As the first (and, so far, only) Trump-branded property to open since the election, the Trump International Hotel and Tower in Vancouver has prompted significant scrutiny. When it opened just five days after President Donald Trump’s inauguration, ethics experts questioned whether the property presented an opportunity for anyone to attempt to influence the president by booking a stay there—a suspicion that seemed to be confirmed when a pro-business lobbying group relocated a meeting from a diplomat’s house to the new hotel the day after it opened.

As with all of Trump’s foreign properties, the property arguably violates the Constitution’s foreign emoluments clause, which says that federal officials can’t receive “any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.” But the first known government expenditure at the Vancouver hotel came not from a foreign entity—it came from the State Department. According to documents obtained by The Washington Post, the State Department spent more than $15,000 to book 19 rooms at the new hotel when the president’s adult sons, Donald Jr. and Eric, and his younger daughter, Tiffany, visited the property for its grand opening in February.

While the Trump Organization both owns and operates some of its flagship properties in the United States, such as Trump Tower in New York, the hotel in Vancouver is one of many licensing deals through which third-party companies pay to operate their hotels under the Trump brand. Though the president’s name appears in large gold letters on the building’s facade, the property is actually owned and managed by a Canadian company called The Holborn Group, which is in turn owned by the Malaysian billionaire Joo Kim Tiah. And, because the Trump Organization is a privately held company, the actual structure of the deal remains unknown: Though Trump declared more than $5 million in revenue from the property on his most recent financial-disclosure forms, it’s unclear whether that sum represents a flat fee or a percent of the hotel’s revenue. However, Slate noted that previous court filings show that some similar Trump properties operate on the latter model, suggesting that what Trump earns from the hotel hinges on its success.

If that is indeed the case, the State Department’s expenditures represent a conflict of interest for him. As I wrote in February, when the Secret Service spent more than $97,000 to accompany Eric Trump on a business trip to Uruguay, it’s first and foremost improper that the Trump Organization appears to be directly profiting from taxpayer money because of the increased security necessary when its leaders visit their holdings.

Moreover, the State Department’s expenditure arguably violates the Constitution’s domestic emoluments clause, which states that the president “shall not receive ... any other Emolument from the United States, or any of them” during his time in office aside from his official salary. Already, the Trump Organization is receiving taxpayer money from multiple federal agencies, including the Secret Service, which not only effectively subsidized Eric Trump’s business trip to Uruguay but also pays to accompany the president’s family on their private airplanes, and the Department of Defense, which CNN revealed in February would be renting space in Trump Tower. These expenditures raise the possibility that groups within the U.S. government as well as those outside of it may influence the president, intentionally or not, by patronizing his businesses. Because even small payments can change a person’s behavior, these payments may warm the president to one department over others, potentially shading his assessments of the advice and intelligence he receives from them.

Even if the Trump Organization doesn’t profit directly from the hotel’s success—that is, if the company makes a flat annual fee instead of a percentage of the property’s revenue—the State Department’s expenditure demonstrates the problems Trump’s continued intermingling of business and government continues to create. As of now, because Trump has disclosed only the minimum financial details he is required to by law, it's impossible to determine how exactly he makes money from properties like the hotel in Vancouver. That in turn makes it impossible to determine the precise nature of his conflict of interest—an epistemological problem that has arisen with several other business endeavors of his.

The Background

President Donald Trump still has not taken the necessary steps to distance himself from his businesses while in office. In accordance with a plan that he and one of his lawyers, Sheri Dillon, laid out at a press conference on January 11, Trump has filed paperwork to remove himself from the day-to-day operation of his eponymous organization. However, numerous ethics experts have voiced strenuous objections to the plan, which they say does very little to resolve the issue: As long as Trump continues to profit from his business empire—which he does whether or not he is nominally in charge—they say, the possibility that outside actors will attempt to affect his policies by plumping up his pocketbook will remain very much in play.

Several of Trump’s critics have moved forward with legal action. The watchdog group Citizens for Responsibility and Ethics in Washington, or CREW, filed a lawsuit alleging that Trump’s business holdings violate the emoluments clause of the Constitution, which makes it illegal for government officials to “accept of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.” CREW’s bipartisan legal team includes, among others, Norm Eisen and Richard Painter, who served as ethics lawyers under Presidents Obama and George W. Bush, respectively; Laurence Tribe, a constitutional law professor at Harvard University; and Zephyr Teachout, a professor at Fordham University (and former congressional candidate) who is considered an authority on the emoluments clause. All have been vocally critical of Trump’s continued refusal to sell off his business, and are now taking their case to court to argue that several of Trump’s businesses present avenues by which foreign governments could seek to influence the president by, for example, booking stays at one of his hotels or renting space at one of his properties. Additionally, the lawsuit seeks to force Trump to reveal his tax returns, something every president has done since Gerald Ford but which Trump has refused to do, significantly limiting the public’s ability to understand the president’s finances. When asked about the lawsuit, Trump described it as “totally without merit.” Eisen was quick to respond on Twitter, offering to “debate Trump (or his chosen champion) on the merits of our case anytime,” making it clear that CREW intends to continue to pursue its case. (CREW has also filed a separate complaint to the General Services Administration arguing that Trump has violated the lease on his Washington, D.C. hotel, which states that “no ... elected official of the Government of the United States … shall be admitted to any share or part of this Lease, or to any benefit that may arise therefrom.”)

Though CREW is the first group to bring a lawsuit against President Trump, it may soon have company. According to The New York Times, Anthony Romero, the executive director of the American Civil Liberties Union, has said that his organization is looking for a plaintiff to sue Trump for violating the emoluments clause, although with a different claim to legal standing: While CREW intends to demonstrate that the group itself has suffered financial harm because the need to focus on the emoluments clause has diverted its resources away from other worthy causes, the ACLU is hoping to find a hotel or bed-and-breakfast owner that can prove he or she has lost business to one of Trump’s hotels during his presidency.

CREW’s lawsuit is just the latest development in what promises to be a continuing saga regarding Trump’s many conflicts of interest that began almost as soon as he won the presidency. Along with his unprecedented wealth, Trump brings to the office unique and gravely concerning entanglements that, whether he recognizes their effects or not, threaten to undermine his decision-making as president. The plan Trump and Dillon announced on January 11 would do very little to resolve the conflicts: It places control of his assets in the hands of his two adult sons and a longtime associate of their father’s with what so far amounts to a pinky-swear assurance that, despite their proximity to the president, they will not discuss any aspect of the business with him. On top of that, the plan supposedly would terminate several of the Trump Organization’s pending deals and place a ban on new foreign deals, two conditions undermined by the announcement that the organization would be moving forward with expanding its golf course in Aberdeen, Scotland.

Even before his most recent plan was laid out, Trump has attempted to deflect criticism by repeatedly asserting that the law barring executive-branch officials from maintaining financial holdings or business ties that overlap with their duties does not apply to the president or vice president. In this, he is correct; the law, passed in 1989, exempts the two chief executives from conflict-of-interest rules on the understanding that their purview is so broad that it would be impossible for them to completely disentangle themselves.

Regardless, legality does not imply propriety. Unless Trump acts to put actual distance between himself and his business ventures, these questions are likely to continue throughout his time in the Oval Office. On top of the aforementioned legal actions, the director of the Office of Government Ethics, Walter Shaub, has declared Trump’s efforts insufficient, remarking, “I don’t think divestiture is too high of a price to pay to be the president of the United States,” and a number of Senate Democrats have introduced legislation that would force Trump to divest or face impeachment. Below is an attempt to catalogue the more clear-cut examples of conflicts of interest that have emerged so far. The most recent entries appear at the top:

• That Clean-Water Rule
• That Development Outside of New Delhi
• That Golf Course in Westchester
• Those Russian Trademarks
• That Trump Organization Event Planner
• That Saudi Arabian Lobbying Effort
• That Golf Course in New Jersey
• That Meeting in Brussels
• That Tower in Toronto
• That Caribbean Villa
• Those Condos for Sale
• Those Reelection-Campaign Funds
• That Second Hotel in Washington, D.C.
• That Property in Azerbaijan
• That Trump Tower Penthouse
• That Resort in the Dominican Republic
• That Chinese Trademark
• That Meeting at Mar-a-Lago
• That Defense Department Trump Tower Rental
• That Red Cross Ball
• That D.C. Labor Dispute
• That Estate in Palm Beach
• Those Expansion Plans
• That Hotel in Vancouver
• That Reality-Television Show
• That Pipeline
• Those HUD Grants
• That Golf Course in Aberdeen
• That Other Billionaire New York Real-Estate Developer
• Those Indonesian Politicians
• That Emirati Businessman
• That Virginia Vineyard
• That Las Vegas Labor Dispute
• That Kuwaiti Event
• Those Certificates of Divestiture
• That Carrier Deal
• That Blind-Trust Issue
• Those Fannie and Freddie Investments
• That Phone Call With Taiwan
• That Deutsche Bank Debt
• That Secret Service Detail
• That Property in Georgia (the Country)
• That Phone Call With Erdogan
• That Hotel in Washington, D.C.
• That Argentinian Office Building
• Those Companies in Saudi Arabia
• That British Wind Farm
• Those Indian Business Partners
• That Envoy From the Philippines

That Clean-Water Rule

In February, President Donald Trump signed an executive order directing the Environmental Protection Agency to review the Obama administration’s Waters of the United States, or WOTUS, rule. The regulation, which was created in 2015 but was put on hold by a court later that year, aims to expand the federal government’s ability to apply anti-pollution statutes to a variety of bodies of water. This week, the Environmental Protection Agency announced that it would be acting on the president’s order and rolling back the regulation.

When he first called upon the EPA to review WOTUS, Trump cited its economic cost, calling it “a disaster” and “a massive power grab” that was “putting people out of jobs by the hundreds of thousands” (a claim The Washington Post gave its lowest fact-checking rating). And while pro-business groups such as the U.S. Chamber of Commerce lauded the EPA’s decision, environmental groups criticized the move, arguing that WOTUS represented a significant step forward in protecting the drinking water of more than one-third of Americans.

The decision also appears to represent a conflict of interest for the president. Along with increasing federal oversight of large bodies of water, WOTUS would have expanded the EPA’s authority to include regulation of smaller streams and ponds. As such, some of the business benefits of rolling back the rule will redound to the golf industry, which has been a major opponent of the regulation since before it was signed in the summer of 2015. The Golf Course Superintendents Association of America, a 17,000-member lobby, spent $30,000 to fight WOTUS in the quarter it was finalized, arguing that the rule would make it excessively costly to maintain golf courses without running afoul of new regulations on water use and polluted runoff. According to the association’s chief executive officer, Rhett Evans, under an earlier, somewhat more expansive, version of the rule, golf courses “would find themselves economically burdened, if not unable to operate profitably.”

Trump, of course, owns 12 golf courses in the United States, all of which would likely be impacted by WOTUS, meaning that he has a significant financial stake in ensuring that it does not ultimately go into effect. And though the decision to fully scrap the regulation was technically made by the EPA and its chairman Scott Pruitt, it was ultimately Trump who called for its review in his February Executive Order—not to mention that he was the one who appointed the notoriously anti-regulation Pruitt in the first place.

The executive branch’s decision to scale back enforcement of WOTUS specifically and clean-water regulation in general is also an example of how Trump’s broader anti-regulatory agenda often overlaps with his personal financial interests. Through his first few months in office, Trump’s domestic agenda has involved chipping away at the regulations his predecessor put in place, following a self-imposed rule that federal agencies must cut two regulations for each they implement. This will likely frequently result in policy decisions that will at least tangentially benefit Trump; for example, many of the tax cuts that Trump seems to favor, such as repealing the estate tax, would reduce his own tax burden as well as those of others in his income bracket. The result is that it’s often difficult to separate Trump’s conflicts of interest from what very well may be a genuine pro-business, anti-regulatory agenda.

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That Development Outside of New Delhi

President Donald Trump’s international real-estate empire continues to grow. According to The Washington Post, two new Trump-branded buildings—one residential development and one office tower—will soon be going up in Gurgaon, a suburb of New Delhi, India, “known for rapacious development and poor planning.”

As with many of the company’s other international projects, the deals create new conflicts of interest as they bring the Trump Organization into contact with more investors, partners, and governments that may seek to influence the president’s decisions. The nature of the real-estate business means that the company and its international partners will have all sorts of interactions with local and national governments, ranging from acquiring permits for construction to health and safety inspections once a project is complete. That creates opportunities to attempt to curry favor withTrump, whether intentionally or not, by creating favorable conditions in which he can do business.

To complicate matters, these deals in India find Trump in partnerships with less-than-savory companies. The companies involved, IREO and M3M India, have both been frequent targets of anti-corruption actions by the Indian government, which is currently investigating the former for illegal land purchases and money laundering and the latter for bribing officials to speed along construction. And Gurgaon is widely seen as a hotbed of corruption, where poor citizens and small landowners are often pushed out by developers through bribery or bullying.

As has been the case with some of the Trump Organization’s other international projects—the tower in Baku, Azerbaijan, that The New Yorker deemed “Donald Trump’s Worst Deal” springs to mind, along with his ongoing developments in Indonesia—the company’s involvement with potentially corrupt officials and companies could create problems going forward. For instance, if someone found demonstrably illegal labor practices at the sites in Gurgaon, he or she could use that information to blackmail the president’s company and its owner (that is, the president himself) into pushing for a particular policy. And to reverse that example, Indian officials seeking a favorable outcome on an issue of international concern from the American government could, explicitly or implicitly, turn a blind eye to any ethical concerns in Gurgaon in return for the president’s good graces, which could end up creating unsafe conditions that hurt the laborers working on the building. Meanwhile, the developments’ investors—currently unknown for the deal with IREO, according to The Washington Post, as the money flowed through banks in Mauritius and Cyprus—have substantial leverage over the president that they could wield by cutting off the flow of funds to the projects.

On top of the concerns regarding the specific details of the projects, the developments in Gurgaon demonstrate how little the Trump Organization’s pledge not to pursue any new foreign deals, which the president announced shortly before taking office, actually means in practice. Technically speaking, the projects in Gurgaon aren’t new deals, as the Trump Organization agreed to the partnerships before Trump became president. However, at a press conference held in January, Trump and one of his lawyers, Sheri Dillon, announced not only that “no new foreign deals will be made whatsoever” but also that the Trump Organization had already terminated “all pending deals.” That these projects in India are moving forward regardless seems to demonstrate that the Trump Organization’s definition of “new foreign deals” is so narrow that the guidelines will do little to prevent the company from continuing to expand while Trump is in office, thus creating new conflicts of interest.

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That Golf Course in Westchester

According to a report by ABC News, the Trump Organization is looking for a tax break for the Trump National Golf Club Westchester in Briarcliff Manor, New York. The company is attempting to halve its tax bill on the golf course by arguing that the tax assessor’s $15 million valuation of the property is twice what the course is actually worth. If the appeal succeeds, the Trump Organization could see the property taxes it owes on the 143-acre club reduced by as much as a quarter of a million dollars.

Contesting a tax assessor’s valuation of a property in the hopes of getting a tax break is a fairly common move for large property owners generally and the Trump Organization specifically. In 2016, after the town’s tax assessor valued the property at $15 million, the Trump Organization tried to assert that the course was only worth $1.35 million, but ultimately relented and paid the bill.

The difference this year is, of course, that the property’s owner is now president, which means that suddenly, Briarcliff Manor is one of many local governments that must weigh the consequences of how they deal with Trump’s businesses. It must decide if giving the Trump Organization a sweet deal is worth the loss in tax revenues, whether because doing so will create a positive affinity that could spill over into preferential treatment from the federal government or because not doing so would mean crossing the famously temperamental president and potentially facing consequences down the line.

The situation demonstrates how the president’s decision to hold onto his business while in office could have ramifications for everyday Americans. While Briarcliff Manor isn’t exactly struggling—according to the latest figures from the U.S. Census Bureau, median household income for the town’s 6,300 adult residents is roughly $141,000, and the poverty rate of 4.3 percent is 10 points lower than the national level—the local government nevertheless relies in part on property taxes for funding. If the town does give the Trump National Golf Club the tax break it has requested, that would mean less money for the town’s schools, police department, and other civic services.

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Those Russian Trademarks

One of the questions underlying the ongoing investigation into the Trump campaign’s interactions with Russian officials is whether the president himself is in debt to the country’s government or state-run banks. Though Trump has insisted recently that he does not do business in Russia, that assertion conflicts with 20 years of his (and his sons’) statements to the contrary.

This weekend, The New York Times reported on details that underline his past dealings in the country: On the night of the 2016 presidential election, the Russian government granted extensions to six expiring trademarks that Trump had received between 1996 and 2007. The trademarks cover branding for a variety of products, including one for Trump Vodka, which debuted in 2007 and folded shortly thereafter, and one for the name “Trump Tower,” for a real-estate deal that the president began exploring in 1996 but that ultimately fell through.

By all appearances, the renewals in November were fairly routine and don’t indicate that the Trump Organization has any actual plans for pursuing business opportunities in Russia in the near future. As was the case with the trademarks the company received in China in February, it’s likely that registering the Trump name is more defensive than anything else, a means of securing the name to ward off potential knockoffs or patent trolls, who in some cases register well-known brand names so that, should a corporation try to expand overseas, they will have to pay to wrest the trademark back.

Even if the renewals were a mere formality, they point to the ongoing complications the president’s decision to retain his business while in office creates. Trademarks certainly aren’t direct financial compensation, but they have distinct monetary value as a means of protecting a company’s business interests, especially for a corporation like the Trump Organization, which relies so heavily on its brand appeal that the Trump name is arguably among the family’s most valuable assets. That leaves open the possibility that the president may be inclined to think more highly of a country because it has recently helped his company by approving a trademark request—which in turn opens the possibility that a foreign government seeking to influence the president might seek to curry favor with him by expediting the process or granting trademarks they wouldn’t for a less important person.

Other trademarks that Trump has received in foreign countries since taking office are not only ethically questionable but arguably violate the Constitution. Though part of the ethics arrangement the president and his lawyer laid out before the inauguration was that the Trump Organization would cease pursuing new deals in foreign countries during Trump’s presidency, the company has continued to register trademarks around the world. China granted him not only the trademark on his name in February but also 38 others in March, on everything from hotels to insurance to escort services, followed by six more last week; his eldest daughter Ivanka, who serves as an adviser within the administration, has also received trademarks there since her father took office. Mexico, too, approved Trump trademarks in March. These developments, which all came about after Trump took office, arguably violate the Constitution’s foreign emoluments clause, which bars federal officials from “accept[ing] of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.”

Moreover, as has frequently been the case with the Trump Organization’s dealings in recent months, the timing of the renewals The New York Times reported on raises additional questions about whether Russia may have been trying to influence the president. Since November 8, the Trump Organization has seen unexpected progress on projects in multiple countries, including not only China but also Argentina and Georgia, where long-stalled developments both began moving forward in November. Though it remains unclear whether any of these actions were specifically meant to influence Trump, the cumulative effect suggests that international offshoots of the Trump brand are benefiting from the Trump presidency.

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That Trump Organization Event Planner

Much has been written about how few high-level government positions President Donald Trump has filled compared to his predecessors; still more has been written about the unusual qualifications of those he has appointed. This week, the president named another appointee whose background doesn’t really comport with her new position: Lynne Patton, who will head the U.S. Department of Housing and Urban Development’s Region II, which comprises New York and New Jersey.

Like Secretary of Housing and Urban Development Ben Carson, to whom she will soon report, Patton has little-to-no directly relevant background in urban planning or housing. According to the New York Daily News, which first reported Patton’s nomination on Thursday, though, Patton has plenty of experience with the Trumps. Patton’s LinkedIn account indicates that since 2009, she has planned and run events for the Trump Organization, including “various marketing projects, philanthropic events & golf tournaments.” From 2011 until January of this year, she was also the vice president of the now-defunct Eric Trump Foundation, which is currently under investigation by the attorney general of New York after a report in Forbes alleged that the family had used the foundation to siphon more than $1.2 billion in charitable donations to the Trump Organization.

Patton’s appointment once again demonstrates how Trump continues to mix his presidency with his business interests. In her new office, Patton will oversee the disbursement of billions of dollars in federal housing funds to the states in which the president’s company owns the most property. Though the Trump brand and federal housing would seem to occupy significantly different sectors, there’s actually significant overlap between the two. As was documented by The American Prospect in April, the Trump Organization has repeatedly benefited from federal funding; for example, Trump owns part of a low-income housing development in Brooklyn that has received numerous grants from HUD (and that the president once called “one of the best investments I ever made”). Trump even came into conflict with the agency over the property in 2007 when he attempted to sell his stake, only to have the transaction blocked. That he has chosen a loyal business associate to administer a position that will have oversight over his own company seems to indicate how, rather than putting the best interests of the American people above all else, the president can make decisions that stack the regulatory deck in his own favor.

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That Saudi Arabian Lobbying Effort

Less than five months into President Donald Trump’s administration, Saudi Arabia has created a template for foreign governments looking to influence the president through his businesses. On Monday, The Daily Caller reported that the country’s government spent nearly $270,000 on lodgings and catering at the Trump International Hotel in Washington, D.C., between November 2016 and February 2017. The expenditures were part of a lobbying campaign in which the Saudi government paid for U.S. veterans to travel to D.C. to advocate against the Justice Against Sponsors of Terrorism Act. The law, which passed in September despite a veto from President Barack Obama, allows American citizens to sue foreign governments that allegedly sponsor terrorist attacks and organizations.

The payment clearly demonstrates the problems with the arrangements Trump has made to prevent ethics violations, which he and his lawyer Sheri Dillon described in January before he took office. Among other steps meant to resolve the president’s conflicts of interest, one measure was specifically designed to address concerns that foreign governments might attempt to influence Trump by paying to stay at his hotel in Washington, D.C. To head off such a possibility, Dillon said in January, the Trump Organization would “voluntarily donate all profits from foreign government payments to his hotels to the United States Treasury.”

In the four months since the inauguration, the Trump Organization itself has demonstrated the insufficiency of this pledge on multiple occasions. First, in March, the company admitted that it hadn’t yet made the payments it had promised, and said it would not be doing so until the end of the calendar year. Then, in May, the organization sent Congress a pamphlet outlining the relatively meager steps it would take to uphold its commitment, stating that it wouldn’t actively attempt to identify foreign agents staying at the hotel because doing so would be “impractical.” Instead, the document suggested, the company would be relying on the foreign governments to identify themselves. After The Daily Caller’s report, the Trump Organization announced that it would indeed be transferring profits from the Saudi payments to the Treasury at the end of the calendar year.

However, it’s unclear whether, under the Trump Organization’s guidelines, they would have done so if not for the attention the story received from the media. The Saudi government didn’t technically pay for the hotel rooms; instead, they paid the American lobbying firm Qorvis MSLGroup, which hired a subcontractor. Qorvis was then required to disclose the source of the funds to the Justice Department under the Foreign Agents Registration Act, and a Daily Caller reporter then reported the story based on those disclosures. Given that the Trump Organization has effectively abdicated the responsibility of tracking payments that aren’t “direct billings from the Property to a foreign government,” it’s entirely possible that the company would not have done the due diligence required to follow the money; as it is, the story didn’t emerge for several months. Moreover, the Trump Organization still hasn’t answered the question of how it will determine what portion of the revenues constitute profits that it will pass along to the treasury.

Theoretically, the Trump Organization may have legitimately not been aware that the money Qorvis spent at the hotel came from the Saudi government, in which case Trump himself also wouldn’t have known about it, either. However, Saudi Arabia has hired Qorvis to carry out PR campaigns twice in the past, once shortly after 9/11 and once after the country invaded Yemen in 2015; both efforts were highly controversial, with the former resulting in a probe by the Justice Department in 2004. Besides, given that the Saudi government would likely have been spending that money on the campaign regardless, the mere possibility that the president would know where the payments came from and think more favorably of the country may very well have been enough of an incentive to make bookings at Trump’s hotel over its competition. Finally, even without the Saudi connection, the situation still constitutes an organization effectively paying the president while lobbying on a controversial issue.

It’s hardly hyperbolic to say that Saudi Arabia’s payment at the Trump International Hotel is exactly what ethics experts worried about when they first raised concerns about the president’s decision to retain ownership of his businesses while in office. As part of an active campaign to lobby the U.S. government, the Saudi government was effectively paying the president, who very well could end up significantly influencing how the policy plays out. In doing so, they demonstrated the inadequacy of Trump’s plan to avoid conflicts of interest: If the disclosure paperwork hadn’t surfaced, all it would have taken to skirt the rules Trump and his company set up was to funnel money through a lobbying firm.

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That Golf Course in New Jersey

During his first few months in office, President Donald Trump spent many of his weekends at Mar-a-Lago, which some have called his “Winter White House,” in Palm Beach, Florida. His trips there were subject to criticism on the grounds of both symbolism and substance. Symbolically, his visits both conflicted with his campaign promise to rarely leave Washington, D.C., and undermined his frequent criticisms of his predecessor for traveling while in office. Substantively, Trump’s trips to Mar-a-Lago make manifest one of the major problems with his decision to retain ownership of his businesses while in office: Anybody seeking to influence Trump could theoretically pay for a membership, putting money in his pocket while potentially gaining direct access to him. In this way, the president’s mere presence serves as an advertisement for the resort.

Many of the same concerns apply to Trump’s “Summer White House,” his golf club in Bedminster, New Jersey. It’s historically been his summer getaway, and, given his penchant for visiting his own properties, it’s expected he will be spending more time there in coming months.

But whereas the problems with Mar-a-Lago have mainly been implicit—neither Trump nor his company, the Trump Organization, has acknowledged any link between the election and, say, the decision to double the club’s initiation fees in January—the intermingling of the presidency and the Trump Organization is on more explicit display in Bedminster. While there’s plenty of evidence (especially on social media) that visiting Mar-a-Lago could lead to an encounter with the president, Bedminster appears to have been actively advertising the possibility. According to Laura Holson of The New York Times, who toured the property with Trump’s son Eric,

Mr. Trump is a selling point for prospective brides and grooms considering holding their weddings at the club. When I was there, I was given a marketing brochure that made the following pledge: “If he is on-site for your big day, he will likely stop in & congratulate the happy couple. He may take some photos with you but we ask you and your guests to be respectful of his time & privacy.”

In a remarkable piece of advertising synergy, Trump made good on the promise in the brochure the weekend after Holson published her article. Between June 9 and June 11, Trump’s second weekend visiting the property since taking office, numerous photos posted on Instagram show the president posing for pictures with his paying guests at the resort, including not only a bride and groom but also a group of eighth-graders at their middle-school graduation party.

Though Holson notes that “a spokeswoman for the club said that the specific brochure has been discontinued,” the fact that it was present after Trump took office in the first place demonstrates the conflict of interest the resort creates. Trump himself has even acknowledged that his presence is a draw for the property: In November, shortly after the election, Trump told paying guests that he would be interviewing prospective members of his cabinet at the golf club and that members might be able to “come along” to the meetings.

Bedminster offers a prime opportunity for anybody with deep enough pockets—the initiation fee reportedly runs $350,000—to attempt to buy his or her way into a meeting with the president, a fact that marketers at the Trump Organization appear to have recognized. And scientific studies show that even minuscule financial transactions can be enough to significantly influence the recipient, meaning that, if and when such a meeting happens, the fact that such visitors are paying Trump to be there will almost certainly hang over the encounter—and make him more inclined to do something in return.

The situation demonstrates how Trump’s continual choice to shirk longstanding ethical procedures threatens to compromise his decisionmaking as president. As Trump himself has noted, the president is technically exempt from federal conflict-of-interest laws (although not, as has been frequently noted, the Constitution’s emoluments clause). But by retaining ownership of his businesses, Trump creates the exact situation those laws were designed to prevent: On issues both large and small, it’s an open question whether Trump is prioritizing the well-being of the country or whether he’s allowing his financial interests to dictate his behavior.

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That Meeting in Brussels

On the European leg of his first foreign trip, President Donald Trump elucidated the relationship between his business and his presidency, although in a way that only further complicates the already-difficult task of understanding how his financial interests might impact his decisions in office. According to the Belgian newspaper Le Soir, in a meeting with Belgian Prime Minister Charles Michel, Trump discussed his skepticism toward the European Union through the lens of his experiences as a real-estate mogul. Per a translation in The Guardian, an anonymous source told the paper, “Every time we talk about a country, [Trump] remembered the things he had done. Scotland? He said he opened a club. Ireland? He said it took him two and a half years to get a license and that did not give him a very good image of the European Union.”

The meeting isn’t the first time the president has discussed the Trump Organization—which he still owns, but no longer operates—with other world leaders: In a phone call with Turkish President Recep Erdogan, one of the first Trump made after his election, he relayed praise from a business partner on the company’s towers in Istanbul; on the line with Mauricio Macri, the president of Argentina, Trump mentioned a long-stalled project in Buenos Aires (which suspiciously began moving forward after the exchange).

His conversation with Michel, though, is different, for one key reason: Trump has no hotels in Belgium—and, unless his company is willing to violate a pledge meant to mitigate conflicts of interest, it won’t be pursuing deals there until Trump is out of office. That doesn’t definitively preclude the possibility that he meant to boost his businesses by venting to Michel, but it certainly reduces its likelihood.

What the conversation does do, though, is demonstrate how inextricable Trump’s businesses are from his behavior as president. It’s not just that Trump has ample knowledge of his holdings to act in his own financial interests and little reason to fear that a Republican-controlled Congress might try to stop him. It’s also that Trump seems to approach every issue with a mind toward how it’s impacted his company in the past—and how it will impact his company in the future. As the aforementioned anonymous source in Le Soir described it, “One feels that he wants a system where everything can be realized very quickly and without formality”—a broad pro-business stance that would just so happen to make it significantly easier for the Trump Organization to operate in Europe as well.

As long as the president retains ownership of his company, it’s possible to impute the Trump Organization’s footprint in a variety of the administration’s policy stances. For instance, the notion that Trump favors leaders of countries where he has property is arguably the least concerning explanation for his affinity for noted authoritarians like Erdogan and Filipino President Rodrigo Duterte. On economic issues as well, the president has supported numerous policies over the years that would mainly help wealthy businesspeople in general and the Trump Organization in particular; for example, he’s in favor of weakening the Foreign Corrupt Practices Act, which would make it significantly easier for his company to move forward on deals in countries like Azerbaijan where bribery of public officials is more common than it is in the U.S. These questions of where genuine policy positions end and self-interest begins will continue—unless, of course, Trump does what ethics experts have urged him to do and actually sells his business.

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That Tower in Toronto

President Donald Trump’s properties around the world bring with them business partners from around the world. Several of these ties have already come under scrutiny: A Trump-branded tower in Baku, Azerbaijan, put him in business with allegedly corrupt officials who are themselves connected with the Iranian Revolutionary Guard, for example, while two properties in Indonesia link him to officials implicated in a bribery scandal and a racially-motivated attempt to oust a sitting governor.

Now, The Wall Street Journal has reported an additional source of a conflict of interest along these lines: Trump International Tower and Hotel in Toronto. According to the Journal, one of Trump’s partners in the project, Alexander Shnaider, received millions of dollars from the Russian bank Vnesheconombank, or VEB, shortly before investing in the project. Shnaider, who is Russian American and was the main developer on the Trump-branded property, sold his own company’s share in a Ukrainian steelmaker to VEB for $850 million in 2010. Shnaider’s lawyer said in April that $15 million from the sale went into the Toronto tower, although he walked back his statement the next day, writing that he is “not able to confirm that any funds” from the sale went into the project.

VEB is owned by the Russian government; according to its website, its mandate is “to enhance [the] competitiveness of the Russian economy, diversify it, and stimulate investment activity,” and the bank’s supervisory board is chaired by the country’s prime minister, Dmitry Medvedev. At the time of the deal with Shnaider’s company, though, its chairman was the current Russian President Vladimir Putin, who, according to a Russian government official and multiple experts, would have had to sign off on such an exchange.

As with many of Trump’s business holdings, the property represents a conflict of interest because it brings him revenue that’s made possible by money from a bank owned and operated by a foreign government. Though Trump doesn’t own the tower—he merely licenses his name to Shnaider, who owns the building through his company Talon International Development Inc.—the Trump Organization nevertheless profits off of the building and, by extension, from VEB’s deal with Shnaider. This potentially gives the Russian government leverage that it could use should it want to influence Trump’s policies. That means that the Trump Organization’s continued involvement with the tower may represent a violation of the Constitution’s emoluments clause, which precludes elected officials from “accept[ing] of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.”

The Journal’s report highlights the inadequacy of the financial disclosures the president has so far offered. Last week, Trump insisted that his company does not have business ties to Russian “persons or entities.” As my colleague David Graham wrote, the letter from Trump’s lawyers that Trump proffered on the subject last week “doesn’t define several key terms,” leaving open the possibility that one of Trump’s projects benefited from Russian funding through a pass-through corporation or another intermediary. VEB’s role in the financing of the Trump-branded property in Toronto is a perfect example: Because money from VEB went toward enriching Trump (through Shnaider), one can reasonably argue that Trump didn’t do enough to eliminate the conflict of interest that the hotel creates for him in office.

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That Caribbean Villa

President Donald Trump has another property on the market: Le Château des Palmiers, his estate on the Caribbean island of St. Maarten. The president’s company bought the 11-bedroom beachfront compound in 2013, and the Trump Organization has been using it as a rental property ever since. It’s listed at $6,000 per night on TripAdvisor; according to specialty sites such as Luxury Retreats, which lists the price as between $6,000 and $20,000, and Mansion Global, which places the upper limit at $28,000, the price increases substantially during the winter, when the Caribbean offers an escape from cold weather. According to the disclosure forms Trump submitted to the Federal Election Commission (which remain the only public documentation of his finances), he derived between $100,001 and $1 million from the property in the year leading up to May 2016.

The asking price for Le Château des Palmiers remains unknown. The Trump Organization is selling the property through the real-estate agency and auction house Sotheby’s; according to the listing for the complex, the price is available only upon request. However, there are some clues available. On his FEC disclosure forms, Trump lists the property as worth between $5 million and $25 million, which does correspond with the $19.7 million he paid for it four years ago. According to Mansion Global, 7th Heaven, a real-estate brokerage in St. Maarten, has identified the asking price as $28 million, although 7th Heaven’s current page for the property lists the price as “PoA,” or Price on Application.

Though Trump no longer runs the Trump Organization, he still owns the company and, by extension, the property, meaning that he will profit from its sale. That means that Le Château des Palmiers offers yet another avenue by which somebody could attempt to influence the president’s decisions by putting a large sum of money in his pocket. It would even be possible for somebody to make an offer well above the currently unknown asking price to curry favor with him (and, possibly, through the artful use of a shell company, hide their identity).

As NPR noted, the Trump Organization’s decision to sell Le Château des Palmiers is “the first known major divestiture of a Trump property since he became president.” As such, it demonstrates the insufficiency of the steps the president has taken to eliminate his conflicts of interest. Trump has put the leadership of his company in the hands of his adult sons and a longtime Trump Organization executive with relatively few—and, based on Donald Jr. and Eric’s frequent presence at administration events and Eric’s statement that he will share some business-related data with his father, relatively permeable—barriers blinding him from knowledge of his financial interests.

Had Trump taken the measures suggested repeatedly by ethics experts on both sides of the political aisle, he would by now have put his assets in what’s called a blind trust, which would entail turning over his empire to a third party with whom he will have no contact, who would sell off the properties and reinvest the resulting money in other assets without providing the president any information about the sales or the purchases. Instead, Trump has set up a system under which, even if he does proceed to sell off his business, one property at a time, he will simply create new conflicts of interest as he takes payments from those who are purchasing the Trump Organization’s real estate.

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Those Condos for Sale

President Donald Trump’s finances are infamously opaque. Since he has not followed the long-standing presidential custom of releasing his tax returns to the public, the only publicly available records of where he derives his income are his two filings with the Federal Elections Commission. Even those are difficult to parse: Much of his business empire comprises limited-liability companies (or LLCs), which face very few disclosure requirements, and shell and pass-through corporations, which can obscure ownership and make money trails harder to follow.

Much the same can be said for whoever has been buying up Trump Organization condominiums. A lengthy investigation published in USA Today found that, “since launching his White House bid, Trump’s companies have sold at least 58 units nationwide”—out of a total of more than 400 currently on the market—”for about $90 million. Almost half of those sold to LLCs.” One of those LLCs, a financial firm created shortly before the Republican National Convention named Milan Investment Limited, spent $3.1 million to buy 11 condominiums in the building the president co-owns in Las Vegas.

Normally, such a story would then identify who is behind the purchase and whether they may have some ulterior motive in buying something from the president. In this case, though, repeated efforts by the USA Today to ascertain who exactly is behind Milan apparently came up empty. The company’s headquarters in a strip mall the outskirts of Las Vegas are registered to two individuals named Jun Xu and Qi Huang; however, the reporters were unable to reach Xu and Huang through either their listed addresses and phone numbers or through business associates. A third individual associated with Milan, Chen Huang, also apparently could not be reached for comment, nor did the Trump Organization respond to inquiries about the identities of the buyers. The newspaper’s attempts to find the buyers of other Trump Organization condos met with mixed results: Though reporters were able to track down the real people behind some of the purchases, including a couple who said they bought the property because they’re fans of Trump’s, others proved just as elusive as whoever is behind Milan.

As the USA Today notes, the story highlights one of the major problems underlying Trump’s decision to retain his businesses while in office. There is no law requiring a shell company like Milan to disclose the identities of its owner(s) or the source of its money while purchasing real estate. The Trump Organization still owns hundreds of condominiums, the sales of which will directly profit it and, by extension, the president; this offers plenty of chances for any individual or corporation to purchase a unit to attempt to curry favor with Trump without having to disclose their own identity to the public.

So far, the Republican-controlled Congress has shown little interest in investigating the constitutionality of Trump’s decision to hold onto his businesses. That means that the only real disincentive for those attempting to influence the president by patronizing his businesses is the bad publicity that might ensue. But Milan Investment Limited’s secretive investment in Trump’s properties shows how easy it would be for an individual or a corporation to stay anonymous and avoid that scrutiny.

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Those Reelection-Campaign Funds

For President Donald Trump, it pays to be in constant campaign mode.

Metaphorically, at least, this isn’t unusual; the idea of the “permanent campaign,” a reference to how politicians consider their reelection chances from almost the moment they take office, has been around for decades. Such is the case for Trump, who filed a letter with the Federal Election Commission establishing his eligibility to run for a second term in 2020 just hours after taking the oath of office. Though the letter declares only that he can run, not necessarily that he will run, it gives broad coverage for the president to begin fundraising and holding campaign events, and to do so far earlier in his first term than have previous presidents.

Since doing so, Trump has held several events that, while officially presented as part of his “thank-you tour,” have seemed an awful lot like his campaign rallies. Meanwhile, between merchandise sales and an already-active fundraising effort, he has raised more than $7.1 million, and the Republican National Committee has raised an additional $23 million. That’s not necessarily noteworthy by itself; by this time, President Obama and the Democratic National Committee had raised $15 million. (Obama had not yet filed for eligibility in 2012 three months into his first term, although he had held events to promote his economic-stimulus package.) What does make Trump unusual is that he has already spent $6.3 million of his reelection campaign funds—and, according to reports he recently filed with the FEC, he is paying some of that money to his own personal businesses—for instance, renting space at his hotels or golfing on his courses—thereby literally profiting off of his permanent campaign.

This practice is nothing new for Trump. As early as 2000, he was speculating that he “could be the first presidential candidate to run and make money on it” by patronizing his own businesses and running the campaign out of one of his properties. During his 2016 bid, he did exactly that, establishing his political headquarters in Trump Tower (and quintupling the rent as soon as he became the Republican nominee and began drawing funds from the party rather than his personal war chest). Shortly before his victory, The Wall Street Journal reported that Trump’s campaign had paid out the unprecedented sum of more than $14 million to his family and companies for such services as flights on his personal airplanes, rent at Trump Tower, and meals and hotel rooms at other Trump buildings.

Similarly, since taking office, Trump has profited off of the federal government’s newfound need to patronize his properties. Both the Secret Service and Department of Defense are renting out space in Trump Tower, for example, with the former believed to be paying at least $3 million per year to do so. This has led to rumblings that Trump may be violating the Constitution’s domestic emoluments clause, which holds that the president “shall not receive ... any other Emolument from the United States, or any of them,” beyond his official salary.

The amount Trump’s reelection campaign has spent at his businesses is comparatively small: According to The Wall Street Journal, more than 6 percent of the $6.3 million it’s spent so far, or almost $500,000, went to Trump’s hotels, golf courses, and restaurants. But that’s a higher rate than when his campaign money was going to his own businesses for the 2016 campaign ($14 million out of a total of $322 million, or about 4.3 percent). At his current rate, if he spends a similar amount over the next election cycle—and given that he’s already started spending, he could easily far outdo himself—he would be directing nearly $20 million to his own businesses.

On top of the arguable impropriety of personally profiting off of his donors’ and his party’s largesse, the situation presents perverse incentives for Trump. Already, elected officials, up to and including the president, to an extent base their behavior in office on what they believe will play well with voters rather than (or, in the best-case scenario, on top of) what is best for America. This is certainly true of Trump, whose every decision seems to prompt discussion of how it plays into the tension between his nationalist base and traditional Republican voters.

The personal financial benefits of campaigning mean that Trump has a little more motivation to delve into his reelection efforts than most politicians in his position. Because he is personally profiting, he has another reason to aim his politics toward his base so that they will continue donating to him and buying his merchandise in the downtime between election years. Moreover, rather than stockpile for 2020, he has an incentive to keep up the campaign rallies—and keep charging for them, as he did in 2016—so that he can continue funneling money from his donors and voters into his personal businesses.

Moreover, that the president is redirecting donors’ money into his own businesses only further highlights the inadequacy of the trust arrangement he has set up to supposedly prevent him from conflicts of interest. Trump and his lawyers have claimed that, by resigning from his positions within the Trump Organization and handing over control to his two adult sons and a long-time business associate, the president has distanced himself from his businesses enough that he will no longer be tempted to act in his own financial interests. Ethics experts (and common sense) immediately disagreed: Unless the president actually sells his businesses, many have said, and has the funds reinvested without his knowledge, he still knows more than enough about his sources of profit to put his own personal gain above that of the country. The almost $500,000 he’s channeled into the Trump Organization via his reelection campaign demonstrates this: Trump doesn’t need to be in charge of his businesses to know how to direct money their way; all he needs to know is where they are.

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That Second Hotel in Washington, D.C.

There may soon be more than one Trump Hotel in Washington D.C. According to The Washington Post, the Trump Organization is considering purchasing another property in the nation’s capital to develop for its recently created Scion brand, which aims to offer a more affordable alternative to the upscale properties bearing the president’s name.

Unlike the Trump International Hotel—the upscale property that opened in September 2016 and has become something of a synecdoche for the president’s conflicts of interest—a new Scion hotel in D.C. would likely be a licensing deal. That means that, rather than the Trump Organization owning and operating the property itself, a third-party hotelier will be paying the president’s company for the right to use the Scion name; candidates identified by the Post include Foxhall Partners, which has two properties in the city and a third under development, and the Beacon Hotel in downtown D.C.

But even if it isn’t actually owned or operated by the Trump Organization, the new hotel would likely attract scrutiny along the same lines as the Trump International. A licensing agreement means that the president will not be profiting off of the building directly; payments from individuals or organizations booking rooms or events there will not go straight to the Trump Organization, but to the hotelier. But Trump will still have a financial stake in the hotel’s viability: The longer it stays in business and the more successful it is, the more (and longer) the licensee will pay to use the Scion name, and the more likely other owners may be to commit to similar partnerships with the fledgling brand. Trump has resigned from his positions with the Trump Organization and transferred control of his assets to his two adult sons and a long-time business partner. But he still owns the company, which means he will still profit from his properties. According to his son Eric, the president will even continue to receive quarterly reports on how his real-estate empire is faring financially. The pathway to Trump’s pocketbook may be slightly more complicated, but it still exists.

The proposed new property also engenders some of the same concerns as the broader round of expansions the Trump Organization announced in February. Developing a hotel, even in an existing building, means working with local government bureaucracies, such as zoning offices that sign off on structural changes or licensing boards. In any city, this would create  conflicting incentives for government officials who are suddenly being asked to rule on the president’s businesses. On the one hand, Washington, D.C., like many of the cities into which the Trump Organization is looking to expand, voted strongly against the president in the 2016 election; city officials, especially those elected by D.C.’s denizens, may feel a need to factor his unpopularity into their decisions with regard to the newly proposed hotel. On the other hand, the federal government still controls D.C.’s budget, placing additional pressure to green-light a proposal from the infamously mercurial commander-in-chief.

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That Property in Azerbaijan

When it comes to President Donald Trump’s constellation of foreign investments, properties, and companies, much of the attention so far has been on his business’s apparent violation of the Constitution’s emoluments clause, which bars officeholders from taking gifts from foreign leaders. According to numerous ethics experts, the clause takes an expansive definition of gifts, encompassing everything from a direct bribe to a foreign official’s approval of construction of a new Trump property. But some of the Trump Organization’s properties raise additional red flags due to the specific partners involved. That’s true in Indonesia, for example, where Trump’s affiliates have been involved in bribery scandals and radical Islamic nationalist parties, and Brazil, where the company pulled out of a branding agreement amid a criminal investigation of a local business partner.

Such is the case in Azerbaijan, which Transparency International ranks as among the most corrupt countries in the world, where the Trump International Hotel and Tower in Baku remains unopened. Though the long-stalled development has generated a steady drip of news and rumors for years, an overview by Adam Davidson in The New Yorker, entitled “Donald Trump’s Worst Deal,” puts into perspective just how convoluted the situation is, and just how much the project has led Trump and his company into a partnership with numerous corrupt officials in the Middle East. The details suggest that, on top of the continual underlying breach of the emoluments clause, the Trump Organization’s involvement may also violate the Foreign Corrupt Practices Act, or FCPA, which forbids American companies from participating, even unknowingly, in bribery schemes in other countries, with a penalty of up to $2 million and up to five years in jail.

According to Davidson, though the project originated in 2008 as a high-end apartment building, the Trump Organization has had a licensing deal with the building’s Azerbaijani developers to turn the property into a hotel since 2012. Though the Trump Organization presented the deal as a straightforward licensing agreement, it was in fact a much more involved agreement granting the company—specifically, Trump’s daughter Ivanka—extensive oversight over the project. Based on his FEC disclosures in 2016, which as of this moment remain the only official record of Trump’s finances, the president has so far made $2.8 million from the partnership.

But what makes this story unique among the dozens of ethical questions surrounding the president is the Trump Organization’s partners on the project. Ostensibly, the main developer behind the property is Anar Mammadov. He is in turn the son of Azerbaijan’s transportation minister Ziya Mammadov, who was once described in a leaked diplomatic cable as “notoriously corrupt even for Azerbaijan.” Also in on the deal, though not initially publicly disclosed, is Ziya’s brother Elton, who founded the company that currently owns the property in Baku while serving in Azerbaijan’s parliament. Then there’s the Mammadovs’ relationships with Iranian oligarchs. For years, the Mammadovs have been closely linked with the Darvishis, whose members include the head of a  construction firm implicated in the Iranian Revolutionary Guard’s possibly illicit financial operations and the former leader of a company that was sanctioned by the United States for its role in Iran’s attempts to develop an arsenal of nuclear missiles. As the Mammadovs’ influence within Azerbaijan has begun to weaken in recent years, they have  increased both their wealth and their mutually profitable relationship with the Darvishis, green-lighting a number of deals that will prove lucrative for both families.

Alan Garten, the chief legal officer for the Trump Organization, asserted to The New Yorker that, as the company has never worked directly with Ziya or Elton Mammadov, it has not engaged in any behavior that should trip ethical alarms. He has additionally claimed that the company did “extensive due diligence” in making the deal, which did not raise “any red flags,” although the actual employees who carried out the process are no longer with the company.

Still, merely by partnering with the Mammadov family, the Trump Organization may have violated the FCPA. The law explicitly covers cases in which an American company claims not to have known it was working with corrupt officials; jurisprudence since its 1977 passage has further expanded the law’s definition to include “conscious avoidance,” or active efforts by an American company to not learn of a foreign partner’s corruption. So though Garten claims that, since the Trump Organization did not have enough control over the project and has not itself engaged in bribery, its hands are essentially clean, experts on the law say that the Trump Organization may be legally liable if its foreign partners engaged in corrupt practices.

Adding to all this is the fact that Trump is on the record as opposing the FCPA in May 2012, right when it would have become relevant to his company’s engagement in Azerbaijan. Trump called the law “absolutely horrible” and argued that, since other countries do not have the same provision, American corporations are at a major disadvantage in which bribery is the norm. Trump’s appointee to the Securities and Exchange Commission (which enforces the statute), Jay Clayton, similarly considers the FCPA an obstacle to U.S. companies seeking to expand abroad. A dissenting voice on the topic is Attorney General Jeff Sessions, who stated in his confirmation hearings that he intends to continue enforcing the statute. Which of these voices will end up winning out on the topic remains an open question.

This, then, is the situation in which the Trump Organization—and, by extension, the president, who has stepped down from his position within the business but who retains ownership—finds itself in Azerbaijan: The company’s direct partner on Trump Tower Baku is the scion of a wealthy and notoriously corrupt family that appears to have only stepped up its self-dealing as its political power wanes. That family is engaged in what appears to be a relationship of mutual graft with Iranian oligarchs with deep connections to their country’s Revolutionary Guard, the ideological militia widely suspected by the international community of gross corruption and sponsoring terror at home and abroad.

These families can be added to the ever-growing list of international partners whose relationships with the Trump Organization could create conflicts of interest for the president. The Mammadovs’ arrangement with Trump’s company may not only violate the emoluments clause but could also feasibly put the president and his family in legal trouble should the SEC choose to actively pursue enforcement of the FCPA in Azerbaijan. And the Darvishis could in turn use their relationship to influence the Mammadovs, which could have significant implications should Trump attempt, as he has said he will, to take hard-line stances that could affect the Iranian Revolutionary Guard’s 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.

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That Trump Tower Penthouse

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.

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.

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.

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That Resort in the Dominican Republic

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.

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 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.

The Cap Cana story is yet another conflict of interest that only became public because of reporting from local media—and because of the nonchalance with which the Trump family handles the relationship between their business and the presidency. The first outlet to report on Eric’s trip was the Dominican newspaper Diario Libre, shortly after Cap Cana posted a picture of the Hazourys with Eric on its website. This follows stories like the president’s phone call with the president of Argentina and his company’s plans to expand into Taiwan, both of which were similarly broken by local newspapers before getting picked up by American press outlets. Further, like the president’s post-election meeting with business partners from India and Eric’s trip to Uruguay, the Trump family’s propensity for photo ops played a role: Even amid intensifying scrutiny of the Trump Organization’s actions, Eric seems unworried about having not only taken the trip but also taken pictures with his business partners.

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.

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That Chinese Trademark

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.

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.

Additional context, though, complicates this picture. The case, it turns out, was largely resolved in November 2016, before there was any indication that the president would waffle on the One China Policy by calling the president of Taiwan, and was the culmination of more than a decade of litigation that largely predates Trump’s involvement in politics. Conflicts of this kind over trademarks are fairly common in China, and, though resolving such cases often costs companies significant time and money, the Trump Organization’s victory is one of several that have gone in favor of American corporations in recent years. None of this rules out the possibility of a quid-pro-quo arrangement, but in sum it suggests that there is more to the case than what Feinstein alleges.

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.

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That Meeting at Mar-a-Lago

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.

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.

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.

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.

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.

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.

One patron of the club, Richard DeAgazio, demonstrated just how much of a breakdown the situation represents. DeAgazio, who, according to a photo he posted on Facebook, joined the club in December after Trump’s election, snapped several pictures of the president and prime minister’s conversation, which helped corroborate a CNN report on the public nature of the ad-hoc meeting and details such as the use of cellphone flashlights to illuminate documents; he also took pictures with Trump’s chief strategist Steve Bannon and the president’s “body man,” whose job is in part to carry the “nuclear football” containing missile-launch codes (and who was initially identified by name in the photo’s caption). As if to reinforce impression that Mar-a-Lago members gain unprecedented access to the the president, even in the middle of a crisis situation, another patron was able to film Trump giving a toast at a wedding shortly after his press conference with Abe.

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.

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.

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That Defense Department Trump Tower Rental

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..

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.

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.

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.

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That Red Cross Ball

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.

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That D.C. Labor Dispute

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.

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That Estate in Palm Beach

To many of President Donald Trump’s critics, his decision to turn Mar-a-Lago, his Florida estate, into a “Southern White House” epitomizes the way he’s mixing his business interests with his duties as president. With each visit to the property, he boosts the resort’s visibility and may very well prompt more people to enroll as members in attempts to get a glimpse of the commander-in-chief. That the club doubled its initiation fees in January, from $100,000 to $200,000, only adds to the impression that Trump—or, at least his namesake company—is banking on his presidency as a means of boosting revenues. And without a publicly available guest list and no word on what security protocols are in place, the possibility that somebody could be using a club membership to gain access to the president has led Democratic members of Congress to draft a bill specifically to mandate better disclosure of the goings-on at the venue.

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.

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Those Expansion Plans

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.

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That Hotel in Vancouver

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.

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That Reality-Television Show

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.

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That Pipeline

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.

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Those HUD Grants

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.

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That Golf Course in Aberdeen

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.

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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.

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Those Indonesian Politicians

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.

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That Emirati Businessman

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.

Since footage of Trump’s shout-out emerged in early January, Sajwani has continued to feature in coverage of the president’s business entanglements. At the January press conference where Trump and his lawyer, Sheri Dillon, laid out the president’s plan to ostensibly avoid conflicts of interest, Trump said that after the election, Sajwani offered him a $2 billion deal, which Trump turned down. Rather than acknowledge that being offered billions of dollars from a foreign businessman constitutes a conflict of interest, Trump presented his decision not to accept as an example of his magnanimity, saying, “I didn’t have to turn it down, because as you know, I have a no-conflict situation because I’m president. It’s a nice thing to have, but I don’t want to take advantage of something.” Later, Sajwani attended Trump’s inauguration, although it’s unclear if he interacted with the president while there.

Then, on Tuesday, Sajwani posted a picture of himself eating with Donald Trump Jr. in Dubai on Instagram with a caption reading, “It was great having my dear friend and business partner Donald Trump Jr. over for lunch. Discussing new ideas and innovation always make [sic] our meetings even more interesting.”

Donald Jr.’s meeting with Sajwani prompts concerns about the president’s conflicts of interest, for two main reasons. First, the meeting offers a reminder of the insufficiency of the steps Trump has taken to distance himself from his businesses. Though Trump and Dillon claimed that their plan resolved questions about conflicts of interest, ethics experts disagree: Because Trump still knows what his assets are and the identities of those with whom he does business, they say, Trump still knows more than enough to favor his company. Moreover, in an actual blind trust, Trump would have turned his assets over to a trustee with whom he would have no contact. Instead, he turned it over to a long-time executive within the Trump Organization and his sons, who he has long counted as among his closest advisers and with whom he has remained in contact during his presidency so far. Donald Jr.’s meeting with Sajwani is a reminder of these inadequacies, especially because Sajwani posted the picture to Instagram, thus increasing the lunch’s visibility and, along with it, the likelihood that the president will know about the ongoing interactions between his company and Sajwani’s (that is, if Donald Jr. hasn’t already made his father aware of them).

Second, Sajwani’s caption further undermines one of the few parts of the arrangement that actually would have meaningfully reduced the president’s conflicts of interest. In January, Dillon said that the Trump Organization would be canceling all of its pending deals and would stop pursuing foreign deals during Trump’s presidency. Since then, numerous developments have called those intentions into question: Projects appear to be moving forward in both Scotland and the Dominican Republic, with the Trump Organization offering narrow, legalistic explanations as to why the progress didn’t violate the terms of the trust. Though a spokeswoman for the Trump Organization has said that Donald Jr. was not seeking new deals while in Dubai, the previous stories, coupled with Sajwani’s Instagram caption, undermine that account.

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That Virginia Vineyard

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.

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That Las Vegas Labor Dispute

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.

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That Kuwaiti Event

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.

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Those Certificates of Divestiture

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.

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That Carrier Deal

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.

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That Blind-Trust Issue

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 as long as he and the trustees—again, his two sons and his long-time business partner—agree that it is “appropriate,” and will not have to disclose when he does so. This goes directly against the purpose of a blind trust, which in this case would be to distance Trump from his sources of income in an attempt to get rid of his incentive—or even ability—to consciously act in his own financial interest. So far, the plan unveiled in January appears to be as inadequate as many ethics experts had feared.

Finally, removing himself from day-to-day operations will do little to change the fact that Trump will retain substantive knowledge of the illiquid assets involved in his business, such as the numerous buildings and other products that bear his name, especially if he remains in frequent contact with his children. Even assuming that Trump does separate himself from any consideration of his holdings, his children will still likely be major players in the family’s organization, which will still bear at least the Trump name—arguably one of their most valuable properties, as much of the family’s wealth derives from licensing the name to third-party companies. Given the family’s oft-touted brand-consciousness (Ivanka, for example, briefly appeared to be distancing herself from the campaign, and several properties considered rebranding under the name “Scion” when it appeared Trump would lose), the situation epitomizes the way Trump’s, and his family’s, business interests may very well prove inextricable from his actions as president.

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Those Fannie and Freddie Investments

After railing against elites during the campaign, Trump has so far stocked his prospective cabinet with an array of billionaires whose policy positions seem likely to significantly benefit those who are also doing very well. Trump’s putative treasury secretary, Steven Mnuchin, is no exception: His resume includes stints as a banker at Goldman Sachs, a Hollywood producer, and the operator of a bank that has been described as a “foreclosure machine” and once foreclosed on a homeowner over a 27-cent discrepancy.

One of Mnuchin’s apparent beliefs is that the government should cede control of the mortgage guarantors Fannie Mae and Freddie Mac, which the government acquired during the 2008 financial crisis. The two financial institutions’ stocks rose by more than 40 percent after Mnuchin stated that he believes the Trump administration “will get it done reasonably fast.”

Doing so would be broadly compatible with Trump’s general antipathy toward regulation of the banking industry. However, The Wall Street Journal identified an additional wrinkle to the story: When Fannie Mae and Freddie Mac’s stocks rose, one major beneficiary was John Paulson, an adviser to the Trump campaign and a business partner of Mnuchin’s. Paulson’s hedge funds include significant investments in both Fannie and Freddie. Trump himself has invested between $3 million and $5 million across three of Paulson’s funds, according to his filings with the Federal Election Commission (which remain the only available window into the president’s financial holdings). In other words, as Fannie Mae and Freddie Mac’s stock prices increase—and they have so far more than doubled since the election on the expectation that the incoming Trump administration will be more lenient toward the financial sector than Obama—Trump’s portfolio benefits.

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That Phone Call With Taiwan

When news first emerged that the president spoke on the phone with Taiwanese President Tsai Ing-wen on December 2, the immediate reaction was uproar over his apparently impetuous breach of decades of U.S. protocol toward China and Taiwan. As my colleague David Graham explained, since 1979, the United States has participated in the “artful diplomatic fiction” of officially recognizing the mainland People’s Republic of China as the only legitimate Chinese government while maintaining loose, unofficial recognition of—and significant economic and military ties to—Taiwan. That Trump would speak to the president of Taiwan, especially before doing the same with Xi Jinping, the president of the PRC, flies in the face of a diplomatic tradition that has undergirded almost 40 years of U.S.-China relations.

Amid the days of dissembling that followed the phone call, an additional worrisome detail came out: At the time, the Trump Organization was apparently exploring expansion into Taiwan. Soon afterwards, the Trump Organization denied that it planned to do so; however, even before the controversy arose, the mayor of Taoyuan, Taiwan, the municipality in which the Trump Organization allegedly wants to build, described in a televised interview a meeting with a representative of the Trump Organization in September to discuss prospective real-estate projects, and at least one Trump employee was found to have posted on Facebook that she was in Taiwan at the time on a business trip. Based on the January 11 announcement that the Trump Organization will be suspending its development plans and will not pursue foreign deals in office, it would appear that any movement on development in Taiwan is no longer on the table.

The phone call, and the many statements that have followed, are of particular interest because of the extent to which they dovetail with some of the biggest concerns about Trump’s approach toward governance. In the ensuing 48 hours, Republican officials offered several, sometimes entirely contradictory, explanations of what initially appeared to be an impulsive move by Trump; depending on who was speaking, the phone call was actually initiated by Ing-wen (which, if technically true, ignores that it was Trump’s staff who arranged the conversation), was just “a courtesy,” or manifested a policy shift weeks in the making—although, regardless, it was made without first consulting the White House or State Department. The defense of the move, and the questions it creates regarding conflicts of interest, have largely hinged on the belief that, since voters apparently don’t mind, the reaction was overblown.

On this issue, though, whether or not voters care is immaterial to the central question. The president of the United States breached decades of international protocol created to preserve a precarious balance of power. That decision raised not only the possibility that Trump was blundering into a potential international incident but also that he may have done so in part out of consideration for his business prospects.

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That Deutsche Bank Debt

Though he often brags about leveraging corporate-finance law to become “The King of Debt,” Trump’s numerous bankruptcy filings have left most large Wall Street banks reticent to lend to him, according to The Wall Street Journal. Among the few exceptions is Deutsche Bank, which “has led or participated in loans of at least $2.5 billion” to the president since 1996, with at least another $1 billion in loan commitments to Trump-affiliated companies; more than $300 million of those loans have come since 2012.

The president’s indebtedness does not itself pose a conflict of interest, but Deutsche Bank’s ongoing legal troubles very well might. The Justice Department is currently negotiating with Deutsche Bank regarding a preliminary settlement of $14 billion to resolve probes into allegedly misleading predatory lending practices in the leadup to the 2008 financial crisis; while it is believed that Deutsche Bank will push back against the sum, there has been no public news regarding negotiations since the initial figure was reported in September. Trump will soon be naming many of the officials with jurisdiction over this and other deals, prompting several House Democrats to send a letter to federal financial agencies calling for close scrutiny of how Trump may seek to influence the settlement through his appointments—although doing so would be just as in keeping with his general stance toward financial regulation as with active protection of his pocketbook. Other Democrats have called for the proactive appointment of independent prosecutors to avoid any appearance of conflict if the case is not resolved before Trump takes office.

Fears that Trump may unduly consider his indebtedness to Deutsche Bank in deciding his administration’s policy toward the financial sector go beyond general anxiety about deregulation. Deutsche Bank is undergoing a period of struggle that may have it on the verge of failure already. Its stock valuation has dropped by more than half since July 2015; in January, it posted its first full-year loss since 2008; and one of its many tranches of bonds—one specifically designed to be a high-risk, high-reward safety valve in times of trouble—has recently begun to crash. In June, the International Monetary Fund called Deutsche Bank “the most important net contributor to systemic risks” among globally important financial institutions. If the bank were to fail, it could have major consequences for not only Trump’s businesses, which would lose their sole remaining lender, but for the global economy as well.

Arguably, the $14 billion fine the Justice Department is seeking to impose has exacerbated rather than alleviated these struggles. Based the company’s market capitalization—the number of shares multiplied by their price— of roughly $16 billion, the sum would leave Deutsche Bank critically low in liquid assets with which to absorb future troubles, although the institution’s own self-valuation of $68 billion argues otherwise. But given the complexity and potential volatility of the situation, it is important for any decision to be free from outside influence, something Trump’s outstanding debt threatens to jeopardize.

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That Secret Service Detail

During the election, the Trump campaign put no small portion of its funds toward paying for use of the candidate’s own properties; perhaps the most notable of these expenditures was the nearly $170,000 the campaign spent in July on rent for its headquarters in Trump Tower. These expenses raised the possibility that, as Trump predicted in 2000, he “could be the first presidential candidate to run and make money on it.” Now that he will be president, he may be able to profit off of the Secret Service by virtue of the fact that he and his family will live in Trump Tower and fly in his private jets—which requires the agents tasked with guarding them to pay him rent and airfare.

The first way Trump could monetize his own protective detail is by having family members travel in his two planes and three helicopters. This is not so much speculative as foregone: Over the course of the campaign, the Secret Service, which traditionally pays for its own travel during elections, spent $2.74 million to fly on a plane owned by one of Trump’s own companies. While in office, Trump will fly exclusively on Air Force One, while Mike Pence will be riding Air Force Two. However, their families may still be flying on Trump’s private planes—along with their protective details, which would effectively direct even more money to Trump. (Previous first families have flown with a detail, whose legal purview covers “the immediate family members,” but none have done so on planes they themselves own.)

A bigger question regards Trump Tower in New York, where the president appears likely to spend a significant amount of time. For the past few decades, it has been common practice for the Secret Service to provide protection for the president and vice president’s non-White House residences, which sometimes entails paying rent to the officeholder. (Joe Biden, for example, received $2,200 per month when the agency rented a cottage he owned near his home in Delaware.)

But Trump Tower is a unique case, as it’s not in Delaware but the middle of Manhattan. Already, pedestrians and tourists are chafing at the increased security around the building, Trump’s frequent use of which has required closing a block of 56th Street and multiple lanes of Fifth Avenue; with multiple outlets reporting that Trump’s wife Melania and 10-year-old son Barron are expected to stay at Trump Tower for at least part of his term, it appears that the consternation will continue, with an enormous price tag for taxpayers: According to the New York Post, it could cost as much as $3 million a year to rent out two of the building’s vacant floors, meaning that Trump will be making money off of his own security detail. Meanwhile, Reuters has reported that the city of New York is calling for federal funds to reimburse the costs of keeping up a security detail around Trump Tower.

This system creates an unusual set of conflicting interests for Trump regarding his own travel and residences. Though presidents as disparate as Dwight Eisenhower and Barack Obama have evoked partisan ire over time spent away from the White House, whether on the golf course or on vacation in Hawaii, only Donald Trump will actually have gained from his and his family’s travels. And if, while in office, Trump visits properties he owns other than Trump Tower—his buildings in other U.S. cities like Chicago and Miami, for example, or his golf course and resort in Scotland, or one of the many international hotels bearing his name—he stands to gain from the stays for which his security detail (and, by extension, taxpayers) may be paying. Moreover, the more his family members fly on his planes, whether they are running his business on his behalf or running interference with foreign leaders, the more the Secret Service will end up paying for seats alongside them.

In fact, there are already signs that the Trump Organization has no qualms about making money off of the New York tower’s new security arrangements in more ways than one. According to Politico, just five days after the election, a prominent New York real-estate firm invoked Trump Tower’s new secret-service detail as a selling point for a $2.1 million condominium, which it described as “The Best Value in the Most Secure Building in Manhattan.” Though the flier was issued by an outside agency, the president’s corporation still stands to benefit from increased traffic through processing and other service fees, making the advertisement a clear example of how Trump stands to benefit off of his new position.

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That Property in Georgia (the Country)

Trump’s election has had the effect of speeding up development on a number of his branded properties, even when the president appears not to be pulling any strings himself. As occurred with Trump Tower Buenos Aires, the completion of an embattled Trump-branded building in the former Soviet republic of Georgia is no longer on hold now that Trump has won. The project, which has been in the works in the seaside resort city of Batumi since 2010, was initially scheduled to break ground in 2013, but has been in stasis for several reasons, possibly including the 2013 electoral defeat of President Mikheil Saakashvili, a friend of Trump’s and a supporter of the deal.

According to a report in The Washington Post, the green-lighting of the Trump property in Batumi has not been linked to a specific conversation with Georgian leaders, and a U.S.-based partner on the project has suggested that it has moved forward without any nudging from the government. However, numerous public statements in the days since suggest that Trump’s election was a major factor, including an interview with a real-estate entrepreneur who said, “Cutting the ribbon on a new Trump Tower in Georgia will be a symbol of victory for all of the free world.”

That the property seems to be moving forward solely because Trump was elected suggests his various business interests around the world may play a role not only in his foreign policy but in how other countries seek to deal with the U.S. as well. America’s relationship with Georgia is largely shaped by concerns about Russian influence and potential aggression in the region, most recently manifested in Russia’s 2008 seizure of two regions of Georgia, South Ossetia and Abkhazia. With controversy already swirling over Trump’s admiration for Putin and Russia’s alleged role in the U.S. election, some in the foreign-policy community have expressed trepidation that Trump’s potential deferential attitude toward Russia would prove deleterious for the continued independence of former satellite nations like Georgia. So, if Georgia has an ulterior motive behind the approval of Trump’s property in Batumi, it would be to keep Russia at bay and maintain the status quo in the region.

According to Trump and his lawyer, as of January 11, the Trump Organization has suspended ongoing development projects and will no longer pursue deals in foreign countries. As the project in Batumi falls under both categories, the statement suggests that progress on the president’s property in the city is no longer moving forward. Still, it’s alarming that a country like Georgia may be giving Trump’s businesses favorable treatment (whether he asked for it or not) in an attempt to influence his foreign policy.

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That Phone Call With Erdogan

One of the worries regarding Trump’s many conflicts of interest is that they may influence policy towards countries whose relationships with the U.S. are currently strained. Such is the case with Turkey, whose president, Recep Erdogan, has been cracking down significantly on civil liberties and democratic institutions within the country after a failed coup last summer. Though Turkey has in the past been a vital U.S. ally as a bulwark against Islamic terror, Erdogan’s authoritarian turn and combative stance toward Europe have led to some reevaluation of that relationship.

Thus, it was troubling news that when Erdogan phoned Trump shortly after the election—it was one of the first calls Trump received after his victory—Trump used the opportunity to plug his business partners in Istanbul. According to the Huffington Post, while on the line with Erdogan, Trump relayed praise for the leader from Mehmet Ali Yalcindag, whose father-in-law, Aydin Dogan, owns the holding company that operates the Trump Towers in Istanbul. Dogan has previously drawn Erdogan’s ire by criticizing the leader; in recent years, however, Dogan’s companies, most notably CNN Turk, have shown support for Erdogan’s regime, including broadcasting his first message after the uprising in July.

Trump’s conversation with Erdogan is also worth noting because of a number of Trump’s previous statements regarding the Turkish president. Though Erdogan briefly called for Trump’s name to be removed from the Istanbul property due to his proposed ban on Muslim immigration, Erdogan dropped the demand when, after the overthrow attempt, Trump praised Erdogan for “turning it around” and essentially dismissed concerns over Erdogan’s crackdown on civil liberties by bringing up domestic problems. Michael Flynn, who was recently named Trump’s national security adviser, wrote an election-day op-ed in The Hill arguing against offering asylum to a Muslim cleric whom Erdogan has accused of orchestrating the uprising, which some have interpreted as a diplomatic overture. Erdogan has also bristled at post-election protests in the U.S. and the description of both himself and Trump as part of a “ring of autocrats.” That the two are now talking about their countries’ relationship as in the same conversation as Trump’s business interests further complicates Trump’s strangely effusive comments about Erdogan.

It’s worth noting that Trump himself considers his hotel in Istanbul a potential conflict of interest. In a December 2015 interview with Stephen Bannon, at the time the chairman of Breitbart News, Trump said as much, telling Bannon, “I have a little conflict of interest ‘cause I have a major, major building in Istanbul. It’s a tremendously successful job.” That he chose to discuss the towers with Erdogan, albeit obliquely, through his references to his business partners when he has already acknowledged the impropriety of doing so simply reinforces the perception that he may prove unable to separate his business from his official duties while in office.  

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That Hotel in Washington, D.C.

The White House is not the only new Trump property in Washington, D.C.; there’s also the new Trump International Hotel, which opened in October and is located just a few blocks away in what was formerly known as the Old Post Office Pavilion. Previously, the hotel played a role in the campaign as the site of the event at which Trump recanted (sort of) his belief that Barack Obama was not born in the United States. Now, the hotel is at the center of speculation as a symbol of how inextricable Trump’s presidential role may be from his personal interests.

First and foremost, since his election, ethics groups and critics of the president have repeatedly alleged that, simply by taking office, Trump has been in continual violation of the lease he holds on the Old Post Office, the government-owned building the Trump International Hotel inhabits. At issue is a clause in the lease stating 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.” As such, watchdog organizations such as Citizens for Responsibility and Ethics in Washington have repeatedly appealed to the Government Services Administration, the federal agency that administers the lease, to terminate the agreement with the Trump Organization.

On March 23, however, the GSA released a letter finding that Trump “is in full compliance” with the lease. According to Kevin Terry, the contract officer who oversaw the initial negotiations between the government and Trump, the president’s plan to turn over his businesses to his two adult sons and the long-time Trump Organization executive Alen Garten is sufficient to meet the terms of the agreement, as Trump is no longer “an officer, director, manager, employee, or other official in any of the entities” involved in operating the hotel. The letter immediately drew outcry from ethics organizations like CREW, which called the ruling “a disappointment” that failed to address the underlying problems of Trump’s businesses, and the left-leaning advocacy group Public Citizen, which described it as “an affront to the rule of law” based on “tortured and wholly uncompelling analysis” that “would get a first-year law student kicked out of law school.”

The GSA’s decision may also prove a blow to the more general argument that Trump has not done enough to distance himself from his namesake organization. Critics have strenuously objected to the plan Trump and his lawyer Sheri Dillon laid out on January 11 to mitigate conflicts of interest, under which the president has stepped down from, but retains ownership of, his numerous business interests, and placed his assets in a trust to be administered by his adult sons and Garten. His opponents maintain that, because Trump still has significant knowledge of his business interests and will still be benefiting from them, and because he has put in place few real barriers between himself and his sons, there is still ample opportunity for outside actors to seek to influence the president’s decisions by patronizing his companies. Though the letter from the GSA discusses only the Trump International Hotel and not the legality of the overall arrangement, it is nonetheless a decidedly favorable outcome for Trump in the first legal challenge over his conflicts of interest.

As if its location didn’t pose enough of an ethical question, the hotel has already hosted at least one promotional event specifically aimed at enticing foreign diplomats to stay at the establishment while in town on official state business. On the one hand, direct influence will likely be difficult to prove: The establishment is, after all, a five-star hotel that would have been likely to attract high-class clientele even if Trump had lost the election, a fact to which Trump and those who surround him may well point in order to maintain a patina of respectability around their dealings. Still, the meeting’s proximity to the election reinforces that it will be worth watching the comings and goings at the hotel closely for signs that Trump, who so often accused his opponent (often without evidence) of pay-for-play, may be using his position as president to promote his businesses.

Trump himself acknowledged that his presidency is likely to increase traffic to his Washington, D.C. property. Speaking to The New York Times, the president noted that the property is “probably a more valuable asset than it was before” and that his brand is “hotter” since the election. However, he went on to insist that there was nothing even potentially problematic about his unprecedented situation and that he sees no reason why he couldn’t run both the presidency and his business without conflict.

Multiple events since the election have made Trump’s lease on the hotel a central focus of discussions of his conflicts of interest, including among Democrats in the House. On November 29, Bahrain—a country whose donations to the Clinton Foundation Trump and his campaign decried during the campaign—announced that it would be celebrating the anniversary of its king’s ascension to the throne at the hotel. Other events announced since the election include a Hannukah celebration co-hosted by the Embassy of Azerbaijan and the Conference of Presidents of Major American Jewish Organizations and a reception for the conservative think tank the Heritage Foundation featuring Vice President Mike Pence as its keynote speaker.

Nor did the string of bookings by international entities end after Trump’s inauguration: On February 9, Politico reported that a lobbying group with connections to the government of Saudi Arabia had booked a four-day stay at the hotel in Washington, D.C. And on March 13, The Daily Caller reported that the Turkish-American Business Council will be co-hosting its annual conference at the Trump International Hotel after a seven-year runat the Ritz-Carlton. The latter announcement is especially notable because the organization’s chairman, Ekim Alptekin, is involved in another of the Trump administration’s scandals: One of Alptekin’s companies, the apparent shell company Inovo BV, paid $530,000 to the former National Security Adviser Michael Flynn to lobby on behalf of the Turkish government, which prompted Flynn to register as a foreign agent shortly after he was ousted from the Trump administration for lying about his contacts with Russian agents while a member of the president’s transition team.

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That Argentinian Office Building

According to a report by the prominent Argentine journalist Jorge Lanata, the president’s first phone call with his Argentine counterpart Mauricio Macri included a discussion of the permit issues currently holding up construction of a new Trump-branded office building in Buenos Aires. Both Macri and Trump quickly denied the report; according to a statement from the Embassy of Argentina, “The subject both leaders talked about was the institutional relationship, and they briefly mentioned the personal relationship they have had for years.”

As summarized in a tweetstorm here, Trump’s relationship with Argentina’s government and business elites—and the story so far on his property there—is already long and convoluted. The phone call with Macri was apparently set up through Felipe Yaryura, one of Trump’s longtime associates whose company, YY Development Group, is in charge of Trump Tower Buenos Aires. The day after the phone call, the PanAm Post reported that YY Development Group had been approved to break ground in June 2017; evidence has since emerged that the permitting process is not, in fact, finished, although Trump’s business associates are moving ahead as though it is.

Based on the information at the president’s January 11 press conference, it appears that the properties in Argentina, as both ongoing development projects and deals in a foreign country, is no longer moving forward. Nevertheless, the questionable circumstances under which it did so in the immediate aftermath of the election demonstrates just how many avenues there are for Trump’s conflicts of interest to interfere with governance around the world.  

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Those Companies in Saudi Arabia

Even as Trump was running for president, his company was continuing to operate and open new properties. While the most memorable openings may have been that of his hotel in Washington, D.C., and his golf course in Turnberry, Scotland, the Trump Organization was continuing to work on projects in other countries, including, according to a report the Washington Post, registering eight new companies in Saudi Arabia during the 16-month campaign.

The organization’s endeavors in Saudi Arabia are notable not only because they may further complicate the shaky relationship between the U.S. and an oil-rich gulf state notorious for human-rights abuses but also because of how they relate to Trump’s campaign rhetoric. One of his criticisms of Hillary Clinton was that her charitable foundation had accepted donations from governments with questionable records on human rights, most notably Qatar and Saudi Arabia, always with the implication (or direct accusation) that they were doing so to curry favor with Clinton when she was secretary of state. That Trump was continuing to level this criticism while his namesake organization was actively pursuing new projects in Saudi Arabia not only bodes ill for his ability to separate his personal and presidential interests but also further calls into question the honesty and transparency of his campaign.

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That British Wind Farm

As he indicated when he stopped there during the campaign, President Trump takes enormous pride in his recently opened golf course in Turnberry, Scotland. The day after the British public voted for Brexit—over intense Scottish opposition—Trump spoke at the property’s opening, proudly touting how the decision’s deflationary effect on the pound would benefit his business.

However, Trump also has a second golf course in Aberdeen, where it appears Trump has attempted to intercede in the interest of his own pocketbook.* According to The New York Times, Trump had a post-election meeting with Nigel Farage in which he “encouraged Mr. Farage and his entourage to oppose the kind of offshore wind farms that Mr. Trump believes will mar the pristine view from one of his two Scottish golf courses.” Hope Hicks, a spokeswoman for the president, denied that the two had discussed the subject, only for Trump to later confirm that the topic had, in fact, come up in their conversation.

* This entry originally misstated that Trump intervened at Turnberry, his other golf course in Scotland. We regret the error.

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Those Indian Business Partners

It didn’t take long after the election for President Trump to be seen in public with international business partners. According to a November 19 article in The New York Times, Trump took a break from his transition schedule to meet with three Indian real-estate executives who are currently building a Trump-branded apartment complex in Mumbai. According to both Trump and the Indian businessmen, the meeting was essentially congratulatory in nature; a picture posted by one of the executives on Twitter shows the four men smiling broadly and giving a thumbs-up to the camera. However, that the meeting happened in the first place suggests that Trump does not currently have any qualms about forestalling official state business for personal business.

On top of that, the meeting raises questions in the blind-trust realm as well. The president himself was not the only member of his family there; two Facebook photos show that Ivanka and Eric Trump both attended the meeting as well. Their presence serves as a reminder that their father seems so far uninterested in maintaining even the nominal separation between himself and his assets that he repeatedly said he would create during the campaign.

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That Envoy From the Philippines

One leader with whom Trump already has an advantage over President Obama is Rodrigo Duterte, the similarly brash president of the Philippines. Duterte, who has threatened to “break up with America,” told Obama to “go to hell,” and called the president a “son of a whore,” expressed admiration for Trump, noting that, among other similarities, they both enjoy swearing.

Duterte’s affinity for Trump apparently goes beyond vulgar word choice. Late in October, Duterte appointed a longtime business associate of Trump’s as a special envoy to the United States, an announcement that became public shortly after the election. This appointment in particular raises questions because it is just as open to exploitation by Duterte as it is to Trump, as the Filipino president could intend to use his new envoy’s relationship with Trump to strengthen the Philippines’ hand. Whichever side the appointment does eventually benefit, however, the situation is nevertheless fraught with conflicts between the three men’s personal and political interests.

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Until 4:44, Jay-Z’s albums could be understood as an indictment of the immorality of capitalism by a man luxuriating in its fruits. Jay-Z argued that there was something revolutionary in this, in a black man born in the projects proving himself a better entrepreneur than white men born into plenty, as if to suggest the infinite human potential destroyed by the circumstances he escaped. He was right.

Jay-Z used the terms of finance to describe the drug trade—referring to his crew as his “staff,” his organization as his “conglomerate,” smoothly transitioning from acknowledging the violence of the trade to comparing it to the stock market (“drug prices up and down like it’s Wall Street homes, but this is worse than the Dow Jones, your brains are now blown”), and connecting the inequality of the system that shaped his life with his determination to triumph over it.

He saw clearly that his pursuit of success visited countless cruelties and indignities upon himself and those around him, and that his triumph would come at unimaginable cost. Perhaps the one thing he didn’t expect was that it would have a happy ending, one with wealth and family, fame and fatherhood.

The contradiction of that transition is that while Shawn Corey Carter’s politics have simplified in disappointing ways, that’s come with an emotional maturity Jay-Z never had. On Reasonable Doubt, Jay-Z’s ideal relationship was one in which fidelity was optional; on 4:44, Carter raps movingly about the devastating realization that someday, his children will learn of his transgressions. He imagines himself on the other end of the knife he used to stab the director Lance “Un” Rivera in 1999. He gives his mother space on the album to speak about the years she spent hiding her sexual orientation.

The tension between Jay-Z’s love of the game and his fear of losing his soul, his indulgence in worldly pleasures as the years ripped away friends and family through death or betrayal, formed the emotional core of every Jay-Z album from Reasonable Doubt to The Blueprint 3. Appropriately enough, 4:44 begins with the metaphorical assassination of the Jay-Z persona as Carter takes on the responsibilities of fatherhood, marriage, and wealth. He offers a new vision of capitalism as a tool for community uplift. Carter is not at the height of his lyrical prowess on 4:44, but the album is ambitious and emotionally vulnerable, and represents a profound shift from Jay-Z’s previous offerings, especially in its belief in the power of the market to improve black lives rather than destroy them.  

***

Perhaps the most concise and perplexing statement of Carter’s new unambiguous love for capitalism comes in a couplet on the second track, “The Story of O.J.,” a song whose main theme is the indelible force of racism against black people regardless of class. On one jarring line, Carter states, “You wanna know what’s more important than throwin’ away money at a strip club? Credit. You ever wonder why Jewish people own all the property in America? This how they did it.”

Carter’s admonition is meant to encourage black people to imitate what he perceives to be a Jewish strength of ethnic solidarity and financial prowess. “‘The Story of O.J.’ is really a song about we as a culture, having a plan, how we’re gonna push this forward,” Carter said on iHeartRadio. But the line is nonetheless startling because it invokes the anti-Semitic canard that Jews maintain financial control of everything you see. It’s beneath Carter, a writer and artist of astonishing ability and sophistication who has every reason to know better. Responding to prior criticisms in his book Decoded, Jay-Z  wrote that “when I use lines like this, I count on people knowing who I am and my intentions, knowing that I’m not anti-Semitic or racist, even when I use stereotypes in my rhymes.”

There’s an old strain of black capitalism here that runs from Booker T. Washington through the Black Power movement to the Nation of Islam and beyond. Carter is also drawing on an old tradition of using American Jews as a model of a downtrodden people who found success in America. Frederick Douglass predicted that just as Jewish people had “risen” despite discrimination in Europe, “in like manner the Negro will rise in social scale.”

“The Jew, who was once in about the same position as the Negro is to-day, has now complete recognition, because he has entwined himself in America in a business or industrial sense,” Washington wrote in Industrial Training for the Negro in 1904. Washington also had a similar vision of community uplift through labor that never materialized, because the white South never truly adhered to its side of the bargain Washington offered—submission to Jim Crow in exchange for peace.

“The organization of the 3,000,000 Jews in America is little less than marvelous,” wrote W.E.B DuBois in the NAACP magazine The Crisis in 1915. “This is the great net work of organization which makes the Jewish people the tremendous force for good and for uplift which they are in this country. Let black men look at them with admiration and emulate them.”  

These sorts of admonitions, drawn from Maureen Adams’s anthology of essays on black-Jewish relations, echo through the high point of black-Jewish cooperation during the civil-rights movement, and its nadir beginning in the late 1960s, when both communities drifted toward nationalisms that would prove to be incompatible. Shirley Chisholm asserted that within Bed-Stuy, Barbadian Americans like her parents were referred to as “Black Jews” “because of their work ethic and obsession with their children’s education,” the historian Michael Woodsworth writes in Battle for Bed-Stuy.

And of course, there were those who bristled at the comparison, such as James Baldwin. He wrote that “the Jew profits from his status in America, and he must expect Negroes to distrust him for it. The Jew does not realize that the credential he offers, the fact that he has been despised and slaughtered, does not increase the Negro’s understanding. It increases the Negro’s rage.”

The analogy has never worked, because even at its worst moments America has generally been a haven for its Jewish immigrants and their descendants, and a place of bondage for its black residents and theirs. We know the names Leo Frank, Andrew Goodman, and Michael Schwerner; the names of black people who were killed in the South under similar circumstances are too numerous to recall without aid.

“Jews had a choice, they could be white and American in all things secular, and Jewish in all things religious,” wrote Julius Lester, a former Amherst professor and African American convert to Judaism. “This choice was not available to black people for obvious reasons.” American Jews simply have not, and likely never will, face the structural barriers that black Americans continue to face. To this day, black Americans are targeted by mainstream financial institutions with predatory loans and subprime mortgages with the potential to wipe out whatever financial success they’ve attained.

You rarely hear black people suggesting that they emulate Jewish success anymore, although as the only Jew in mostly black spaces growing up, and almost always the only black Jew, I sometimes heard it, often with the same ambivalent mix of admiration and hostility with which it comes across on 4:44. That advice isn’t given anymore because of the popular recognition that if American blacks had the same access to credit as American Jews, if thrift and moral rectitude were all that was necessary for economic success, the Bed-Stuy that created Shawn Carter would never have existed.  

***

At first, the Brooklyn neighborhood was actually two different ones: Bedford and Stuyvesant Heights. But when black families began to move into the adjacent communities in the 1930s, they became one entity. By 1940, the New Deal-era Home Owners’ Loan Corporation graded the neighborhood as “hazardous” because of an “infiltration of negroes.” The HOLC noted that “Colored infiltration” was  “a definitely adverse influence on neighborhood desirability although Negroes will buy properties at fair prices and usually rent rooms.” Racism made Bed-Stuy, and then the government drew a red line around it.

As Woodsworth writes in Battle for Bed-Stuy, “subsequent assessments by private lenders reinforced the notion that Central Brooklyn, with its expanding black population, should be quarantined. As a result, few prospective homebuyers in the area, black or white, could access federally guaranteed mortgages; existing homeowners, foreseeing plummeting property values, sold out while they could.”

The HOLC’s designation ensured that banks would not extend their usual loans there—depriving black Americans of the credit lines and capital investment that other communities would use to build wealth, and then look down their noses at black people wondering why they had not done the same. Ten years after the HOLC’s assessment, the New York City Housing Authority opened a 27-building complex known as the Marcy Houses, built on nearly 30 acres of homes and businesses cleared to make room for the public housing project. It was built to house working-class Americans and veterans, and was the childhood home of Shawn Corey Carter.

That Bed-Stuy, like all of New York City and black neighborhoods all over America, was created through private racism and state discrimination, by the hands of presidents like Franklin Roosevelt and city bureaucrats like Robert Moses. “Until the last quarter of the twentieth century,” writes Richard Rothstein in The Color of Law, “racially explicit policies of federal, state, and local governments defined where whites and African Americans should live.” Black Americans in Bed-Stuy (as elsewhere) organized to fight these policies, but as Woodsworth describes, fighting segregation in the North could be as daunting as fighting it in the South: “The problem for New York activists was that segregation was illegal, even if it persisted on the ground. They could not hope to deal a fatal blow to the Jim Crow system, since the Jim Crow system did not officially exist.”

That historical context is lacking from the economic nationalism of 4:44. The strip club line is a more risque expression of the Obamaesque notion that black people would have better credit if they spent less money on vice, that they would have money to invest in gentrifying Brooklyn real estate or fine art that appreciates in value. “What’s better than one billionaire? Two,” Carter raps on “Smile.” “Especially when they from the same hue as you.” Does Carter really believe a few more black members of the one percent club is going to change circumstances for the black masses?

This is far afield from the Jay-Z on Reasonable Doubt who acknowledged, “nine to five is how you survive but I’m not trying to survive I’m trying to live it to the limit and love it a lot”; who recalled the fleeting and bittersweet triumph of drug money, allowing him to sit at the bar “laughin’ hard, happy to be escapin’ poverty, however brief.” It’s not the Jay-Z who reveled in the skills he learned in the same drug trade, while confessing that drugs killed his father and led him to carry the gun that he used to shoot his brother. Who bragged about being able to sell “ice in the winter, I’ll sell fire in hell, I am a hustler baby, I’ll sell water to a well,” a line that’s brilliant because it identifies the essence of hustling as selling people things they don’t need. The Jay-Z who confessed that “the pressure for success can put a good strain, on a friend you call best, and yes, it could bring out the worst in every person, even the good and sane.” The rapper who acknowledged that his experience, the “American dream,” was “a journey seldom seen.”

There are hints of the old Jay-Z on 4:44 (“I still ain’t trippin’, that’s life, winners and losers, drug dealers and abusers, America likes me ruthless”), but he is largely gone, replaced by Shawn Carter the mogul, who raps on “Legacy” about leaving his wealth to his children over a sample of Donny Hathaway singing “one day we’ll all be free.” In 1999, Jay-Z told Vibe that his most important goal was “to create a comfortable position for me and everybody around me ... blacks, when we come up, we don’t normally inherit business. That’s not a common thing for us to have old money, like three and four generations, inheriting our parents’ businesses. That’s what we workin on right now, a legacy.” Nearly two decades later, Jay-Z’s vision of legacy has evolved past his inner circle to the larger black community.  

It’s a sunny optimism that stands out across the release of albums from black artists over the past two years from Solange Knowles to Kendrick Lamar that linger in the shadow of post-Obama melancholy, the sort of feeling Jay-Z might have been describing when he said in 2000, “niggas say it’s the dawn but I’m superstitious, shit is as dark as it’s been, nothing has moved as you predicted.” The point is not that 4:44’s message of community uplift is not inspiring—it is. But a lack of inspiration or motivation is not the reason that the black community suffers disproportionately from poverty, unemployment, crime, or incarceration.

And so the arc that began with Reasonable Doubt comes to an end of sorts: Jay-Z was willing to exploit the unjust system that condemned him to a life of poverty to escape it; Shawn Carter the mogul believes that system can set black people free, implying his improbable success and undeniable genius could or should be imitated. Jay-Z savaged the hypocrisy and cruelty of American capitalism while mastering it; on 4:44, Carter wonders if the system might work after all.  

Jay-Z has always asked a lot of his audience, rewarding those who look for a deeper meaning behind his deceptively casual flow. Carter’s newfound positivity and calls to buy black—and therefor subscribe to his TIDAL streaming service and buy his  champagne and cognac—whether sincere or otherwise, help his bottom line.

It’s hard not to think back to The Black Album, Jay-Z’s temporary farewell to the industry in 2003, in which he explains why he doesn’t adopt the more overtly political and activist stances of rappers like Talib Kweli and Common, and wonder whether, like Batman hiding behind Bruce Wayne, Jay-Z  the hustler is as dead as you might presume from listening to 4:44’s first track.

“If skills sold, truth be told, I’d probably be lyrically Talib Kweli, truthfully I wanna rhyme like Common Sense, but I did 5 mill, I ain’t been rhyming like Common since,” Jay-Z raps. Later, he says, “so next time you see the homie and his rims spin, just know my mind is working just like them (the rims, that is).”

President Donald Trump still has not taken the necessary steps to distance himself from his businesses while in office. In accordance with a plan that he and one of his lawyers, Sheri Dillon, laid out at a press conference on January 11, Trump has filed paperwork to remove himself from the day-to-day operation of his eponymous organization. However, numerous ethics experts have voiced strenuous objections to the plan, which they say does very little to resolve the issue: As long as Trump continues to profit from his business empire—which he does whether or not he is nominally in charge—they say, the possibility that outside actors will attempt to affect his policies by plumping up his pocketbook will remain very much in play.

Several of Trump’s critics have moved forward with legal action. The watchdog group Citizens for Responsibility and Ethics in Washington, or CREW, filed a lawsuit alleging that Trump’s business holdings violate the Emoluments Clause of the Constitution, which makes it illegal for government officials to “accept of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.” CREW’s bipartisan legal team includes, among others, Norm Eisen and Richard Painter, who served as ethics lawyers under Presidents Obama and George W. Bush, respectively; Laurence Tribe, a constitutional law professor at Harvard University; and Zephyr Teachout, a professor at Fordham University (and former congressional candidate) who is considered an authority on the Emoluments Clause. All have been vocally critical of Trump’s continued refusal to sell off his business, and are now taking their case to court to argue that several of Trump’s businesses present avenues by which foreign governments could seek to influence the president by, for example, booking stays at one of his hotels or renting space at one of his properties. Additionally, the lawsuit seeks to force Trump to reveal his tax returns, something every president has done since Gerald Ford but which Trump has refused to do, significantly limiting the public’s ability to understand the president’s finances. When asked about the lawsuit, Trump described it as “totally without merit.” Eisen was quick to respond on Twitter, offering to “debate Trump (or his chosen champion) on the merits of our case anytime,” making it clear that CREW intends to continue to pursue its case. (CREW has also filed a separate complaint to the General Services Administration arguing that Trump has violated the lease on his Washington, D.C. hotel, which states that “no ... elected official of the Government of the United States … shall be admitted to any share or part of this Lease, or to any benefit that may arise therefrom.”)

Though CREW is the first group to bring a lawsuit against President Trump, it may soon have company. According to The New York Times, Anthony Romero, the executive director of the American Civil Liberties Union, has said that his organization is looking for a plaintiff to sue Trump for violating the Emoluments Clause, although with a different claim to legal standing: While CREW intends to demonstrate that the group itself has suffered financial harm because the need to focus on the Emoluments Clause has diverted its resources away from other worthy causes, the ACLU is hoping to find a hotel or bed-and-breakfast owner that can prove he or she has lost business to one of Trump’s hotels during his presidency.

CREW’s lawsuit is just the latest development in what promises to be a continuing saga regarding Trump’s many conflicts of interest that began almost as soon as he won the presidency. Along with his unprecedented wealth, Trump brings to the office unique and gravely concerning entanglements that, whether he recognizes their effects or not, threaten to undermine his decision-making as president. The plan Trump and Dillon announced on January 11 would do very little to resolve the conflicts: It places control of his assets in the hands of his two adult sons and a longtime associate of their father’s with what so far amounts to a pinky-swear assurance that, despite their proximity to the president, they will not discuss any aspect of the business with him. On top of that, the plan supposedly would terminate several of the Trump Organization’s pending deals and place a ban on new foreign deals, two conditions undermined by the announcement that the organization would be moving forward with expanding its golf course in Aberdeen, Scotland.

Even before his most recent plan was laid out, Trump has attempted to deflect criticism by repeatedly asserting that the law barring executive-branch officials from maintaining financial holdings or business ties that overlap with their duties does not apply to the president or vice president. In this, he is correct; the law, passed in 1989, exempts the two chief executives from conflict-of-interest rules on the understanding that their purview is so broad that it would be impossible for them to completely disentangle themselves.

Regardless, legality does not imply propriety. Unless Trump acts to put actual distance between himself and his business ventures, these questions are likely to continue throughout his time in the Oval Office. On top of the aforementioned legal actions, the director of the Office of Government Ethics, Walter Shaub, has declared Trump’s efforts insufficient, remarking, “I don’t think divestiture is too high of a price to pay to be the president of the United States,” and a number of Senate Democrats have introduced legislation that would force Trump to divest or face impeachment. Below is an attempt to catalogue the more clear-cut examples of conflicts of interest that have emerged so far. The most recent entries appear at the top:

• That Meeting in Brussels
• That Tower in Toronto
• That Caribbean Villa
• Those Condos for Sale
• Those Reelection-Campaign Funds
• That Second Hotel in Washington, D.C.
• That Property in Azerbaijan
• That Trump Tower Penthouse
• That Resort in the Dominican Republic
• That Chinese Trademark
• That Meeting at Mar-a-Lago
• That Defense Department Trump Tower Rental
• That Red Cross Ball
• That D.C. Labor Dispute
• That Estate in Palm Beach
• Those Expansion Plans
• That Hotel in Vancouver
• That Reality-Television Show
• That Pipeline
• Those HUD Grants
• That Golf Course in Aberdeen
• That Other Billionaire New York Real-Estate Developer
• Those Indonesian Politicians
• That Emirati Businessman
• That Virginia Vineyard
• That Las Vegas Labor Dispute
• That Kuwaiti Event
• Those Certificates of Divestiture
• That Carrier Deal
• That Blind-Trust Issue
• Those Fannie and Freddie Investments
• That Phone Call With Taiwan
• That Deutsche Bank Debt
• That Secret Service Detail
• That Property in Georgia (the Country)
• That Phone Call With Erdogan
• That Hotel in Washington, D.C.
• That Argentinian Office Building
• Those Companies in Saudi Arabia
• That British Wind Farm
• Those Indian Business Partners
• That Envoy From the Philippines  

That Meeting in Brussels

On the European leg of his first foreign trip, President Donald Trump elucidated the relationship between his business and his presidency, although in a way that only further complicates the already-difficult task of understanding how his financial interests might impact his decisions in office. According to the Belgian newspaper Le Soir, in a meeting with Belgian Prime Minister Charles Michel, Trump discussed his skepticism toward the European Union through the lens of his experiences as a real-estate mogul. Per a translation in The Guardian, an anonymous source told the paper, “Every time we talk about a country, [Trump] remembered the things he had done. Scotland? He said he opened a club. Ireland? He said it took him two and a half years to get a license and that did not give him a very good image of the European Union.”

The meeting isn’t the first time the president has discussed the Trump Organization—which he still owns, but no longer operates—with other world leaders: In a phone call with Turkish President Recep Erdogan, one of the first Trump made after his election, he relayed praise from a business partner on the company’s towers in Istanbul; on the line with Mauricio Macri, the president of Argentina, Trump mentioned a long-stalled project in Buenos Aires (which suspiciously began moving forward after the exchange).

His conversation with Michel, though, is different, for one key reason: Trump has no hotels in Belgium—and, unless his company is willing to violate a pledge meant to mitigate conflicts of interest, it won’t be pursuing deals there until Trump is out of office. That doesn’t definitively preclude the possibility that he meant to boost his businesses by venting to Michel, but it certainly reduces its likelihood.

What the conversation does do, though, is demonstrate how inextricable Trump’s businesses are from his behavior as president. It’s not just that Trump has ample knowledge of his holdings to act in his own financial interests and little reason to fear that a Republican-controlled Congress might try to stop him. It’s also that Trump seems to approach every issue with a mind toward how it’s impacted his company in the past—and how it will impact his company in the future. As the aforementioned anonymous source in Le Soir described it, “One feels that he wants a system where everything can be realized very quickly and without formality”—a broad pro-business stance that would just so happen to make it significantly easier for the Trump Organization to operate in Europe as well.

As long as the president retains ownership of his company, it’s possible to impute the Trump Organization’s footprint in a variety of the administration’s policy stances. For instance, the notion that Trump favors leaders of countries where he has property is arguably the least concerning explanation for his affinity for noted authoritarians like Erdogan and Filipino President Rodrigo Duterte. On economic issues as well, the president has supported numerous policies over the years that would mainly help wealthy businesspeople in general and the Trump Organization in particular; for example, he’s in favor of weakening the Foreign Corrupt Practices Act, which would make it significantly easier for his company to move forward on deals in countries like Azerbaijan where bribery of public officials is more common than it is in the U.S. These questions of where genuine policy positions end and self-interest begins will continue—unless, of course, Trump does what ethics experts have urged him to do and actually sells his business.

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That Tower in Toronto

President Donald Trump’s properties around the world bring with them business partners from around the world. Several of these ties have already come under scrutiny: A Trump-branded tower in Baku, Azerbaijan, put him in business with allegedly corrupt officials who are themselves connected with the Iranian Revolutionary Guard, for example, while two properties in Indonesia link him to officials implicated in a bribery scandal and a racially-motivated attempt to oust a sitting governor.

Now, The Wall Street Journal has reported an additional source of a conflict of interest along these lines: Trump International Tower and Hotel in Toronto. According to the Journal, one of Trump’s partners in the project, Alexander Shnaider, received millions of dollars from the Russian bank Vnesheconombank, or VEB, shortly before investing in the project. Shnaider, who is Russian American and was the main developer on the Trump-branded property, sold his own company’s share in a Ukrainian steelmaker to VEB for $850 million in 2010. Shnaider’s lawyer said in April that $15 million from the sale went into the Toronto tower, although he walked back his statement the next day, writing that he is “not able to confirm that any funds” from the sale went into the project.

VEB is owned by the Russian government; according to its website, its mandate is “to enhance [the] competitiveness of the Russian economy, diversify it, and stimulate investment activity,” and the bank’s supervisory board is chaired by the country’s prime minister, Dmitry Medvedev. At the time of the deal with Shnaider’s company, though, its chairman was the current Russian President Vladimir Putin, who, according to a Russian government official and multiple experts, would have had to sign off on such an exchange.

As with many of Trump’s business holdings, the property represents a conflict of interest because it brings him revenue that’s made possible by money from a bank owned and operated by a foreign government. Though Trump doesn’t own the tower—he merely licenses his name to Shnaider, who owns the building through his company Talon International Development Inc.—the Trump Organization nevertheless profits off of the building and, by extension, from VEB’s deal with Shnaider. This potentially gives the Russian government leverage that it could use should it want to influence Trump’s policies. That means that the Trump Organization’s continued involvement with the tower may represent a violation of the Constitution’s Emoluments Clause, which precludes elected officials from “accept[ing] of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.”

The Journal’s report highlights the inadequacy of the financial disclosures the president has so far offered. Last week, Trump insisted that his company does not have business ties to Russian “persons or entities.” As my colleague David Graham wrote, the letter from Trump’s lawyers that Trump proffered on the subject last week “doesn’t define several key terms,” leaving open the possibility that one of Trump’s projects benefited from Russian funding through a pass-through corporation or another intermediary. VEB’s role in the financing of the Trump-branded property in Toronto is a perfect example: Because money from VEB went toward enriching Trump (through Shnaider), one can reasonably argue that Trump didn’t do enough to eliminate the conflict of interest that the hotel creates for him in office.

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That Caribbean Villa

President Donald Trump has another property on the market: Le Château des Palmiers, his estate on the Caribbean island of St. Maarten. The president’s company bought the 11-bedroom beachfront compound in 2013, and the Trump Organization has been using it as a rental property ever since. It’s listed at $6,000 per night on TripAdvisor; according to specialty sites such as Luxury Retreats, which lists the price as between $6,000 and $20,000, and Mansion Global, which places the upper limit at $28,000, the price increases substantially during the winter, when the Caribbean offers an escape from cold weather. According to the disclosure forms Trump submitted to the Federal Election Commission (which remain the only public documentation of his finances), he derived between $100,001 and $1 million from the property in the year leading up to May 2016.

The asking price for Le Château des Palmiers remains unknown. The Trump Organization is selling the property through the real-estate agency and auction house Sotheby’s; according to the listing for the complex, the price is available only upon request. However, there are some clues available. On his FEC disclosure forms, Trump lists the property as worth between $5 million and $25 million, which does correspond with the $19.7 million he paid for it four years ago. According to Mansion Global, 7th Heaven, a real-estate brokerage in St. Maarten, has identified the asking price as $28 million, although 7th Heaven’s current page for the property lists the price as “PoA,” or Price on Application.

Though Trump no longer runs the Trump Organization, he still owns the company and, by extension, the property, meaning that he will profit from its sale. That means that Le Château des Palmiers offers yet another avenue by which somebody could attempt to influence the president’s decisions by putting a large sum of money in his pocket. It would even be possible for somebody to make an offer well above the currently unknown asking price to curry favor with him (and, possibly, through the artful use of a shell company, hide their identity).

As NPR noted, the Trump Organization’s decision to sell Le Château des Palmiers is “the first known major divestiture of a Trump property since he became president.” As such, it demonstrates the insufficiency of the steps the president has taken to eliminate his conflicts of interest. Trump has put the leadership of his company in the hands of his adult sons and a longtime Trump Organization executive with relatively few—and, based on Donald Jr. and Eric’s frequent presence at administration events and Eric’s statement that he will share some business-related data with his father, relatively permeable—barriers blinding him from knowledge of his financial interests.

Had Trump taken the measures suggested repeatedly by ethics experts on both sides of the political aisle, he would by now have put his assets in what’s called a blind trust, which would entail turning over his empire to a third party with whom he will have no contact, who would sell off the properties and reinvest the resulting money in other assets without providing the president any information about the sales or the purchases. Instead, Trump has set up a system under which, even if he does proceed to sell off his business, one property at a time, he will simply create new conflicts of interest as he takes payments from those who are purchasing the Trump Organization’s real estate.

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Those Condos for Sale

President Donald Trump’s finances are infamously opaque. Since he has not followed the long-standing presidential custom of releasing his tax returns to the public, the only publicly available records of where he derives his income are his two filings with the Federal Elections Commission. Even those are difficult to parse: Much of his business empire comprises limited-liability companies (or LLCs), which face very few disclosure requirements, and shell and pass-through corporations, which can obscure ownership and make money trails harder to follow.

Much the same can be said for whoever has been buying up Trump Organization condominiums. A lengthy investigation published in USA Today found that, “since launching his White House bid, Trump’s companies have sold at least 58 units nationwide”—out of a total of more than 400 currently on the market—”for about $90 million. Almost half of those sold to LLCs.” One of those LLCs, a financial firm created shortly before the Republican National Convention named Milan Investment Limited, spent $3.1 million to buy 11 condominiums in the building the president co-owns in Las Vegas.

Normally, such a story would then identify who is behind the purchase and whether they may have some ulterior motive in buying something from the president. In this case, though, repeated efforts by the USA Today to ascertain who exactly is behind Milan apparently came up empty. The company’s headquarters in a strip mall the outskirts of Las Vegas are registered to two individuals named Jun Xu and Qi Huang; however, the reporters were unable to reach Xu and Huang through either their listed addresses and phone numbers or through business associates. A third individual associated with Milan, Chen Huang, also apparently could not be reached for comment, nor did the Trump Organization respond to inquiries about the identities of the buyers. The newspaper’s attempts to find the buyers of other Trump Organization condos met with mixed results: Though reporters were able to track down the real people behind some of the purchases, including a couple who said they bought the property because they’re fans of Trump’s, others proved just as elusive as whoever is behind Milan.

As the USA Today notes, the story highlights one of the major problems underlying Trump’s decision to retain his businesses while in office. There is no law requiring a shell company like Milan to disclose the identities of its owner(s) or the source of its money while purchasing real estate. The Trump Organization still owns hundreds of condominiums, the sales of which will directly profit it and, by extension, the president; this offers plenty of chances for any individual or corporation to purchase a unit to attempt to curry favor with Trump without having to disclose their own identity to the public.

So far, the Republican-controlled Congress has shown little interest in investigating the constitutionality of Trump’s decision to hold onto his businesses. That means that the only real disincentive for those attempting to influence the president by patronizing his businesses is the bad publicity that might ensue. But Milan Investment Limited’s secretive investment in Trump’s properties shows how easy it would be for an individual or a corporation to stay anonymous and avoid that scrutiny.

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Those Reelection-Campaign Funds

For President Donald Trump, it pays to be in constant campaign mode.

Metaphorically, at least, this isn’t unusual; the idea of the “permanent campaign,” a reference to how politicians consider their reelection chances from almost the moment they take office, has been around for decades. Such is the case for Trump, who filed a letter with the Federal Election Commission establishing his eligibility to run for a second term in 2020 just hours after taking the oath of office. Though the letter declares only that he can run, not necessarily that he will run, it gives broad coverage for the president to begin fundraising and holding campaign events, and to do so far earlier in his first term than have previous presidents.

Since doing so, Trump has held several events that, while officially presented as part of his “thank-you tour,” have seemed an awful lot like his campaign rallies. Meanwhile, between merchandise sales and an already-active fundraising effort, he has raised more than $7.1 million, and the Republican National Committee has raised an additional $23 million. That’s not necessarily noteworthy by itself; by this time, President Obama and the Democratic National Committee had raised $15 million. (Obama had not yet filed for eligibility in 2012 three months into his first term, although he had held events to promote his economic-stimulus package.) What does make Trump unusual is that he has already spent $6.3 million of his reelection campaign funds—and, according to reports he recently filed with the FEC, he is paying some of that money to his own personal businesses—for instance, renting space at his hotels or golfing on his courses—thereby literally profiting off of his permanent campaign.

This practice is nothing new for Trump. As early as 2000, he was speculating that he “could be the first presidential candidate to run and make money on it” by patronizing his own businesses and running the campaign out of one of his properties. During his 2016 bid, he did exactly that, establishing his political headquarters in Trump Tower (and quintupling the rent as soon as he became the Republican nominee and began drawing funds from the party rather than his personal war chest). Shortly before his victory, The Wall Street Journal reported that Trump’s campaign had paid out the unprecedented sum of more than $14 million to his family and companies for such services as flights on his personal airplanes, rent at Trump Tower, and meals and hotel rooms at other Trump buildings.

Similarly, since taking office, Trump has profited off of the federal government’s newfound need to patronize his properties. Both the Secret Service and Department of Defense are renting out space in Trump Tower, for example, with the former believed to be paying at least $3 million per year to do so. This has led to rumblings that Trump may be violating the Constitution’s Domestic Emoluments Clause, which holds that the president “shall not receive ... any other Emolument from the United States, or any of them,” beyond his official salary.

The amount Trump’s reelection campaign has spent at his businesses is comparatively small: According to The Wall Street Journal, more than 6 percent of the $6.3 million it’s spent so far, or almost $500,000, went to Trump’s hotels, golf courses, and restaurants. But that’s a higher rate than when his campaign money was going to his own businesses for the 2016 campaign ($14 million out of a total of $322 million, or about 4.3 percent). At his current rate, if he spends a similar amount over the next election cycle—and given that he’s already started spending, he could easily far outdo himself—he would be directing nearly $20 million to his own businesses.

On top of the arguable impropriety of personally profiting off of his donors’ and his party’s largesse, the situation presents perverse incentives for Trump. Already, elected officials, up to and including the president, to an extent base their behavior in office on what they believe will play well with voters rather than (or, in the best-case scenario, on top of) what is best for America. This is certainly true of Trump, whose every decision seems to prompt discussion of how it plays into the tension between his nationalist base and traditional Republican voters.

The personal financial benefits of campaigning mean that Trump has a little more motivation to delve into his reelection efforts than most politicians in his position. Because he is personally profiting, he has another reason to aim his politics toward his base so that they will continue donating to him and buying his merchandise in the downtime between election years. Moreover, rather than stockpile for 2020, he has an incentive to keep up the campaign rallies—and keep charging for them, as he did in 2016—so that he can continue funneling money from his donors and voters into his personal businesses.

Moreover, that the president is redirecting donors’ money into his own businesses only further highlights the inadequacy of the trust arrangement he has set up to supposedly prevent him from conflicts of interest. Trump and his lawyers have claimed that, by resigning from his positions within the Trump Organization and handing over control to his two adult sons and a long-time business associate, the president has distanced himself from his businesses enough that he will no longer be tempted to act in his own financial interests. Ethics experts (and common sense) immediately disagreed: Unless the president actually sells his businesses, many have said, and has the funds reinvested without his knowledge, he still knows more than enough about his sources of profit to put his own personal gain above that of the country. The almost $500,000 he’s channeled into the Trump Organization via his reelection campaign demonstrates this: Trump doesn’t need to be in charge of his businesses to know how to direct money their way; all he needs to know is where they are.

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That Second Hotel in Washington, D.C.

There may soon be more than one Trump Hotel in Washington D.C. According to The Washington Post, the Trump Organization is considering purchasing another property in the nation’s capital to develop for its recently created Scion brand, which aims to offer a more affordable alternative to the upscale properties bearing the president’s name.

Unlike the Trump International Hotel—the upscale property that opened in September 2016 and has become something of a synecdoche for the president’s conflicts of interest—a new Scion hotel in D.C. would likely be a licensing deal. That means that, rather than the Trump Organization owning and operating the property itself, a third-party hotelier will be paying the president’s company for the right to use the Scion name; candidates identified by the Post include Foxhall Partners, which has two properties in the city and a third under development, and the Beacon Hotel in downtown D.C.

But even if it isn’t actually owned or operated by the Trump Organization, the new hotel would likely attract scrutiny along the same lines as the Trump International. A licensing agreement means that the president will not be profiting off of the building directly; payments from individuals or organizations booking rooms or events there will not go straight to the Trump Organization, but to the hotelier. But Trump will still have a financial stake in the hotel’s viability: The longer it stays in business and the more successful it is, the more (and longer) the licensee will pay to use the Scion name, and the more likely other owners may be to commit to similar partnerships with the fledgling brand. Trump has resigned from his positions with the Trump Organization and transferred control of his assets to his two adult sons and a long-time business partner. But he still owns the company, which means he will still profit from his properties. According to his son Eric, the president will even continue to receive quarterly reports on how his real-estate empire is faring financially. The pathway to Trump’s pocketbook may be slightly more complicated, but it still exists.

The proposed new property also engenders some of the same concerns as the broader round of expansions the Trump Organization announced in February. Developing a hotel, even in an existing building, means working with local government bureaucracies, such as zoning offices that sign off on structural changes or licensing boards. In any city, this would create  conflicting incentives for government officials who are suddenly being asked to rule on the president’s businesses. On the one hand, Washington, D.C., like many of the cities into which the Trump Organization is looking to expand, voted strongly against the president in the 2016 election; city officials, especially those elected by D.C.’s denizens, may feel a need to factor his unpopularity into their decisions with regard to the newly proposed hotel. On the other hand, the federal government still controls D.C.’s budget, placing additional pressure to green-light a proposal from the infamously mercurial commander-in-chief.

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That Property in Azerbaijan

When it comes to President Donald Trump’s constellation of foreign investments, properties, and companies, much of the attention so far has been on his business’s apparent violation of the Constitution’s Emoluments Clause, which bars officeholders from taking gifts from foreign leaders. According to numerous ethics experts, the clause takes an expansive definition of gifts, encompassing everything from a direct bribe to a foreign official’s approval of construction of a new Trump property. But some of the Trump Organization’s properties raise additional red flags due to the specific partners involved. That’s true in Indonesia, for example, where Trump’s affiliates have been involved in bribery scandals and radical Islamic nationalist parties, and Brazil, where the company pulled out of a branding agreement amid a criminal investigation of a local business partner.

Such is the case in Azerbaijan, which Transparency International ranks as among the most corrupt countries in the world, where the Trump International Hotel and Tower in Baku remains unopened. Though the long-stalled development has generated a steady drip of news and rumors for years, an overview by Adam Davidson in The New Yorker, entitled “Donald Trump’s Worst Deal,” puts into perspective just how convoluted the situation is, and just how much the project has led Trump and his company into a partnership with numerous corrupt officials in the Middle East. The details suggest that, on top of the continual underlying breach of the Emoluments Clause, the Trump Organization’s involvement may also violate the Foreign Corrupt Practices Act, or FCPA, which forbids American companies from participating, even unknowingly, in bribery schemes in other countries, with a penalty of up to $2 million and up to five years in jail.

According to Davidson, though the project originated in 2008 as a high-end apartment building, the Trump Organization has had a licensing deal with the building’s Azerbaijani developers to turn the property into a hotel since 2012. Though the Trump Organization presented the deal as a straightforward licensing agreement, it was in fact a much more involved agreement granting the company—specifically, Trump’s daughter Ivanka—extensive oversight over the project. Based on his FEC disclosures in 2016, which as of this moment remain the only official record of Trump’s finances, the president has so far made $2.8 million from the partnership.

But what makes this story unique among the dozens of ethical questions surrounding the president is the Trump Organization’s partners on the project. Ostensibly, the main developer behind the property is Anar Mammadov. He is in turn the son of Azerbaijan’s transportation minister Ziya Mammadov, who was once described in a leaked diplomatic cable as “notoriously corrupt even for Azerbaijan.” Also in on the deal, though not initially publicly disclosed, is Ziya’s brother Elton, who founded the company that currently owns the property in Baku while serving in Azerbaijan’s parliament. Then there’s the Mammadovs’ relationships with Iranian oligarchs. For years, the Mammadovs have been closely linked with the Darvishis, whose members include the head of a  construction firm implicated in the Iranian Revolutionary Guard’s possibly illicit financial operations and the former leader of a company that was sanctioned by the United States for its role in Iran’s attempts to develop an arsenal of nuclear missiles. As the Mammadovs’ influence within Azerbaijan has begun to weaken in recent years, they have  increased both their wealth and their mutually profitable relationship with the Darvishis, green-lighting a number of deals that will prove lucrative for both families.

Alan Garten, the chief legal officer for the Trump Organization, asserted to The New Yorker that, as the company has never worked directly with Ziya or Elton Mammadov, it has not engaged in any behavior that should trip ethical alarms. He has additionally claimed that the company did “extensive due diligence” in making the deal, which did not raise “any red flags,” although the actual employees who carried out the process are no longer with the company.

Still, merely by partnering with the Mammadov family, the Trump Organization may have violated the FCPA. The law explicitly covers cases in which an American company claims not to have known it was working with corrupt officials; jurisprudence since its 1977 passage has further expanded the law’s definition to include “conscious avoidance,” or active efforts by an American company to not learn of a foreign partner’s corruption. So though Garten claims that, since the Trump Organization did not have enough control over the project and has not itself engaged in bribery, its hands are essentially clean, experts on the law say that the Trump Organization may be legally liable if its foreign partners engaged in corrupt practices.

Adding to all this is the fact that Trump is on the record as opposing the FCPA in May 2012, right when it would have become relevant to his company’s engagement in Azerbaijan. Trump called the law “absolutely horrible” and argued that, since other countries do not have the same provision, American corporations are at a major disadvantage in which bribery is the norm. Trump’s appointee to the Securities and Exchange Commission (which enforces the statute), Jay Clayton, similarly considers the FCPA an obstacle to U.S. companies seeking to expand abroad. A dissenting voice on the topic is Attorney General Jeff Sessions, who stated in his confirmation hearings that he intends to continue enforcing the statute. Which of these voices will end up winning out on the topic remains an open question.

This, then, is the situation in which the Trump Organization—and, by extension, the president, who has stepped down from his position within the business but who retains ownership—finds itself in Azerbaijan: The company’s direct partner on Trump Tower Baku is the scion of a wealthy and notoriously corrupt family that appears to have only stepped up its self-dealing as its political power wanes. That family is engaged in what appears to be a relationship of mutual graft with Iranian oligarchs with deep connections to their country’s Revolutionary Guard, the ideological militia widely suspected by the international community of gross corruption and sponsoring terror at home and abroad.

These families can be added to the ever-growing list of international partners whose relationships with the Trump Organization could create conflicts of interest for the president. The Mammadovs’ arrangement with Trump’s company may not only violate the Emoluments Clause but could also feasibly put the president and his family in legal trouble should the SEC choose to actively pursue enforcement of the FCPA in Azerbaijan. And the Darvishis could in turn use their relationship to influence the Mammadovs, which could have significant implications should Trump attempt, as he has said he will, to take hard-line stances that could affect the Iranian Revolutionary Guard’s 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.

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That Trump Tower Penthouse

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.

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.

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.

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That Resort in the Dominican Republic

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.

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 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.

The Cap Cana story is yet another conflict of interest that only became public because of reporting from local media—and because of the nonchalance with which the Trump family handles the relationship between their business and the presidency. The first outlet to report on Eric’s trip was the Dominican newspaper Diario Libre, shortly after Cap Cana posted a picture of the Hazourys with Eric on its website. This follows stories like the president’s phone call with the president of Argentina and his company’s plans to expand into Taiwan, both of which were similarly broken by local newspapers before getting picked up by American press outlets. Further, like the president’s post-election meeting with business partners from India and Eric’s trip to Uruguay, the Trump family’s propensity for photo ops played a role: Even amid intensifying scrutiny of the Trump Organization’s actions, Eric seems unworried about having not only taken the trip but also taken pictures with his business partners.

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.

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That Chinese Trademark

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.

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.

Additional context, though, complicates this picture. The case, it turns out, was largely resolved in November 2016, before there was any indication that the president would waffle on the One China Policy by calling the president of Taiwan, and was the culmination of more than a decade of litigation that largely predates Trump’s involvement in politics. Conflicts of this kind over trademarks are fairly common in China, and, though resolving such cases often costs companies significant time and money, the Trump Organization’s victory is one of several that have gone in favor of American corporations in recent years. None of this rules out the possibility of a quid-pro-quo arrangement, but in sum it suggests that there is more to the case than what Feinstein alleges.

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.

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That Meeting at Mar-a-Lago

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.

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.

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.

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.

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.

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.

One patron of the club, Richard DeAgazio, demonstrated just how much of a breakdown the situation represents. DeAgazio, who, according to a photo he posted on Facebook, joined the club in December after Trump’s election, snapped several pictures of the president and prime minister’s conversation, which helped corroborate a CNN report on the public nature of the ad-hoc meeting and details such as the use of cellphone flashlights to illuminate documents; he also took pictures with Trump’s chief strategist Steve Bannon and the president’s “body man,” whose job is in part to carry the “nuclear football” containing missile-launch codes (and who was initially identified by name in the photo’s caption). As if to reinforce impression that Mar-a-Lago members gain unprecedented access to the the president, even in the middle of a crisis situation, another patron was able to film Trump giving a toast at a wedding shortly after his press conference with Abe.

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.

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.

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That Defense Department Trump Tower Rental

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..

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.

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.

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.

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That Red Cross Ball

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.

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That D.C. Labor Dispute

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.

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That Estate in Palm Beach

To many of President Donald Trump’s critics, his decision to turn Mar-a-Lago, his Florida estate, into a “Southern White House” epitomizes the way he’s mixing his business interests with his duties as president. With each visit to the property, he boosts the resort’s visibility and may very well prompt more people to enroll as members in attempts to get a glimpse of the commander-in-chief. That the club doubled its initiation fees in January, from $100,000 to $200,000, only adds to the impression that Trump—or, at least his namesake company—is banking on his presidency as a means of boosting revenues. And without a publicly available guest list and no word on what security protocols are in place, the possibility that somebody could be using a club membership to gain access to the president has led Democratic members of Congress to draft a bill specifically to mandate better disclosure of the goings-on at the venue.

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.

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Those Expansion Plans

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.

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That Hotel in Vancouver

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.

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That Reality-Television Show

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.

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That Pipeline

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.

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Those HUD Grants

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.

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That Golf Course in Aberdeen

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.

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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.

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Those Indonesian Politicians

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.

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That Emirati Businessman

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.

Since footage of Trump’s shout-out emerged in early January, Sajwani has continued to feature in coverage of the president’s business entanglements. At the January press conference where Trump and his lawyer, Sheri Dillon, laid out the president’s plan to ostensibly avoid conflicts of interest, Trump said that after the election, Sajwani offered him a $2 billion deal, which Trump turned down. Rather than acknowledge that being offered billions of dollars from a foreign businessman constitutes a conflict of interest, Trump presented his decision not to accept as an example of his magnanimity, saying, “I didn’t have to turn it down, because as you know, I have a no-conflict situation because I’m president. It’s a nice thing to have, but I don’t want to take advantage of something.” Later, Sajwani attended Trump’s inauguration, although it’s unclear if he interacted with the president while there.

Then, on Tuesday, Sajwani posted a picture of himself eating with Donald Trump Jr. in Dubai on Instagram with a caption reading, “It was great having my dear friend and business partner Donald Trump Jr. over for lunch. Discussing new ideas and innovation always make [sic] our meetings even more interesting.”

Donald Jr.’s meeting with Sajwani prompts concerns about the president’s conflicts of interest, for two main reasons. First, the meeting offers a reminder of the insufficiency of the steps Trump has taken to distance himself from his businesses. Though Trump and Dillon claimed that their plan resolved questions about conflicts of interest, ethics experts disagree: Because Trump still knows what his assets are and the identities of those with whom he does business, they say, Trump still knows more than enough to favor his company. Moreover, in an actual blind trust, Trump would have turned his assets over to a trustee with whom he would have no contact. Instead, he turned it over to a long-time executive within the Trump Organization and his sons, who he has long counted as among his closest advisers and with whom he has remained in contact during his presidency so far. Donald Jr.’s meeting with Sajwani is a reminder of these inadequacies, especially because Sajwani posted the picture to Instagram, thus increasing the lunch’s visibility and, along with it, the likelihood that the president will know about the ongoing interactions between his company and Sajwani’s (that is, if Donald Jr. hasn’t already made his father aware of them).

Second, Sajwani’s caption further undermines one of the few parts of the arrangement that actually would have meaningfully reduced the president’s conflicts of interest. In January, Dillon said that the Trump Organization would be canceling all of its pending deals and would stop pursuing foreign deals during Trump’s presidency. Since then, numerous developments have called those intentions into question: Projects appear to be moving forward in both Scotland and the Dominican Republic, with the Trump Organization offering narrow, legalistic explanations as to why the progress didn’t violate the terms of the trust. Though a spokeswoman for the Trump Organization has said that Donald Jr. was not seeking new deals while in Dubai, the previous stories, coupled with Sajwani’s Instagram caption, undermine that account.

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That Virginia Vineyard

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.

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That Las Vegas Labor Dispute

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.

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That Kuwaiti Event

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.

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Those Certificates of Divestiture

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.

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That Carrier Deal

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.

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That Blind-Trust Issue

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 as long as he and the trustees—again, his two sons and his long-time business partner—agree that it is “appropriate,” and will not have to disclose when he does so. This goes directly against the purpose of a blind trust, which in this case would be to distance Trump from his sources of income in an attempt to get rid of his incentive—or even ability—to consciously act in his own financial interest. So far, the plan unveiled in January appears to be as inadequate as many ethics experts had feared.

Finally, removing himself from day-to-day operations will do little to change the fact that Trump will retain substantive knowledge of the illiquid assets involved in his business, such as the numerous buildings and other products that bear his name, especially if he remains in frequent contact with his children. Even assuming that Trump does separate himself from any consideration of his holdings, his children will still likely be major players in the family’s organization, which will still bear at least the Trump name—arguably one of their most valuable properties, as much of the family’s wealth derives from licensing the name to third-party companies. Given the family’s oft-touted brand-consciousness (Ivanka, for example, briefly appeared to be distancing herself from the campaign, and several properties considered rebranding under the name “Scion” when it appeared Trump would lose), the situation epitomizes the way Trump’s, and his family’s, business interests may very well prove inextricable from his actions as president.

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Those Fannie and Freddie Investments

After railing against elites during the campaign, Trump has so far stocked his prospective cabinet with an array of billionaires whose policy positions seem likely to significantly benefit those who are also doing very well. Trump’s putative treasury secretary, Steven Mnuchin, is no exception: His resume includes stints as a banker at Goldman Sachs, a Hollywood producer, and the operator of a bank that has been described as a “foreclosure machine” and once foreclosed on a homeowner over a 27-cent discrepancy.

One of Mnuchin’s apparent beliefs is that the government should cede control of the mortgage guarantors Fannie Mae and Freddie Mac, which the government acquired during the 2008 financial crisis. The two financial institutions’ stocks rose by more than 40 percent after Mnuchin stated that he believes the Trump administration “will get it done reasonably fast.”

Doing so would be broadly compatible with Trump’s general antipathy toward regulation of the banking industry. However, The Wall Street Journal identified an additional wrinkle to the story: When Fannie Mae and Freddie Mac’s stocks rose, one major beneficiary was John Paulson, an adviser to the Trump campaign and a business partner of Mnuchin’s. Paulson’s hedge funds include significant investments in both Fannie and Freddie. Trump himself has invested between $3 million and $5 million across three of Paulson’s funds, according to his filings with the Federal Election Commission (which remain the only available window into the president’s financial holdings). In other words, as Fannie Mae and Freddie Mac’s stock prices increase—and they have so far more than doubled since the election on the expectation that the incoming Trump administration will be more lenient toward the financial sector than Obama—Trump’s portfolio benefits.

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That Phone Call With Taiwan

When news first emerged that the president spoke on the phone with Taiwanese President Tsai Ing-wen on December 2, the immediate reaction was uproar over his apparently impetuous breach of decades of U.S. protocol toward China and Taiwan. As my colleague David Graham explained, since 1979, the United States has participated in the “artful diplomatic fiction” of officially recognizing the mainland People’s Republic of China as the only legitimate Chinese government while maintaining loose, unofficial recognition of—and significant economic and military ties to—Taiwan. That Trump would speak to the president of Taiwan, especially before doing the same with Xi Jinping, the president of the PRC, flies in the face of a diplomatic tradition that has undergirded almost 40 years of U.S.-China relations.

Amid the days of dissembling that followed the phone call, an additional worrisome detail came out: At the time, the Trump Organization was apparently exploring expansion into Taiwan. Soon afterwards, the Trump Organization denied that it planned to do so; however, even before the controversy arose, the mayor of Taoyuan, Taiwan, the municipality in which the Trump Organization allegedly wants to build, described in a televised interview a meeting with a representative of the Trump Organization in September to discuss prospective real-estate projects, and at least one Trump employee was found to have posted on Facebook that she was in Taiwan at the time on a business trip. Based on the January 11 announcement that the Trump Organization will be suspending its development plans and will not pursue foreign deals in office, it would appear that any movement on development in Taiwan is no longer on the table.

The phone call, and the many statements that have followed, are of particular interest because of the extent to which they dovetail with some of the biggest concerns about Trump’s approach toward governance. In the ensuing 48 hours, Republican officials offered several, sometimes entirely contradictory, explanations of what initially appeared to be an impulsive move by Trump; depending on who was speaking, the phone call was actually initiated by Ing-wen (which, if technically true, ignores that it was Trump’s staff who arranged the conversation), was just “a courtesy,” or manifested a policy shift weeks in the making—although, regardless, it was made without first consulting the White House or State Department. The defense of the move, and the questions it creates regarding conflicts of interest, have largely hinged on the belief that, since voters apparently don’t mind, the reaction was overblown.

On this issue, though, whether or not voters care is immaterial to the central question. The president of the United States breached decades of international protocol created to preserve a precarious balance of power. That decision raised not only the possibility that Trump was blundering into a potential international incident but also that he may have done so in part out of consideration for his business prospects.

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That Deutsche Bank Debt

Though he often brags about leveraging corporate-finance law to become “The King of Debt,” Trump’s numerous bankruptcy filings have left most large Wall Street banks reticent to lend to him, according to The Wall Street Journal. Among the few exceptions is Deutsche Bank, which “has led or participated in loans of at least $2.5 billion” to the president since 1996, with at least another $1 billion in loan commitments to Trump-affiliated companies; more than $300 million of those loans have come since 2012.

The president’s indebtedness does not itself pose a conflict of interest, but Deutsche Bank’s ongoing legal troubles very well might. The Justice Department is currently negotiating with Deutsche Bank regarding a preliminary settlement of $14 billion to resolve probes into allegedly misleading predatory lending practices in the leadup to the 2008 financial crisis; while it is believed that Deutsche Bank will push back against the sum, there has been no public news regarding negotiations since the initial figure was reported in September. Trump will soon be naming many of the officials with jurisdiction over this and other deals, prompting several House Democrats to send a letter to federal financial agencies calling for close scrutiny of how Trump may seek to influence the settlement through his appointments—although doing so would be just as in keeping with his general stance toward financial regulation as with active protection of his pocketbook. Other Democrats have called for the proactive appointment of independent prosecutors to avoid any appearance of conflict if the case is not resolved before Trump takes office.

Fears that Trump may unduly consider his indebtedness to Deutsche Bank in deciding his administration’s policy toward the financial sector go beyond general anxiety about deregulation. Deutsche Bank is undergoing a period of struggle that may have it on the verge of failure already. Its stock valuation has dropped by more than half since July 2015; in January, it posted its first full-year loss since 2008; and one of its many tranches of bonds—one specifically designed to be a high-risk, high-reward safety valve in times of trouble—has recently begun to crash. In June, the International Monetary Fund called Deutsche Bank “the most important net contributor to systemic risks” among globally important financial institutions. If the bank were to fail, it could have major consequences for not only Trump’s businesses, which would lose their sole remaining lender, but for the global economy as well.

Arguably, the $14 billion fine the Justice Department is seeking to impose has exacerbated rather than alleviated these struggles. Based the company’s market capitalization—the number of shares multiplied by their price— of roughly $16 billion, the sum would leave Deutsche Bank critically low in liquid assets with which to absorb future troubles. although the institution’s own self-valuation of $68 billion argues otherwise. But given the complexity and potential volatility of the situation, it is important for any decision to be free from outside influence, something Trump’s outstanding debt threatens to jeopardize.

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That Secret Service Detail

During the election, the Trump campaign put no small portion of its funds toward paying for use of the candidate’s own properties; perhaps the most notable of these expenditures was the nearly $170,000 the campaign spent in July on rent for its headquarters in Trump Tower. These expenses raised the possibility that, as Trump predicted in 2000, he “could be the first presidential candidate to run and make money on it.” Now that he will be president, he may be able to profit off of the Secret Service by virtue of the fact that he and his family will live in Trump Tower and fly in his private jets—which requires the agents tasked with guarding them to pay him rent and airfare.

The first way Trump could monetize his own protective detail is by having family members travel in his two planes and three helicopters. This is not so much speculative as foregone: Over the course of the campaign, the Secret Service, which traditionally pays for its own travel during elections, spent $2.74 million to fly on a plane owned by one of Trump’s own companies. While in office, Trump will fly exclusively on Air Force One, while Mike Pence will be riding Air Force Two. However, their families may still be flying on Trump’s private planes—along with their protective details, which would effectively direct even more money to Trump. (Previous first families have flown with a detail, whose legal purview covers “the immediate family members,” but none have done so on planes they themselves own.)

A bigger question regards Trump Tower in New York, where the president appears likely to spend a significant amount of time. For the past few decades, it has been common practice for the Secret Service to provide protection for the president and vice president’s non-White House residences, which sometimes entails paying rent to the officeholder. (Joe Biden, for example, received $2,200 per month when the agency rented a cottage he owned near his home in Delaware.)

But Trump Tower is a unique case, as it’s not in Delaware but the middle of Manhattan. Already, pedestrians and tourists are chafing at the increased security around the building, Trump’s frequent use of which has required closing a block of 56th Street and multiple lanes of Fifth Avenue; with multiple outlets reporting that Trump’s wife Melania and 10-year-old son Barron are expected to stay at Trump Tower for at least part of his term, it appears that the consternation will continue, with an enormous price tag for taxpayers: According to the New York Post, it could cost as much as $3 million a year to rent out two of the building’s vacant floors, meaning that Trump will be making money off of his own security detail. Meanwhile, Reuters has reported that the city of New York is calling for federal funds to reimburse the costs of keeping up a security detail around Trump Tower.

This system creates an unusual set of conflicting interests for Trump regarding his own travel and residences. Though presidents as disparate as Dwight Eisenhower and Barack Obama have evoked partisan ire over time spent away from the White House, whether on the golf course or on vacation in Hawaii, only Donald Trump will actually have gained from his and his family’s travels. And if, while in office, Trump visits properties he owns other than Trump Tower—his buildings in other U.S. cities like Chicago and Miami, for example, or his golf course and resort in Scotland, or one of the many international hotels bearing his name—he stands to gain from the stays for which his security detail (and, by extension, taxpayers) may be paying. Moreover, the more his family members fly on his planes, whether they are running his business on his behalf or running interference with foreign leaders, the more the Secret Service will end up paying for seats alongside them.

In fact, there are already signs that the Trump Organization has no qualms about making money off of the New York tower’s new security arrangements in more ways than one. According to Politico, just five days after the election, a prominent New York real-estate firm invoked Trump Tower’s new secret-service detail as a selling point for a $2.1 million condominium, which it described as “The Best Value in the Most Secure Building in Manhattan.” Though the flier was issued by an outside agency, the president’s corporation still stands to benefit from increased traffic through processing and other service fees, making the advertisement a clear example of how Trump stands to benefit off of his new position.

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That Property in Georgia (the Country)

Trump’s election has had the effect of speeding up development on a number of his branded properties, even when the president appears not to be pulling any strings himself. As occurred with Trump Tower Buenos Aires, the completion of an embattled Trump-branded building in the former Soviet republic of Georgia is no longer on hold now that Trump has won. The project, which has been in the works in the seaside resort city of Batumi since 2010, was initially scheduled to break ground in 2013, but has been in stasis for several reasons, possibly including the 2013 electoral defeat of President Mikheil Saakashvili, a friend of Trump’s and a supporter of the deal.

According to a report in The Washington Post, the green-lighting of the Trump property in Batumi has not been linked to a specific conversation with Georgian leaders, and a U.S.-based partner on the project has suggested that it has moved forward without any nudging from the government. However, numerous public statements in the days since suggest that Trump’s election was a major factor, including an interview with a real-estate entrepreneur who said, “Cutting the ribbon on a new Trump Tower in Georgia will be a symbol of victory for all of the free world.”

That the property seems to be moving forward solely because Trump was elected suggests his various business interests around the world may play a role not only in his foreign policy but in how other countries seek to deal with the U.S. as well. America’s relationship with Georgia is largely shaped by concerns about Russian influence and potential aggression in the region, most recently manifested in Russia’s 2008 seizure of two regions of Georgia, South Ossetia and Abkhazia. With controversy already swirling over Trump’s admiration for Putin and Russia’s alleged role in the U.S. election, some in the foreign-policy community have expressed trepidation that Trump’s potential deferential attitude toward Russia would prove deleterious for the continued independence of former satellite nations like Georgia. So, if Georgia has an ulterior motive behind the approval of Trump’s property in Batumi, it would be to keep Russia at bay and maintain the status quo in the region.

According to Trump and his lawyer, as of January 11, the Trump Organization has suspended ongoing development projects and will no longer pursue deals in foreign countries. As the project in Batumi falls under both categories, the statement suggests that progress on the president’s property in the city is no longer moving forward. Still, it’s alarming that a country like Georgia may be giving Trump’s businesses favorable treatment (whether he asked for it or not) in an attempt to influence his foreign policy.

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That Phone Call With Erdogan

One of the worries regarding Trump’s many conflicts of interest is that they may influence policy towards countries whose relationships with the U.S. are currently strained. Such is the case with Turkey, whose president, Recep Erdogan, has been cracking down significantly on civil liberties and democratic institutions within the country after a failed coup last summer. Though Turkey has in the past been a vital U.S. ally as a bulwark against Islamic terror, Erdogan’s authoritarian turn and combative stance toward Europe have led to some reevaluation of that relationship.

Thus, it was troubling news that when Erdogan phoned Trump shortly after the election—it was one of the first calls Trump received after his victory—Trump used the opportunity to plug his business partners in Istanbul. According to the Huffington Post, while on the line with Erdogan, Trump relayed praise for the leader from Mehmet Ali Yalcindag, whose father-in-law, Aydin Dogan, owns the holding company that operates the Trump Towers in Istanbul. Dogan has previously drawn Erdogan’s ire by criticizing the leader; in recent years, however, Dogan’s companies, most notably CNN Turk, have shown support for Erdogan’s regime, including broadcasting his first message after the uprising in July.

Trump’s conversation with Erdogan is also worth noting because of a number of Trump’s previous statements regarding the Turkish president. Though Erdogan briefly called for Trump’s name to be removed from the Istanbul property due to his proposed ban on Muslim immigration, Erdogan dropped the demand when, after the overthrow attempt, Trump praised Erdogan for “turning it around” and essentially dismissed concerns over Erdogan’s crackdown on civil liberties by bringing up domestic problems. Michael Flynn, who was recently named Trump’s national security adviser, wrote an election-day op-ed in The Hill arguing against offering asylum to a Muslim cleric whom Erdogan has accused of orchestrating the uprising, which some have interpreted as a diplomatic overture. Erdogan has also bristled at post-election protests in the U.S. and the description of both himself and Trump as part of a “ring of autocrats.” That the two are now talking about their countries’ relationship as in the same conversation as Trump’s business interests further complicates Trump’s strangely effusive comments about Erdogan.

It’s worth noting that Trump himself considers his hotel in Istanbul a potential conflict of interest. In a December 2015 interview with Stephen Bannon, at the time the chairman of Breitbart News, Trump said as much, telling Bannon, “I have a little conflict of interest ‘cause I have a major, major building in Istanbul. It’s a tremendously successful job.” That he chose to discuss the towers with Erdogan, albeit obliquely, through his references to his business partners when he has already acknowledged the impropriety of doing so simply reinforces the perception that he may prove unable to separate his business from his official duties while in office.  

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That Hotel in Washington, D.C.

The White House is not the only new Trump property in Washington, D.C.; there’s also the new Trump International Hotel, which opened in October and is located just a few blocks away in what was formerly known as the Old Post Office Pavilion. Previously, the hotel played a role in the campaign as the site of the event at which Trump recanted (sort of) his belief that Barack Obama was not born in the United States. Now, the hotel is at the center of speculation as a symbol of how inextricable Trump’s presidential role may be from his personal interests.

First and foremost, since his election, ethics groups and critics of the president have repeatedly alleged that, simply by taking office, Trump has been in continual violation of the lease he holds on the Old Post Office, the government-owned building the Trump International Hotel inhabits. At issue is a clause in the lease stating 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.” As such, watchdog organizations such as Citizens for Responsibility and Ethics in Washington have repeatedly appealed to the Government Services Administration, the federal agency that administers the lease, to terminate the agreement with the Trump Organization.

On March 23, however, the GSA released a letter finding that Trump “is in full compliance” with the lease. According to Kevin Terry, the contract officer who oversaw the initial negotiations between the government and Trump, the president’s plan to turn over his businesses to his two adult sons and the long-time Trump Organization executive Alen Garten is sufficient to meet the terms of the agreement, as Trump is no longer “an officer, director, manager, employee, or other official in any of the entities” involved in operating the hotel. The letter immediately drew outcry from ethics organizations like CREW, which called the ruling “a disappointment” that failed to address the underlying problems of Trump’s businesses, and the left-leaning advocacy group Public Citizen, which described it as “an affront to the rule of law” based on “tortured and wholly uncompelling analysis” that “would get a first-year law student kicked out of law school.”

The GSA’s decision may also prove a blow to the more general argument that Trump has not done enough to distance himself from his namesake organization. Critics have strenuously objected to the plan Trump and his lawyer Sheri Dillon laid out on January 11 to mitigate conflicts of interest, under which the president has stepped down from, but retains ownership of, his numerous business interests, and placed his assets in a trust to be administered by his adult sons and Garten. His opponents maintain that, because Trump still has significant knowledge of his business interests and will still be benefiting from them, and because he has put in place few real barriers between himself and his sons, there is still ample opportunity for outside actors to seek to influence the president’s decisions by patronizing his companies. Though the letter from the GSA discusses only the Trump International Hotel and not the legality of the overall arrangement, it is nonetheless a decidedly favorable outcome for Trump in the first legal challenge over his conflicts of interest.

As if its location didn’t pose enough of an ethical question, the hotel has already hosted at least one promotional event specifically aimed at enticing foreign diplomats to stay at the establishment while in town on official state business. On the one hand, direct influence will likely be difficult to prove: The establishment is, after all, a five-star hotel that would have been likely to attract high-class clientele even if Trump had lost the election, a fact to which Trump and those who surround him may well point in order to maintain a patina of respectability around their dealings. Still, the meeting’s proximity to the election reinforces that it will be worth watching the comings and goings at the hotel closely for signs that Trump, who so often accused his opponent (often without evidence) of pay-for-play, may be using his position as president to promote his businesses.

Trump himself acknowledged that his presidency is likely to increase traffic to his Washington, D.C. property. Speaking to The New York Times, the president noted that the property is “probably a more valuable asset than it was before” and that his brand is “hotter” since the election. However, he went on to insist that there was nothing even potentially problematic about his unprecedented situation and that he sees no reason why he couldn’t run both the presidency and his business without conflict.

Multiple events since the election have made Trump’s lease on the hotel a central focus of discussions of his conflicts of interest, including among Democrats in the House. On November 29, Bahrain—a country whose donations to the Clinton Foundation Trump and his campaign decried during the campaign—announced that it would be celebrating the anniversary of its king’s ascension to the throne at the hotel. Other events announced since the election include a Hannukah celebration co-hosted by the Embassy of Azerbaijan and the Conference of Presidents of Major American Jewish Organizations and a reception for the conservative think tank the Heritage Foundation featuring Vice President Mike Pence as its keynote speaker.

Nor did the string of bookings by international entities end after Trump’s inauguration: On February 9, Politico reported that a lobbying group with connections to the government of Saudi Arabia had booked a four-day stay at the hotel in Washington, D.C. And on March 13, The Daily Caller reported that the Turkish-American Business Council will be co-hosting its annual conference at the Trump International Hotel after a seven-year runat the Ritz-Carlton. The latter announcement is especially notable because the organization’s chairman, Ekim Alptekin, is involved in another of the Trump administration’s scandals: One of Alptekin’s companies, the apparent shell company Inovo BV, paid $530,000 to the former National Security Adviser Michael Flynn to lobby on behalf of the Turkish government, which prompted Flynn to register as a foreign agent shortly after he was ousted from the Trump administration for lying about his contacts with Russian agents while a member of the president’s transition team.

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That Argentinian Office Building

According to a report by the prominent Argentine journalist Jorge Lanata, the president’s first phone call with his Argentine counterpart Mauricio Macri included a discussion of the permit issues currently holding up construction of a new Trump-branded office building in Buenos Aires. Both Macri and Trump quickly denied the report; according to a statement from the Embassy of Argentina, “The subject both leaders talked about was the institutional relationship, and they briefly mentioned the personal relationship they have had for years.”

As summarized in a tweetstorm here, Trump’s relationship with Argentina’s government and business elites—and the story so far on his property there—is already long and convoluted. The phone call with Macri was apparently set up through Felipe Yaryura, one of Trump’s longtime associates whose company, YY Development Group, is in charge of Trump Tower Buenos Aires. The day after the phone call, the PanAm Post reported that YY Development Group had been approved to break ground in June 2017; evidence has since emerged that the permitting process is not, in fact, finished, although Trump’s business associates are moving ahead as though it is.

Based on the information at the president’s January 11 press conference, it appears that the properties in Argentina, as both ongoing development projects and deals in a foreign country, is no longer moving forward. Nevertheless, the questionable circumstances under which it did so in the immediate aftermath of the election demonstrates just how many avenues there are for Trump’s conflicts of interest to interfere with governance around the world.  

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Those Companies in Saudi Arabia

Even as Trump was running for president, his company was continuing to operate and open new properties. While the most memorable openings may have been that of his hotel in Washington, D.C., and his golf course in Turnberry, Scotland, the Trump Organization was continuing to work on projects in other countries, including, according to a report the Washington Post, registering eight new companies in Saudi Arabia during the 16-month campaign.

The organization’s endeavors in Saudi Arabia are notable not only because they may further complicate the shaky relationship between the U.S. and an oil-rich gulf state notorious for human-rights abuses but also because of how they relate to Trump’s campaign rhetoric. One of his criticisms of Hillary Clinton was that her charitable foundation had accepted donations from governments with questionable records on human rights, most notably Qatar and Saudi Arabia, always with the implication (or direct accusation) that they were doing so to curry favor with Clinton when she was secretary of state. That Trump was continuing to level this criticism while his namesake organization was actively pursuing new projects in Saudi Arabia not only bodes ill for his ability to separate his personal and presidential interests but also further calls into question the honesty and transparency of his campaign.

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That British Wind Farm

As he indicated when he stopped there during the campaign, President Trump takes enormous pride in his recently opened golf course in Turnberry, Scotland. The day after the British public voted for Brexit—over intense Scottish opposition—Trump spoke at the property’s opening, proudly touting how the decision’s deflationary effect on the pound would benefit his business.

However, Trump also has a second golf course in Aberdeen, where it appears Trump has attempted to intercede in the interest of his own pocketbook.* According to The New York Times, Trump had a post-election meeting with Nigel Farage in which he “encouraged Mr. Farage and his entourage to oppose the kind of offshore wind farms that Mr. Trump believes will mar the pristine view from one of his two Scottish golf courses.” Hope Hicks, a spokeswoman for the president, denied that the two had discussed the subject, only for Trump to later confirm that the topic had, in fact, come up in their conversation.

* This entry originally misstated that Trump intervened at Turnberry, his other golf course in Scotland. We regret the error.

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Those Indian Business Partners

It didn’t take long after the election for President Trump to be seen in public with international business partners. According to a November 19 article in The New York Times, Trump took a break from his transition schedule to meet with three Indian real-estate executives who are currently building a Trump-branded apartment complex in Mumbai. According to both Trump and the Indian businessmen, the meeting was essentially congratulatory in nature; a picture posted by one of the executives on Twitter shows the four men smiling broadly and giving a thumbs-up to the camera. However, that the meeting happened in the first place suggests that Trump does not currently have any qualms about forestalling official state business for personal business.

On top of that, the meeting raises questions in the blind-trust realm as well. The president himself was not the only member of his family there; two Facebook photos show that Ivanka and Eric Trump both attended the meeting as well. Their presence serves as a reminder that their father seems so far uninterested in maintaining even the nominal separation between himself and his assets that he repeatedly said he would create during the campaign.

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That Envoy From the Philippines

One leader with whom Trump already has an advantage over President Obama is Rodrigo Duterte, the similarly brash president of the Philippines. Duterte, who has threatened to “break up with America,” told Obama to “go to hell,” and called the president a “son of a whore,” expressed admiration for Trump, noting that, among other similarities, they both enjoy swearing.

Duterte’s affinity for Trump apparently goes beyond vulgar word choice. Late in October, Duterte appointed a longtime business associate of Trump’s as a special envoy to the United States, an announcement that became public shortly after the election. This appointment in particular raises questions because it is just as open to exploitation by Duterte as it is to Trump, as the Filipino president could intend to use his new envoy’s relationship with Trump to strengthen the Philippines’ hand. Whichever side the appointment does eventually benefit, however, the situation is nevertheless fraught with conflicts between the three men’s personal and political interests.

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NASA is preparing to solicit proposals for a Europa lander mission despite uncertain funding for it.

NASA issued a “community announcement” Wednesday stating it would issue an announcement of opportunity later this year for instruments that could fly on the proposed lander.

NASA will use fiscal year 2017 funding to support Phase A studies of about 10 proposals in 2018 and 2019.

NASA is going ahead with these plans even though the administration’s fiscal year 2018 budget blueprint included no funding for a Europa lander mission.

That mission, though, has as a strong advocate in Rep. John Culberson (R-Texas), chairman of the House appropriations subcommittee that funds NASA. [NASA]

More News

A Soyuz rocket carrying an SES satellite lifted off this morning. The Soyuz launched from French Guiana on schedule at 7:54 a.m. Eastern carrying the SES-15 satellite. The Boeing-built spacecraft, weighing 2,300 kilograms, carries a Ku-band payload with connectivity to gateways in Ka-band, as well a Wide Area Augmentation System hosted payload for the FAA to support GPS use in aviation. Spacecraft separation is scheduled for more than five hours after liftoff. [Spaceflight Now]

China Great Wall Industry Corporation has won a contract to build an Indonesian communications satellite. China Great Wall and Palapa Satelit Nusantara Sejahtera, an Indonesian joint venture, signed the contract Wednesday in Jakarta for the Palapa-N1 spacecraft. Palapa-N1 will carry a Ku-band payload and replace Palapa-D, whose orbital lifetime was limited when the Long March rocket that launched it in 2009 underperformed. The companies also announced a non-binding agreement for a Ka-band satellite, PSN-7. [SpaceNews]

Intelsat issued a new debt exchange offer with a revised deadline. The company said Thursday that it is making new offers to bondholders to exchange existing debt, with a new deadline of May 31. The company originally set a deadline of late April for bondholders to accept the original offer, extending it three times prior to this latest announcement. The debt exchange is key to Intelsat’s plans to merge with OneWeb. [Intelsat]

Nearly one third of the U.S. Senate has signed a letter calling on appropriators to fund NASA’s education office. The letter, released Wednesday, was signed by 32 senators, led by Sens. Tim Kaine (D-Va.) and Tammy Baldwin (D-Wis.), and addressed to the chairman and ranking member of the Senate appropriations subcommittee that funds NASA. The letter asks the subcommittee to restore funding for NASA’s education office. The administration’s fiscal year 2018 budget blueprint, released in March, offered no funding for the education office, which received $100 million in the fiscal year 2017 omnibus spending bill. The senators asked that funding be restored to the office “because its mission is critical to boosting the nation’s workforce competitiveness.” A detailed fiscal year 2018 budget request is expected to be released next week. [U.S. Senate]

Spaceflight has purchased an Electron launch from Rocket Lab for medium-inclination payloads. The companies announced the contract Wednesday, but did not disclose terms of the deal or indicate when the launch would take place. Spaceflight, which brokers launches of smallsats as secondary payloads, said it purchased the Electron launch for satellites seeking to fly to inclinations of 45 to 60 degrees, which are not well-served by existing rideshares that primarily go to sun-synchronous orbit. Rocket Lab is still on track to launch its first Electron in a 10-day window that opens Sunday. [SpaceNews]

The founder of the Mars Society is not a fan of NASA’s latest human exploration plans. Robert Zubrin criticized NASA’s plan for a cislunar outpost, called the Deep Space Gateway, as “NASA’s worst plan yet” in an op-ed and reiterated that criticism during a panel session this week. “There is not a plan” to go to Mars, said Zubrin at the forum. “This is random activity.” Zubrin has long advocated for concepts that would send humans to Mars as soon as possible. [Washington Post / National Review]

The head of a leading Russian space company is critical of SpaceX’s proposed circumlunar mission. In an interview, Vladimir Solntsev, general director of RSC Energia, said he doubted SpaceX would be able to send a Dragon spacecraft carrying two people around the moon and back in 2020, let alone SpaceX’s current plan to do so in 2018. “Nobody has yet even seen the designs. There’s no launch vehicle, no spacecraft,” he said of the proposed mission, announced in February but with few details disclosed. Solntsev said he expected NASA to exercise options for three seats on Soyuz spacecraft in 2019 because of commercial crew delays, and added Russia would likely revive efforts to sell Soyuz seats to space tourists once NASA astronauts start using Boeing and SpaceX vehicles. [Space.com]

Russian officials believe it will be cheaper to develop a new heavy-lift rocket from scratch rather than try to revive the Energia vehicle. Igor Radugin, deputy general designed of RSC Energia, said a “super-heavy” rocket using current technologies would cost about 30 percent less than rebuilding the Energia, which first launched 30 years ago this week but was retired after only two launches. A new vehicle, though, may not be ready for flight until the mid-2030s. [TASS]

An artist is using crowdfunding to reissue a famous plaque flown on the Pioneer 10 and 11 spacecraft. The plaque was designed in the early 1970s as a message to any extraterrestrial civilization that might find the spacecraft, with information about humanity and the Earth’s location in the galaxy. Duane King is seeking to raise $70,000 by mid-June to produce replicas: $399 for a limited-edition manually engraved copy, and $99 for a laser-engraved one. [collectSPACE]

SpaceNews.com

President Donald Trump’s properties around the world bring with them business partners from around the world. Several of these ties have already come under scrutiny: A Trump-branded tower in Baku, Azerbaijan, put him in business with allegedly corrupt officials who are themselves connected with the Iranian Revolutionary Guard, for example, while two properties in Indonesia link him to officials implicated in a bribery scandal and a racially-motivated attempt to oust a sitting governor.

Now, The Wall Street Journal has reported an additional source of a conflict of interest along these lines: Trump International Tower and Hotel in Toronto. According to the Journal, one of Trump’s partners in the project, Alexander Shnaider, received millions of dollars from the Russian bank Vnesheconombank, or VEB, shortly before investing in the project. Shnaider, who is Russian American and was the main developer on the Trump-branded property, sold his own company’s share in a Ukrainian steelmaker to VEB for $850 million in 2010. Shnaider’s lawyer said in April that $15 million from the sale went into the Toronto tower, although he walked back his statement the next day, writing that he is “not able to confirm that any funds” from the sale went into the project.

VEB is owned by the Russian government; according to its website, its mandate is “to enhance [the] competitiveness of the Russian economy, diversify it, and stimulate investment activity,” and the bank’s supervisory board is chaired by the country’s prime minister, Dmitry Medvedev. At the time of the deal with Shnaider’s company, though, its chairman was the current Russian President Vladimir Putin, who, according to a Russian government official and multiple experts, would have had to sign off on such an exchange.

As with many of Trump’s business holdings, the property represents a conflict of interest because it brings him revenue that’s made possible by money from a bank owned and operated by a foreign government. Though Trump doesn’t own the tower—he merely licenses his name to Shnaider, who owns the building through his company Talon International Development Inc.—the Trump Organization nevertheless profits off of the building and, by extension, from VEB’s deal with Shnaider. This potentially gives the Russian government leverage that it could use should it want to influence Trump’s policies. That means that the Trump Organization’s continued involvement with the tower may represent a violation of the Constitution’s Emoluments Clause, which precludes elected officials from “accept[ing] of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.”

The Journal’s report highlights the inadequacy of the financial disclosures the president has so far offered. Last week, Trump insisted that his company does not have business ties to Russian “persons or entities.” As my colleague David Graham wrote, the letter from Trump’s lawyers that Trump proffered on the subject last week “doesn’t define several key terms,” leaving open the possibility that one of Trump’s projects benefited from Russian funding through a pass-through corporation or another intermediary. VEB’s role in the financing of the Trump-branded property in Toronto is a perfect example: Because money from VEB went toward enriching Trump (through Shnaider), one can reasonably argue that Trump didn’t do enough to eliminate the conflict of interest that the hotel creates for him in office.

The Background

President Donald Trump still has not taken the necessary steps to distance himself from his businesses while in office. In accordance with a plan that he and one of his lawyers, Sheri Dillon, laid out at a press conference on January 11, Trump has filed paperwork to remove himself from the day-to-day operation of his eponymous organization. However, numerous ethics experts have voiced strenuous objections to the plan, which they say does very little to resolve the issue: As long as Trump continues to profit from his business empire—which he does whether or not he is nominally in charge—they say, the possibility that outside actors will attempt to affect his policies by plumping up his pocketbook will remain very much in play.

Several of Trump’s critics have moved forward with legal action. The watchdog group Citizens for Responsibility and Ethics in Washington, or CREW, filed a lawsuit alleging that Trump’s business holdings violate the Emoluments Clause of the Constitution, which makes it illegal for government officials to “accept of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.” CREW’s bipartisan legal team includes, among others, Norm Eisen and Richard Painter, who served as ethics lawyers under Presidents Obama and George W. Bush, respectively; Laurence Tribe, a constitutional law professor at Harvard University; and Zephyr Teachout, a professor at Fordham University (and former congressional candidate) who is considered an authority on the Emoluments Clause. All have been vocally critical of Trump’s continued refusal to sell off his business, and are now taking their case to court to argue that several of Trump’s businesses present avenues by which foreign governments could seek to influence the president by, for example, booking stays at one of his hotels or renting space at one of his properties. Additionally, the lawsuit seeks to force Trump to reveal his tax returns, something every president has done since Gerald Ford but which Trump has refused to do, significantly limiting the public’s ability to understand the president’s finances. When asked about the lawsuit, Trump described it as “totally without merit.” Eisen was quick to respond on Twitter, offering to “debate Trump (or his chosen champion) on the merits of our case anytime,” making it clear that CREW intends to continue to pursue its case. (CREW has also filed a separate complaint to the General Services Administration arguing that Trump has violated the lease on his Washington, D.C. hotel, which states that “no … elected official of the Government of the United States … shall be admitted to any share or part of this Lease, or to any benefit that may arise therefrom.”)

Though CREW is the first group to bring a lawsuit against President Trump, it may soon have company. According to The New York Times, Anthony Romero, the executive director of the American Civil Liberties Union, has said that his organization is looking for a plaintiff to sue Trump for violating the Emoluments Clause, although with a different claim to legal standing: While CREW intends to demonstrate that the group itself has suffered financial harm because the need to focus on the Emoluments Clause has diverted its resources away from other worthy causes, the ACLU is hoping to find a hotel or bed-and-breakfast owner that can prove he or she has lost business to one of Trump’s hotels during his presidency.

CREW’s lawsuit is just the latest development in what promises to be a continuing saga regarding Trump’s many conflicts of interest that began almost as soon as he won the presidency. Along with his unprecedented wealth, Trump brings to the office unique and gravely concerning entanglements that, whether he recognizes their effects or not, threaten to undermine his decision-making as president. The plan Trump and Dillon announced on January 11 would do very little to resolve the conflicts: It places control of his assets in the hands of his two adult sons and a longtime associate of their father’s with what so far amounts to a pinky-swear assurance that, despite their proximity to the president, they will not discuss any aspect of the business with him. On top of that, the plan supposedly would terminate several of the Trump Organization’s pending deals and place a ban on new foreign deals, two conditions undermined by the announcement that the organization would be moving forward with expanding its golf course in Aberdeen, Scotland.

Even before his most recent plan was laid out, Trump has attempted to deflect criticism by repeatedly asserting that the law barring executive-branch officials from maintaining financial holdings or business ties that overlap with their duties does not apply to the president or vice president. In this, he is correct; the law, passed in 1989, exempts the two chief executives from conflict-of-interest rules on the understanding that their purview is so broad that it would be impossible for them to completely disentangle themselves.

Regardless, legality does not imply propriety. Unless Trump acts to put actual distance between himself and his business ventures, these questions are likely to continue throughout his time in the Oval Office. On top of the aforementioned legal actions, the director of the Office of Government Ethics, Walter Shaub, has declared Trump’s efforts insufficient, remarking, “I don’t think divestiture is too high of a price to pay to be the president of the United States,” and a number of Senate Democrats have introduced legislation that would force Trump to divest or face impeachment. Below is an attempt to catalogue the more clear-cut examples of conflicts of interest that have emerged so far. The most recent entries appear at the top:

• That Caribbean Villa
• Those Condos for Sale
• Those Reelection-Campaign Funds
• That Second Hotel in Washington, D.C.
• That Property in Azerbaijan
• That Trump Tower Penthouse
• That Resort in the Dominican Republic
• That Chinese Trademark
• That Meeting at Mar-a-Lago
• That Defense Department Trump Tower Rental
• That Red Cross Ball
• That D.C. Labor Dispute
• That Estate in Palm Beach
• Those Expansion Plans
• That Hotel in Vancouver
• That Reality-Television Show
• That Pipeline
• Those HUD Grants
• That Golf Course in Aberdeen
• That Other Billionaire New York Real-Estate Developer
• Those Indonesian Politicians
• That Emirati Businessman
• That Virginia Vineyard
• That Las Vegas Labor Dispute
• That Kuwaiti Event
• Those Certificates of Divestiture
• That Carrier Deal
• That Blind-Trust Issue
• Those Fannie and Freddie Investments
• That Phone Call With Taiwan
• That Deutsche Bank Debt
• That Secret Service Detail
• That Property in Georgia (the Country)
• That Phone Call With Erdogan
• That Hotel in Washington, D.C.
• That Argentinian Office Building
• Those Companies in Saudi Arabia
• That British Wind Farm
• Those Indian Business Partners
• That Envoy From the Philippines  

That Caribbean Villa

President Donald Trump has another property on the market: Le Château des Palmiers, his estate on the Caribbean island of St. Maarten. The president’s company bought the 11-bedroom beachfront compound in 2013, and the Trump Organization has been using it as a rental property ever since. It’s listed at $6,000 per night on TripAdvisor; according to specialty sites such as Luxury Retreats, which lists the price as between $6,000 and $20,000, and Mansion Global, which places the upper limit at $28,000, the price increases substantially during the winter, when the Caribbean offers an escape from cold weather. According to the disclosure forms Trump submitted to the Federal Election Commission (which remain the only public documentation of his finances), he derived between $100,001 and $1 million from the property in the year leading up to May 2016.

The asking price for Le Château des Palmiers remains unknown. The Trump Organization is selling the property through the real-estate agency and auction house Sotheby’s; according to the listing for the complex, the price is available only upon request. However, there are some clues available. On his FEC disclosure forms, Trump lists the property as worth between $5 million and $25 million, which does correspond with the $19.7 million he paid for it four years ago. According to Mansion Global, 7th Heaven, a real-estate brokerage in St. Maarten, has identified the asking price as $28 million, although 7th Heaven’s current page for the property lists the price as “PoA,” or Price on Application.

Though Trump no longer runs the Trump Organization, he still owns the company and, by extension, the property, meaning that he will profit from its sale. That means that Le Château des Palmiers offers yet another avenue by which somebody could attempt to influence the president’s decisions by putting a large sum of money in his pocket. It would even be possible for somebody to make an offer well above the currently unknown asking price to curry favor with him (and, possibly, through the artful use of a shell company, hide their identity).

As NPR noted, the Trump Organization’s decision to sell Le Château des Palmiers is “the first known major divestiture of a Trump property since he became president.” As such, it demonstrates the insufficiency of the steps the president has taken to eliminate his conflicts of interest. Trump has put the leadership of his company in the hands of his adult sons and a longtime Trump Organization executive with relatively few—and, based on Donald Jr. and Eric’s frequent presence at administration events and Eric’s statement that he will share some business-related data with his father, relatively permeable—barriers blinding him from knowledge of his financial interests.

Had Trump taken the measures suggested repeatedly by ethics experts on both sides of the political aisle, he would by now have put his assets in what’s called a blind trust, which would entail turning over his empire to a third party with whom he will have no contact, who would sell off the properties and reinvest the resulting money in other assets without providing the president any information about the sales or the purchases. Instead, Trump has set up a system under which, even if he does proceed to sell off his business, one property at a time, he will simply create new conflicts of interest as he takes payments from those who are purchasing the Trump Organization’s real estate.

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Those Condos for Sale

President Donald Trump’s finances are infamously opaque. Since he has not followed the long-standing presidential custom of releasing his tax returns to the public, the only publicly available records of where he derives his income are his two filings with the Federal Elections Commission. Even those are difficult to parse: Much of his business empire comprises limited-liability companies (or LLCs), which face very few disclosure requirements, and shell and pass-through corporations, which can obscure ownership and make money trails harder to follow.

Much the same can be said for whoever has been buying up Trump Organization condominiums. A lengthy investigation published in USA Today found that, “since launching his White House bid, Trump’s companies have sold at least 58 units nationwide”—out of a total of more than 400 currently on the market—”for about $90 million. Almost half of those sold to LLCs.” One of those LLCs, a financial firm created shortly before the Republican National Convention named Milan Investment Limited, spent $3.1 million to buy 11 condominiums in the building the president co-owns in Las Vegas.

Normally, such a story would then identify who is behind the purchase and whether they may have some ulterior motive in buying something from the president. In this case, though, repeated efforts by the USA Today to ascertain who exactly is behind Milan apparently came up empty. The company’s headquarters in a strip mall the outskirts of Las Vegas are registered to two individuals named Jun Xu and Qi Huang; however, the reporters were unable to reach Xu and Huang through either their listed addresses and phone numbers or through business associates. A third individual associated with Milan, Chen Huang, also apparently could not be reached for comment, nor did the Trump Organization respond to inquiries about the identities of the buyers. The newspaper’s attempts to find the buyers of other Trump Organization condos met with mixed results: Though reporters were able to track down the real people behind some of the purchases, including a couple who said they bought the property because they’re fans of Trump’s, others proved just as elusive as whoever is behind Milan.

As the USA Today notes, the story highlights one of the major problems underlying Trump’s decision to retain his businesses while in office. There is no law requiring a shell company like Milan to disclose the identities of its owner(s) or the source of its money while purchasing real estate. The Trump Organization still owns hundreds of condominiums, the sales of which will directly profit it and, by extension, the president; this offers plenty of chances for any individual or corporation to purchase a unit to attempt to curry favor with Trump without having to disclose their own identity to the public.

So far, the Republican-controlled Congress has shown little interest in investigating the constitutionality of Trump’s decision to hold onto his businesses. That means that the only real disincentive for those attempting to influence the president by patronizing his businesses is the bad publicity that might ensue. But Milan Investment Limited’s secretive investment in Trump’s properties shows how easy it would be for an individual or a corporation to stay anonymous and avoid that scrutiny.

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Those Reelection-Campaign Funds

For President Donald Trump, it pays to be in constant campaign mode.

Metaphorically, at least, this isn’t unusual; the idea of the “permanent campaign,” a reference to how politicians consider their reelection chances from almost the moment they take office, has been around for decades. Such is the case for Trump, who filed a letter with the Federal Election Commission establishing his eligibility to run for a second term in 2020 just hours after taking the oath of office. Though the letter declares only that he can run, not necessarily that he will run, it gives broad coverage for the president to begin fundraising and holding campaign events, and to do so far earlier in his first term than have previous presidents.

Since doing so, Trump has held several events that, while officially presented as part of his “thank-you tour,” have seemed an awful lot like his campaign rallies. Meanwhile, between merchandise sales and an already-active fundraising effort, he has raised more than $7.1 million, and the Republican National Committee has raised an additional $23 million. That’s not necessarily noteworthy by itself; by this time, President Obama and the Democratic National Committee had raised $15 million. (Obama had not yet filed for eligibility in 2012 three months into his first term, although he had held events to promote his economic-stimulus package.) What does make Trump unusual is that he has already spent $6.3 million of his reelection campaign funds—and, according to reports he recently filed with the FEC, he is paying some of that money to his own personal businesses—for instance, renting space at his hotels or golfing on his courses—thereby literally profiting off of his permanent campaign.

This practice is nothing new for Trump. As early as 2000, he was speculating that he “could be the first presidential candidate to run and make money on it” by patronizing his own businesses and running the campaign out of one of his properties. During his 2016 bid, he did exactly that, establishing his political headquarters in Trump Tower (and quintupling the rent as soon as he became the Republican nominee and began drawing funds from the party rather than his personal war chest). Shortly before his victory, The Wall Street Journal reported that Trump’s campaign had paid out the unprecedented sum of more than $14 million to his family and companies for such services as flights on his personal airplanes, rent at Trump Tower, and meals and hotel rooms at other Trump buildings.

Similarly, since taking office, Trump has profited off of the federal government’s newfound need to patronize his properties. Both the Secret Service and Department of Defense are renting out space in Trump Tower, for example, with the former believed to be paying at least $3 million per year to do so. This has led to rumblings that Trump may be violating the Constitution’s Domestic Emoluments Clause, which holds that the president “shall not receive ... any other Emolument from the United States, or any of them,” beyond his official salary.

The amount Trump’s reelection campaign has spent at his businesses is comparatively small: According to The Wall Street Journal, more than 6 percent of the $6.3 million it’s spent so far, or almost $500,000, went to Trump’s hotels, golf courses, and restaurants. But that’s a higher rate than when his campaign money was going to his own businesses for the 2016 campaign ($14 million out of a total of $322 million, or about 4.3 percent). At his current rate, if he spends a similar amount over the next election cycle—and given that he’s already started spending, he could easily far outdo himself—he would be directing nearly $20 million to his own businesses.

On top of the arguable impropriety of personally profiting off of his donors’ and his party’s largesse, the situation presents perverse incentives for Trump. Already, elected officials, up to and including the president, to an extent base their behavior in office on what they believe will play well with voters rather than (or, in the best-case scenario, on top of) what is best for America. This is certainly true of Trump, whose every decision seems to prompt discussion of how it plays into the tension between his nationalist base and traditional Republican voters.

The personal financial benefits of campaigning mean that Trump has a little more motivation to delve into his reelection efforts than most politicians in his position. Because he is personally profiting, he has another reason to aim his politics toward his base so that they will continue donating to him and buying his merchandise in the downtime between election years. Moreover, rather than stockpile for 2020, he has an incentive to keep up the campaign rallies—and keep charging for them, as he did in 2016—so that he can continue funneling money from his donors and voters into his personal businesses.

Moreover, that the president is redirecting donors’ money into his own businesses only further highlights the inadequacy of the trust arrangement he has set up to supposedly prevent him from conflicts of interest. Trump and his lawyers have claimed that, by resigning from his positions within the Trump Organization and handing over control to his two adult sons and a long-time business associate, the president has distanced himself from his businesses enough that he will no longer be tempted to act in his own financial interests. Ethics experts (and common sense) immediately disagreed: Unless the president actually sells his businesses, many have said, and has the funds reinvested without his knowledge, he still knows more than enough about his sources of profit to put his own personal gain above that of the country. The almost $500,000 he’s channeled into the Trump Organization via his reelection campaign demonstrates this: Trump doesn’t need to be in charge of his businesses to know how to direct money their way; all he needs to know is where they are.

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That Second Hotel in Washington, D.C.

There may soon be more than one Trump Hotel in Washington D.C. According to The Washington Post, the Trump Organization is considering purchasing another property in the nation’s capital to develop for its recently created Scion brand, which aims to offer a more affordable alternative to the upscale properties bearing the president’s name.

Unlike the Trump International Hotel—the upscale property that opened in September 2016 and has become something of a synecdoche for the president’s conflicts of interest—a new Scion hotel in D.C. would likely be a licensing deal. That means that, rather than the Trump Organization owning and operating the property itself, a third-party hotelier will be paying the president’s company for the right to use the Scion name; candidates identified by the Post include Foxhall Partners, which has two properties in the city and a third under development, and the Beacon Hotel in downtown D.C.

But even if it isn’t actually owned or operated by the Trump Organization, the new hotel would likely attract scrutiny along the same lines as the Trump International. A licensing agreement means that the president will not be profiting off of the building directly; payments from individuals or organizations booking rooms or events there will not go straight to the Trump Organization, but to the hotelier. But Trump will still have a financial stake in the hotel’s viability: The longer it stays in business and the more successful it is, the more (and longer) the licensee will pay to use the Scion name, and the more likely other owners may be to commit to similar partnerships with the fledgling brand. Trump has resigned from his positions with the Trump Organization and transferred control of his assets to his two adult sons and a long-time business partner. But he still owns the company, which means he will still profit from his properties. According to his son Eric, the president will even continue to receive quarterly reports on how his real-estate empire is faring financially. The pathway to Trump’s pocketbook may be slightly more complicated, but it still exists.

The proposed new property also engenders some of the same concerns as the broader round of expansions the Trump Organization announced in February. Developing a hotel, even in an existing building, means working with local government bureaucracies, such as zoning offices that sign off on structural changes or licensing boards. In any city, this would create  conflicting incentives for government officials who are suddenly being asked to rule on the president’s businesses. On the one hand, Washington, D.C., like many of the cities into which the Trump Organization is looking to expand, voted strongly against the president in the 2016 election; city officials, especially those elected by D.C.’s denizens, may feel a need to factor his unpopularity into their decisions with regard to the newly proposed hotel. On the other hand, the federal government still controls D.C.’s budget, placing additional pressure to green-light a proposal from the infamously mercurial commander-in-chief.

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That Property in Azerbaijan

When it comes to President Donald Trump’s constellation of foreign investments, properties, and companies, much of the attention so far has been on his business’s apparent violation of the Constitution’s Emoluments Clause, which bars officeholders from taking gifts from foreign leaders. According to numerous ethics experts, the clause takes an expansive definition of gifts, encompassing everything from a direct bribe to a foreign official’s approval of construction of a new Trump property. But some of the Trump Organization’s properties raise additional red flags due to the specific partners involved. That’s true in Indonesia, for example, where Trump’s affiliates have been involved in bribery scandals and radical Islamic nationalist parties, and Brazil, where the company pulled out of a branding agreement amid a criminal investigation of a local business partner.

Such is the case in Azerbaijan, which Transparency International ranks as among the most corrupt countries in the world, where the Trump International Hotel and Tower in Baku remains unopened. Though the long-stalled development has generated a steady drip of news and rumors for years, an overview by Adam Davidson in The New Yorker, entitled “Donald Trump’s Worst Deal,” puts into perspective just how convoluted the situation is, and just how much the project has led Trump and his company into a partnership with numerous corrupt officials in the Middle East. The details suggest that, on top of the continual underlying breach of the Emoluments Clause, the Trump Organization’s involvement may also violate the Foreign Corrupt Practices Act, or FCPA, which forbids American companies from participating, even unknowingly, in bribery schemes in other countries, with a penalty of up to $2 million and up to five years in jail.

According to Davidson, though the project originated in 2008 as a high-end apartment building, the Trump Organization has had a licensing deal with the building’s Azerbaijani developers to turn the property into a hotel since 2012. Though the Trump Organization presented the deal as a straightforward licensing agreement, it was in fact a much more involved agreement granting the company—specifically, Trump’s daughter Ivanka—extensive oversight over the project. Based on his FEC disclosures in 2016, which as of this moment remain the only official record of Trump’s finances, the president has so far made $2.8 million from the partnership.

But what makes this story unique among the dozens of ethical questions surrounding the president is the Trump Organization’s partners on the project. Ostensibly, the main developer behind the property is Anar Mammadov. He is in turn the son of Azerbaijan’s transportation minister Ziya Mammadov, who was once described in a leaked diplomatic cable as “notoriously corrupt even for Azerbaijan.” Also in on the deal, though not initially publicly disclosed, is Ziya’s brother Elton, who founded the company that currently owns the property in Baku while serving in Azerbaijan’s parliament. Then there’s the Mammadovs’ relationships with Iranian oligarchs. For years, the Mammadovs have been closely linked with the Darvishis, whose members include the head of a  construction firm implicated in the Iranian Revolutionary Guard’s possibly illicit financial operations and the former leader of a company that was sanctioned by the United States for its role in Iran’s attempts to develop an arsenal of nuclear missiles. As the Mammadovs’ influence within Azerbaijan has begun to weaken in recent years, they have  increased both their wealth and their mutually profitable relationship with the Darvishis, green-lighting a number of deals that will prove lucrative for both families.

Alan Garten, the chief legal officer for the Trump Organization, asserted to The New Yorker that, as the company has never worked directly with Ziya or Elton Mammadov, it has not engaged in any behavior that should trip ethical alarms. He has additionally claimed that the company did “extensive due diligence” in making the deal, which did not raise “any red flags,” although the actual employees who carried out the process are no longer with the company.

Still, merely by partnering with the Mammadov family, the Trump Organization may have violated the FCPA. The law explicitly covers cases in which an American company claims not to have known it was working with corrupt officials; jurisprudence since its 1977 passage has further expanded the law’s definition to include “conscious avoidance,” or active efforts by an American company to not learn of a foreign partner’s corruption. So though Garten claims that, since the Trump Organization did not have enough control over the project and has not itself engaged in bribery, its hands are essentially clean, experts on the law say that the Trump Organization may be legally liable if its foreign partners engaged in corrupt practices.

Adding to all this is the fact that Trump is on the record as opposing the FCPA in May 2012, right when it would have become relevant to his company’s engagement in Azerbaijan. Trump called the law “absolutely horrible” and argued that, since other countries do not have the same provision, American corporations are at a major disadvantage in which bribery is the norm. Trump’s appointee to the Securities and Exchange Commission (which enforces the statute), Jay Clayton, similarly considers the FCPA an obstacle to U.S. companies seeking to expand abroad. A dissenting voice on the topic is Attorney General Jeff Sessions, who stated in his confirmation hearings that he intends to continue enforcing the statute. Which of these voices will end up winning out on the topic remains an open question.

This, then, is the situation in which the Trump Organization—and, by extension, the president, who has stepped down from his position within the business but who retains ownership—finds itself in Azerbaijan: The company’s direct partner on Trump Tower Baku is the scion of a wealthy and notoriously corrupt family that appears to have only stepped up its self-dealing as its political power wanes. That family is engaged in what appears to be a relationship of mutual graft with Iranian oligarchs with deep connections to their country’s Revolutionary Guard, the ideological militia widely suspected by the international community of gross corruption and sponsoring terror at home and abroad.

These families can be added to the ever-growing list of international partners whose relationships with the Trump Organization could create conflicts of interest for the president. The Mammadovs’ arrangement with Trump’s company may not only violate the Emoluments Clause but could also feasibly put the president and his family in legal trouble should the SEC choose to actively pursue enforcement of the FCPA in Azerbaijan. And the Darvishis could in turn use their relationship to influence the Mammadovs, which could have significant implications should Trump attempt, as he has said he will, to take hard-line stances that could affect the Iranian Revolutionary Guard’s 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.

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That Trump Tower Penthouse

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.

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.

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.

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That Resort in the Dominican Republic

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.

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 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.

The Cap Cana story is yet another conflict of interest that only became public because of reporting from local media—and because of the nonchalance with which the Trump family handles the relationship between their business and the presidency. The first outlet to report on Eric’s trip was the Dominican newspaper Diario Libre, shortly after Cap Cana posted a picture of the Hazourys with Eric on its website. This follows stories like the president’s phone call with the president of Argentina and his company’s plans to expand into Taiwan, both of which were similarly broken by local newspapers before getting picked up by American press outlets. Further, like the president’s post-election meeting with business partners from India and Eric’s trip to Uruguay, the Trump family’s propensity for photo ops played a role: Even amid intensifying scrutiny of the Trump Organization’s actions, Eric seems unworried about having not only taken the trip but also taken pictures with his business partners.

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.

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That Chinese Trademark

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.

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.

Additional context, though, complicates this picture. The case, it turns out, was largely resolved in November 2016, before there was any indication that the president would waffle on the One China Policy by calling the president of Taiwan, and was the culmination of more than a decade of litigation that largely predates Trump’s involvement in politics. Conflicts of this kind over trademarks are fairly common in China, and, though resolving such cases often costs companies significant time and money, the Trump Organization’s victory is one of several that have gone in favor of American corporations in recent years. None of this rules out the possibility of a quid-pro-quo arrangement, but in sum it suggests that there is more to the case than what Feinstein alleges.

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.

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That Meeting at Mar-a-Lago

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.

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.

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.

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.

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.

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.

One patron of the club, Richard DeAgazio, demonstrated just how much of a breakdown the situation represents. DeAgazio, who, according to a photo he posted on Facebook, joined the club in December after Trump’s election, snapped several pictures of the president and prime minister’s conversation, which helped corroborate a CNN report on the public nature of the ad-hoc meeting and details such as the use of cellphone flashlights to illuminate documents; he also took pictures with Trump’s chief strategist Steve Bannon and the president’s “body man,” whose job is in part to carry the “nuclear football” containing missile-launch codes (and who was initially identified by name in the photo’s caption). As if to reinforce impression that Mar-a-Lago members gain unprecedented access to the the president, even in the middle of a crisis situation, another patron was able to film Trump giving a toast at a wedding shortly after his press conference with Abe.

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.

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.

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That Defense Department Trump Tower Rental

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..

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.

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.

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.

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That Red Cross Ball

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.

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That D.C. Labor Dispute

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.

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That Estate in Palm Beach

To many of President Donald Trump’s critics, his decision to turn Mar-a-Lago, his Florida estate, into a “Southern White House” epitomizes the way he’s mixing his business interests with his duties as president. With each visit to the property, he boosts the resort’s visibility and may very well prompt more people to enroll as members in attempts to get a glimpse of the commander-in-chief. That the club doubled its initiation fees in January, from $100,000 to $200,000, only adds to the impression that Trump—or, at least his namesake company—is banking on his presidency as a means of boosting revenues. And without a publicly available guest list and no word on what security protocols are in place, the possibility that somebody could be using a club membership to gain access to the president has led Democratic members of Congress to draft a bill specifically to mandate better disclosure of the goings-on at the venue.

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.

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Those Expansion Plans

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.

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That Hotel in Vancouver

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.

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That Reality-Television Show

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.

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That Pipeline

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.

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Those HUD Grants

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.

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That Golf Course in Aberdeen

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.

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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.

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Those Indonesian Politicians

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.

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That Emirati Businessman

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.

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That Virginia Vineyard

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.

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That Las Vegas Labor Dispute

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.

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That Kuwaiti Event

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.

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Those Certificates of Divestiture

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.

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That Carrier Deal

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.

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That Blind-Trust Issue

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 as long as he and the trustees—again, his two sons and his long-time business partner—agree that it is “appropriate,” and will not have to disclose when he does so. This goes directly against the purpose of a blind trust, which in this case would be to distance Trump from his sources of income in an attempt to get rid of his incentive—or even ability—to consciously act in his own financial interest. So far, the plan unveiled in January appears to be as inadequate as many ethics experts had feared.

Finally, removing himself from day-to-day operations will do little to change the fact that Trump will retain substantive knowledge of the illiquid assets involved in his business, such as the numerous buildings and other products that bear his name, especially if he remains in frequent contact with his children. Even assuming that Trump does separate himself from any consideration of his holdings, his children will still likely be major players in the family’s organization, which will still bear at least the Trump name—arguably one of their most valuable properties, as much of the family’s wealth derives from licensing the name to third-party companies. Given the family’s oft-touted brand-consciousness (Ivanka, for example, briefly appeared to be distancing herself from the campaign, and several properties considered rebranding under the name “Scion” when it appeared Trump would lose), the situation epitomizes the way Trump’s, and his family’s, business interests may very well prove inextricable from his actions as president.

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Those Fannie and Freddie Investments

After railing against elites during the campaign, Trump has so far stocked his prospective cabinet with an array of billionaires whose policy positions seem likely to significantly benefit those who are also doing very well. Trump’s putative treasury secretary, Steven Mnuchin, is no exception: His resume includes stints as a banker at Goldman Sachs, a Hollywood producer, and the operator of a bank that has been described as a “foreclosure machine” and once foreclosed on a homeowner over a 27-cent discrepancy.

One of Mnuchin’s apparent beliefs is that the government should cede control of the mortgage guarantors Fannie Mae and Freddie Mac, which the government acquired during the 2008 financial crisis. The two financial institutions’ stocks rose by more than 40 percent after Mnuchin stated that he believes the Trump administration “will get it done reasonably fast.”

Doing so would be broadly compatible with Trump’s general antipathy toward regulation of the banking industry. However, The Wall Street Journal identified an additional wrinkle to the story: When Fannie Mae and Freddie Mac’s stocks rose, one major beneficiary was John Paulson, an adviser to the Trump campaign and a business partner of Mnuchin’s. Paulson’s hedge funds include significant investments in both Fannie and Freddie. Trump himself has invested between $3 million and $5 million across three of Paulson’s funds, according to his filings with the Federal Election Commission (which remain the only available window into the president’s financial holdings). In other words, as Fannie Mae and Freddie Mac’s stock prices increase—and they have so far more than doubled since the election on the expectation that the incoming Trump administration will be more lenient toward the financial sector than Obama—Trump’s portfolio benefits.

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That Phone Call With Taiwan

When news first emerged that the president spoke on the phone with Taiwanese President Tsai Ing-wen on December 2, the immediate reaction was uproar over his apparently impetuous breach of decades of U.S. protocol toward China and Taiwan. As my colleague David Graham explained, since 1979, the United States has participated in the “artful diplomatic fiction” of officially recognizing the mainland People’s Republic of China as the only legitimate Chinese government while maintaining loose, unofficial recognition of—and significant economic and military ties to—Taiwan. That Trump would speak to the president of Taiwan, especially before doing the same with Xi Jinping, the president of the PRC, flies in the face of a diplomatic tradition that has undergirded almost 40 years of U.S.-China relations.

Amid the days of dissembling that followed the phone call, an additional worrisome detail came out: At the time, the Trump Organization was apparently exploring expansion into Taiwan. Soon afterwards, the Trump Organization denied that it planned to do so; however, even before the controversy arose, the mayor of Taoyuan, Taiwan, the municipality in which the Trump Organization allegedly wants to build, described in a televised interview a meeting with a representative of the Trump Organization in September to discuss prospective real-estate projects, and at least one Trump employee was found to have posted on Facebook that she was in Taiwan at the time on a business trip. Based on the January 11 announcement that the Trump Organization will be suspending its development plans and will not pursue foreign deals in office, it would appear that any movement on development in Taiwan is no longer on the table.

The phone call, and the many statements that have followed, are of particular interest because of the extent to which they dovetail with some of the biggest concerns about Trump’s approach toward governance. In the ensuing 48 hours, Republican officials offered several, sometimes entirely contradictory, explanations of what initially appeared to be an impulsive move by Trump; depending on who was speaking, the phone call was actually initiated by Ing-wen (which, if technically true, ignores that it was Trump’s staff who arranged the conversation), was just “a courtesy,” or manifested a policy shift weeks in the making—although, regardless, it was made without first consulting the White House or State Department. The defense of the move, and the questions it creates regarding conflicts of interest, have largely hinged on the belief that, since voters apparently don’t mind, the reaction was overblown.

On this issue, though, whether or not voters care is immaterial to the central question. The president of the United States breached decades of international protocol created to preserve a precarious balance of power. That decision raised not only the possibility that Trump was blundering into a potential international incident but also that he may have done so in part out of consideration for his business prospects.

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That Deutsche Bank Debt

Though he often brags about leveraging corporate-finance law to become “The King of Debt,” Trump’s numerous bankruptcy filings have left most large Wall Street banks reticent to lend to him, according to The Wall Street Journal. Among the few exceptions is Deutsche Bank, which “has led or participated in loans of at least $2.5 billion” to the president since 1996, with at least another $1 billion in loan commitments to Trump-affiliated companies; more than $300 million of those loans have come since 2012.

The president’s indebtedness does not itself pose a conflict of interest, but Deutsche Bank’s ongoing legal troubles very well might. The Justice Department is currently negotiating with Deutsche Bank regarding a preliminary settlement of $14 billion to resolve probes into allegedly misleading predatory lending practices in the leadup to the 2008 financial crisis; while it is believed that Deutsche Bank will push back against the sum, there has been no public news regarding negotiations since the initial figure was reported in September. Trump will soon be naming many of the officials with jurisdiction over this and other deals, prompting several House Democrats to send a letter to federal financial agencies calling for close scrutiny of how Trump may seek to influence the settlement through his appointments—although doing so would be just as in keeping with his general stance toward financial regulation as with active protection of his pocketbook. Other Democrats have called for the proactive appointment of independent prosecutors to avoid any appearance of conflict if the case is not resolved before Trump takes office.

Fears that Trump may unduly consider his indebtedness to Deutsche Bank in deciding his administration’s policy toward the financial sector go beyond general anxiety about deregulation. Deutsche Bank is undergoing a period of struggle that may have it on the verge of failure already. Its stock valuation has dropped by more than half since July 2015; in January, it posted its first full-year loss since 2008; and one of its many tranches of bonds—one specifically designed to be a high-risk, high-reward safety valve in times of trouble—has recently begun to crash. In June, the International Monetary Fund called Deutsche Bank “the most important net contributor to systemic risks” among globally important financial institutions. If the bank were to fail, it could have major consequences for not only Trump’s businesses, which would lose their sole remaining lender, but for the global economy as well.

Arguably, the $14 billion fine the Justice Department is seeking to impose has exacerbated rather than alleviated these struggles. Based the company’s market capitalization—the number of shares multiplied by their price— of roughly $16 billion, the sum would leave Deutsche Bank critically low in liquid assets with which to absorb future troubles. although the institution’s own self-valuation of $68 billion argues otherwise. But given the complexity and potential volatility of the situation, it is important for any decision to be free from outside influence, something Trump’s outstanding debt threatens to jeopardize.

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That Secret Service Detail

During the election, the Trump campaign put no small portion of its funds toward paying for use of the candidate’s own properties; perhaps the most notable of these expenditures was the nearly $170,000 the campaign spent in July on rent for its headquarters in Trump Tower. These expenses raised the possibility that, as Trump predicted in 2000, he “could be the first presidential candidate to run and make money on it.” Now that he will be president, he may be able to profit off of the Secret Service by virtue of the fact that he and his family will live in Trump Tower and fly in his private jets—which requires the agents tasked with guarding them to pay him rent and airfare.

The first way Trump could monetize his own protective detail is by having family members travel in his two planes and three helicopters. This is not so much speculative as foregone: Over the course of the campaign, the Secret Service, which traditionally pays for its own travel during elections, spent $2.74 million to fly on a plane owned by one of Trump’s own companies. While in office, Trump will fly exclusively on Air Force One, while Mike Pence will be riding Air Force Two. However, their families may still be flying on Trump’s private planes—along with their protective details, which would effectively direct even more money to Trump. (Previous first families have flown with a detail, whose legal purview covers “the immediate family members,” but none have done so on planes they themselves own.)

A bigger question regards Trump Tower in New York, where the president appears likely to spend a significant amount of time. For the past few decades, it has been common practice for the Secret Service to provide protection for the president and vice president’s non-White House residences, which sometimes entails paying rent to the officeholder. (Joe Biden, for example, received $2,200 per month when the agency rented a cottage he owned near his home in Delaware.)

But Trump Tower is a unique case, as it’s not in Delaware but the middle of Manhattan. Already, pedestrians and tourists are chafing at the increased security around the building, Trump’s frequent use of which has required closing a block of 56th Street and multiple lanes of Fifth Avenue; with multiple outlets reporting that Trump’s wife Melania and 10-year-old son Barron are expected to stay at Trump Tower for at least part of his term, it appears that the consternation will continue, with an enormous price tag for taxpayers: According to the New York Post, it could cost as much as $3 million a year to rent out two of the building’s vacant floors, meaning that Trump will be making money off of his own security detail. Meanwhile, Reuters has reported that the city of New York is calling for federal funds to reimburse the costs of keeping up a security detail around Trump Tower.

This system creates an unusual set of conflicting interests for Trump regarding his own travel and residences. Though presidents as disparate as Dwight Eisenhower and Barack Obama have evoked partisan ire over time spent away from the White House, whether on the golf course or on vacation in Hawaii, only Donald Trump will actually have gained from his and his family’s travels. And if, while in office, Trump visits properties he owns other than Trump Tower—his buildings in other U.S. cities like Chicago and Miami, for example, or his golf course and resort in Scotland, or one of the many international hotels bearing his name—he stands to gain from the stays for which his security detail (and, by extension, taxpayers) may be paying. Moreover, the more his family members fly on his planes, whether they are running his business on his behalf or running interference with foreign leaders, the more the Secret Service will end up paying for seats alongside them.

In fact, there are already signs that the Trump Organization has no qualms about making money off of the New York tower’s new security arrangements in more ways than one. According to Politico, just five days after the election, a prominent New York real-estate firm invoked Trump Tower’s new secret-service detail as a selling point for a $2.1 million condominium, which it described as “The Best Value in the Most Secure Building in Manhattan.” Though the flier was issued by an outside agency, the president’s corporation still stands to benefit from increased traffic through processing and other service fees, making the advertisement a clear example of how Trump stands to benefit off of his new position.

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That Property in Georgia (the Country)

Trump’s election has had the effect of speeding up development on a number of his branded properties, even when the president appears not to be pulling any strings himself. As occurred with Trump Tower Buenos Aires, the completion of an embattled Trump-branded building in the former Soviet republic of Georgia is no longer on hold now that Trump has won. The project, which has been in the works in the seaside resort city of Batumi since 2010, was initially scheduled to break ground in 2013, but has been in stasis for several reasons, possibly including the 2013 electoral defeat of President Mikheil Saakashvili, a friend of Trump’s and a supporter of the deal.

According to a report in The Washington Post, the green-lighting of the Trump property in Batumi has not been linked to a specific conversation with Georgian leaders, and a U.S.-based partner on the project has suggested that it has moved forward without any nudging from the government. However, numerous public statements in the days since suggest that Trump’s election was a major factor, including an interview with a real-estate entrepreneur who said, “Cutting the ribbon on a new Trump Tower in Georgia will be a symbol of victory for all of the free world.”

That the property seems to be moving forward solely because Trump was elected suggests his various business interests around the world may play a role not only in his foreign policy but in how other countries seek to deal with the U.S. as well. America’s relationship with Georgia is largely shaped by concerns about Russian influence and potential aggression in the region, most recently manifested in Russia’s 2008 seizure of two regions of Georgia, South Ossetia and Abkhazia. With controversy already swirling over Trump’s admiration for Putin and Russia’s alleged role in the U.S. election, some in the foreign-policy community have expressed trepidation that Trump’s potential deferential attitude toward Russia would prove deleterious for the continued independence of former satellite nations like Georgia. So, if Georgia has an ulterior motive behind the approval of Trump’s property in Batumi, it would be to keep Russia at bay and maintain the status quo in the region.

According to Trump and his lawyer, as of January 11, the Trump Organization has suspended ongoing development projects and will no longer pursue deals in foreign countries. As the project in Batumi falls under both categories, the statement suggests that progress on the president’s property in the city is no longer moving forward. Still, it’s alarming that a country like Georgia may be giving Trump’s businesses favorable treatment (whether he asked for it or not) in an attempt to influence his foreign policy.

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That Phone Call With Erdogan

One of the worries regarding Trump’s many conflicts of interest is that they may influence policy towards countries whose relationships with the U.S. are currently strained. Such is the case with Turkey, whose president, Recep Erdogan, has been cracking down significantly on civil liberties and democratic institutions within the country after a failed coup last summer. Though Turkey has in the past been a vital U.S. ally as a bulwark against Islamic terror, Erdogan’s authoritarian turn and combative stance toward Europe have led to some reevaluation of that relationship.

Thus, it was troubling news that when Erdogan phoned Trump shortly after the election—it was one of the first calls Trump received after his victory—Trump used the opportunity to plug his business partners in Istanbul. According to the Huffington Post, while on the line with Erdogan, Trump relayed praise for the leader from Mehmet Ali Yalcindag, whose father-in-law, Aydin Dogan, owns the holding company that operates the Trump Towers in Istanbul. Dogan has previously drawn Erdogan’s ire by criticizing the leader; in recent years, however, Dogan’s companies, most notably CNN Turk, have shown support for Erdogan’s regime, including broadcasting his first message after the uprising in July.

Trump’s conversation with Erdogan is also worth noting because of a number of Trump’s previous statements regarding the Turkish president. Though Erdogan briefly called for Trump’s name to be removed from the Istanbul property due to his proposed ban on Muslim immigration, Erdogan dropped the demand when, after the overthrow attempt, Trump praised Erdogan for “turning it around” and essentially dismissed concerns over Erdogan’s crackdown on civil liberties by bringing up domestic problems. Michael Flynn, who was recently named Trump’s national security adviser, wrote an election-day op-ed in The Hill arguing against offering asylum to a Muslim cleric whom Erdogan has accused of orchestrating the uprising, which some have interpreted as a diplomatic overture. Erdogan has also bristled at post-election protests in the U.S. and the description of both himself and Trump as part of a “ring of autocrats.” That the two are now talking about their countries’ relationship as in the same conversation as Trump’s business interests further complicates Trump’s strangely effusive comments about Erdogan.

It’s worth noting that Trump himself considers his hotel in Istanbul a potential conflict of interest. In a December 2015 interview with Stephen Bannon, at the time the chairman of Breitbart News, Trump said as much, telling Bannon, “I have a little conflict of interest ‘cause I have a major, major building in Istanbul. It’s a tremendously successful job.” That he chose to discuss the towers with Erdogan, albeit obliquely, through his references to his business partners when he has already acknowledged the impropriety of doing so simply reinforces the perception that he may prove unable to separate his business from his official duties while in office.  

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That Hotel in Washington, D.C.

The White House is not the only new Trump property in Washington, D.C.; there’s also the new Trump International Hotel, which opened in October and is located just a few blocks away in what was formerly known as the Old Post Office Pavilion. Previously, the hotel played a role in the campaign as the site of the event at which Trump recanted (sort of) his belief that Barack Obama was not born in the United States. Now, the hotel is at the center of speculation as a symbol of how inextricable Trump’s presidential role may be from his personal interests.

First and foremost, since his election, ethics groups and critics of the president have repeatedly alleged that, simply by taking office, Trump has been in continual violation of the lease he holds on the Old Post Office, the government-owned building the Trump International Hotel inhabits. At issue is a clause in the lease stating 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.” As such, watchdog organizations such as Citizens for Responsibility and Ethics in Washington have repeatedly appealed to the Government Services Administration, the federal agency that administers the lease, to terminate the agreement with the Trump Organization.

On March 23, however, the GSA released a letter finding that Trump “is in full compliance” with the lease. According to Kevin Terry, the contract officer who oversaw the initial negotiations between the government and Trump, the president’s plan to turn over his businesses to his two adult sons and the long-time Trump Organization executive Alen Garten is sufficient to meet the terms of the agreement, as Trump is no longer “an officer, director, manager, employee, or other official in any of the entities” involved in operating the hotel. The letter immediately drew outcry from ethics organizations like CREW, which called the ruling “a disappointment” that failed to address the underlying problems of Trump’s businesses, and the left-leaning advocacy group Public Citizen, which described it as “an affront to the rule of law” based on “tortured and wholly uncompelling analysis” that “would get a first-year law student kicked out of law school.”

The GSA’s decision may also prove a blow to the more general argument that Trump has not done enough to distance himself from his namesake organization. Critics have strenuously objected to the plan Trump and his lawyer Sheri Dillon laid out on January 11 to mitigate conflicts of interest, under which the president has stepped down from, but retains ownership of, his numerous business interests, and placed his assets in a trust to be administered by his adult sons and Garten. His opponents maintain that, because Trump still has significant knowledge of his business interests and will still be benefiting from them, and because he has put in place few real barriers between himself and his sons, there is still ample opportunity for outside actors to seek to influence the president’s decisions by patronizing his companies. Though the letter from the GSA discusses only the Trump International Hotel and not the legality of the overall arrangement, it is nonetheless a decidedly favorable outcome for Trump in the first legal challenge over his conflicts of interest.

As if its location didn’t pose enough of an ethical question, the hotel has already hosted at least one promotional event specifically aimed at enticing foreign diplomats to stay at the establishment while in town on official state business. On the one hand, direct influence will likely be difficult to prove: The establishment is, after all, a five-star hotel that would have been likely to attract high-class clientele even if Trump had lost the election, a fact to which Trump and those who surround him may well point in order to maintain a patina of respectability around their dealings. Still, the meeting’s proximity to the election reinforces that it will be worth watching the comings and goings at the hotel closely for signs that Trump, who so often accused his opponent (often without evidence) of pay-for-play, may be using his position as president to promote his businesses.

Trump himself acknowledged that his presidency is likely to increase traffic to his Washington, D.C. property. Speaking to The New York Times, the president noted that the property is “probably a more valuable asset than it was before” and that his brand is “hotter” since the election. However, he went on to insist that there was nothing even potentially problematic about his unprecedented situation and that he sees no reason why he couldn’t run both the presidency and his business without conflict.

Multiple events since the election have made Trump’s lease on the hotel a central focus of discussions of his conflicts of interest, including among Democrats in the House. On November 29, Bahrain—a country whose donations to the Clinton Foundation Trump and his campaign decried during the campaign—announced that it would be celebrating the anniversary of its king’s ascension to the throne at the hotel. Other events announced since the election include a Hannukah celebration co-hosted by the Embassy of Azerbaijan and the Conference of Presidents of Major American Jewish Organizations and a reception for the conservative think tank the Heritage Foundation featuring Vice President Mike Pence as its keynote speaker.

Nor did the string of bookings by international entities end after Trump’s inauguration: On February 9, Politico reported that a lobbying group with connections to the government of Saudi Arabia had booked a four-day stay at the hotel in Washington, D.C. And on March 13, The Daily Caller reported that the Turkish-American Business Council will be co-hosting its annual conference at the Trump International Hotel after a seven-year runat the Ritz-Carlton. The latter announcement is especially notable because the organization’s chairman, Ekim Alptekin, is involved in another of the Trump administration’s scandals: One of Alptekin’s companies, the apparent shell company Inovo BV, paid $530,000 to the former National Security Adviser Michael Flynn to lobby on behalf of the Turkish government, which prompted Flynn to register as a foreign agent shortly after he was ousted from the Trump administration for lying about his contacts with Russian agents while a member of the president’s transition team.

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That Argentinian Office Building

According to a report by the prominent Argentine journalist Jorge Lanata, the president’s first phone call with his Argentine counterpart Mauricio Macri included a discussion of the permit issues currently holding up construction of a new Trump-branded office building in Buenos Aires. Both Macri and Trump quickly denied the report; according to a statement from the Embassy of Argentina, “The subject both leaders talked about was the institutional relationship, and they briefly mentioned the personal relationship they have had for years.”

As summarized in a tweetstorm here, Trump’s relationship with Argentina’s government and business elites—and the story so far on his property there—is already long and convoluted. The phone call with Macri was apparently set up through Felipe Yaryura, one of Trump’s longtime associates whose company, YY Development Group, is in charge of Trump Tower Buenos Aires. The day after the phone call, the PanAm Post reported that YY Development Group had been approved to break ground in June 2017; evidence has since emerged that the permitting process is not, in fact, finished, although Trump’s business associates are moving ahead as though it is.

Based on the information at the president’s January 11 press conference, it appears that the properties in Argentina, as both ongoing development projects and deals in a foreign country, is no longer moving forward. Nevertheless, the questionable circumstances under which it did so in the immediate aftermath of the election demonstrates just how many avenues there are for Trump’s conflicts of interest to interfere with governance around the world.  

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Those Companies in Saudi Arabia

Even as Trump was running for president, his company was continuing to operate and open new properties. While the most memorable openings may have been that of his hotel in Washington, D.C., and his golf course in Turnberry, Scotland, the Trump Organization was continuing to work on projects in other countries, including, according to a report the Washington Post, registering eight new companies in Saudi Arabia during the 16-month campaign.

The organization’s endeavors in Saudi Arabia are notable not only because they may further complicate the shaky relationship between the U.S. and an oil-rich gulf state notorious for human-rights abuses but also because of how they relate to Trump’s campaign rhetoric. One of his criticisms of Hillary Clinton was that her charitable foundation had accepted donations from governments with questionable records on human rights, most notably Qatar and Saudi Arabia, always with the implication (or direct accusation) that they were doing so to curry favor with Clinton when she was secretary of state. That Trump was continuing to level this criticism while his namesake organization was actively pursuing new projects in Saudi Arabia not only bodes ill for his ability to separate his personal and presidential interests but also further calls into question the honesty and transparency of his campaign.

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That British Wind Farm

As he indicated when he stopped there during the campaign, President Trump takes enormous pride in his recently opened golf course in Turnberry, Scotland. The day after the British public voted for Brexit—over intense Scottish opposition—Trump spoke at the property’s opening, proudly touting how the decision’s deflationary effect on the pound would benefit his business.

However, Trump also has a second golf course in Aberdeen, where it appears Trump has attempted to intercede in the interest of his own pocketbook.* According to The New York Times, Trump had a post-election meeting with Nigel Farage in which he “encouraged Mr. Farage and his entourage to oppose the kind of offshore wind farms that Mr. Trump believes will mar the pristine view from one of his two Scottish golf courses.” Hope Hicks, a spokeswoman for the president, denied that the two had discussed the subject, only for Trump to later confirm that the topic had, in fact, come up in their conversation.

* This entry originally misstated that Trump intervened at Turnberry, his other golf course in Scotland. We regret the error.

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Those Indian Business Partners

It didn’t take long after the election for President Trump to be seen in public with international business partners. According to a November 19 article in The New York Times, Trump took a break from his transition schedule to meet with three Indian real-estate executives who are currently building a Trump-branded apartment complex in Mumbai. According to both Trump and the Indian businessmen, the meeting was essentially congratulatory in nature; a picture posted by one of the executives on Twitter shows the four men smiling broadly and giving a thumbs-up to the camera. However, that the meeting happened in the first place suggests that Trump does not currently have any qualms about forestalling official state business for personal business.

On top of that, the meeting raises questions in the blind-trust realm as well. The president himself was not the only member of his family there; two Facebook photos show that Ivanka and Eric Trump both attended the meeting as well. Their presence serves as a reminder that their father seems so far uninterested in maintaining even the nominal separation between himself and his assets that he repeatedly said he would create during the campaign.

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That Envoy From the Philippines

One leader with whom Trump already has an advantage over President Obama is Rodrigo Duterte, the similarly brash president of the Philippines. Duterte, who has threatened to “break up with America,” told Obama to “go to hell,” and called the president a “son of a whore,” expressed admiration for Trump, noting that, among other similarities, they both enjoy swearing.

Duterte’s affinity for Trump apparently goes beyond vulgar word choice. Late in October, Duterte appointed a longtime business associate of Trump’s as a special envoy to the United States, an announcement that became public shortly after the election. This appointment in particular raises questions because it is just as open to exploitation by Duterte as it is to Trump, as the Filipino president could intend to use his new envoy’s relationship with Trump to strengthen the Philippines’ hand. Whichever side the appointment does eventually benefit, however, the situation is nevertheless fraught with conflicts between the three men’s personal and political interests.

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JAKARTA, Indonesia — China Great Wall Industry Corp. has clinched a contract with an Indonesian joint venture to build a replacement for a satellite that is running out of fuel early due to an underperformed Long March launch.

Palapa Satelit Nusantara Sejahtera, a joint venture of Indosat Ooredoo and Pasifik Satelit Nusantara (PSN), signed the contract for Palapa-N1, a high-throughput Ku-band satellite with 10 Gbps of capacity here May 17 with Beijing-based CGWIC, a subsidiary of China Aerospace Science and Technology Corporation.

CGWIC also received a non-binding agreement for a second satellite with PSN — a Ka-band high-throughput satellite called PSN-7 that would deliver 100 Gbps of capacity through 104 spot beams covering Indonesia, the Philippines and other Southeast Asian countries.

Palapa-N1 is the second commercial satellite that CGWIC has won with an established satellite operator in less than a year’s time. In October 2016, Thaicom purchased a Ka-band high-throughput satellite from CGWIC, proving the company’s intention and ability to compete more aggressively on the commercial market. Both are based on the DFH-4 platform.

CGWIC, the only company with the Chinese government’s approval to do commercial satellite manufacturing and launch, has primarily done business with entirely new satellite operators. The United States’ International Traffic in and Arms Regulations, known as ITAR, restrict American satellites, and satellites with certain American components, from launching on Chinese rockets — a rule that has largely isolated China on the international market, often prompting CGWIC to bundle satellite orders with launches to avoid this problem altogether.

According to Sun Weide, charge d’affaires of the Chinese Embassy in Indonesia, China and Indonesia have strengthened space ties through cooperation agreements signed in 2013 and 2015.

“I believe the signing of this very important agreement today between CGWIC and PSNS will create new opportunities and make a good example for our mutually beneficial cooperation,” Sun Weide, charge d’affaires of the Chinese Embassy in Indonesia, said May 17 here immediately preceding the contract signing.

Additionally, Surya University in Banten, Indonesia, is building a telecommunications cubesat with assistance from PSN and CGWIC.

Palapa-N1 is a replacement for Palapa-D, an Indosat satellite that initially failed to reach geostationary transfer orbit because of a subpar Long March 3B launch in 2009. Thales Alenia Space, manufacturer of the Palapa-D satellite, used some of the fuel initially meant for station-keeping to instead raise the satellite to its proper orbit. The orbit-raising maneuver shortened the satellite’s expected lifespan to 11 years instead of the typical 15.

In a more expansive agreement than other deals, CGWIC is providing not only the satellite and a Long March 3B launch, but also the ground control system, insurance and financing support for Palapa-N1.

PSN’s constellation plans

With Palapa-N1 and PSN-7, PSN CEO Adi Rahman Adiwoso said the operator is planning to have a fleet of four satellites in orbit by 2021.

“We will invest close to $900 million within the next four years,” he said. “Today three satellites are fully funded, and we are working to fund the fourth one.” 

The funded satellites are PSN-6, a C- and Ku-band satellite ordered from Space Systems Loral in 2014 that is scheduled to launch next year on a SpaceX Falcon 9 rocket, the Palapa-N1 joint venture satellite, and the ageing Palapa-D. Adiwoso said PSN will seek to prolong the life of Palapa-D by moving it from 113 degrees east into a different orbit at 144 degrees east. Adiwoso said 70 percent of the capacity on PSN-6 is already sold.

These satellites, combined with the capacity of Indonesia’s other domestic operators, PT Telkom and Bank Rakyat Indonesia, will bring 150 Gbps of satellite capacity to the country, by Adiwoso’s estimate.

“I think 150 Gbps will bring the capabilities in Indonesia to reply to the demand growth,” he said. “There is still room for others to play in Indonesia, but I think we will start taking control like this.”

SpaceNews.com

The global creative industries have never been stronger. According to a 2015 report from UNESCO, in 2013, the creative economy employed nearly 30 million people worldwide and generated $2.25 billion in revenue – accounting for three per cent of the world’s GDP. 

Since then, the global creative industries have continued to grow, driving economic growth and raising quality of life all over the world. This is great news for designers: whether you’re considering a permanent change of scenery post Brexit or Trump, or simply planning an inspirational holiday, there are dozens of exciting cities to choose from.

• 5 creative cities for weekend getaways

So where are the most amazing places to live, work and visit as a creative professional? We’ve analysed the stats to bring you 10 of the best.

Of course, this isn’t a definitive list – we haven’t mentioned Tokyo, Paris, San Francisco or Sydney, to name but a few. And should we have included the world’s leading supercities, London and New York, when increasingly unaffordable rents are forcing some creatives out of the city?

Debate aside, what we can tell you is that the following cities are shining examples of creative economies. Each has its challenges, but all are packed with culture, innovation and stunning examples of design being used for good. Read on for some truly global inspiration…

01. Mexico City

Recently named one of the 50 most beautiful cities in the world by Condé Nast Traveler, Mexico City will become the sixth World Design Capital in 2018. The title recognises Mexico City’s commitment to using design as an effective tool for economic, social and cultural development – making it an inspirational model for other global cities, and an attractive destination for creatives.

Home to branches of world-class design studios like Anagrama – which has more Facebook followers than Sagmeister & Walsh – the city isn’t short on design talent or work opportunities. Nearly every major American corporation has a presence in the oldest capital in the Americas, from Apple and Amazon to Procter & Gamble, and in 2014, the creative sector accounted for seven per cent of the GDP.

“There’s a lot of work; everyone is busy,” says Rafael Prieto, co-founder of branding and architecture agency, Savvy Studio. “There are a lot of companies and the city itself is all about entrepreneurship – there’s always someone opening something. Competition exists, but it’s healthy and makes things interesting.”

The cost of living in Mexico City might be higher than the national average, but so are average design wages, points out Prieto, although they’re still a whopping 60 per cent lower than in London. And inspiration is everywhere: Mexico City is a melting pot of history and culture. Recognised as a World Heritage City in 1987, historic monuments like the Palacio de Bellas and ancient Aztec temple ruins Templo Mayor attract tourists from all over the world, while numerous museums, art galleries and theatres provide constant cultural activity.

“I chose to live in Mexico City because of its character,” says Prieto. “It’s relevant, it has energy, and somehow it feels that there are possibilities – creative people from everywhere are all busy just doing their thing,” he smiles.

02. Berlin

Long a hotspot for the trendy start-up scene, Germany’s culturally diverse, tolerant and cosmopolitan capital remains a thriving mecca for talented creative minds from all around the world.

In fact, according to the UNESCO Creative Cities Network Monitoring Report 2008-2016, creativity is Berlin’s key distinguishing feature today. More than 195,000 people are currently working in the creative industries – that’s 10 per cent of all employees in Berlin. The city’s 30,000 companies in the sector generate a yearly turnover of more than €18 billion, adds the report, which shows that a dense landscape of design companies, service providers, showrooms, fairs and sales platforms has emerged in the last decade.

So why is Berlin so attractive to designers? With consistently high scores in international rankings for quality of life, affordable rents and moderate cost of living, it’s an economically viable proposition for studios, freelancers and big business alike. Factor in the city’s rich cultural offerings, vibrant atmosphere and outstanding education facilities, and it’s not difficult to see why heavy hitters like Edenspiekermann have a base here.

“Berlin’s vibe is much more chilled than, say, London,” says Lauren Kelly, a ‘designer-comepsychologist’ at design studio DURA, and founder of Glug Berlin. “There’s more of a focus on quality of life and life outside of work – the lower cost of living, sprawling parks and long summers definitely help. Money goes further, so there’s time to play, experiment and work on side projects.”

If you’re visiting the city, she suggests taking a walk to Teufelsberg. “It used to be NSA’s listening towers before the wall fell,” she explains. “Afterwards it became the playground of graffiti artists. It’s a great spot to enjoy breathtaking views.”

According to Coroflot, the median annual salary for a graphic designer is €36,000. That’s lower than other capital cities, says Kelly, but she points out that pay goes further in Berlin. “There’s a lot of opportunity for designers, especially those working in digital and product, due to increasing investment in the start-up scene,” she adds. “You can already see the influx of talent and business after recent political shifts outside of Germany. It’s a really exciting time to be here.”

03. New York

A raft of research puts New York City as the world’s leading creative hub. According to EY’s Global Talent in Global Cities 2015 study, New York takes the top spot for “creative class attraction”. Its unique cultural scene is, it says: “embedded in a cosmopolitan and forward-thinking urban environment, generally considered beneficial to creative activities.”

Certainly much work is available: NYC is America’s capital of finance and law, and with big business comes big design opportunities – as the city’s dense network of studios and agencies attests. According to AIGA, in 2014, NYC had 52 per cent more graphic design jobs than the next most-concentrated US city it studied (Los Angeles).

But competition between design shops is high. “New York attracts super bright people, all aiming for the same prize: to be the best. It takes incredible focus, discipline and hard work to run a business here,” points out Richard Cumming, owner of experiential marketing agency Two Goats Creative and founder of the New York Chapter of Glug. He’s worked at leading advertising agencies around the world and says NYC is one of the most multi-sensorial, immersive cities he’s ever lived in: “Between every blink, I take in a wealth of creative inspiration. And it’s great for networking.”

Salaries are good. Coroflot puts the median graphic designer annual wage at $51,000; while others place it closer to $65,000. “If you’re a good freelance senior designer, you could earn $1,250 per day,” adds Cumming. But with the cost of living 20 per cent more in NYC than London, and 68 per cent more than the average US state (AIGA), it doesn’t always go far. “Apartments are small and expensive, food is expensive, medical is ridiculously complicated and expensive, and entertainment is amazing – but expensive,” he says.

However, despite many arts organisations being priced out of Manhattan, NYC’s economic power, openness to ideas and world-class cultural assets remain a potent combination for creatives.

“The vibe is electric, enthusiastic, positive, progressive, exploratory, encouraging, competitive, courteous and kind,” says Cumming. “It’s not just about the city either: New York state is vast and has much to offer – I encourage you to explore all of it.”

04. London

When the New York Times declared London the design capital of the world in September 2012, there were 1.7 million jobs in the creative industries across the UK. By 2015, this figure had risen to 1.9 million, with a huge 40 per cent of those based in the capital. One thing is clear: despite the growth of creative clusters like Bristol, Manchester and Edinburgh, London remains the epicentre of the UK’s booming creative industries.

Steeped in history, London is a magnetic, multicultural metropolis that attracts business, tourism and talent. A world-class education system ensures a culturally diverse incubation of design talent, while a wealth of high-profile international design firms promise jobs, competition and opportunity. “London has top-class music, art, fashion, sport, tech, film and design – the list doesn’t really end,” agrees Hamish Gardner, a designer at creative agency The Beautiful Meme. “As graphic designers, we have the privilege to dip in and out of these worlds. I’d recommend it to anyone.”

Yet London failed to make the world’s top 30 cities for best quality of life in Mercer’s 2016 survey. Social unrest dented the capital’s stability during the 2011 London riots, and today the UK faces new challenges with Brexit. Cost of living, too, is wildly inflated compared to the rest of the country.

So how tough is it to make it as a designer in the Big Smoke? “Entry level internships and placements normally pay London ‘living wage’ – £19K per year,” reflects Gardner. “A junior salary will make things easier, but we’re talking about London. We pay twice whatever you do for what you buy.”

Nevertheless, London remains a tantalising creative prospect. “Competition is tough, but the huge wash of agencies and studios that range in discipline from packaging to 3D allows you to specialise, and carve a niche for your creative path without alienating too many job opportunities,” he adds. “This alone is a huge advantage to seeking meaningful design work in London.”

05. Cape Town

A visit to Cape Town soon shows why designers are drawn to the city. The 2014 World Design Capital is home to a number of flagship global industry events, including the annual Design Indaba conference and festival, as well as a high number of design-led organisations, events, networks and publications.

Inspiration is everywhere. Influenced by Zulu, Xhosa and other African tribes – as well as Dutch, British, German, French and Indonesian settlers – distinct neighbourhoods with diverse histories and architecture offer cultural stimulation, while breathtaking landscapes, an agreeable climate and a relatively low cost of living add to the appeal. Statistics from Numbeo show that the cost of living in Cape Town is 55.45 per cent lower than in New York and 46.38 per cent lower than London. Wages are lower, too, of course: according to Ad Talent’s 2016 salary survey, graphic designers with two to five years’ experience earn on average between R168,000-300,000 per year (versus R192,000-R360,000 in Johannesburg).

However, while South Africa has made significant strides since 1994 to reduce extreme poverty and crime, Cape Town ranked within the 10 most violent cities in the world in the most recent report from the Mexican Council for Public Security and Criminal Justice. Nevertheless, creativity is a key driver of growth. The Design Indaba Expo, for example, contributed more than R2 billion to the South African GDP over the seven years in which it ran.

Pure Creative founder Andrew Burke returned to South Africa in the 1990s after 10 years living and working in the UK. He watched a new energy develop after Mandela’s release in 1990: “This energy passed over into the world of design and was simply electric,” he recalls. “From typographers to product manufacturers, fashion designers and artists, creatives are no longer ashamed to be African. We have embraced our unique history, taking inspiration from the geographic colours, landscape textures and the many tribes of Africa to develop an entirely new style that can stand proudly on the international design stage. It’s an exciting design hub,” he says.

06. Seoul

A fast-paced metropolis with a vibrant pop culture, ancient historical sites, exciting nightlife, an innovative arts scene and one of the world’s fastest digital infrastructure systems, Seoul has transformed into a prosperous, global cultural capital in a remarkably short amount of time. Since the 1990s, the South Korean government has targeted the creative industries to drive growth – and with approximately 73 per cent of Korean designers concentrated in Seoul, the city sits firmly at the heart of the national design scene.

Cost of living is only 2.5 per cent lower than in London, but low crime rates, high quality of life and a thriving design scene make it an attractive destination for creatives. “Lots of things happen here – projects, festivals and exhibitions,” confirms Jin Kang, a member of Seoul-based design collective Ordinary People. “It’s fast-paced, and this atmosphere challenges us to create cool new projects. There are a lot of opportunities and many fun people. We recommend a visit.”

07. Barcelona

There’s more to Barcelona than the Sagrada Família, Antoni Gaudí and the Picasso Museum. Design is everywhere: bold logos and vibrant identities cover the buses, beach and boulevards, while a rich concentration of progressive studios and freelancers – including the likes of Mucho, Hey, Toormix and Folch – continue to raise the stakes in exciting, forward-thinking design.

Barcelona is undoubtedly an attractive proposition for creatives. But despite its cultural diversity and ideal climate, the city dropped to 39 in Mercer’s 2016 Quality of Living Survey after the recession, which hit the city hard. “‘Rent’ has become the world’s most hated word here,” says Nathalie Koutia, communications director of OFFF Barcelona. She adds that creatives in Barcelona are more likely to be working for companies abroad than on local projects.

Hey founder Verònica Fuerte agrees. “There aren’t a lot of opportunities here, and Barcelona is becoming very expensive to live. The cost of living has gone up but our salaries haven’t.”

However, neither wouldn’t leave: “I love it here,” says Fuerte. “It’s intimate, uncomplicated and exciting. The design scene is very active – there’s a lot of collaboration – and there’s a good balance between work and life. I can’t imagine living in a city where it’s grey all day.”

08. Buenos Aires

Dubbed the ‘Paris of the Southern Hemisphere’, Buenos Aires is a seductive city of contrasts and contradictions. Skyscrapers sit alongside shanty towns; global trends are interpreted with the city’s effervescent Latin lifeblood. “It’s magical and crude at the same time,” says Mariano Sigal, founder of multidisciplinary design studio Cinco. “An air of freedom and non-prejudice transits its streets, and this is translated into the design scene: simple, neutral lines coexist with pop colours; French curves are mixed with rational and modernist terminations. There is an orderly disorder that’s very difficult to describe.”

Between 2004 and 2012, the creative sector grew by 89.1 per cent in real terms, according to UNESCO’s 2016 Buenos Aires City of Design report. Today it represents up to 8.6 per cent of the city’s GDP and 9.1 per cent of the city’s workforce, employing almost 150,000 people. “Unfortunately, the country is in a recessive stage, economically speaking,” says Sigal, adding that independent designers have responded by creating “small, genuine brands” – which is where the interesting work is, in lieu of a large local client pool. “Designers can support themselves, though, and live in Buenos Aires in a dignified way – they can have good wine from time to time and enjoy the wonderful Argentine beef,” he adds.

Mercer’s 2016 Quality of Living Survey ranked Buenos Aires relatively low (93rd out of 230 countries) thanks to issues in safety and drug-related violence, but with a low cost of living (34.65 per cent lower than London), good work-life balance and a rich cultural heritage, Buenos Aires remains an attractive proposition for expats and visitors.

09. Montreal

Montreal isn’t called a ‘city of designers’ for nothing. Data obtained by UNESCO shows that in 2015, over 25,000 designers worked in the city, with the field responsible for 34 per cent of the overall economic impact of the cultural sector. With a thriving arts and music scene, Montreal is young, multicultural and boasts some of the most exciting names in the industry – including studio Vallée Duhamel.

“Montreal is big enough to have all the good parts of a city; nice museums, great restaurants and a very good music scene, but at the same time it’s small enough that you can connect with a lot of different people and grow a network that’s really interesting professionally,” says Julien Vallée, cofounder of Vallée Duhamel. He highlights Mile End – an ethnically diverse neighbourhood in-between Montreal’s francophone and anglophone districts – as a particularly active neighbourhood for creatives.

Salaries tend to be a little lower than other cities in Canada – Payscale.com puts Montreal’s median graphic designer salary at C$40,222 – but the cost of living is lower too. “There are a lot of great studios and freelancers here,” adds Vallée.

10. Melbourne

In Melbourne, food and drink are taken as seriously as design. Peer into any of the city’s gritty alleyways and you’ll be rewarded with cool cafes, trendy bars and boutique galleries, while a thriving design culture ensures creativity around every corner. “You can’t walk far without seeing a really well-crafted piece of graphic communication, cool sign or cafe identity,” says Pete Johnson, founder of design studio Can I Play. “There are world-class graphic, fashion and furniture designers along with some of the best architects on the planet. Inspiration is only a block or two away.”

Average pay sits around AU$50,190 per year, says PayScale, but while cost of living is cheaper than Sydney, Melbourne isn’t cheap. “Housing prices are though the roof,” says Johnson, adding that design is a popular career choice so competition for jobs can be tough. “That said, it’s a great place to get in the mood to design. And everyone seems to be having a good time on a Friday evening!”

This article was originally published in Computer Arts magazine issue 264. Buy it here.

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You were going to get one-click access to the full text of nearly every book that’s ever been published. Books still in print you’d have to pay for, but everything else—a collection slated to grow larger than the holdings at the Library of Congress, Harvard, the University of Michigan, at any of the great national libraries of Europe—would have been available for free at terminals that were going to be placed in every local library that wanted one.

At the terminal you were going to be able to search tens of millions of books and read every page of any book you found. You’d be able to highlight passages and make annotations and share them; for the first time, you’d be able to pinpoint an idea somewhere inside the vastness of the printed record, and send somebody straight to it with a link. Books would become as instantly available, searchable, copy-pasteable—as alive in the digital world—as web pages.

It was to be the realization of a long-held dream. “The universal library has been talked about for millennia,” Richard Ovenden, the head of Oxford’s Bodleian Libraries, has said. “It was possible to think in the Renaissance that you might be able to amass the whole of published knowledge in a single room or a single institution.” In the spring of 2011, it seemed we’d amassed it in a terminal small enough to fit on a desk.

“This is a watershed event and can serve as a catalyst for the reinvention of education, research, and intellectual life,” one eager observer wrote at the time.

On March 22 of that year, however, the legal agreement that would have unlocked a century’s worth of books and peppered the country with access terminals to a universal library was rejected under Rule 23(e)(2) of the Federal Rules of Civil Procedure by the U.S. District Court for the Southern District of New York.

When the library at Alexandria burned it was said to be an “international catastrophe.” When the most significant humanities project of our time was dismantled in court, the scholars, archivists, and librarians who’d had a hand in its undoing breathed a sigh of relief, for they believed, at the time, that they had narrowly averted disaster.

* * *

Google’s secret effort to scan every book in the world, codenamed “Project Ocean,” began in earnest in 2002 when Larry Page and Marissa Mayer sat down in the office together with a 300-page book and a metronome. Page wanted to know how long it would take to scan more than a hundred-million books, so he started with one that was lying around. Using the metronome to keep a steady pace, he and Mayer paged through the book cover-to-cover. It took them 40 minutes.

Page had always wanted to digitize books. Way back in 1996, the student project that eventually became Google—a “crawler” that would ingest documents and rank them for relevance against a user’s query—was actually conceived as part of an effort “to develop the enabling technologies for a single, integrated and universal digital library.” The idea was that in the future, once all books were digitized, you’d be able to map the citations among them, see which books got cited the most, and use that data to give better search results to library patrons. But books still lived mostly on paper. Page and his research partner, Sergey Brin, developed their popularity-contest-by-citation idea using pages from the World Wide Web.

By 2002, it seemed to Page like the time might be ripe to come back to books. With that 40-minute number in mind, he approached the University of Michigan, his alma mater and a world leader in book scanning, to find out what the state of the art in mass digitization looked like. Michigan told Page that at the current pace, digitizing their entire collection—7 million volumes—was going to take about a thousand years. Page, who’d by now given the problem some thought, replied that he thought Google could do it in six.

He offered the library a deal: You let us borrow all your books, he said, and we’ll scan them for you. You’ll end up with a digital copy of every volume in your collection, and Google will end up with access to one of the great untapped troves of data left in the world. Brin put Google’s lust for library books this way: “You have thousands of years of human knowledge, and probably the highest-quality knowledge is captured in books.” What if you could feed all the knowledge that’s locked up on paper to a search engine?

By 2004, Google had started scanning. In just over a decade, after making deals with Michigan, Harvard, Stanford, Oxford, the New York Public Library, and dozens of other library systems, the company, outpacing Page’s prediction, had scanned about 25 million books. It cost them an estimated $400 million. It was a feat not just of technology but of logistics.

Every weekday, semi trucks full of books would pull up at designated Google scanning centers. The one ingesting Stanford’s library was on Google’s Mountain View campus, in a converted office building. The books were unloaded from the trucks onto the kind of carts you find in libraries and wheeled up to human operators sitting at one of a few dozen brightly lit scanning stations, arranged in rows about six to eight feet apart.

The stations—which didn’t so much scan as photograph books—had been custom-built by Google from the sheet metal up. Each one could digitize books at a rate of 1,000 pages per hour. The book would lie in a specially designed motorized cradle that would adjust to the spine, locking it in place. Above, there was an array of lights and at least $1,000 worth of optics, including four cameras, two pointed at each half of the book, and a range-finding LIDAR that overlaid a three-dimensional laser grid on the book’s surface to capture the curvature of the paper. The human operator would turn pages by hand—no machine could be as quick and gentle—and fire the cameras by pressing a foot pedal, as though playing at a strange piano.

What made the system so efficient is that it left so much of the work to software. Rather than make sure that each page was aligned perfectly, and flattened, before taking a photo, which was a major source of delays in traditional book-scanning systems, cruder images of curved pages were fed to de-warping algorithms, which used the LIDAR data along with some clever mathematics to artificially bend the text back into straight lines.

At its peak, the project involved about 50 full-time software engineers. They developed optical character-recognition software for turning raw images into text; they wrote de-warping and color-correction and contrast-adjustment routines to make the images easier to process; they developed algorithms to detect illustrations and diagrams in books, to extract page numbers, to turn footnotes into real citations, and, per Brin and Page’s early research, to rank books by relevance. “Books are not part of a network,” Dan Clancy, who was the engineering director on the project during its heyday, has said. “There is a huge research challenge, to understand the relationship between books.”

At a time when the rest of Google was obsessed with making apps more “social”—Google Plus was released in 2011—Books was seen by those who worked on it as one of those projects from the old era, like Search itself, that made good on the company’s mission “to organize the world’s information and make it universally accessible and useful.”

It was the first project that Google ever called a “moonshot.” Before the self-driving car and Project Loon—their effort to deliver Internet to Africa via high-altitude balloons—it was the idea of digitizing books that struck the outside world as a wide-eyed dream. Even some Googlers themselves thought of the project as a boondoggle. “There were certainly lots of folks at Google that while we were doing Google Book Search were like, Why are we spending all this money on this project?,” Clancy said to me. “Once Google started being a little more conscious about how it was spending money, it was like, wait, you have $40 million a year, $50 million a year on the cost of scanning? It’s gonna cost us $300 to $400 million before we’re done? What are you thinking? But Larry and Sergey were big supporters.”

In August 2010, Google put out a blog post announcing that there were 129,864,880 books in the world. The company said they were going to scan them all.

Of course, it didn’t quite turn out that way. This particular moonshot fell about a hundred-million books short of the moon. What happened was complicated but how it started was simple: Google did that thing where you ask for forgiveness rather than permission, and forgiveness was not forthcoming. Upon hearing that Google was taking millions of books out of libraries, scanning them, and returning them as if nothing had happened, authors and publishers filed suit against the company, alleging, as the authors put it simply in their initial complaint, “massive copyright infringement.”

* * *

When Google started scanning, they weren’t actually setting out to build a digital library where you could read books in their entirety; that idea would come later. Their original goal was just to let you search books. For books in copyright, all they would show you were “snippets,” just a few sentences of context around your search terms. They likened their service to a card catalog.

Google thought that creating a card catalog was protected by “fair use,” the same doctrine of copyright law that lets a scholar excerpt someone’s else’s work in order to talk about it. “A key part of the line between what’s fair use and what’s not is transformation,” Google’s lawyer, David Drummond, has said. “Yes, we’re making a copy when we digitize. But surely the ability to find something because a term appears in a book is not the same thing as reading the book. That’s why Google Books is a different product from the book itself.”

It was important for Drummond to be right. Statutory damages for “willful infringement” of a copyright can run as high as $150,000 for each work infringed. Google’s potential liability for copying tens of millions of books could have run into the trillions of dollars. “Google had some reason to fear that it was betting the firm on its fair-use defense,” Pamela Samuelson, a law professor at UC Berkeley, wrote in 2011. Copyright owners pounced.

They had good reason to. Instead of asking for anyone’s permission, Google had plundered libraries. This seemed obviously wrong: If you wanted to copy a book, you had to have the right to copy it—you had to have the damn copyright. Letting Google get away with the wholesale copying of every book in America struck them as setting a dangerous precedent, one that might well render their copyrights worthless. An advocacy group called the Authors Guild, and several book authors, filed a class action lawsuit against Google on behalf of everyone with a U.S. copyright interest in a book. (A group of publishers filed their own lawsuit but joined the Authors Guild class action shortly thereafter.)

There’s actually a long tradition of technology companies disregarding intellectual-property rights as they invent new ways to distribute content. In the early 1900s, makers of the “piano rolls” that control player pianos ignored copyrights in sheet music and were sued by music publishers. The same thing happened with makers of vinyl records and early purveyors of commercial radio. In the 60s, cable operators re-aired broadcast TV signals without first getting permission and found themselves in costly litigation. Movie studios sued VCR makers. Music labels sued KazaA and Napster.

As Tim Wu pointed out in a 2003 law review article, what usually becomes of these battles—what happened with piano rolls, with records, with radio, and with cable—isn’t that copyright holders squash the new technology. Instead, they cut a deal and start making money from it. Often this takes the form of a “compulsory license” in which, for example, musicians are required to license their work to the piano-roll maker, but in exchange, the piano-roll maker has to pay a fixed fee, say two cents per song, for every roll they produce. Musicians get a new stream of income, and the public gets to hear their favorite songs on the player piano. “History has shown that time and market forces often provide equilibrium in balancing interests,” Wu writes.

But even if everyone typically ends up ahead, each new cycle starts with rightsholders fearful they’re being displaced by the new technology. When the VCR came out, film executives lashed out. “I say to you that the VCR is to the American film producer and the American public as the Boston strangler is to the woman home alone,” Jack Valenti, then the president of the MPAA, testified before Congress. The major studios sued Sony, arguing that with the VCR, the company was trying to build an entire business on intellectual property theft. But Sony Corp. of America v. Universal City Studios, Inc. became famous for its holding that as long as a copying device was capable of “substantial noninfringing uses”—like someone watching home movies—its makers couldn’t be held liable for copyright infringement.

The Sony case forced the movie industry to accept the existence of VCRs. Not long after, they began to see the device as an opportunity. “The VCR turned out to be one of the most lucrative inventions—for movie producers as well as hardware manufacturers—since movie projectors,” one commentator put it in 2000.

It only took a couple of years for the authors and publishers who sued Google to realize that there was enough middle ground to make everyone happy. This was especially true when you focused on the back catalog, on out-of-print works, instead of books still on store shelves. Once you made that distinction, it was possible to see the whole project in a different light. Maybe Google wasn’t plundering anyone’s work. Maybe they were giving it a new life. Google Books could turn out to be for out-of-print books what the VCR had been for movies out of the theater.

If that was true, you wouldn’t actually want to stop Google from scanning out-of-print books—you’d want to encourage it. In fact, you’d want them to go beyond just showing snippets to actually selling those books as digital downloads. Out-of-print books, almost by definition, were commercial dead weight. If Google, through mass digitization, could make a new market for them, that would be a real victory for authors and publishers. “We realized there was an opportunity to do something extraordinary for readers and academics in this country,” Richard Sarnoff, who was then Chairman of the American Association of Publishers, said at the time. “We realized that we could light up the out-of-print backlist of this industry for two things: discovery and consumption.”

But once you had that goal in mind, the lawsuit itself—which was about whether Google could keep scanning and displaying snippets—began to seem small time. Suppose the Authors Guild won: they were unlikely to recoup anything more than the statutory minimum in damages; and what good would it do to stop Google from providing snippets of old books? If anything those snippets might drive demand. And suppose Google won: Authors and publishers would get nothing, and all readers would get for out-of-print books would be snippets—not access to full texts.

The plaintiffs, in other words, had gotten themselves into a pretty unusual situation. They didn’t want to lose their own lawsuit—but they didn’t want to win it either.

* * *

The basic problem with out-of-print books is that it’s unclear who owns most of them. An author might have signed a book deal with their publisher 40 years ago; that contract stipulated that the rights revert to the author after the book goes out of print, but required the author to send a notice to that effect, and probably didn’t say anything about digital rights; and all this was recorded on some pieces of paper that nobody has.

It’s been estimated that about half the books published between 1923 and 1963 are actually in the public domain—it’s just that no one knows which half. Copyrights back then had to be renewed, and often the rightsholder wouldn’t bother filing the paperwork; if they did, the paperwork could be lost. The cost of figuring out who owns the rights to a given book can end up being greater than the market value of the book itself. “To have people go and research each one of these titles,” Sarnoff said to me, “It’s not just Sisyphean—it’s an impossible task economically.” Most out-of-print books are therefore locked up, if not by copyright then by inconvenience.

The tipping point toward a settlement of Authors Guild v. Google was the realization that it offered a way to skirt this problem entirely. Authors Guild was a class action lawsuit, and the class included everyone who held an American copyright in one or more books. In a class action, the named plaintiffs litigate on behalf of the whole class (though anyone who wants to can opt out).

So a settlement of the Authors Guild case could theoretically bind just about every author and publisher with a book in an American library. In particular, you could craft a deal in which copyright owners, as a class, agreed to release any claims against Google for scanning and displaying their books, in exchange for a cut of the revenue on sales of those books.

“If you have a kind of an institutional problem,” said Jeff Cunard, a partner at Debevoise & Plimpton who represented the publishers in the case, “you can address the issue through a class-action settlement mechanism, which releases all past claims and develops a solution on a going-forward basis. And I think the genius here was of those who saw this as a way of addressing the problem of out-of-print books and liberating them from the dusty corners to which they’d been consigned.”

It was a kind of hack. If you could get the class on board with your settlement, and if you could convince a judge to approve it—a step required by law, because you want to make sure the class representatives are acting in the class’s best interests—then you could in one stroke cut the Gordian knot of ambiguous rights to old books. With the class action settlement, authors and publishers who stayed in the class would in effect be saying to Google, “go ahead.”

Naturally, they’d have to get something in return. And that was the clever part. At the heart of the settlement was a collective licensing regime for out-of-print books. Authors and publishers could opt out their books at any time. For those who didn’t, Google would be given wide latitude to display and sell their books, but in return, 63 percent of the revenues would go into escrow with a new entity called the Book Rights Registry. The Registry’s job would be to distribute funds to rightsholders as they came forward to claim their works; in ambiguous cases, part of the money would be used to figure out who actually owned the rights.

“Book publishing isn’t the healthiest industry in the world, and individual authors don’t make any money out of out-of-print books,” Cunard said to me. “Not that they would have made gazillions of dollars” with Google Books and the Registry, “but they would at least have been paid something for it. And most authors actually want their books to be read.”

What became known as the Google Books Search Amended Settlement Agreement came to 165 pages and more than a dozen appendices. It took two and a half years to hammer out the details. Sarnoff described the negotiations as “four-dimensional chess” between the authors, publishers, libraries, and Google. “Everyone involved,” he said to me, “and I mean everyone—on all sides of this issue—thought that if we were going to get this through, this would be the single most important thing they did in their careers.” Ultimately the deal put Google on the hook for about $125 million, including a one-time $45 million payout to the copyright holders of books it had scanned—something like $60 per book—along with $15.5 million in legal fees to the publishers, $30 million to the authors, and $34.5 million toward creating the Registry.

But it also set the terms for how out-of-print books, newly freed, would be displayed and sold. Under the agreement, Google would be able to preview up to 20 percent of a given book to entice individual users to buy, and it would be able to offer downloadable copies for sale, with the prices determined by an algorithm or by the individual rightsholder, in price bins initially ranging from $1.99 to $29.99. All the out-of-print books would be packaged into an “institutional subscription database” that would be sold to universities, where students and faculty could search and read the full collection for free. And in §4.8(a), the agreement describes in bland legalese the creation of an incomparable public utility, the “public-access service” that would be deployed on terminals to local libraries across the country.

Sorting out the details had taken years of litigation and then years of negotiation, but now, in 2011, there was a plan—a plan that seemed to work equally well for everyone at the table. As Samuelson, the Berkeley law professor, put it in a paper at the time, “The proposed settlement thus looked like a win-win-win: the libraries would get access to millions of books, Google would be able to recoup its investment in GBS, and authors and publishers would get a new revenue stream from books that had been yielding zero returns. And legislation would be unnecessary to bring about this result.”

In this, she wrote, it was “perhaps the most adventuresome class action settlement ever attempted.” But to her way of thinking, that was the very reason it should fail.

* * *

The publication of the Amended Settlement Agreement to the Authors Guild case was headline news. It was quite literally a big deal—a deal that would involve the shakeup of an entire industry. Authors, publishers, Google’s rivals, legal scholars, librarians, the U.S. government, and the interested public paid attention to the case’s every move. When the presiding judge, Denny Chin, put out a call for responses to the proposed settlement, responses came in droves.

Those who had been at the table crafting the agreement had expected some resistance, but not the “parade of horribles,” as Sarnoff described it, that they eventually saw. The objections came in many flavors, but they all started with the sense that the settlement was handing to Google, and Google alone, an awesome power. “Did we want the greatest library that would ever exist to be in the hands of one giant corporation, which could really charge almost anything it wanted for access to it?”, Robert Darnton, then president of Harvard’s library, has said.

Darnton had initially been supportive of Google’s scanning project, but the settlement made him wary. The scenario he and many others feared was that the same thing that had happened to the academic journal market would happen to the Google Books database. The price would be fair at first, but once libraries and universities became dependent on the subscription, the price would rise and rise until it began to rival the usurious rates that journals were charging, where for instance by 2011 a yearly subscription to the Journal of Comparative Neurology could cost as much as $25,910.

Although academics and library enthusiasts like Darnton were thrilled by the prospect of opening up out-of-print books, they saw the settlement as a kind of deal with the devil. Yes, it would create the greatest library there’s ever been—but at the expense of creating perhaps the largest bookstore, too, run by what they saw as a powerful monopolist. In their view, there had to be a better way to unlock all those books. “Indeed, most elements of the GBS settlement would seem to be in the public interest, except for the fact that the settlement restricts the benefits of the deal to Google,” the Berkeley law professor Pamela Samuelson wrote.

Certainly Google’s competitors felt put out by the deal. Microsoft, predictably, argued that it would further cement Google’s position as the world’s dominant search engine, by making it the only one that could legally mine out-of-print books. By using those books in results for user’s long-tail queries, Google would have an unfair advantage over competitors. Google’s response to this objection was simply that anyone could scan books and show them in search results if they wanted—and that doing so was fair use. (Earlier this year, a Second Circuit court ruled finally that Google’s scanning of books and display of snippets was, in fact, fair use.)

“There was this hypothesis that there was this huge competitive advantage,” Clancy said to me, regarding Google’s access to the books corpus. But he said that the data never ended up being a core part of any project at Google, simply because the amount of information on the web itself dwarfed anything available in books. “You don’t need to go to a book to know when Woodrow Wilson was born,” he said. The books data was helpful, and interesting for researchers, but “the degree to which the naysayers characterized this as being the strategic motivation for the whole project—that was malarkey.”

Amazon, for its part, worried that the settlement allowed Google to set up a bookstore that no one else could. Anyone else who wanted to sell out-of-print books, they argued, would have to clear rights on a book-by-book basis, which was as good as impossible, whereas the class action agreement gave Google a license to all of the books at once.

This objection got the attention of the Justice Department, in particular the Antitrust division, who began investigating the settlement. In a statement filed with the court, the DOJ argued that the settlement would give Google a de facto monopoly on out-of-print books. That’s because for Google’s competitors to get the same rights to those books, they’d basically have to go through the exact same bizarre process: scan them en masse, get sued in a class action, and try to settle. “Even if there were reason to think history could repeat itself in this unlikely fashion,” the DOJ wrote, “it would scarcely be sound policy to encourage deliberate copyright violations and additional litigation.”

Google’s best defense was that the whole point of antitrust law was to protect consumers, and, as one of their lawyers put it, “From the perspective of consumers, one way to get something is unquestionably better than no way to get it at all.” Out-of-print books had been totally inaccessible online; now there’d be a way to buy them. How did that hurt consumers? A person closely involved in the settlement said to me, “Each of the publishers would go into the Antitrust Division and say well but look, Amazon has 80 percent of the e-book market. Google has 0 percent or 1 percent. This is allowing someone else to compete in the digital books space against Amazon. And so you should be regarding this as pro-competitive, not anti-competitive. Which seemed also very sensible to me. But it was like they were talking to a brick wall. And that reaction was shameful.”

The DOJ held fast. In some ways, the parties to the settlement didn’t have a good way out: no matter how “non-exclusive” they tried to make the deal, it was in effect a deal that only Google could get—because Google was the only defendant in the case. For a settlement in a class action titled Authors Guild v. Google to include not just Google but, say, every company that wanted to become a digital bookseller, would be to stretch the class action mechanism past its breaking point.

This was a point that the DOJ kept coming back to. The settlement was already a stretch, they argued: the original case had been about whether Google could show snippets of books it had scanned, and here you had a settlement agreement that went way beyond that question to create an elaborate online marketplace, one that depended on the indefinite release of copyrights by authors and publishers who might be difficult to find, particularly for books long out of print. “It is an attempt,” they wrote, “to use the class-action mechanism to implement forward-looking business arrangements that go far beyond the dispute before the Court in this litigation.”

The DOJ objections left the settlement in a double bind: Focus the deal on Google and you get accused of being anticompetitive. Try to open it up and you get accused of stretching the law governing class actions.

The lawyers who had crafted the settlement tried to thread the needle. The DOJ acknowledged as much. “The United States recognizes that the parties to the ASA are seeking to use the class action mechanism to overcome legal and structural challenges to the emergence of a robust and diverse marketplace for digital books,” they wrote. “Despite this worthy goal, the United States has reluctantly concluded that use of the class-action mechanism in the manner proposed by the ASA is a bridge too far.”

Their argument was compelling, but the fact that the settlement was ambitious didn’t mean it was illegal—just unprecedented. Years later, another class-action settlement that involved opt-out, “forward-looking business arrangements” very similar to the kind set up by the Google settlement was approved by another district court. That case involved the prospective exploitation of publicity rights of retired NFL players; the settlement made those rights available to an entity that would license them and distribute the proceeds. “What was interesting about it,” says Cunard, who was also involved in that litigation, “was that not a single opponent of the settlement ever raised Judge Chin’s decision or any of the oppositions to it with respect to that settlement being ‘beyond the scope of the pleadings.’” Had that case been decided ten years ago, Cunard said, it would have been “a very important and substantial precedent,” significantly undercutting the “bridge too far” argument against the Authors Guild agreement. “It demonstrates that the law is a very fluid thing,” he said. “Somebody’s got to be first.”

In the end, the DOJ’s intervention likely spelled the end of the settlement agreement. No one is quite sure why the DOJ decided to take a stand instead of remaining neutral. Dan Clancy, the Google engineering lead on the project who helped design the settlement, thinks that it was a particular brand of objector—not Google’s competitors but “sympathetic entities” you’d think would be in favor of it, like library enthusiasts, academic authors, and so on—that ultimately flipped the DOJ. “I don’t know how the settlement would have transpired if those naysayers hadn’t been so vocal,” he told me. “It’s not clear to me that if the libraries and the Bob Darntons and the Pam Samuelsons of the world hadn’t been so active that the Justice Department ever would have become involved, because it just would have been Amazon and Microsoft bitching about Google. Which is like yeah, tell me something new.”

Whatever the motivation, the DOJ said its piece and that seemed to carry the day. In his ruling concluding that the settlement was not “fair, adequate, and reasonable” under the rules governing class actions, Judge Denny Chin recited the DOJ’s objections and suggested that to fix them, you’d either have to change the settlement to be an opt-in arrangement—which would render it toothless—or try to accomplish the same thing in Congress.

“While the digitization of books and the creation of a universal digital library would benefit many,” Chin wrote in his decision, “the ASA would simply go too far.”

* * *

At the close of the “fairness hearing,” where people spoke for and against the settlement, Judge Chin asked, as if merely out of curiosity, just how many objections had there been? And how many people had opted out of the class? The answers were more than 500, and more than 6,800.

Reasonable people could disagree about the legality of the settlement; there were strong arguments on either side, and it was by no means obvious to observers which side Judge Chin was going to come down on. What seemed to turn the tide against the settlement was the reaction of the class itself. “In my more than twenty-five years of practice in class action litigation, I’ve never seen a settlement reacted to that way, with that many objectors,” said Michael Boni, who was the lead negotiator for the authors class in the case. That strong reaction was what likely led to the DOJ’s intervention; it turned public opinion against the agreement; and it may have led Chin to look for ways to kill it. After all, the question before him was whether the agreement was fair to class members. The more class members came out of the woodwork, and the more upset they seemed to be, the more reason he’d have to think that the settlement didn’t represent their interests.

The irony is that so many people opposed the settlement in ways that suggested they fundamentally believed in what Google was trying to do. One of Pamela Samuelson’s main objections was that Google was going to be able to sell books like hers, whereas she thought they should be made available for free. (The fact that she, like any author under the terms of the settlement, could set her own books’ price to zero was not consolation enough, because “orphan works” with un-findable authors would still be sold for a price.) In hindsight, it looks like the classic case of perfect being the enemy of the good: surely having the books made available at all would be better than keeping them locked up—even if the price for doing so was to offer orphan works for sale. In her paper concluding that the settlement went too far, Samuelson herself even wrote, “It would be a tragedy not to try to bring this vision to fruition, now that it is so evident that the vision is realizable.”

Many of the objectors indeed thought that there would be some other way to get to the same outcome without any of the ickiness of a class action settlement. A refrain throughout the fairness hearing was that releasing the rights of out-of-print books for mass digitization was more properly “a matter for Congress.” When the settlement failed, they pointed to proposals by the U.S. Copyright Office recommending legislation that seemed in many ways inspired by it, and to similar efforts in the Nordic countries to open up out-of-print books, as evidence that Congress could succeed where the settlement had failed.

Of course, nearly a decade later, nothing of the sort has actually happened. “It has got no traction,” Cunard said to me about the Copyright Office’s proposal, “and is not going to get a lot of traction now I don’t think.” Many of the people I spoke to who were in favor of the settlement said that the objectors simply weren’t practical-minded—they didn’t seem to understand how things actually get done in the world. “They felt that if not for us and this lawsuit, there was some other future where they could unlock all these books, because Congress would pass a law or something. And that future... as soon as the settlement with Guild, nobody gave a shit about this anymore,” Clancy said to me.

It certainly seems unlikely that someone is going to spend political capital—especially today—trying to change the licensing regime for books, let alone old ones. “This is not important enough for the Congress to somehow adjust copyright law,” Clancy said. “It’s not going to get anyone elected. It’s not going to create a whole bunch of jobs.” It’s no coincidence that a class action against Google turned out to be perhaps the only plausible venue for this kind of reform: Google was the only one with the initiative, and the money, to make it happen. “If you want to look at this in a raw way,” Allan Adler, in-house counsel for the publishers, said to me, “a deep pocketed, private corporate actor was going to foot the bill for something that everyone wanted to see.” Google poured resources into the project, not just to scan the books but to dig up and digitize old copyright records, to negotiate with authors and publishers, to foot the bill for a Books Rights Registry. Years later, the Copyright Office has gotten nowhere with a proposal that re-treads much the same ground, but whose every component would have to be funded with Congressional appropriations.

I asked Bob Darnton, who ran Harvard’s library during the Google Books litigation and who spoke out against the settlement, whether he had any regrets about what ended up happening. “Insofar as I have a regret, it is that the attempts to out-Google Google are so limited by copyright law,” he said. He’s been working on another project to scan library books; the scanning has been limited to books in the public domain. “I’m in favor of copyright, don’t get me wrong, but really to leave books out of the public domain for more than a century—to keep most American literature behind copyright barrier,” he said, “I think is crazy.”

The first copyright statute in the United States, passed in 1790, was called An Act for the Encouragement of Learning. Copyright terms were to last fourteen years, with the option to renew for another fourteen, but only if the author was alive at the end of the first term. The idea was to strike a “pragmatic bargain” between authors and the reading public. Authors would get a limited monopoly on their work so they could make a living from it; but their work would retire quickly into the public domain.

Copyright terms have been radically extended in this country largely to keep pace with Europe, where the standard has long been that copyrights last for the life of the author plus 50 years. But the European idea, “It’s based on natural law as opposed to positive law,” Lateef Mtima, a copyright scholar at Howard University Law School, said. “Their whole thought process is coming out of France and Hugo and those guys that like, you know, ‘My work is my enfant,’” he said, “and the state has absolutely no right to do anything with it—kind of a Lockean point of view.” As the world has flattened, copyright laws have converged, lest one country be at a disadvantage by freeing its intellectual products for exploitation by the others. And so the American idea of using copyright primarily as a vehicle, per the constitution, “to promote the Progress of Science and useful Arts,” not to protect authors, has eroded to the point where today we’ve locked up nearly every book published after 1923.

“The greatest tragedy is we are still exactly where we were on the orphan works question. That stuff is just sitting out there gathering dust and decaying in physical libraries, and with very limited exceptions,” Mtima said, “nobody can use them. So everybody has lost and no one has won.”

After the settlement failed, Clancy told me that at Google “there was just this air let out of the balloon.” Despite eventually winning Authors Guild v. Google, and having the courts declare that displaying snippets of copyrighted books was fair use, the company all but shut down its scanning operation.

It was strange to me, the idea that somewhere at Google there is a database containing 25-million books and nobody is allowed to read them. It’s like that scene at the end of the first Indiana Jones movie where they put the Ark of the Covenant back on a shelf somewhere, lost in the chaos of a vast warehouse. It’s there. The books are there. People have been trying to build a library like this for ages—to do so, they’ve said, would be to erect one of the great humanitarian artifacts of all time—and here we’ve done the work to make it real and we were about to give it to the world and now, instead, it’s 50 or 60 petabytes on disk, and the only people who can see it are half a dozen engineers on the project who happen to have access because they’re the ones responsible for locking it up.

I asked someone who used to have that job, what would it take to make the books viewable in full to everybody? I wanted to know how hard it would have been to unlock them. What’s standing between us and a digital public library of 25 million volumes?

You’d get in a lot of trouble, they said, but all you’d have to do, more or less, is write a single database query. You’d flip some access control bits from off to on. It might take a few minutes for the command to propagate.

President Trump signed an executive order April 18 that he says will promote a "Buy American and Hire American" agenda. The order targets the US H1-B visa program, which is designed to attract foreign workers with specialized advanced skills, and directs government agencies to enact changes to prevent fraud and abuse of the program.

Trump signed the order at the headquarters of Snap-On Inc., a hand and power tool manufacturer based in Wisconsin.

"We are going to defend our workers, protect our jobs and finally put America first," Trump said in his remarks. 

But a recent examination of US hotels owned by the Trump Organization reveals just how much they rely on foreign imports, a practice that could come under fire from his own administration.

The rooms in Trump hotels are adorned with furniture and products that have traveled farther than most guests. Sets of toiletries in the bathroom were imported from Central America, shipped to the US from the Trump Hotel in Panama City. Headboards, tall and grand and often covered in velvet or leather, came from Jiashan, China. Light fixtures were brought in from Kamenický Šenov, a town in the Czech Republic.

To track where Trump hotels buy goods, Business Insider consulted ImportGenius, a company that compiles data from US Customs into proprietary databases. The resulting list shows Trump’s businesses have imported furniture, fixtures, building materials, apparel, and supplies from more than 15 countries since 2012. Over the past two years, the companies have received shipments nearly 50 times.

Trump has repeatedly emphasized his commitment to domestic manufacturing — both on the campaign trail and as president. He wasted no time in pulling the US out of the Trans-Pacific Partnership, and has continued to highlight his stance against globalism and free trade.

"We will follow two simple rules: Buy American and hire American," the president said in his inauguration speech, using the same language that's in the new executive order. But that agenda stands in conflict with the Trump Organization's own business practices.

Buying globally

On November 25, the Trump Doral — an 800-acre golf resort in Miami — received a 924-pound shipment from Hong Kong that included golf-club covers. In January 2016, the Doral received two containers of massage beds (15,290 pounds' worth) from Moers, Germany. In February 2015, the hotel received 18,566 pounds' worth of logo-emblazoned dark-brown ice buckets with accompanying lids and trays, sent from Nonthaburi, Thailand, to Los Angeles.

The information about these shipments comes from bills of lading, which note everything a ship is carrying as well as who is sending and receiving the cargo. Michael Kanko, the CEO of ImportGenius, tells Business Insider that the company compiled the data by pulling all the records connected with the businesses and addresses that Trump listed in his public financial-disclosure forms.

“We painted a picture of Trump's reliance on foreign imports by searching our global-shipping databases for cargo movements related to Trump companies,” Kanko says. The list is incomplete — because products might not have been made in the cities they were shipped from, and items that arrived in the US by truck or plane are not included — but it does show the globalized nature of the Trump family's hospitality empire.

Trump hotels are not alone in the practice of sourcing furnishings, fixtures, technology, and supplies from other countries.

“It's certainly common in the hospitality world to import supplies and decor from overseas, especially China,” Kanko says.

Arthur Dong, a professor of strategy and economics at Georgetown University's McDonough School of Business, has consulted for companies in the hospitality industry, and says people would probably be shocked by how many components of US hotels come from foreign sources.

"The irony of this situation is that it's pretty well known within the hospitality industries that there are global vendors who supply many of the hotel chains around the world," he says, referring to the contrast between Trump's rhetoric and his family's business practices. (Four Seasons, Marriott, and Hilton all declined to comment on their practices.)

"President Trump will be, in a sense, hurting some of his own business interests by putting up these barriers," Dong says.

The new free-trade debate

Throughout his campaign, Trump repeatedly promised to renegotiate the US's free-trade agreements, claiming they kill American jobs by making it easy for companies to move production overseas or import products from foreign manufacturers. His executive order on the TPP likely killed that trade deal, which was negotiated under President Obama but was not ratified by Congress. The TPP would have created stronger economic ties between the US and 11 other countries — including Japan, Vietnam, Canada, and Mexico but not China — by reducing tariffs and other restrictive policies for trade between them.

Trump is also expected to issue an executive order to renegotiate NAFTA, a deal that eliminated most tariffs on goods traded between the US, Canada, and Mexico. He has called NAFTA, which was negotiated by George H. W. Bush and later approved by Bill Clinton, “the single worst trade deal ever approved in this country.”

Since World War II, trade deals have been largely embraced by both Democrats and Republicans because economists have found the agreements drive economic growth. Until Trump campaigned in opposition to free trade, most criticism of TPP and other deals came from progressives like Bernie Sanders, who said free trade creates winners and losers, even though overall gains might outweigh losses. A corporation may profit from access to foreign markets with lower wages, but domestic workers could consequently lose their jobs.

Since the election, Trump has stuck with his anti-free-trade rhetoric. In a meeting with The New York Times before his inauguration, Trump suggested he would favor a 45% tariff on Chinese exports to the US. On January 23, he suggested he would impose a "very major" border tax on companies that move their operations outside the US. And the following week, press Secretary Sean Spicer suggested that a 20% tax on imports from Mexico could help fund Trump's proposed border wall.

Yet many of Trump’s imports come from China. ImportGenius' data shows that Trump has received 20 shipments from the country over the past five years, as well as 17 from Hong Kong. (The largest shipment received in 2016 had six containers — weighing a total of 217,382 pounds — full of Miss Universe-branded Chi hair straighteners and hair dryers, which were shipped from Shenzhen to Houston in September.)

Made in USA

Susan Helper, a professor of economics at Case Western Reserve University and the former chief economist at the US Department of Commerce, says that imposing higher tariffs could lead more hotel chains to buy things like furniture or light fixtures from US makers. But that will depend on what kinds of changes the administration makes.

“If there are tariffs just on a couple countries like China or Mexico, then stuff can move to other countries,” she says, suggesting that companies might simply find production facilities elsewhere or start buying from places that aren’t subject to higher fees. “If it’s across-the-board tariffs, then you’d be more likely to see stuff come to the US.”

While Trump hasn’t said much about the origins of items in his hotels, he has repeatedly acknowledged that his clothing was manufactured abroad. (Shipping data shows that much of Ivanka’s line is too.) When pressed, Trump has said he’d like to buy domestically made products but that it was hard to find them.

“They don’t even make this stuff here,” Trump said on ABC, after anchor George Stephanopoulos suggested he should lead by example.

Trump only mentioned apparel and TVs in relation to that claim (it is true that no TVs are 100% US-made), but when it comes to headboards and chairs, there are plenty of domestic manufacturers that furnish hotels.

“It’s certainly very possible and it’s certainly not difficult,” says Amy Wolbert, senior vice president at Kindel Furniture, which is based in Grand Rapids, Michigan. Wolbert is quick to acknowledge, however, that furniture is generally more expensive when made in the US. “The project has to have budgets that will support it. Everything comes down to budgets.”

Kindel, which was founded in 1901, provided a couple of pieces for Trump’s new International Hotel in DC: a coffee table and leather armchair. Wolbert says that while Kindel sometimes makes pieces for hotels, its furniture is so high-end that the company usually sells only a few items at a time, rather than furnishing every room.

“We seek to do more commercial work because it helps us grow and it helps increase volume and shipments,” she says. “It’s always great to get that kind of work because it helps balance out the consumer who’s going to buy a sofa one year and then maybe not buy furniture again for two, five, seven years.”

Wolbert says she's watched many Michigan furniture makers pack up shop, a phenomenon that Dong says has been the case nationwide. Trump's trade policies could shift the market back in favor of US makers, he says, or even incentivize foreign companies to establish furniture factories in the US. But companies might also just start making components overseas and assembling the parts in the US so that they can get a "Made in USA" label and avoid tariffs.

'His credibility would go up'

Wolbert isn’t sure whether policy changes like the ones Trump is proposing would bring Kindel more business. But she points out that there are other good reasons (besides US jobs) for clients to buy furniture from American makers, since they can deliver and repair products much faster.

Helper says switching to domestic manufacturing could even save money because of those factors. In addition to lowering shipping costs, she says, eliminating the long lead time provides other benefits.

“What companies sometimes do is order more than they think they’re going to need and put it in their warehouse in case,” she says. “This is particularly an issue in clothing. The average apparel company that’s importing from China may import three times as much as they expect to sell so they’re covered in case there’s a run on demand. So there’s just a huge amount of waste.”

If hotel chains do start buying more American-made products, however, they'd most likely have to find ways to accommodate the higher prices — either by cutting budgets elsewhere or charging guests more.

"The cost will be passed onto the consumer in the way of higher room rates, because they're confronting higher costs on many of the inputs," Dong adds.

But he says that the president would be wise to put his money where his mouth is, regardless of those challenges.

"If he doesn't start buying from American sources, it'll make him look a little bit hypocritical," Dong says. "His credibility would go up if he were to direct his company managers to start sourcing [in the US], and I believe that when they start doing that, they're going to make it very public to make Americans aware that he's going to eat his own cooking."

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Bryan Goldberg, 33, is the founder of Bustle, a digital-media startup with 55 million monthly readers that covers everything from politics to "The Bachelor." Its latest valuation puts it on par with Goldberg's last startup, Bleacher Report, which sold for about $200 million to Turner Media.

In his 20s, Goldberg cofounded Bleacher Report, a sports website, with three middle school friends. After the sale to Turner, Goldberg did what successful 20-somethings should do to celebrate: He and his cofounders went to party in Las Vegas, and they paid for each of their 160 employees to join them.

"As we know, what happens in Vegas stays in Vegas," Goldberg told Business Insider on the podcast "Success! How I Did It." "But I would say that on a scale of 1 to 10 — like, OMFG — it's probably a 10. I don’t know what an 11 would look like. I'm not going into it, except to say we all came back alive."

Though Goldberg wouldn't reveal what happened in Vegas, he did share the tips and tricks he’s used to become a successful businessman.

The podcast explores:

• How four middle school friends came up with a startup idea over beers
• How a $200 million startup acquisition actually goes down
• An "OMFG" party in Las Vegas after the acquisition, in which Bleacher Report's founders paid out of pocket for all 160 employees to join them
• How playing "Magic The Gathering" made Goldberg a good media CEO
• What to expect in media over the next few years — lots of acquisitions and billion-dollar exits
• Why Bryan tortures friends with videos of him weightlifting Facebook

The "Success! How I Did It" podcast interviews inspiring people about the career paths that took them to the top of their industries. You can listen to the episode with Bryan Goldberg below and subscribe to the podcast on Acast or iTunes.

You can also check out another episode of "Success! How I Did It": "Tinder cofounder on what it's really like to build a $3 billion business in your 20s."

The following podcast and transcript of the interview has been edited for clarity and length. 

Alyson Shontell: Bryan, you've been a founder for a decade now.

Bryan Goldberg: Yes, over a decade, which is a long time. In the case of digital media specifically, it's really for most of digital media's existence, so I can say this one thing I was early in, and it has changed a lot and it's continuing to change even more.

As long as I'm in the game here, there's more to learn and more to build and more to do.

Shontell: For people who don't know, what is Bustle and where is it now?

Goldberg: Bustle is not only the largest media property in the United States aimed at young women, it's also a platform for young women. In January, we had 55 million monthly unique visitors coming to read our content in news and entertainment, lifestyle, fashion, and beauty.

Shontell: Is that traffic partly from the Trump bump or was it "The Bachelor" bump?

Goldberg: Both. In January, we had many millions of people coming to the site for both of those topics. I'd say those were the two biggest draws. That dichotomy between really smart, insightful content about news and politics as well as some of the best "Bachelor" coverage you're ever going to find, is symbolic of who we are, as a site that is really proud of our coverage of what in the past has been viewed as very different types of topics that appeal to, often, the same young woman.

How 4 middle school friends started a company over beers

Shontell: I want to get into all of that, and how the media industry has changed in your decade since you joined it. But first, let's go back to 2007, to those early days when you and your buddies from middle school decided to start a company. You'd never founded anything before, right?

Goldberg: Yep, and I'm going to take it back even further, to 2005, because we launched Bleacher in earnest in 2007, but the story begins in 2005, right when we graduated from college.

So, 2005: My cofounders and I had just graduated from college and we were all very above average. None of us were remarkable. None of us had gone to Ivy League schools. We had all applied to Ivy League schools; we did not get in.

None of us were remarkable. None of us had gone to Ivy League schools. We had all applied to Ivy League schools; we did not get in.

Back in 2005, if you wanted to go into business, broadly speaking, the game plan was simple. Go to a good college, and then you have two choices: investment banking, with Goldman Sachs being where you wanted to be, or Lehman Brothers, or management consulting, in which Mackenzie or Bain or BCG was the dream.

I started going down the path of management consulting. The plan was to get an MBA, and for most people like me or my cofounders, the first decade of your career — banking, consulting, business school, then back into banking and consulting — was really prescribed.

Shortly after college, we had this idea to start a "dot-com." That's what we said in those days. I wanted to launch a website, a dot-com, around sports. People thought this was so stupid. They basically said this was yesterday's dream. "This is so nostalgic of you to go think you can start a website in the year 2005." The dot-com disaster was four or five years gone and banking was so hot.

These same people seven years later, by the way, who graduated from Harvard Business School, were quitting their jobs at Goldman to go start a startup. By 2012, it wasn't too late to start a company but a lot more crowded.

Those few years after 9/11, and before Lehman Brothers collapsed, really were this dead period. There were no venture-capital firms throwing out money.

Shontell: That was the year after Facebook launched, so there was some stuff brewing. But you're right, it was kind of dead.

Goldberg: You know what's funny is, if you were to say 2005, 2006, what was the company that got people excited? You think it's Facebook and you think about the Google IPO. The one that actually got people excited was Digg.

In 2006, there was this picture of Kevin Rose on the cover of Business Week. What's memorable is Kevin Rose on the cover giving a thumbs-up and how this kid made $60 million in 18 months.

Really, for people starting companies in that time period, that was sort of the "Oh, my God." We knew that Facebook was going to be huge. We knew that was once in a decade. Lightning in a bottle.

We knew Google was the same thing a decade earlier, but the thing that was just like, "Hey, you can go do this" — regular guys can go launch a cool Web 2.0 idea — was definitely Digg, around 2005, 2006.

That's what really made us say to ourselves, "Oh, my God, we have this great idea, let's go get this off the ground. We have this business plan and this dream."

Shontell: I love that you had a business plan. That feels like a rookie Silicon Valley startup move.

Goldberg: It was sketched based on the business plans I had learned about. I had taken competitive strategy in college, a sort of pre-MBA course for what was supposed to be a very pre-MBA life. We had a four- or five-page business plan with competitive advantage and differentiation.

I give all the credit in the world to those who pivot, but Bleacher Report's game plan ... if you found that business plan from 2005, 2006, which we cannot find — my mom might have it, so I'll have to ask. But if you ever found it, you would look at Bleacher Report today in 2017 and say, "You know what? It's not identical but it's pretty damn close." The same thing for Bustle.

Our founding story is a lot like everyone else's. A group of guys got together with this cool idea. We wanted to go do it. We talked about it over beers, and 99.99% of the time people sober up the next day, forget about it, and then years later at a birthday or bachelor party they go, "Hey, remember that idea we had that we never did?" That was Bleacher Report, except we actually did it.

We talked about it over beers, and 99.99% of the time people sober up the next day, forget about it, and then years later go, 'Hey, remember that idea we had that we never did?' That was Bleacher Report, except we actually did it.

Shontell: You're a first-time founder. All of you stumble into media after this drinks meeting that you then sober up and decide to do. How are you welcomed into the startup community? You didn't go to Ivies, you have no experience, and VC's weren't really investing.

Goldberg: Back in San Francisco around 2007, 2008, it was a pretty small community. People remember it very romantically — "Oh, there weren't a lot of people, but every idea had a chance. You could be having drinks with the Airbnb guys and drinks with the Twitter guys." Some of that was true, but we weren't hanging out with them.

Between 2007 and 2011, you couldn't go raise money as a media company because no media company had ever been sold for anything valuable.

You had to say, "This is about tech." You always have to begin every VC pitch by saying, "Oh, we're not a media company. This isn't about advertising. This is about technology." Which was complete bulls---. But you know what? It got the job done, and you have to live one day at a time.

Technology is important to media. It still is, but it wasn't until about 2010 that we looked in the mirror and said, "Hey, wait a minute. This is a media company. We are a media company."

Then, when Huffington Post was purchased for hundreds of millions of dollars, we got to be a lot more out about it and say, "Hey, we are a media company. We're building this."

Shontell: You were four cofounders. How did you all split up the business, how did you start growing it, and when did you know that you had something on your hands?

Goldberg: It took years until we all had a "role." We were all critical.

People say to me, "Which cofounder was the most important?" I say to them: "Asking me which cofounder was the most important is as pointless as asking me, 'Would you rather live without a heart or lungs?'" You're dead either way. Without my cofounders, this wouldn't have happened.

We're all similar guys. We all did different things in the beginning. I was the head of tech. I got the website up. I managed the engineers, which, in hindsight, is preposterous, because I can't write a line of code. But I was the geekiest. I was, in a very superficial way, the geekiest.

Shontell: Did you have a "Star Wars" poster and they were like, "You are the geekiest"?

Goldberg: Exactly. It was literally like that. I played video games growing up. I was the first one to get an iPod and the first one to get even a pre-iPod MP3 player, so I was the geekiest. We eventually hired a real CTO, but I, for the first year and a half, got the website up and did so competently.

Ultimately, after a couple of years of doing the technology stuff, I started focusing on advertising. Again, we talk about "Why was I the one who became the advertising cofounder?"

Part of it was, I was the single one for a lot of that time, in 2010, 2011, 2012, so I could fly to New York every other weekend and babysit our very smart, very successful 20-something-year-old advertising team. Then we hired a big-name head of sales. I changed hats a lot, probably more than the other guys.

We all did different things throughout the history of the company, and I think that's one of the reasons why we've all been able to continue doing big things in media — we all saw all the parts. Media companies are complicated. They are among the most complex companies you can run.

Media companies are complicated. They are among the most complex companies you can run.

You've got a creative side, the sales side, and the technology piece, so you're thinking with all three sections of your brain.

Shontell: You got a lot of criticism as you were growing. People thought it was aggregation. They thought you had contributors you weren't paying well. So this was pretty new stuff, especially in sports. How did you deal with all the negativity, and how did you decide what to listen to and what not to?

Goldberg: First of all, we have very thick skin. You cannot be in media without having incredibly thick skin. That's just the rule. Don't go into banking if you can't work a lot of hours, don't go into medicine if you can't stand the sight of blood, and do not go into media if you do not have very thick skin.

Don't go into banking if you can't work a lot of hours, don't go into medicine if you can't stand the sight of blood, and do not go into media if you do not have very thick skin.

The fact that people found us in a distributed way — through message boards and search — versus going to www.bleacherreport.com, really irked the establishment.

The term "distributed content" had not yet existed. I give BuzzFeed a lot of credit for putting terminology to some of these concepts, but Bleacher Report was doing it really early on and we got attacked relentlessly for it.

If you were to look at the game plan of what is digital media in the year 2017, no one gets more credit than us for advancing that game plan, making that game plan work. We're proud of it, but the attacks were relentless and in hindsight undeserved. I guess you can look back, and there's never such a thing as I told you so, but we feel good about it.

How Turner bought Bleacher Report for $200 million

Shontell: Let's talk about that "I told you so" moment. You ended up getting acquired for a very hefty sum, about $200 million. You were the second-largest media acquisition after Huffington Post at the time. How does an acquisition like that come about?

Goldberg: I want to make a point here because I think it's really salient now for young founders. Midway through our story, in late 2010, we hired a grown-up CEO, which really was the model until Mark Zuckerberg was such a genius.

His name was Brian Grey. He had run Yahoo Sports and Fox Sports and he lived in San Francisco, which was unusual for a media person. He became available and we said, "Hey, we need this guy to be our CEO because he's a grown-up" and our investors had been pressuring us. We didn't have a CEO. We had run it as a three-headed monster for years and years. We were in our mid-20s and people were starting to say to us, "Hey, this thing's really big. You've got 70 employees. You're making real money. You're selling to top brands. You guys should have a real grown-up CEO."

We were very mature about that. The reason I want to highlight this is because so many young founders feel it is just unthinkable. "How dare you make us hire a boss!"

Shontell: I think they see that Mark Zuckerberg never did that and he was fine.

Goldberg: And he's the model now, but guess what? Prior to that the model was Eric Schmidt and Google — Larry Page and Sergey Brin, and then the grown-up [Schmidt] who came in. Larry and Sergey were Ph.D.s from Stanford, they were in their 30s, and they still hired a grown-up CEO. They made billions of dollars and had nothing to regret.

Frankly, I think Mark Zuckerberg is the exception. Some of these companies should have grown-up CEOs. I think hiring one did help us both grow, and it helped us sell the company, because would a big corporation in New York, like Time Warner, have bought Bleacher Report from three guys in their 20s? Maybe, probably, but certainly not for sure. Brian Grey did make the company better. He brought a lot of experience, and was central to negotiating.

Shontell: But how did Turner find you guys? What was the first conversation? Wasn't it an eight-month process?

Goldberg: These negotiations take a long time and we had an investment banker, RBC Capital, on the deal.

Shontell: Were you trying to sell yourselves?

Goldberg: They had leaned in. We tried to run a process of getting others interested. There was interest, but it was very clear there was one buyer who frickin' wanted to own this thing. The banks did what they did. They got us in conversations with — I'm not going say who — but other big sports-media companies.

Shontell: Enough time has passed — you can say!

Goldberg: I'm not going to say anything definitive. Did ESPN kick the tires? Did CBS, NBC kick the tires? There was tire-kicking going on. Maybe now they're kicking themselves because they should have done the deal, though I don't think Disney has much to lose sleep over these days. They're doing terrific.

People kicked it around, but this was a case where there was one buyer who needed us. It was about five months of banter until we could get to a price.

We let the bankers and Brian Grey handle all of the negotiation on price. And look, you should have bankers on any M&A deal. People say don't. You absolutely should have a banker. It's not the first time they've negotiated.

I know that's the sexy part. For me, the sexy part was saying, "OK, this thing is going to sell in two or three months. This deal is probably going to happen. It makes sense. When it's done, I'm going to have money. I'm going to be 30 years old and I need to figure out what I'm doing with the rest of my life." Which is actually a scary position to be in.

Making a little bit of money doesn't mean that the next 60 years of your life are just sitting on a beach. That's not who I am, so I had to figure out, what the hell's my game plan here?

Making a little bit of money doesn't mean that the next 60 years of your life are just sitting on a beach. That's not who I am, so I had to figure out, what the hell's my game plan here?

What do I do next, being 30 years old, having some money, and knowing that I'm not going to be hanging around Bleacher Report for the next 50 years?

Shontell: Why didn't you want to hang around?

Goldberg: I had one more thing left to do. I think you know when you have one more startup left in you. Bleacher Report was an amazing experience. The cofounder experience was critical. It wouldn't have happened without them.

But I wanted to go do my own show, and I had one market I wanted to try out. I wanted to test what I could do on my own. I think that's very natural after seven years with a band. You want to go solo.

I didn't want to go start five more media companies. I'd been saying pretty openly that I don't think I'm going to start another media company after this.

Celebrating in 'OMFG' Vegas style

Shontell: Before we go into that, you all sold the company, and you and your cofounders went to Vegas. Tell me about the trip.

Goldberg: Under no circumstances will I talk about the Vegas trip.

Shontell: Oh, come on! You were young and dumb then. It doesn't matter.

Goldberg: I cannot believe we did that.

Shontell: Why? That's what everyone should do when they sell, right?

Goldberg: No, it's not what you should do!

Shontell: Who all went to Vegas?

Goldberg: The whole company.

Shontell: The entire company, all of Bleacher Report?

Goldberg: The entire company.

Shontell: Did you pay for them all?

Goldberg: We did. The founders paid for it. We had sold the company. We had made money, and we said, "Let's each chip in like X-thousand dollars and fly the company to Vegas."

Shontell: How many people was it at that point?

Goldberg: At that point it was like 160 people, 170 people. The CEO, Brian Grey, very wisely didn't go. I think one of the fun things about having a CEO when you're in your 20s running a company is he can be the grown-up and he can look the other way. He was like, "I'm not going anywhere near this. You pay for it out of pocket. You do it on the weekend. This is not a Bleacher Report event."

It was so early after the sale that I think Turner hadn't really put their arms around us, so we had this very narrow window for the founders to pay out of pocket to do a noncompany event on the weekend to go to Vegas.

As we know, what happens in Vegas stays in Vegas, but I would say that on a scale of 1 to 10 — like, OMFG — it's probably a 10. I don't know what an 11 would look like. I'm not going into it, except to say we all came back alive.

As we know, what happens in Vegas stays in Vegas, but I would say on a scale of 1 to 10 — like OMFG — it's probably a 10.

Shontell: What does a 10 look like?

Goldberg: You want to know what a 10 looks like? It looks like all the things you think about in a rock-star moment. It helped build the team. It was not forgotten, and that sort of behavior never again happened, and will never happen again.

Shontell: There's not going to be some Bustle Cancun trip when you sell?

Goldberg: If we sell Bustle, and I hate to say it — and my team at Bustle is going to hear this podcast and say, "Well, wait a minute. Bleacher Report got to do a Vegas trip — why don't we?" — and I'm going to say, "You know what, because I was young then and I'm old now, and old, boring, stodgy Bryan in his mid-30s is not going to do a trip to Vegas because it's just not the right thing to do."

I'm beet red right now — thank God this is a podcast. Because you just can't do those sorts of things. Not in the year 2017, 2018, 2019, whatever it turns out to be.

Shontell: Not with social media there to capture it all.

Goldberg: Exactly. I mean, Twitter existed but things were different back then.

How to launch a second media company and scale it to 55 million readers

Shontell: OK, so old, stodgy Bryan has now founded Bustle. You bring 55 million readers to your site, which is pretty incredible, because now everything seems to be distributed. People are reading Facebook as their homepage rather than going to most homepages of publishers.

What have you learned from Bleacher to apply at Bustle, and how was this launch easier than the first?

Goldberg: Every company is tough and every day is tough in media. It's a lot easier the second time. The core structure, the core game plan of Bustle, has similarities with Bleacher Report, like distributed content.

I was scared when we started Bustle. Not just because I was doing it alone. Not just because there was a lot of pressure to raise all this money. But because sports is very easy to create a taxonomy, to know what you're going to write about.

For Bleacher, there are four or five mainstream sports and 30-something teams. You know you're going to cover football. You know you're going to cover baseball. You know you're going to write about a certain player. When going into this new world with Bustle, it wasn't so clearly painted for me. What was even tougher was I'm not in my demographic.

The only way I could think to do it was hire six or seven early editors who are very different from each other, coming from different publications, and listening a lot. Then ultimately bringing in writers and saying to the writers, what's important to you? What matters to you?

There were certain things we knew we were going to cover, like popular television. I knew we were going cover the news and an election. But there were whole worlds that hadn't occurred to me. Topics like body positivity, which is really big for us. And tattoos. It never occurred to me that tattoo inspiration was a big thing for teenage girls and young women, but it's huge for us.

Shontell: But you did have a plan, at least from a distribution standpoint, right? You knew how much traffic you could maybe get from Google versus Pinterest. How did you map that out?

Goldberg: Anyone who tells you they're getting most of their traffic from anything other than search or social, they're being dishonest or they have a very small audience. You can build a couple million loyal, type-in-URL, direct visitors. That's possible over years, but this is the distributed era, so search and social.

We're very fortunate in women's media that you can get Facebook traffic and you can get Pinterest traffic. Bleacher Report is never going to get Pinterest traffic. Twitter, in my opinion, has not been a great platform for audience building, really since its inception.

What's been a big challenge but very rewarding for Bustle versus Bleacher Report is evergreen and long-tail search traffic. This idea that you can write great content on Bustle and two years later it's still useful. Example: We might be the top result for how to mix curly hair and bangs.

There are some women with curly hair who would like to have bangs, and they'd like celebrity inspiration so they can get ideas of how to make it work. It had never occurred to me that a person with curly hair may not think that bangs fall properly on their forehead. So we create the best article ever on that topic and it's still useful one year later, two years later, three years later.

That is not the case in sports. Sports content has a shelf life of six days, at most. If it's Monday and you're making football predictions for Sunday, you will get six days of juice out of that. It's useless after. If you look at Bleacher Report's traffic, they get a lot of traffic but only a small percentage is to stories that were written years ago.

Shontell: Let's talk about your launch, because it was sort of infamous. I know you've talked about it a lot, but there was a PR debacle. You said, "I'm Bryan Goldberg. I'm going to start the first women's site ever," to which every other woman in media was like, "What the hell, Bryan?!" Talk about that.

Goldberg: Broadly speaking, in media, you do want to make noise. You do want to be noticed. You do want to be loud. You do want to be provocative. But you want to keep it under control and you don't want to piss people off. I don't believe that all attention, all press, is good press.

If everyone's yelling at you and throwing rocks at you, then you've gone too far. You look at the launch, basically I was very loud and I was a man being very loud.

I said, "Hey, this is going to be a feminist website. We're going to talk about fashion and beauty. We're also going to talk about what's going on in Syria, with no apologies about it."

The tone — I didn't know a lot of thought leaders in women's media at the time. I was an unfamiliar face, certainly the wrong face, so sort of this dude, this young, white male who's made money, talking about rocking the world and changing the world, and talking about women's media. It wasn't a great image and wasn't a great look.

In hindsight, I would've handled it differently and didn't really want to piss people off. It came from a very sincere place. I really was excited about going to market, raising all this money and launching a feminist publication. That excitement came from the right place, but it pissed everyone off.

My general advice is look, be loud, make a lot of noise. In media you have to be noticed. But there are different ways to do it. The great story, though, in the end is I'm now friends with a lot of the people who were my initial critics, so it was a great way to meet people. It's not how you should always meet people, but it's one way to meet people.

Shontell: One other thing that I thought was notable was you did get this money from the sale of Bleacher Report, and yet you decided to raise a big round for Bustle. Why not fund it yourself?

Goldberg: I put a lot of money into Bustle. I made a good amount of money on Bleacher Report, but it wasn't what you might picture. I owned a very small, single-digit percentage of the company when we sold it for $200 million.

Shontell: Well, there were four founders and you all raised tens of millions of dollars.

Goldberg: During recessions. I owned a very small slice by the end ... I owned a few percent of the company, we sold it, and so I made money, and I put several hundred thousand dollars of my money, and my family's as well, in to start these companies.

In my opinion, you do need to raise at least $20 to $30 million. Usually you can't raise that on day one, so you have to go raise $5 or $6 million, and then prove that you know what you're doing and get some traction. Then VCs will follow with a series B or series C check and get you to $20 to $30 million.

Media companies require scale. Bustle has "only" raised $37 million. That's nothing compared to our peers at BuzzFeed, Vox, or Refinery 29, who have raised hundreds of millions of dollars. So, I knew that when we raised $6-plus-million in the beginning that that was only the first step, and that we'd have to raise tens of millions more just to have a seat at the table.

Between myself and my family members, we put in close to $1 million. That's a lot of money for me, that's a lot of money for my family. We're not that rich here. It was a lot. It was a big bet, and a pretty gutsy bet. I think that's one of the reasons investors got excited is because I said, "Look, I'm putting a big percentage of my net worth into this company because I believe in it," and nothing will bring investors to the table faster than when you put your own money into something.

Frankly, if you don't it's a red flag.

'Magic the Gathering' can make you a good media CEO

Shontell: This is your first time as CEO. What have you learned?

Goldberg: First of all, it's a lot of fun. It's a different capacity than being the founder.

Being a media CEO is a very specific type of CEO. There are a lot of media CEOs who are unsuccessful and very few who are successful. If you want to know how to be a successful media CEO, I will tell you right now.

This framework works every time:

The job of a media CEO is to balance three power bases: your editorial power base, your sales and marketing power base, and your tech and operations power base. If you ever let one of those three gain hegemony over the other, your company will fail. Think of it as a three-legged stool. If one leg gets too long, you will fall off the stool and you will crack your head open.

If you look at most digital-media companies, the CEO came out of one of those three camps. In some media companies it was founded by a techie person and they think that data and AB testing and headline manipulation is the key to success, and they want to see the data, data, data. The editors are saying, "You know, this isn't just about data." The sales team's saying, "Hey, there's a lot of art and science to this."

I've seen a lot of media companies that are too techie and they fail for that reason.

Shontell: I think you need to have a creative person at the helm and someone who's analytical.

Goldberg: Exactly. And look, I love to write. I'm not a creative type; I don't think anyone looks at me and goes, "Oh, Bryan's an artist," but I do love to write. The one thing I know I will do one day long down the road is I'm going to be a writer again, because I love it.

But I'm also an economics major. I love data. I'm very business-oriented. I'm very comfortable in financial conversations, but I'm also very at home with editors, talking about writing, editorial, and like I said, there's a geek part of me.

For example, play "Magic the Gathering." Every month at Bustle I host "Magic the Gathering" night —

Shontell: Wait, what's that?

Goldberg: You don't know what "Magic the Gathering" is?

Shontell: No.

Goldberg: If there were a studio audience they'd all be laughing, like, "You don't know what 'Magic the Gathering' is?" It is ostensibly the nerdiest thing. It's like a wizardry card game where you have ogres and goblins and vampires and they're battling it out.

Shontell: You play this at Bustle?

Goldberg: I play it at my house and all Bustlers are invited to come play it with me. It's like the nerdiest thing ever. It's so nerdy that I've played it all my life, but when I was in high school I had to stop playing it because I was just embarrassed, because I was a high-schooler and I cared what people thought.

I still play the game now. I'm very open about it, but truly, it's like the geekiest thing ever, and I love it and I'm proud of it. I go to tournaments. I don't win — I'm not good at it. To be good at this game you've got to play it more than I play it. This is a whole separate conversation, but I do nerdy, geeky things, and I'm not afraid to go party at a club until five in the morning and then the next day over lunch play "Magic the Gathering." I'd like to think I'm multitasking.

Shontell: You're at clubs till 5? You told me that it's old, stodgy Bryan now.

Goldberg: Well, yes, but old, stodgy Bryan in New York City. That's different than being old, stodgy Bryan in San Francisco, where one goes to bed at 11 and wakes up and hikes.

On the media industry

Shontell: I will save you from yourself and switch the topic. It's important to cover what the media industry is doing right now. You've had 10 years of looking at it and being deep in the weeds, and you're an ad guy at heart. So what trends are you seeing in advertising right now?

It seems like everyone was thinking, when BuzzFeed was raising $200 million and Vox was raising $200 million, that TV dollars were open to them, but now it seems like all of the ad money that's flowing to digital is really going to Google and Facebook, and publishers aren't getting the cuts that they had thought about. What are you seeing?

Goldberg: So I'm going to give you a couple of high-level theses that I believe are correct and I have high conviction about. Conviction No. 1 is, dollars are not leaving TV anytime soon. The dollars are just too big to move. You can't pull deals that measure in the hundreds of millions of dollars out of TV so quickly. Media takes time, because we're talking about hundreds of billions of dollars in play here, and those are very cumbersome amounts to move around. The dollars are going to stay in TV a long time.

It's still king. It's an aging king, but it's still king. Thesis No. 2: Yes, Google and Facebook are going to get a lot of the digital dollars. Maybe it's half, maybe it's two-thirds, maybe it's three-quarters. But that duopoly — it's called a duopoly, but be careful using the term duopoly, because there are a lot of very powerful interests who have a lot reason to make sure that Google and Facebook don't get a true duopoly.

If you go talk to the CMOs who are spending billions of dollars, they have a true, strategic, existential threat in the idea of a duopoly.

If you are a major CPG company, or a major auto company, and you let your media supplier be only two companies, you are putting yourself in an extremely dangerous position. So the marketing people, who are sitting on hundreds of billions of dollars of marketing and who are going to spend $80, $90, $100 billion on digital spend in the future, they realize that Google and Facebook are terrific avenues for advertising, and they are two of the most efficient, data-driven, outstanding places to spend your marketing money, no doubt about it. But they're not going to let them get a complete hegemony because that would be a true danger.

Then they would be at risk of losing pricing control, so Facebook and Google are going to get a lot of money, but the traditional media companies, the publishers, are still going to have many billions of dollars at play. What I think we're going to have to see is more consolidation. I don't think that your buddy's blog is going to get a piece of that 30 billion. If Google and Facebook are not getting $30 billion of those digital ad dollars, your friend's blog with 300,000 readers, they're not going to make a play.

You look at telecom, and there are only two dominant players. You look at a lot of industries, you know, airlines, there are only three players right now. Do I think there will be a day, three, four years from now, where there are literally like three media companies, perhaps subsidiaries of giant telcos? Probably, and everything's going to roll through it, and they will have power.

Shontell: So if you're a media company right now, what do you do before that three- to four-year period when all the consolidation happens? How do you keep surviving?

Goldberg: You just keep growing and you keep doing your thing. You just keep getting better. As long as the big media companies, the traditional players, are not getting better at digital — and they're not. In some cases they're doing absolutely nothing as long as they're not improving ... The Bustles and the Voxes and the BuzzFeeds, we're getting much better at what we do. Bustle today versus a year ago, you can't even compare.

I think some of the others would say the same thing. We're all getting much better at what we do. We're all getting, in the eyes of big players, more legitimate. We're growing our revenues. Think about how much flak BuzzFeed has taken on their revenue growth — and their revenue growth is really great. People are like, "Oh, my God, they didn't triple revenue this year from $130 million to $400 million?" You can't triple revenue every year.

Bustle tripled revenue last year. We tripled revenue. I'm telling you, we're not tripling revenue every year for the next three years.

Shontell: You did $30 million last year?

Goldberg: We did close to $10 million the year before and we did close to $30 million last year. It's almost all direct sales.

Shontell: That's unusual because a lot of people are trying subscriptions, which I haven't seen you try. Everyone's trying to dive into video, which you guys aren't doing much of.

Goldberg: I should probably be talking about it more, because I think part of video is how much do you talk about it. What I will say is yes, direct ad sales is still the model, so when I hear Medium say, "We're going to figure something else out," I'm like, give me a break, Medium. I'm not a fan of that particular company's moves and the announcement that Evan Williams made, because he basically retreated from advertising and said, "This is BS." No, advertising is a $200 billion industry — you just gotta be good at it and you gotta offer something to your clients and offer something to your readers.

Subscription can make you money. There are, like, three publishers who I think can make real money: The New York Times, The Wall Street Journal, and The New Yorker, and maybe a couple others here and there — Vogue. Even for them advertising is critical. If New York Times has a terrible year in advertising, it's really going to hurt them.

Advertising's a great industry. Anyone who's like, "Oh, stay away from advertising." That's complete BS. That's just people who don't know what they're talking about, frankly. It's a huge market. Companies like Vox or BuzzFeed should be looking to grow their revenue significantly. No, we're not going triple it every year, that's not reasonable, but it will grow significantly. It will grow linearly.

Shontell: If a founder came up to you and they were like, "Bryan, I want to start a media company right now." Would you recommend it?

Goldberg: It's hard to start now. It's hard to start now because of scale. That's the biggest impediment. If you didn't start a few years ago, you're not at scale today; if you're not at scale today, it's harder to be in some of these advertising conversations, because at Bustle we can go to an advertiser and say, "Here's what a million-dollar deal with Bustle looks like." If you're an advertiser, a CPG advertiser, you don't want to write $50,000 advertising checks.

Shontell: How do you get scale?

Goldberg: You need a lot of money up front.

Shontell: Because you're buying traffic?

Goldberg: No, well, you're buying a lot of salaries. You're hiring a lot of people. I was just walking around Business Insider's newsroom and — I don't know — it looked like there were a hundred people in the room. You draw big audiences; you do have to create a lot of content. No one wants to admit you have to create a lot of content, but look, how much content does Time Inc. put out every day? Hundreds of stories a day. It's across dozens of properties, but Time Inc., in their giant office downtown, is doing hundreds of stories a day.

You need scale, and the scale begins with, like, the scale of a newsroom with 50, 60, 100 people in it, or more. A thousand people, in the case of The Journal and The New York Times. If you're going to go higher, a hundred employees, you need millions and millions of dollars, because you're going to burn a lot of cash, and I burned a lot of cash in the beginning of Bustle. Now we're making good money, but when I was burning a lot of cash in the beginning my investors were scared.

They felt like we were driving full speed toward a cliff. We burned an eight-figure amount of money in 2015, and we burned very little and much less in 2016. We're not going to burn anything in 2017, hoping to have a good profit line, but those first years where you burn cash before you can recover and grow your sales, those are painful years. That's a scary PNL.

If you're a CEO and you've got to go to investors and say, "Guess what! We're going to burn $12 million next year, but I promise you revenue is coming later" — that's a scary statement to make. And I'm very lucky. I have very supportive investors who understand media, and so they were with me on the ride, and we're driving 80 miles an hour toward a cliff, and they're totally cool with it and get a little nervous, but I'm like, "Don't worry. The revenue is going to come in a year."

You gotta have people that do that, and unfortunately if you're a first-time founder in media, knowing how to do that, knowing how to drive 80 miles an hour toward a cliff, when to throw on the brakes, when to speed up, how to jump over that cliff and land on the other side — very hard to do if you haven't done it before. You'll probably screw it up.

That's the hesitation for young founders going into media. I hate to be the guy who's like, "Oh, I got in the door but now it's closed," but it is a different world, because when I and my cofounders started in 2005, it was a new world and there was no one to say, "I've done this before." It really was sort of fresh powder. It's not anymore, and so I do mentor and invest and support a lot of young, really talented media founders, and I give them all this important advice I can give them, and some of them are going to make it.

Shontell: OK, so there is some positivity out there, but it's getting harder. That's the bottom line.

Goldberg: It's getting harder. There'll be fewer winners, but the ones who win are going to win big. I mean, there are not a lot of venture-backed sectors where there are going to be many, many multibillion-dollar exits.

Shontell: You think that's the case here in media?

Goldberg: Yes, yes. They are perfect growth-stage investments. There's a reason why firms like Fidelity have poured hundreds of millions of dollars into these media bets. It's because they're going to make a great return, but they're only pouring money into a select few because there are going to be a half-dozen winners. There are not going to be 30 or 40 winners. But there will be multibillion-dollar exits.

On torturing friends with weightlifting videos

Shontell: How much can you lift these days? I see your Facebook and Instagram videos all the time with you and your trainer.

Goldberg: People say to me, "Don't write editorial, don't write politics on Facebook, because no one wants to hear what you have to say." So it's like, great, you know what? You'll get weightlifting videos.

Shontell: Yes, you have a lot of them.

Goldberg: The text messages I get from my closest friends, the people I should be listening to, say, "Bryan, don't you ever upload another weightlifting video or I will unfollow you and never talk to you again."

I'm like, "Well, guess what! That is the one thing you can do to make me upload more weightlifting videos!"

At some point last year I said, I want to be able to bench press a lot. There's no particular reason; I just want to be able to do it, so I've been working out three times a week.

For anyone who's a sports fan, if you're a fan of the NFL and how things work in the NFL, it's not about how much you can bench press; it's how many repetitions of 225 pounds you can do. You know what the combine is, the NFL combine, where the college players kind of show off their strength and ability to the pros? The great test in the NFL combine is, how many times can you lift 225 pounds? In a bench press, that's two plates on each side of the bell.

I think the record in the NFL is like 30-something. If you can do 10, even in the NFL at certain positions, 10 means you're in the conversation. I can almost do 10. I will never get to 20. I will probably never get to 15, but my goal before I'm done is to be able to do 14 repetitions of 225.

If I can do it, it will be filmed. It will be streamed on Facebook Live. You can all watch it.

Shontell: Just what I want to see.

Goldberg: Every few weeks I really go for it and I'm like, "This is going to be the day." I set up the little Facebook Live and I try to do it, and that's when I always fail. And once I can do 14 reps of 225 you will never see it again. Then I'll gain all the weight back.

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Despite a tough year in 2016, Thaicom Chief Commercial Officer Patompob (Nile) Suwansiri is confident the operator will be able to bounce back as it looks to return to profit and revenue growth. He admitted to Via Satellite that 2017 will likely be “no different from 2016,” but is optimistic Thaicom’s tough period will not get any worse.

“We believe that by the end of 2017 the market will recover and net margins will start to look better. It is important to use the current softness in the market to develop new business and investment strategies in order to come out strong of the crisis that the satellite industry is experiencing right now,” he said.

Like all the other satellite operators, Suwansiri admitted Thaicom is currently facing tough price pressures. The flat demand for satellite capacity in 2016 should continue into this year, he said.

Thaicom is probably best known for its position of investing in broadband before a number of other operators in the region. Its Ipstar satellite was one of the first broadband satellites ever launched, and while making a business model out of broadband has proved far from easy, the operator has to be commended for its bravery in doing something years ahead of everybody else.

Suwansiri pointed out that demand in other markets, such as Indonesia and the Philippines, will help compensate for a weaker Australian market where Thaicom’s contract with the National Broadband Network (NBN) is ending this year. He believes as a result of this, the broadband market will “bounce back” for Thaicom.

So, with a tough year ahead for the company, will it be looking to invest in new satellites? Suwansiri points to High Throughput Satellites (HTS). “There is no doubt that there is a growing demand for broadband services in the future which will lead to a lot of competition and interesting developments. But we believe that there continues to be a strong market for Geosynchronous Earth Orbit (GEO) satellite-enabled broadband services. Thus we continue to invest in our in-orbit resources and our broadband program — especially when we believe that we can attach a solid business case to it. Ipstar was the first HTS in the world and since its launch in 2005 our name has become synonymous with satellite broadband services in Asia Pacific. Therefore we want to continue to build upon this legacy,” he said.

Suwansiri highlighted markets such as Myanmar and Kampuchea as some that may offer great potential for growth in the short and medium term for Thaicom. “The operator intends to expand its presence in Asia and beyond through investments and partnerships. One example is its recent agreement with China Great Wall Industry Corporation (CGWIC) for the construction and launch of a high throughput Ka-band broadband satellite with 37 GHz of capacity. The satellite is scheduled for launch in late 2019,” he said.

While Thaicom hopes it can make an impact in new markets, and that the broadband market will bounce back, the broadcast market will remain a strong barometer in terms of measuring how the company is doing. With viewers’ habits changing toward consuming video, being successful here will be a major challenge for the operator.

Suwansiri said the video market is seeing huge changes as viewers gravitate toward Over-the-Top (OTT) and other non-linear forms of TV viewing. He believes for Thaicom to stay ahead of the curve it must adapt to this emerging new ecosystem where broadcasters can only survive and grow their business if they provide more of what viewers want in terms of how they access content.

“So in this situation of declining advertising revenues from traditional linear TV and changing viewer habits, how can our customers deliver new multiscreen formats including Ultra-HD TV and explore new markets at the same time? Thaicom is embracing this new challenge and is working hard to provide quality HD distribution platforms and multiscreen services for our customers to efficiently distribute their programming and still grow their markets. It is important to be part of the revolution, which is unstoppable, rather than fighting it,” Suwansiri said.

The post Thaicom CCO: 2018 Will be the Year When Operator Bounces Back appeared first on Via Satellite.

There are many competing interpretations for why Hillary Clinton lost last fall’s election, but most observers do agree that economics played a big role. Clinton simply didn’t articulate a vision compelling enough to compete with Donald Trump’s rousing, if dubious, message that bad trade deals and illegal immigration explain the downward mobility of so many Americans.

As it happens, Clinton did have the germ of exactly such an idea—if one knew where to look. In an October 2015 op-ed, she wrote that “large corporations are concentrating control over markets” and “using their power to raise prices, limit choices for consumers, lower wages for workers, and hold back competition from startups and small businesses. It’s no wonder Americans feel the deck is stacked for those at the top.” In a speech in Toledo last fall, Clinton assailed “old-fashioned monopolies” and vowed to appoint “tough” enforcers “so the big don’t keep getting bigger and bigger.”

Clinton’s words were in keeping with Bernie Sanders’s attacks on big banks, but went further, tracing how concentration is a problem throughout the economy. It was a message seemingly tailor-made for the wrathful electorate of 2016. Yet after the Ohio speech, Clinton rarely touched again on the issue. Few other Democrats even mentioned the word monopoly.

The pity is that Clinton’s stance wasn’t simple campaign rhetoric. It was based on a substantial and growing body of research that confirms that consolidation is at the root of many of America’s most pressing economic and political problems.

These include the declining fortunes of rural America as farmers struggle against agriculture conglomerates. It includes the fading of heartland cities like Memphis and Minneapolis as corporate giants in coastal cities buy out local banks and businesses. It includes plunging rates of entrepreneurship and innovation as concentrated markets choke off independent businesses and new start-ups. It includes falling real wages, as decades of mergers have reduced the need for employers to compete to attract and retain workers.

Monopoly is a main driver of inequality, as profits concentrate more wealth in the hands of the few. The effects of monopoly enrage voters in their day-to-day lives, as they face the sky-high prices set by drug-company cartels and the abuses of cable providers, health insurers, and airlines. Monopoly provides much of the funds the wealthy use to distort American politics.

For most of the 20th century the Democratic Party worked hard to prevent such extreme concentration of power. This tradition, which dates to the time of Thomas Jefferson, found expression in anti-monopoly policies designed to protect Americans not just as consumers, but also as citizens and producers, from domination by the powerful. Yet today most Americans associate terms like “freedom” and “liberty” with Republicans, and if that remains the case, Democrats will likely have trouble rebuilding their party as they look to 2018. Many Republicans also oppose the formation of monopolies, but the Democrats in particular would benefit from making it a centerpiece of their platform in the coming years.

The idea that America has a monopoly problem is now beyond dispute. Since 2008 there have been more than $10 trillion in mergers, and the pace of deal-making continues to accelerate, with 2015 setting a record for the most mergers in a year and October 2016 setting the record for the most mergers in a month.

In 2016, The Economist published three cover stories on America’s monopoly problem. The magazine reported that two-thirds of all corporate sectors have become more concentrated since the 1990s, that corporations are far more profitable now than at any time since the 1920s, and that an inordinate amount of profit goes to a very few immense investment funds, such as BlackRock and State Street. In April, the White House Council of Economic Advisers came to much the same conclusion, and called for a “robust reaction to market power abuses.”

Ordinary Americans didn’t need experts to explain the danger of monopoly. Populist movements like the Tea Party, Occupy, and the Sanders campaign have all focused to varying degrees on the threats posed by concentration. Polls show that a majority of Americans now believe big corporations are too powerful. Yet through 2016, mainstream Democrats didn’t acknowledge that this growing fear of monopoly power might affect how citizens vote.

Consider some of the mainstays of Democratic confidence going into the fall, and how these collided with the real world.

Party leaders were, for instance, right that millions of Americans today are grateful for Obamacare. But the travails of Obamacare also reinforced for millions of other Americans that hospital, insurance, and pharmaceutical monopolists are driving up costs and cutting back on care, and that the administration had no plan to stop them.

Party leaders were also right that the U.S. economy is on sounder footing than when Barack Obama took power. But while most citizens are in less-dire straits than they were eight years ago, they also have more time to consider the rest of their lives. They see internet providers blocking them from faster service and cable companies charging too much for their entertainment. They see giant food companies driving down the quality of their milk and chicken, and agriculture corporations driving up the cost of seeds and pesticides. They see a few huge corporations dominating the sale of home mortgages, groceries, office supplies, and restaurant meals, and gouging consumers when they buy everything from eyeglasses to cowboy boots.

Further, party leaders were not wrong that the rate of joblessness has fallen sharply from 2009. But those figures do nothing to address the fact that many of those jobs feel very different from the ones that vanished after the crash of 2008. For millions of working Americans, the vanguard technologies of the last decade are fast turning into oppressive systems of direct control. Consider the truck drivers, warehouse workers, receptionists, nurses, and cabbies who find their actions and even their speech monitored and directed in ever-increasing detail. Or consider the white-collar workers in the Seattle headquarters of Amazon, where, according to a New York Times feature, executives run a “continual performance improvement algorithm on its staff.” Such forms of control, especially when wielded by giant corporations, tend only to amplify the sense of powerlessness.

Further, mainstream Democrats are correct, in their post-election assessments, to acknowledge the need to combat fake news reports. But party leaders would be wise to also address the effects of monopoly on the flow of information between citizens, and the business models of mainstream media. Facebook actively manipulates the flow of real news between journalist and citizen. Amazon actively manipulates the flow of books between America’s authors and readers. By claiming more than 80 percent of all online advertising revenues, Facebook and Google help to drive traditional news publishers and online news start-ups out of business. All political groups rely on independent news media to communicate effectively with voters, and that’s especially true of parties out of power.

* * *

The election of a man like Donald Trump is precisely what the Democratic Party was first built, and then rebuilt, to prevent.                                                                    

When Thomas Jefferson and James Madison founded the party in 1792, their goal was to oppose Alexander Hamilton’s plan to centralize power in a financial aristocracy tied to the state. In place of Hamilton’s vision of an America in which a few capitalists managed most business, leaders of the new party envisioned a political economy in which fighting monopoly and the concentration of power would foster the creation of independent, self-governing citizens.

This experiment in radical economic democracy did not last. In the 1840s, Southern planters seized the party and used it to protect their slave estates. After the Civil War, a new Southern elite wielded the party as a shield against Northern capital and the will of the free farmer, white and black. For a short while the new Republican Party took up the flag of liberty. But the GOP was soon captured by the emerging class of Wall Street tycoons and Gilded Age monopolists.

Only in 1896, during William Jennings Bryan’s run for president, did a group of white, male citizens dedicated to anti-monopolism recapture the levers of control within the Democratic Party. This time they held on, and for most of the next 100 years, through the administrations of Woodrow Wilson, FDR, Harry Truman, and beyond, a prime purpose of the Democratic Party was to protect the worker, farmer, shopkeeper, and other independent citizens and innovators from concentrated power.

During these decades, Democrats understood that in making markets and regulating competition they were also establishing a set of political economic checks and balances that helped citizens maintain control over their own destinies and those of the communities in which they lived. In defending this vision, leaders like President Wilson used much the same language as had Jefferson and Madison. “There is no salvation for men in the pitiful condescensions of industrial masters,” Wilson said during the 1912 campaign. “Guardians have no place in a land of freemen.”

In the years between the election of Wilson and the beginning of World War II, Americans built the world’s first modern political economy designed to preserve both liberty and democracy, and also to enable economic growth and innovation. Guided largely by the thinking of Supreme Court Justice Louis Brandeis, they did so by devising three distinct but coordinated approaches to competition policy.

In the case of network industries like electricity, railroads, and other “natural monopolies,” they held that the public must directly own the corporation or regulate its actions. In the case of industrial activities like manufacturing cars or chemicals, citizens accepted high degrees of vertical integration and concentration of capital, but they also insisted that all such corporations compete with at least three or four other large corporations making the same products. In all other sectors of the economy—such as retail, farming, and banking—the aim was to promote as wide a distribution of power and opportunity as possible by preventing concentration almost everywhere. Across the political economy, but especially in sectors where capital and power were highly concentrated, they promoted unions to protect the worker.

The result was a revolutionary success. For years, conventional wisdom among mainstream Democrats has held that the New Deal was mainly an experiment in concentration and socialization. Yet with a few exceptions, the main thrust of both the Roosevelt administration and Congress was to promote, in the words of one of the main advocates of centralization under FDR, the “atomization” of American business. Indeed, the U.S. economy became steadily less consolidated year after year from the mid-1930s until the early 1980s.

Besides delivering to citizens much of the—in the words of Justice Brandeis—“industrial liberty” they had demanded, this anti-monopolism also laid the basis for a period of rapid technological advance, material prosperity, and financial stability that helped make possible the broad expansion of American democracy in the great mid-century battles for civil rights. It was a vision that bridged the racial divide; one of the greatest advocates of the Brandeisian vision was Supreme Court Justice Thurgood Marshall. It was a vision that even bridged the two parties: Presidents Dwight Eisenhower and Richard Nixon both maintained strong antitrust operations during their administrations.

In 1792, Madison wrote that it was the “independent” citizen who served as “the best basis of public liberty, and the strongest bulwark of public safety.” This proved true in the 20th century. For decades, the Democratic Party’s overwhelming electoral success was due in no small part to the fact that it delivered an important form of political economic freedom to the businessperson, worker, shopkeeper, and farmer. These free citizens then returned the party to power.

The end came after the election of Ronald Reagan in 1980. Reagan brought to power a group of lawyers and economists—loosely affiliated with the University of Chicago—dedicated to overturning the anti-monopoly philosophy of the Democrats. Key leaders of the group included the economist Milton Friedman and the lawyers Richard Posner and Robert Bork. These Reaganites argued that instead of using competition to protect liberty and democracy, the laws should instead promote only efficiency, theoretically in the interest of the consumer. Even straight-up monopoly was fine, they said, as long as the monopolist promised to lower prices.

In previous decades, Democrats would have moved swiftly to counter Reagan’s new pro-monopoly policies. But in the late 1970s a new generation of party leaders had begun to embrace aspects of the libertarianism of the Chicago Schoolers (or, as the Democrats would later call it, neoliberalism). Unlike traditional Democratic ideology, which holds that all economics is political, libertarian ideology holds that markets are self-regulating and inherently competitive and that monopolies are naturally efficient in ways that are good for consumers.

Many among this new breed of Democrats also embraced the corporate monopolists themselves, along with their partners on Wall Street, and competed with Republicans for campaign contributions from the biggest of the big. In the 1990s, this way of thinking and acting lay behind Bill Clinton’s decisions to unleash concentration in the banking, media, energy, and defense sectors, and to embrace a new approach to trade policy that largely opened the U.S. border to foreign monopolists, such as the Brazilian bankers who in recent years have taken over Anheuser-Busch, MillerCoors, Kraft, Heinz, and Burger King. (Late in his administration, Clinton partially corrected course by bringing a tough antitrust suit against Microsoft. The Obama White House followed a similar trajectory: early indifference followed in the last year by vigorous, if insufficient, attempts to take on power.)

The Democratic Party almost entirely failed to live up to its traditional promise to protect the independent farmer, shopkeeper, and businessperson. Instead, party leaders sat by quietly as Wall Street financiers armed with giant corporations expropriated the livelihoods of millions of American families.

Some in the Democratic Party, however, have finally awakened to America’s monopoly problem. Last June, Senator Elizabeth Warren delivered what was the most important anti-monopoly speech in America by a major political figure since Franklin Roosevelt. “Concentration,” Warren said, “threatens our markets, threatens our economy, and threatens our democracy.”

In July, reformers succeeded in writing strong anti-monopoly language into the Democratic Party platform, the first time since 1988. In September, Renata Hesse, then Obama’s acting assistant attorney general for antitrust, delivered a speech that went a long way toward overturning the Chicago School approach to antitrust.

But with the exception of Warren, most of today’s Democrats, to the extent that they even understand the threat posed by monopoly, still treat competition policy as one of many potential solutions to America’s problems, an arrow of roughly equal importance with all the other arrows in the quiver, rather than as a philosophy able to guide thoughts and actions in all corners of the political economy. Donald Trump has proved that economic populism is smart politics. If what he perfected was a version of dangerous populism, based on resentment, xenophobia, and paranoia, then anti-monopolism is smart populism—it directs anger not at immigrants or China, but at monopolists and the policies that empowered them.

An anti-monopoly stance would also provide a way for the Democrats to address their Electoral College problem. One of the by-products of monopolization is that business is becoming concentrated in a few cities, mainly along the coast. Consider St. Louis. In 1980, 22 Fortune 500 companies called the city home; today only nine are left. In 1979, per-capita income in the metro area was 89 percent as high as in New York; since then it has fallen to 77 percent. Even when St. Louisans launch smart companies—like Twitter and Square—they usually flee to the new metropoles.

This, in turn, leads to a concentration of certain kinds of people who tend to think and vote in certain ways, in fewer places. It is no coincidence that this pattern of growing regional inequality looks remarkably like the 2016 electoral map, with coastal states blue and a sea of red in the center of the country. Donald Trump’s success was partly due to the fact that he spoke to the fears of voters in this increasingly stripped-out red zone.

Fully endorsing anti-monopolism would immediately give Democrats a believable pro-business, pro-liberty message that would play in almost every section of every state, and indeed could be wielded immediately by state legislators and attorneys general. In the longer term, a true anti-monopoly program will help to distribute opportunity, commerce, and people more evenly across the nation, exactly as the framers of the Constitution intended.

Perhaps more importantly, anti-monopoly is a simple philosophy that can be understood by every American. Almost everyone wants freedom from bosses, economic and cultural and racial. Almost everyone wants the freedom to make their own families and communities, and their own careers and characters.

Donald Trump rumbled about monopolists a few times during his campaign. And, true, he may yet deliver on his promises to block AT&T’s takeover of Time Warner and to bring an antitrust case against Amazon. But given Trump’s embrace of such Wall Street monopoly-makers as Wilbur Ross and Paul Singer, it’s much easier to imagine that under his administration, concentration in America will get only worse.

The last time the country faced such threats, after the rise of the plutocrats in the early decades of the 20th century, it was the Democrats who spoke directly to the fears of the citizenry. Consider Franklin Roosevelt’s words in 1938. “The liberty of a democracy is not safe,” he said, “if the people tolerate the growth of private power to a point where it becomes stronger than their democratic state itself. That, in its essence, is Fascism—ownership of Government by an individual, by a group, or by any other controlling private power. … Among us today a concentration of private power without equal in history is growing.”

The age of true American liberty—in which it is the people who rule both the government and the economy—lies in the muck. But there is a political party with a history of fighting to make it a reality.

This post is adapted from an article in Washington Monthly.

The web of President Donald Trump’s conflicts of interest has grown to encompass the American Red Cross, which will be hosting 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 will be accepting 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 celebrates 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 is 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.

The Background

President Donald Trump still has not taken the necessary steps to distance himself from his businesses while in office. In accordance with a plan that he and one of his lawyers, Sheri Dillon, laid out at a press conference on January 11, Trump has filed paperwork to remove himself from the day-to-day operation of his eponymous organization. However, numerous ethics experts have voiced strenuous objections to the plan, which they say does very little to resolve the issue: As long as Trump continues to profit from his business empire—which he does whether or not he is nominally in charge—they say, the possibility that outside actors will attempt to affect his policies by plumping up his pocketbook will remain very much in play.

This week, some of Trump’s critics moved forward with legal action. The watchdog group Citizens for Responsibility and Ethics in Washington, or CREW, filed a lawsuit alleging that Trump’s business holdings violate the Emoluments Clause of the Constitution, which makes it illegal for government officials to “accept of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.” CREW’s bipartisan legal team includes, among others, Norm Eisen and Richard Painter, who served as ethics lawyers under Presidents Obama and George W. Bush, respectively; Laurence Tribe, a constitutional law professor at Harvard University; and Zephyr Teachout, a professor at Fordham University (and former congressional candidate) who is considered an authority on the Emoluments Clause. All have been vocally critical of Trump’s continued refusal to sell off his business, and are now taking their case to court to argue that several of Trump’s businesses present avenues by which foreign governments could seek to influence the president by, for example, booking stays at one of his hotels or renting space at one of his properties. Additionally, the lawsuit seeks to force Trump to reveal his tax returns, something every president has done since Gerald Ford but which Trump has refused to do, significantly limiting the public’s ability to understand the president’s finances. When asked about the lawsuit, Trump described it as “totally without merit.” Eisen was quick to respond on Twitter, offering to “debate Trump (or his chosen champion) on the merits of our case anytime,” making it clear that CREW intends to continue to pursue its case. (CREW has also filed a separate complaint to the General Services Administration arguing that Trump has violated the lease on his Washington, D.C. hotel, which states that “no … elected official of the Government of the United States … shall be admitted to any share or part of this Lease, or to any benefit that may arise therefrom.”)

Though CREW is the first group to bring a lawsuit against President Trump, it may soon have company. According to The New York Times, Anthony Romero, the executive director of the American Civil Liberties Union, has said that his organization is looking for a plaintiff to sue Trump for violating the Emoluments Clause, although with a different claim to legal standing: While CREW intends to demonstrate that the group itself has suffered financial harm because the need to focus on the Emoluments Clause has diverted its resources away from other worthy causes, the ACLU is hoping to find a hotel or bed-and-breakfast owner that can prove he or she has lost business to one of Trump’s hotels during his presidency.

CREW’s lawsuit is just the latest development in what promises to be a continuing saga regarding Trump’s many conflicts of interest that began almost as soon as he won the presidency. Along with his unprecedented wealth, Trump brings to the office unique and gravely concerning entanglements that, whether he recognizes their effects or not, threaten to undermine his decision-making as president. The plan Trump and Dillon announced on January 11 would do very little to resolve the conflicts: It places control of his assets in the hands of his two adult sons and a longtime associate of their father’s with what so far amounts to a pinky-swear assurance that, despite their proximity to the president, they will not discuss any aspect of the business with him. On top of that, the plan supposedly would terminate several of the Trump Organization’s pending deals and place a ban on new foreign deals, two conditions undermined by the announcement that the organization would be moving forward with expanding its golf course in Aberdeen, Scotland.

Even before his most recent plan was laid out, Trump has attempted to deflect criticism by repeatedly asserting that the law barring executive-branch officials from maintaining financial holdings or business ties that overlap with their duties does not apply to the president or vice president. In this, he is correct; the law, passed in 1989, exempts the two chief executives from conflict-of-interest rules on the understanding that their purview is so broad that it would be impossible for them to completely disentangle themselves.

Regardless, legality does not imply propriety. Unless Trump acts to put actual distance between himself and his business ventures, these questions are likely to continue throughout his time in the Oval Office. On top of the aforementioned legal actions, the director of the Office of Government Ethics, Walter Shaub, has declared Trump’s efforts insufficient, remarking, “I don’t think divestiture is too high of a price to pay to be the president of the United States,” and a number of Senate Democrats have introduced legislation that would force Trump to divest or face impeachment. Below is an attempt to catalogue the more clear-cut examples of conflicts of interest that have emerged so far. The most recent entries appear at the top:

• That D.C. Labor Dispute
• That Estate in Palm Beach
• Those Expansion Plans
• That Hotel in Vancouver
• That Reality-Television Show
• That Pipeline
• Those HUD Grants
• That Golf Course in Aberdeen
• That Other Billionaire New York Real-Estate Developer
• Those Indonesian Politicians
• That Emirati Businessman
• That Virginia Vineyard
• That Las Vegas Labor Dispute
• That Kuwaiti Event
• Those Certificates of Divestiture
• That Carrier Deal
• That Blind-Trust Issue
• Those Fannie and Freddie Investments
• That Phone Call With Taiwan
• That Deutsche Bank Debt
• That Secret Service Detail
• That Property in Georgia (the Country)
• That Phone Call With Erdogan
• That Hotel in Washington, D.C.
• That Argentinian Office Building
• Those Companies in Saudi Arabia
• That British Wind Farm
• Those Indian Business Partners
• That Envoy From the Philippines  

That D.C. Labor Dispute

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.

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That Estate in Palm Beach

Even before President Donald Trump took office, Mar-a-Lago, his golf club in Palm Beach, Florida, was involved in instances of self-dealing that attracted scrutiny. During the presidential campaign, David Fahrenthold of The Washington Post discovered that Trump used donated funds to buy a $20,000 portrait of himself to reside at the resort and that he used foundation money to settle a lawsuit over the size of the his flag on the property. Then, on New Year’s Day, footage emerged from an event the previous evening at Mar-a-Lago in which Trump praised an Emirati business partner to the assembled crowd, seemingly confirming that those who have done business with the president in the past may receive preferential treatment in the future.

Now, it appears that Trump may be exploiting his new position to make more money off of the club. On January 25, NBC reported that the resort had doubled its initiation fee, from $100,000 to $200,000. The increase, which took effect on January 1, is the first change to the cost of admission since 2012, when, amid a decline in membership in the aftermath of the Bernie Madoff scandal (which affected a large number of Palm Beach residents), the club made the exact opposite decision, halving the fee from $200,000 to $100,000.

The increase drew widespread criticism due to the perception that Trump is using the presidency to pad his wallet. As Mar-a-Lago’s owner, Trump directly profits from any increase in revenues at the club. He has also designated it his “winter White House,” meaning there’s plenty of reason to believe that people will be willing to pony up the increased initiation fee for the chance to rub shoulders with him, whether that means an opportunity to actually talk to him about an issue or just for the chance that they’ll catch his eye and make a good impression.

On the surface, the situation appears similar to previous examples of access-selling; there’s a long history of wealthy citizens paying large sums of money to attend events where they may have a chance to bend a politician’s ear. What makes this case different is that, while such events usually benefit a charity or campaign, here, Trump himself will be the beneficiary.

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Those Expansion Plans

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.

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That Hotel in Vancouver

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.

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That Reality-Television Show

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.

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That Pipeline

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 has 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. 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.

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Those HUD Grants

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.

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That Golf Course in Aberdeen

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.

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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.

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Those Indonesian Politicians

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 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..

Since Trump and his lawyer announced on January 11 that the company would be suspending its unfinished development projects and pursuing no new foreign deals, the current state and eventual fate of the projects in Indonesia are unclear. Regardless, they have already created a remarkably complicated situation among the president and politicians and businesspeople involved in the country’s political scandals and ethnic divisions, jeopardizing his ability to appropriately interact with the nation’s leadership.

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That Emirati Businessman

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 ac