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, Michael 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 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 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. Since Trump was elected, the property has requested temporary H-2A visas for six foreign workers, according to The Washington Post. 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, will be in charge of appointing a new Secretary of Homeland Security once he assumes the presidency, which gives Trump authority over the very department responsible for deciding whether to grant the visas that the vineyard has requested. His current nominee, 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 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. Once he assumes office, 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 will likely be withdrawn once Trump becomes 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 once he assumes office, 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

Over the past few months, a number of experts have called for President Trump to either sell off his business holdings or, if the illiquidity of his assets prevents him from doing so, to put as much as possible into a blind trust managed by a lawyer or other trustee with whom he will have no contact. Pursuing one of these two options is seen by many as an important step to distancing himself from even the appearance that he will be considering his own financial prospects in addition to those of the nation while in office. In response, Trump repeatedly said during the campaign that he intends to cede control of his business to his three adult children, Donald Jr., Ivanka, and Eric, although, as has been previously noted, doing so would barely even create the appearance of a blind trust given how his children are close advisers, members of his transition team, and, well, his children. (Trump has also alluded on Twitter to an upcoming press conference in which he intends to more fully explain his plans, although doubts remain that the arrangement he proposes will actually create the necessary barriers between Trump and his business.)

Moreover, even if one does take take the president at his word that his children will be entirely separate from his administration, events since his election strongly suggest otherwise. All three have been seen in contexts that significantly diminish the appearance of separation 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. Officials within the State Department have begun to express frustration with the optics of the Trump family’s current system.

Much of the focus, though, has been on Ivanka, whom many consider to be among her father’s most trusted advisers, and the various ways she has indicated that she will remain a part of both the family business and her father’s administration. Ivanka also appeared in the photos with the family’s Indian business partners, and she and her husband Jared Kushner—also one of Trump’s advisers—sat in on a meeting between the president and Japanese Prime Minister Shinzo Abe; reports later emerged that, at the time, Ivanka was in negotiation with the Japanese apparel company Sanei International, whose parent company is owned in large part by the Japanese government. A number of outlets have reported that, while Melania Trump will be the official First Lady, Ivanka plans to assume a policy portfolio akin to that of previous first ladies; one issue she apparently plans to take on is climate change, on which she recently met with her father and former Vice President Al Gore. Even the optics of physical distance are diminishing: According to CNN, Ivanka and Jared plan to move from New York to Washington, D.C. once the Trump administration begins. That the president’s children appear involved in both the Trump administration and the Trump Organization presents a major threat to the long-established norm that presidents should distance themselves from business interests that could interfere with their official duties.

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. Once Trump takes office, he 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 earlier this month—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 once he assumes 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, Trump does not own the location outright; instead, he leases the building from the federal government’s General Services Administration, an agency whose next administrator Trump will soon be appointing. The GSA has explicit regulations prohibiting contracts with government employees to prevent conflicts “that might arise between the employees’ interests and their Government duties, and to avoid the appearance of favoritism or preferential treatment.” The Trump Organization’s 60-year lease on the property likewise states, “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.” According to House Democrats, the GSA has ruled that Trump “will be in breach of the lease agreement the moment he takes office” and must divest from the property before he does so.

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. Numerous ethics experts, many of whom are calling for Trump to generally divest his business holdings, have singled out the building’s lease, which will likely be breached the moment Trump takes office even if he does transfer his company to his children. And on November 30, mere hours after Trump stated on Twitter that “legal documents are being crafted which take [him] completely out of business operations,” Buzzfeed reported that Trump and the federal government were closing in on a tax subsidy for the property that could be worth as much as $32 million. As a result of the increasing scrutiny, the hotel and his handling of the commotion about it have become emblematic of the broader issues surrounding Trump’s conflicts of interest.

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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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