopping network QVC and Carnival Company (which operates the eponymous cruise line), are providing on-air sponsorships for the newest season of The Apprentice; a twelfth, the Japanese motorcycle company Kawasaki, withdrew from a previously reported deal after customers threatened a boycott because of its sponsorship of the show. All of these companies—plus the numerous companies that run ads during the show’s commercial breaks—are effectively putting money into the pockets of the president, not to mention supporting one of his products.

Trump apparently believes himself immune to such conflicts of interest, both in terms of legal impunity and his ability to ignore them, despite a good deal of research indicating that even minuscule financial incentives (minuscule for a billionaire, that is) can be enough to significantly influence behavior. Additionally, there is little doubt that Trump cares deeply about the ongoing success of The Apprentice: The weekend after the new Schwarzenegger-led season debuted, the then president-elect took to Twitter to voice his thoughts on the new season’s ratings. So when one of the companies that sponsors the show interacts with the executive branch—as when Carnival reached a $40 million settlement with the U.S. government over pollution in the Atlantic Ocean, for example, or when QVC settled a $7.5 million suit regarding deceptive advertising in 2009—the question will necessarily arise how their contributions to Trump’s pocketbook and beloved TV show will affect the outcome.

Even if Trump were able to fully blind himself to the conflicts described above, the president’s role would remain a problem because it provides an unprecedented bargaining chip for both the companies currently sponsoring in the show and those that could seek to use it to attempt to manipulate the president. Consider, for a moment, the potential negotiations between one of Trump’s sponsors and a government agency that finds it in violation of federal regulations. That company, though, has a trump card the likes of which has never been seen in American politics: Should it become apparent that the case is going awry, they can threaten to pull their support of the president’s television show. The move would inevitably make waves on cable news of the kind that Trump has repeatedly demonstrated himself to be susceptible to. Any decision, whether in favor of the company or against it, immediately loses credibility: If the company is found guilty, the decision is easily framed as retaliatory, a vindictive manifestation of the president’s ego and narcissism; if the company is let off the hook, it will appear that the company has manipulated his venality for its own gain. A formerly uninvolved company facing federal investigation could essentially pull the same gambit in reverse: By publicly committing to sponsor The Apprentice, a company could create a situation in which any decision appears to reflect not the facts of the case but the sticky situation created by its involvement with the show. In this sense, then, Trump’s decision to stay on as executive producer, and the conflicts of interest the position creates, jeopardizes not only the president’s ability to carry out his job but also the fundamental legitimacy of the rule of law for any company that currently is or in the future may become involved with the show.

Additionally, the president’s continued involvement with the show creates a strange and tricky situation for NBC. Trump’s reputation is inextricably intertwined with that of the show, meaning that NBC will to some extent be caught between promoting Trump as a successful businessman and doing its journalistic work. The network will likely also be advertising The Apprentice during its other programs, not only through commercials but also possibly in-studio promotions on other shows, creating conflicting incentives for NBC journalists who will be trying simultaneously to talk about the Trump administration fairly while their own network markets one of his products.

The Dakota Access Pipeline, or DAPL, was the subject of continual controversy during the presidential campaign, drawing months of protests because of the perceived environmental impact it would create by crossing the Missouri River in close proximity to a Standing Rock Sioux reservation. Shortly before the election, the Army Corps of Engineers announced that it would be halting progress on the pipeline for further environmental review and to study potential routes that might avoid crossing both the river and Native American territory. On January 24, however, only four days after President Trump took office, he decided to move forward with both DAPL and the Keystone XL pipeline, which the Obama administration likewise blocked because of environmental and tribal-sovereignty concerns; the Army Corps of Engineers finalized the easement on the project on February 7. Trump has been vocally supportive of the pipelines for months, claiming that they would create new jobs in construction and the oil industry.

Trump’s FEC filings, which remain the only public record of his finances, suggest that he may have had an additional incentive to greenlight the projects: According to financial-disclosure forms he filed in June 2015 and May 2016, Trump has owned stock in Energy Transfer Partners, the company seeking to build DAPL. The stock was worth between $500,001 and $1,000,000 in 2015 and between $15,001 and $50,000 in 2016.

The president and one of his spokesmen, Jason Miller, have both stated, without offering evidence, that Trump’s stock-related conflicts of interest have been resolved. According to Trump and Miller, the president sold off his stocks in June of last year specifically to head off concerns that they may influence his decision-making in office. However, they have offered no meaningful evidence to back up their claims—evidence which, in this case, would likely be fairly easy to provide. They could, for example, offer more details on when exactly the stocks were sold beyond simply “back in June,” or explain why they did not mention the sale until December, just after the election, if the intention was to proactively address conflict-of-interest questions.

Given Trump’s penchant for dissembling about his personal finances and the lack of evidence that he has sold off his stocks, Trump’s decision to push ahead on DAPL and Keystone XL simply underscores the need for him to take larger, and more public, steps to distance himself from his financial interests. Moving forward with the pipelines is not the first instance of Trump making a significant decision that benefits a company whose stock is listed in his financial disclosures. For example, when Trump announced his intention to intervene at the factory of the air-conditioner manufacturer Carrier in Indianapolis, the Indianapolis Star noted that Trump’s filings list stock in Carrier’s parent company, United Technologies.

As has been noted on several previous occasions, one of the overarching questions about America’s first businessman presidency is just how President Trump’s vast empire will interact with federal agencies that answer to him. One of these potentially sticky situations became something of a flashpoint at the hearing for Dr. Ben Carson, Trump’s appointee to lead the Department of Housing and Urban Development. At the hearing, Senator Elizabeth Warren pressed Carson over the fact that, as the head of the department, he would be in charge of numerous programs that the president could manipulate to profit his real estate empire, asking Carson, “Can you assure me that not a single taxpayer dollar that you give out will financially benefit the president-elect or his family?” Though Carson did not respond to the question with regard to Trump specifically, he responded that he “will absolutely not play favorites for anyone” or act with an “intention to do anything to benefit any American, particularly.” (Warren went on to expound on how Trump’s lack of financial transparency makes it borderline impossible to know if a policy will benefit him.)

Warrens’s line of questioning was not entirely hypothetical: Trump does, in fact, own properties the maintenance of which falls under HUD’s purview. Thanks to an inheritance from his father, the president holds an ownership stake in—and has made millions from—Starrett City, a 153-acre, 5,881-unit low-income housing development in Brooklyn. The development, according to ABC News, receives substantial federal funding via HUD’s many programs designed to support low-income renters and homeowners. Trump could easily press for policies that would increase his profits from Starrett, most notably allowing for the sale of the complex, an action HUD blocked in 2007—and, potentially, to other properties from which he may profit in ways that, without more complete financial information, the American public may not even know.

The potential for a profitable relationship with HUD underscores a central problem with Trump’s refusal to fully divest from his holdings before entering office. It’s not just high-ranking officials who will possess the ability to act in a manner that benefits the president’s pocketbook—it’s ordinary civil servants as well. Shortly before his inauguration, The Washington Post noted several additional ways employees in Trump’s executive branch could do so: Trademark disputes, for instance, will be adjudicated by judges appointed by his Commerce secretary, while the EPA could roll back environmental regulations that reduce profits at his golf courses.

Meanwhile, lower-level officials tasked with the day-to-day work of regulating Trump’s properties are likely to face pressure as well—if not explicit from superiors, then from the implicit, inescapable knowledge that enforcement decisions will impact the president personally. Federal Aviation Administration inspectors, for instance, are in charge of on-the-spot, random inspections of aircraft, including Trump’s, and at one point during the campaign grounded one of his planes after its registration expired; the Occupational Safety and Health Administration oversees construction sites, and has fined the Trump Organization on multiple occasions for workplace-safety violations. Only 10 years ago, politically motivated firings within the Justice Department became one of the many enduring scandals of George W. Bush’s administration; with so many executive-branch employees interacting with the president’s properties in so many different ways, some will inevitably face difficult decisions between proper enforcement at his expense or looking the other way to stay in the boss’s good graces.

Though his golf course at Turnberry is the more famous of his two properties in Scotland, it is Trump’s resort in Aberdeen that has attracted attention for the conflicts of interest it created when Trump spoke with the British politician and Brexit cheerleader Nigel Farage about blocking a proposed wind turbine that Trump believed would have blocked views from the resort. Now, attention has once again turned to Scotland after The Guardian reported that the Trump Organization will soon be moving forward with a multi-million dollar plan to expand its Aberdeen resort, including a new 450-room, five-star hotel and a second 18-hole golf course.

The announced expansion drew criticism almost immediately, especially coming as it did only three days after the press conference at which Trump unveiled his (woefully insufficient) 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 expansion permissible in light of these statements. 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 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 relies on a tactic Trump and his many surrogates have used with alarming frequency. On several occasions, Trump has come out with what appears to be a clear policy statement, which then becomes increasingly vague as he and his surrogates attempt to justify an action or position. One famous example is his proposal to ban Muslims from immigrating to the United States: As critics started to question its constitutionality, and as support for the measure declined, he revised it to a vaguer policy of “extreme vetting,” which itself varied significantly depending on who was describing it to whom and what part of the plan they were defending. Here, the Trump Organization has done something similar: In the face of allegations that the Aberdeen development violated the company’s pledges regarding conflicts of interest, the pledges have been revised to create a more vague, and therefore more permissive, stance. As Richard Painter, who served at the chief ethics adviser for President George W. Bush, put it, the new, more ambiguous 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.”

If, as they argue, the expansion of the Aberdeen golf course constitutes neither a “new foreign deal” nor a “pending deal,” that only further complicates the picture regarding the Trump Organization’s future behavior during Trump’s presidency. The organization currently has several nascent development projects, several of which, including those in Georgia, Argentina, Indonesia, and Taiwan, have already prompted concerns over conflicts of interest. Trump and Dillon’s statements at his press conference appeared to rule out continued development of these properties, but the ongoing development in Scotland calls into question whether other development plans have truly been canceled or whether Trump will find a similarly legalistic framework under which they claim they can proceed. By moving forward in Aberdeen, Trump has demonstrated just how easily he can—and, in all likelihood, will—continue to flout concerns regarding his conflicts of interest by simply redefining the terms of his promises in order to allow for his latest move.

That Other Billionaire New York Real-Estate Developer

President Trump’s promise to erect a big, beautiful wall between himself and his business lasted slightly more than 48 hours.

Almost exactly two days after the January 11 press conference at which Trump announced plans purported to disentangle himself from his namesake business, the Huffington Post reported that the president had scheduled a meeting with Steven Roth. Roth, a fellow New York-based billionaire real-estate developer, is in charge of Vornado Realty Trust, an investment firm that co-owns two of Trump’s most valuable properties, one in Manhattan and one in San Francisco, and served as an economic adviser during the campaign. What Trump and Roth discussed at their meeting remains unknown, nor is it clear when exactly the meeting was scheduled. Regardless, that the meeting came directly on the heels of the press conference at which Trump and his lawyer laid out a plan supposedly meant to resolve conflicts of interest, throws the reality of the problems that come from having a businessman as president—and one who seems completely uninterested in taking steps that would actually distance him from his business—into sharp relief.

Shortly thereafter, The Wall Street Journal reported that Roth may soon become involved with the Trump administration beyond just his pre-existing friendship and partnership with the president. Trump, it seems, will soon be naming Roth and Richard LeFrak, yet another New York-based billionaire real-estate developer, to oversee a council of 15 to 20 builders and engineers who will be carrying out the president’s $1 trillion infrastructure proposal, a situation which itself provides ripe opportunities for the pair to direct federal dollars toward projects from which they will financially benefit. This news comes on top of a December report in The Washington Post that Roth’s firm had put in a bid to rebuild the FBI’s headquarters, a deal that could be worth as much as $2 billion. In other words, Trump, mere days after promising to remove himself from his businesses, is instead ushering a longtime partner into his administration.

The move could also end up providing yet another avenue by which Trump could enrich himself in office and by which others could attempt to curry favor. Whether or not he intended to do so, the president’s decision to place Roth at the head of such a large pool of money sends a signal to other companies about the continued intermingling of his business and his presidency: that working with the Trump Organization can be a path to increased influence or even appointment. And though Trump claims that he will no longer be in involved in day-to-day operations, he will be actively profiting off from the company, meaning that he will be personally making money off of the attempts of others to gain influence over American public policy.

Despite President Trump’s assurance that he has stopped pursuing deals since the election, his namesake organization apparently moved forward with a pair of projects in Indonesia. According to The New York Times, the two properties that will bear the Trump name, one overlooking a Hindu temple in Bali and the other abutting a theme park in West Java, presented ethical problems even before the election.

To begin with, through his Indonesian partner on the projects, the billionaire media mogul Hary Tanoesoedibjo (known in Indonesia as Hary Tanoe), Trump has forged relationships with several top Indonesian politicians. One such leader is Setya Novanto, the speaker of the country’s House of Representatives who temporarily lost his post for trying to extort $4 billion from the American mining company Freeport-McMoRan (a company which counts Carl Icahn, who will be serving as a special adviser in Trump’s administration, among its largest shareholders, and which has been frequently criticized by labor advocates and environmentalists). Trump had lunch with Novanto and several other Indonesian politicians during the campaign in September 2015 to discuss the Trump Organization’s planned expansion into Indonesia. At a post-luncheon press conference, Trump pulled Novanto in front of the cameras, calling him “an amazing man” and “one of the most powerful men” and asserting, “we will do great things for the United States.” (It is unclear exactly whom Trump meant when he used the word “we.”) Trump then asked Novanto to confirm that “they like me in Indonesia,” which Novanto did.

Another of the politicians who attended the lunch with Trump is Fadli Zon, the vice chairman of Indonesia’s House of Representatives, whose district includes one of the cities in which one of the Trump-branded properties will be built. According to the Australian Broadcasting Corporation, Zon is associated with a political movement seeking to unseat and jail the current governor of Jakarta, Basuki Tjahaja Purnama, also known by his nickname, Ahok, and has spoken at rallies against Ahok. The anti-Ahok movement is rooted partly in centuries of ethnic tension within the country: Ahok is both Christian, which has made him the target of attacks by hardline clerics claiming to represent Indonesia’s Muslim majority, and a member of the country’s historically oppressed Chinese minority, which was the target of a massacre in 1998. Aside from an interim governor appointed half a century ago, Ahok is the first governor of Jakarta to fall into either category, and is currently on trial for blasphemy for allegedly insulting the Koran, although Ahok’s supporters claim that it is Ahok’s accusers who are guilty of blasphemy for denigrating Ahok’s Christianity.

Both Trump’s question to Novanto and Zon’s presence at the meeting underscore another difficulty the president introduces into the United States’ relations with Indonesia. Indonesia is both the largest predominantly Muslim country in the world and the nation with the largest population of Muslims. Novanto received significant blowback for his statement that, yes, Indonesians do like Trump, because it turns out that, no, many Indonesians don’t like Trump, in large part because of his on-again, off-again proposal to ban Muslims from immigrating to the U.S.; in fact, faced with mounting criticism, Novanto’s party apologized not only for Novanto’s statement but also for his mere attendance at the luncheon. Since Trump’s victory, both Novanto and Zon have stood up for the president, arguing that Trump’s hardline stance toward Muslim immigration was merely campaign rhetoric and not actually reflective of the president’s own beliefs, something Novanto claimed Trump personally assured him was the case. Regardless, it is clear that the Trump Organization’s planned expansion into Indonesia—which, again, is the reason Trump met with Novanto and Zon in the first place—could introduce major complications into the relationship between the president and the political leaders of the world’s largest Muslim country, not to mention a significant trade partner and an important ally in the South China Sea region.

As if that weren’t enough, Tanoe himself has shown increasing interest in becoming involved in Indonesian politics. In 2014, Tanoe publicly supported the retired general Prabowo Subianto in the nation’s presidential election; Subianto lost to the country’s current leader, Joko Widodo. Then, in 2015, he helped found a new political party, the United Indonesia Party, or Partai Perindo, which intends to field candidates for national office in the near future, including Tanoe himself: Shortly after The New York Times reported on the project, Tanoe told the Australian Broadcasting Corporation that, “If there is no one I can believe who can fix the problems of the country, I may try to run for president.”

If Tanoe does so, it will create the possibility that Trump will be dealing with a head of state with whom he has shared business interests, which, as the ethics lawyer Richard Painter told The New York Times, “makes it impossible to conduct diplomacy in an evenhanded manner”—especially considering that, after Trump’s election, stock in Tanoe’s company rose significantly. Moreover, Tanoe, like Ahok, is both Christian and ethnically Chinese, which some insiders consider an obstacle to his electoral chances, although Tanoe argues that it is not Ahok’s religion but his lack of firm leadership that has led to the large-scale protests against the governor. Nevertheless, if Tanoe does choose to run for office, it is difficult to see how his race, religion, and business partnership with a president many see as blatantly Islamophobic could do anything other than create further difficulties both within Indonesia and in the country’s relationship with the U.S..

Tanoe remains close to Trump. He attended the inauguration as a guest of the Trump Organization; he and his wife posted several photos commemorating the occasion on their Instagram accounts, including pictures with Donald Jr. and Eric Trump and a video taken out the window of a car driving along the inaugural parade route. Then, in a February 7 interview with the Indonesian news magazine Tempo, Tanoe bragged about his access to the president. In the interview, he claimed to have seen Trump as recently as January 4 in New York, though he demurred when asked what they discussed, saying, “It wouldn’t be ethical, especially now that he is the president.” Tanoe also confirmed that “nothing has changed” regarding the branding deals in Indonesia, which he says will be moving forward with Trump’s sons in charge, a statement that would seem to contradict Trump and his lawyer’s January 11 announcement that the company would be suspending unfinished development projects.

Though the biggest controversy over the New Year’s Eve celebration at Mar-a-Lago, Trump’s Florida estate, was apparently whether or not Joe Scarborough could accurately be described as having “partied” there, video footage taken by a guest and obtained by CNN the next day brought renewed scrutiny to President Trump’s own presence at the event. During a 10-minute speech given in front of the party’s 800-odd attendees, Trump praised his Emirati business partner Hussain Sajwani and Sajwani’s family, saying, “The most beautiful people from Dubai are here tonight, and they’re seeing it and they love it.” CNN identifies Sajwani as a “billionaire developer in Dubai” who has “paid Trump millions of dollars to license the Trump name for golf courses in Dubai.” Trump’s spokeswoman, Hope Hicks, defended the remarks by clarifying that the president and Sajwani “had no formal meetings of professional discussions. Their interactions were social.”

Whether or not Hicks’s statement was true, Trump’s commendation of Sajwani is part of a pattern in which the president praises his business partners in ways that suggest he has little interest in extricating himself from his company’s interests. Previously, he has name-dropped business partners in Turkey and Argentina while on official calls with the countries’ leaders; he also met, and took photos, with associates from India shortly after the election. Moreover, as with several of the countries in which Trump-branded buildings are located, the United Arab Emirates has a questionable record on human rights; Human Rights Watch specifically states that the nation “uses its affluence to mask the government’s human-rights problems.”

By singling out Sajwani, Trump also runs headlong into accusations that he and his family are selling access to his administration through their organization and family foundations. According to Politico, tickets to celebrate with the president at Mar-a-Lago, went for upwards of $500; the stated attendance of at least 800 people means that the Trump Organization made at least $400,000 off of ticket sales for the event. (There is no indication that the party was a fundraiser for any outside organization, such as a charity or campaign fund, as is often the case when politicians attend such an event.) Whether or not the president sees it as such, the event offered attendees the opportunity to be in the same room as Trump and bend his ear for a price. This follows consternation regarding an auction for a face-to-face meeting with Trump’s daughter, Ivanka, and a charity event that offered a reception with the president and a hunting trip with his two sons, both of which have since been cancelled, as well as ongoing speculation that foreign entities will attempt to curry favor with Trump by booking rooms and events at his hotel in Washington, D.C. That Trump singled out Sajwani at the New Year’s Eve party lends credence to these concerns—it’s an instance of someone receiving the president’s attention simply by buying a ticket to one of his events.

Among the dozens of properties President Trump owns is Trump Vineyard Estates and Winery in Charlottesville, Virginia, the source of his namesake wine. On December 23, the property requested temporary H-2A visas for six foreign workers, according to The Washington Post; on February 17, BuzzFeed reported an additional request that upped the total to 29. The visas, which are administered by the Citizenship and Immigration Services wing of the Department of Homeland Security, allow businesses to temporarily hire foreign, unskilled workers provided that the employer proves that there are not enough domestic candidates to fulfill a one-time or seasonal shortage and that the hiring will not depress wages for U.S.-born employees. Trump, of course, appointed the current Secretary of Homeland Security, which gives Trump authority over the very department responsible for deciding whether to grant the visas that the vineyard has requested. His choice for the position, the retired general John Kelly has a relatively scant track record when it comes to immigration, leaving open the question of how much influence Trump himself will have over the DHS’s policy on the matter.

On top of the fact that Trump will soon be able to influence the outcome of the request, that his organization has continued to request visas after his election underscores a tension in the president’s stance on immigration. From the moment that he announced that he would be running for president, Trump made antagonism toward immigration the central aspect of his campaign, arguing that both legal and illegal immigrants are taking jobs that should be filled by native-born Americans and depressing wages for others. Though he did not specifically single out the H-2B visa, the president has on multiple occasions spoken critically about the H-1B program, which enables employers to temporarily hire foreign workers for skilled jobs like those in the tech industry.

But the Trump Organization has long been a beneficiary of immigrant labor. For example, according to a Reuters report from August 2015, nine companies of which Trump is the majority owner have requested at least 1,100 foreign visas since 2000. The majority of these requests were from Trump’s Mar-a-Lago Club in Florida, which has requested at least 787 foreign visas since 2006, including 70 applications in 2015. (Meanwhile, The New York Times reported that, since 2010, only 17 of the nearly 300 domestic applicants for positions at the Mar-a-Lago have been hired.) The Trump Organization also famously may have benefited from illegal immigration: There is significant evidence that many of the Polish construction workers at the Trump Tower construction site in New York in 1980 were in the country illegally. In other words, Trump’s track record includes not just taking advantage of the very visa process he claims to abhor but also actually subverting existing law for his own profit. Now, by applying for visas for his vineyard, Trump is signaling that he expects that his business will continue to be able to profit from one of the very immigration programs he continually denounces.

On top of owning various properties and enterprises, Trump and his company employ roughly 34,000 people, according to an analysis by CNN. On December 21, several hundred of those workers resolved a labor dispute against the president—one in which, had it continued for even a few weeks more, Trump would have had the unprecedented power to make appointments to affect its outcome.

Here’s the situation: In October 2015, several hundred employees, primarily housekeeping staff, at the Trump International Hotel in Las Vegas voted to join the local branch of the Culinary Workers Union. Trump Ruffin Commercial LLC, which owns the hotel and is itself owned by Trump and the casino magnate Phil Ruffin, contested the vote, first by enlisting an anti-union consulting firm (for whose services it paid $500,000) and then by filing complaints with the National Labor Relations Board (NLRB). Shortly before the election, the NLRB not only rejected Trump and Ruffin’s complaints but also found that, because the pair had refused to negotiate with the nascent union, they had violated federal law and their hotel was operating illegally. Trump and Ruffin have since appealed to the U.S. Court of Appeals for the District of Columbia.

On December 21, more than a year after the hotel’s workers first voted to join the union, the workers announced that they arrived at their first collectively-bargained contract, achieved, according to an employee quoted in ThinkProgress, despite significant pressure from ownership that attempting to unionize would cost workers their jobs. According to the union, the new agreement “will provide the employees with annual wage increases, a pension, family health care, and job security” comparable to that of other Las Vegas hotels. Moreover, the Culinary Workers Union’s parent organization, UNITE HERE, has reached an agreement to represent workers at Trump’s recently-opened hotel in Washington, D.C..

Although this dispute has been resolved, it is included here because it exemplifies the type of situation in which Trump’s business interests are likely to overlap with his duties as president. Trump will be tasked with appointing members to fill current openings on the NLRB, the very body that ruled against him shortly before the election and will be tasked with resolving any future disputes between the hotel’s owners and its employees. Moreover, as Slate noted, the chief justice of the D.C. Court of Appeals is none other than Merrick Garland, whose nomination to the Supreme Court has spent months languishing in the Republican-controlled Congress and was withdrawn once Trump became president. Finally, if disputes of this nature go beyond the Court of Appeals, the case would go to the Supreme Court, to which Trump will be appointing a justice, which is expected to tip the balance decisively in a more conservative (and likely anti-union) direction. In other words, no matter how far up the chain future disputes of this nature go, Trump’s presidency will give him new power to influence the results.

According to an anonymous source and documents obtained by ThinkProgress, representatives from the Trump Organization pressured the ambassador of Kuwait to hold its embassy’s annual celebration of the country’s independence at the Trump International Hotel in Washington, D.C. The event, held annually on February 25, was originally scheduled to take place at the Four Seasons Hotel in Georgetown; the location was allegedly changed after members of the Trump Organization contacted the country’s ambassador. ThinkProgress’s source “described the decision as political,” suggesting that the embassy chose to relocate the event in an effort to curry favor with the president. The Kuwaiti ambassador has since disputed the report, telling The Washington Post that he had not been contacted by the Trump Organization and that the move “was solely done with the intention of providing our guests with a new venue.”

If ThinkProgress’s account is correct, Kuwait’s decision represents an escalation of a situation that has been developing since Trump’s election. The Trump International Hotel has been the subject of continual scrutiny for the conflict of interest it poses, in part because its lease explicitly bars elected officials from holding it, but mainly because Trump’s ownership of the hotel will almost definitely result in a violation of the Emoluments Clause, which prohibits the president from receiving payments from foreign powers—something that will arguably be happening any time a foreign government books a room at the hotel. Already, the hotel has begun advertising itself as a destination for diplomats and dignitaries, and the embassies of Azerbaijan and Bahrain have both scheduled events in the building. However, before the ThinkProgress report, there was no evidence that the Trump Organization had individually reached out to a foreign government in hopes of getting it to relocate an event to the hotel.

In addition to the many possibilities for President Trump to pursue his financial interests in office, the unique makeup of his cabinet also creates a new set of financial motivations. While Trump’s own fortune automatically makes his administration the wealthiest in history, he has also surrounded himself with an unprecedented collection of billionaires and multi-millionaires whose investments are likely to also come under scrutiny.

Unlike the president himself, those who are up for Trump’s cabinet, such as his proposed Secretary of the Treasury Steven Mnuchin and Secretary of Education Betsy DeVos, will be legally obligated to divest from any holdings which may pose a conflict of interest. However, as The Washington Post noted, even selling off their holdings offers an opportunity for Trump’s cabinet members to enhance their fortunes. A federal program known as a “certificate of divestiture” allows executive-branch appointees and employees to avoid capital-gains taxes when selling their assets. The program has existed since 1989, and most recently received attention when President George W. Bush appointed Hank Paulson, then the chief executive of Goldman Sachs as his Treasury Secretary in 2006. Paulson was forced to sell off $700 million in shares of the bank; the certificate of divestiture enabled him to avoid a potential $200 million in capital-gains tax liability. According to The Washington Post, the Office of Government Ethics is currently researching whether the president himself would qualify for the tax break; even if he doesn’t, the unprecedented wealth of Trump’s cabinet promises to push this provision, and the financial incentives it creates, to the limit.

One of President Trump’s first major economic moves as president was the deal that he and Vice President Mike Pence struck with the air-conditioner manufacturer Carrier, which had planned to move 2,100 jobs from its Indiana plant to Mexico. Finalized on November 29, the compromise kept 730 of the plant’s jobs in Indiana in exchange for $7 million in tax breaks over 10 years. The deal immediately attracted praise and criticism on both sides of the aisle, with much of the scrutiny going toward the tradeoff between jobs and tax breaks and Trump’s idiosyncratic, ad-hoc negotiation techniques.

An additional detail soon emerged regarding the deal: According to his FEC filings (which, despite Trump and his spokesman Jason Miller’s unverified statements that the president sold off his stock in June, remain the most recent public record of the president’s finances), Trump holds stock in Carrier’s parent company, United Technologies. In 2014, his investment in the company was between $100,001 and $250,000, while in 2015, the stock is listed as worth less than $1,001, which could indicate that he sold some or most of the stock; each year, his holdings earned him between $2,500 and $5,000.

The paucity of information in the FEC filings makes it difficult to ascertain why his holdings appear to have decreased; regardless, the investment is not only one of several hundred but also a relatively minor one among Trump’s many holdings, some of which are worth over $5,000,000. As a result, it’s difficult to know how much, if at all, Trump may have considered the stock, particularly considering that he didn’t appear to remember his initial promise to save the Carrier plant. Additionally, Trump does not have stock in the next company he called out on Twitter, Rexnord Corporation (which is also based in Indiana), or its parent company, The Carlyle Group. Still, Trump’s deal with Carrier demonstrates the unprecedented challenge the president’s conflicts of interest create: Unless he either puts his holdings in a truly blind trust or divests completely, a significant number of the decisions he makes will involve some level of financial incentive for himself as well as for the country.

Almost as soon as Donald Trump and a lawyer from the Trump Organization unveiled their plans to distance the president from his businesses on January 11, many ethics experts argued that the proposal didn’t do nearly enough to ward off concerns that Trump’s business involvements would produce conflicts of interest during his presidency.

Under that plan, Trump resigned from the positions he held at the many companies that make up his real-estate empire, ceding control to his two adult sons and a longtime business associate, with his assets placed in a trust run by his two adult sons and Allen Weisselberg, a longtime Trump Organization executive, for the duration of his presidency. In unveiling the plan, the president vowed to refrain from talking about his financial interests with Donald Jr. and Eric Trump and said that all future business decisions would be reviewed by a newly appointed compliance officer to prevent even accidental impropriety. However, critics said, as long as Trump still profits from his businesses, these measures do almost nothing to mitigate worries about conflicts of interest. Besides, with so much of his fortune derived from highly visible real-estate and branding deals, some lawyers note that no trust would fully blind him from knowing where his financial interests lie; they say the only way to fully protect against conflicts of interest would have been for him to have sold off his businesses before taking office.

Events since the election demonstrate that these experts’ doubts are well-founded. Trump and his sons have shown little interest in maintaining the appearance of separation, with Eric and Donald Jr. showing up at numerous political events for their father. Roughly two weeks before the election, Donald Jr. met with a pro-Russian group in Paris to discuss his father’s policy toward Syria and, according to Politico, was involved in his father’s search for a Secretary of the Interior; he was also spotted hunting in Turkey shortly after his father’s phone call with Turkish President Recep Erdogan in which the president praised a Turkish business partner. Eric, meanwhile, appeared in photos with his father and a group of Indian businessmen mere days after the election. And both were present for the president’s announcement of his nominee for the Supreme Court.

Then, when asked about the blind trust in a March 24 interview with Forbes, Eric gave answers that seemed to contradict not only the arrangement to which he supposedly agreed but also his own statements on the topic. “I do not talk about the government with him, and he does not talk about the business with us. That’s kind of a steadfast pact we made, and it’s something that we honor,” he said, before telling the interviewer that he will be providing updates to his father “on the bottom line, profitability reports and stuff like that” on a quarterly basis. “My father and I are very close. I talk to him a lot. We’re pretty inseparable,” he concluded. If Trump is in constant contact with Eric and receiving updates on his businesses from his sons, it renders the trust they created effectively meaningless—and validates the concerns watchdog groups raised when Trump first unveiled his plan in January.

After Eric Trump made those comments to Forbes, other holes in Trump’s plan have come to light. On April 3, ProPublica discovered a previously unreported change to the trust arrangement that effectively allows the president to personally withdraw money from his businesses at virtually any time he chooses. On February 10, a clause was apparently added to a letter outlining the details of the trust stating that “the Trustees shall distribute net income or principal to Donald J. Trump at his request, as the Trustees deem necessary for his maintenance, support or uninsured medical expenses, or as the Trustees otherwise deem appropriate.” In other words, Trump will be able to draw profits from his businesses at any time during his presidency

cgmcnama on April 8th, 2017 at 16:50 UTC »

This is a friendly reminder from /all that **to impeach a President you need 50% of the House (for a trial) and 66% of the Senate (for a conviction). Democrats are about 24 votes short in each chamber AND are unlikely to win the Senate in 2018** as it is far too unfavorable number wise. (*And the reason Democrats can win the House in 2018 but they won't win the Senate is because there are far too many Democrats defending their seats (25 Democrats to 9 Republicans) meaning they are likely to lose seats in the 2018 Senate race...not gain them. 2016 was their big advantage over Republican candidates...not 2018*.) I'm all for political movements but lets keep this grounded in reality here. Even special investigation committees are controlled by the Republicans and you won't even get those back unless Democrats win in 2018. Republicans might be frustrated with Trump but that is a far cry from impeachment and turning their own reliable voters (base) against them in 2018.

I_know_left on April 8th, 2017 at 15:07 UTC »

Violating the emoluments clause isn't nearly as accessible as getting a BJ in the Oval Office and then lying about it. "Emoluments!?!? That sounds like a fake word! No way it can be real!" If the general public don't understand, right from the start, what the impeachable offense is, there will be no outrage or a call to action. It's the way she goes.

yeti77 on April 8th, 2017 at 14:41 UTC »

This is why the Georgia, Kansas, and Montana special elections are so important. If Republicans see that this guy is going to cost them bigly in their own elections they'll be quicker to throw him overboard.