Donald Trump: A list of potential conflicts of interest

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Republican Donald Trump appears at a campaign roundtable event in Manchester, New Hampshire, U.S., October 28, 2016.Image source, Reuters

Donald Trump's extensive, international business holdings mean he will have to make decisions as leader of the US that also affect his businesses. Here's a look at some of his potential conflicts of interest.

The Trump Organization is an umbrella company for Donald Trump's hundreds of investments in real estate, brands and other businesses.

As head of the executive branch and a business owner, he has the ability to influence both US policy and government agencies to benefit his bottom line.

Presidents are not subject to the same conflict of interest rules as other government employees, but previous commanders-in-chief have placed their investments into a blind trust to prevent any question of corruption.

Ahead of the inauguration, Mr Trump placed his business holdings in a revocable trust managed by his two adult sons, Eric and Donald Jr. But while this removes him from the day-to-day decision making of his business, the president still retains a long-term interest in making sure his companies are doing well.

Eric Trump told Forbes in March he may share quarterly reports with his father, despite a statement that they would not discuss business or government with each other. Shortly after, ProPublica reported Mr Trump could draw money from the trust at any time, without external disclosure.

Ethics experts have urged Mr Trump to liquidate his business holdings so that he can avoid any appearance of a conflict, as the public nature of most of his businesses means it impossible to prevent him from knowing how government policies will affect his bottom line.

Below is a list of known conflicts of interest for Mr Trump, both foreign and domestic. Because his business is private, the full extent of his holdings - and the potential for conflicts - is not known.

American conflicts of interest

Trump International Hotel

Image source, Getty Images
Image caption,
Donald Trump (C) and his family prepare to cut the ribbon at the new Trump International Hotel in October 2016

The Trump Organization leases the Old Post Office Building from US government's General Services Administration (GSA) for the Trump International Hotel in Washington, DC.Trump as president is both "landlord and tenant" of this building, says Steven Schooner, who along with Daniel Gordon, has called on Trump to end the lease.

The 60-year lease will likely involve renegotiations - and the person responsible for setting the rent prices would ultimately report to the head of the GSA, a Trump appointee.In addition, the lease bars any federal employee, including elected officials, from benefitting from contracts with the government.

But in a March letter, the GSA said it had determined Mr Trump was in "full compliance" with the lease because his interests in the hotel had been placed in a revocable trust, which he would see no personal benefit from during his term in office.

The letter was written by the GSA employee who had done the initial negotiations over the building.

The letter has not stopped criticism.

"Donald Trump still owns the hotel, still will benefit from payments and still has a vested interest in its success," Noah Bookbinder, executive director of Citizens for Responsibility and Ethics in Washington, told CNN. Bookbinder's organisation sued Mr Trump shortly after he was sworn in over foreign conflicts of interests.

Meanwhile, the hotel has already been pitched to foreign diplomats as a place to stay while in Washington, raising concerns that foreign governments could see booking expensive rooms at the Trump International as a way to gain favour with the Trump administration.

40 Wall Street

Image source, Getty Images

The Trump Organization owns the right to lease the space in this office building in Manhattan - and makes money from the rent paid to the building.

According to Bloomberg News, there are five ongoing federal investigations into current or former tenants of 40 Wall Street, mostly for securities fraud.

Those investigations are headed up by the Securities and Exchange Commission (SEC).

Mr Trump's appointee to head the SEC, Jay Clayton, has been criticised for his ties to Wall Street firms by Democrats during his confirmation hearings.

Dakota Access Pipeline

Image source, Getty Images

Sioux tribes and allies had protesting for months to prevent the Dakota Access pipeline from being built under water supplies near the Standing Rock reservation.

Trump had a partial investment - somewhere between $500,000 and $1m - in the parent company of the firm building Dakota Access pipeline, Energy Transfers Partners.

Trump campaign spokeswoman Hope Hicks says Mr Trump has sold his stock in Energy Transfer Partners. But another one of Trump's stock holdings, Phillips 66, owns a 25% share in the project.

It's unclear if the president has also sold his stock in Phillips 66, as his last financial disclosure was in May 2016.


On 24 January, Mr Trump signed an executive order paving the way for final construction of the pipeline. ETP began work in early February and oil is expected to flow by early April. The pipeline remains the subject of a lawsuit by the Cheyenne River Sioux.

Deutsche Bank

One of Trump's major lenders on his real estate projects is Deutsche Bank.

The bank is currently in negotiations with the US justice department to settle a case involving misleading buyers when it sold mortgage bonds backed by risky loans.

Update: Deutsche Bank settled the mortgage bonds case for $7.2bn in late December 2016.


The president has another job title beyond "commander-in-chief": executive producer. He will continue to have a "big stake" in The Celebrity Apprentice, which airs on NBC, linking Mr Trump's business interests with the network.

NBC and its parent company, Comcast, is regulated by the Federal Communications Commission (FCC). Mr Trump's pick for the chairman, Ajit Pai, will be need to be reconfirmed by the Senate this year, in order to continue on at the commission.

National Labor Relations Board

On 3 November, the National Labor Relations Board (NLRB) ruled that Trump International Hotel Las Vegas - which Trump co-owns - broke the law by refusing to negotiate with a hotel workers' union.

The hotel appealed the case to a higher court. But three other labour disputes involving the Las Vegas hotel are currently before the board, as well as several others involving the Trump Organization.

NLRB is facing an unprecedented situation on how to rule on disputes that will affect the president's business. Mr Trump has named current board member Philip Miscimarra as acting chair and will be able to appoint two new members to vacant spots.

Secret Service

Image source, Reuters

During the campaign, Trump's airplane company, TAG Air, billed the Secret Service for flying on Trump's Boeing 757 while protecting the candidate. It is standard for Secret Service to pay their own way on private aircraft, and during the campaign, this was tracked by the Federal Election Commission through campaign finance reports.

While Mr Trump flies on Air Force One and other US aircraft as president, if Trump or Pence family members are assigned protective detail and decide to fly on Trump planes, the Secret Service would need to reimburse TAG Air - and ultimately Mr Trump - for the flights.

In addition, Secret Service will reportedly pay the Trump Organization for the space they use in Trump Tower while protecting Melania and Barron Trump as they stay in New York for part of 2017. The Washington Post has reported the Secret Service has requested $27m extra for the overall protective detail in New York.

Secret Service has also paid to protect Eric Trump and Donald Trump Jr, as members of the president's family - even as they travel to take care of business for the Trump Organization.


Jason Miller, the transition team's spokesman, has said the president sold all his stocks in June 2016, a month after the required financial disclosure, but the campaign did not furnish proof nor provide an updated list of Mr Trump's investments.

Since his election, Mr Trump has singled out specific companies for criticism on Twitter, causing price swings on the stock market. If Mr Trump still owns these stocks, he could make money off of selling and buying before and after such tweets.

Foreign holdings

According to Trump's financial disclosure, as of mid-2016, he had investments in or owned companies in at least 20 countries. Unlike his domestic business, Mr Trump could run afoul of a clause in the US constitution by continuing to profit from these deals.

The emoluments clause specifically prevents anyone who holds a US "office of trust or profit" from accepting gifts, payments or any benefit from a foreign nation.

Even routine business benefits like tax breaks could violate the emoluments clause.

One former White House ethics lawyer has argued Mr Trump would be violation of the constitution "on day one".

In addition to emoluments, Mr Trump's foreign policy decisions could be called into question in any country in which the Trump Organization does business, especially when his policies would benefit the firm's holdings overseas.Here are some of Mr Trump's larger business deals that intersect with US foreign policy.

BBC Monitoring contributed to this report


An Argentine broadcaster reported that Mr Trump allegedly asked President Mauricio Macri for his support to build an office tower in Buenos Aires while on call during Mr Trump's transition period.

Mr Macri's office and the Trump campaign have denied the report.


A waterfront property in Rio de Janeiro, branded with the Trump name through a licensing deal, is the subject of a federal inquiry after two small Brazilian pension funds invested heavily in the unfinished project, with allegations of bribery.

Update: The Trump Organization has reportedly cancelled their licensing deal with the developers in Rio. Trump lawyer Alan Garten told the AP in December this and a few other cancellations were "normal housekeeping" and not part of a strategy to reduce potential conflicts of interests.


The Trump Organization has licensing deals with two hotel towers in Canada - one in Toronto and one in Vancouver.

The Vancouver building is now open, with a ribbon-cutting ceremony attended by the Trump sons, but the Toronto tower is up for auction after the developer went bankrupt and was put into receivership by a Canadian judge in November.


The Bank of China is one of China's largest banks and also majority state-owned. It holds the title on a $950m loan for a New York Building in which Trump is a part owner. Mr Trump has previously labelled China a currency manipulator.

Another largely government-owned Chinese bank - the Industrial and Commercial Bank of China - has space in Trump Tower, paying rent to the Trump Organization.

The Trump Organization has also previously attempted to open a series of hotels in the country, and Trump Hotels chief executive Eric Danziger told a Hong Kong media outlet in October they wanted to open 20 to 30 hotels in the country in 2017.

Media caption,

Jared Kushner has a long list of things to do

Meanwhile, Trump's son-in-law and now senior adviser, Jared Kushner, was negotiating a deal with China's Anbang Insurance Group to redevelop 666 Fifth Avenue in New York City before backing out of talks in late March.

Mr Kushner has been given a senior role inside the White House. His lawyer told the New York Times he "would recuse from particular matters that would have a direct and predictable effect on his remaining financial interests" without giving specifics.

Ivanka Trump, who has her own non-paying position at the White House, has advised her father on a broad number of policy areas, including high-profile foreign policy meetings.

On the same day she sat next to Chinese President at a dinner at Mar-a-Lago, the Chinese government approved three new trademarks for Ms Trump's firm to sell items in China.

While Ms Trump has moved her firm to a trust and said she will not partake in decisions could led to conflicts, ethics experts are concerned with the broadening scope of both her business, which bears her name, and her advisory role at the White House.

Dominican Republic

Despite a promise to do "no new deals" while Mr Trump is in office, the Trump Organization is testing that definition in the Dominican Republic.

The firm with developers of a beachfront planned community but the project stalled, and Trump sued in 2012 for unpaid licencing fees.

After a settlement of that lawsuit, the developments did not use the Trump name or discuss any involvement with the Trump Organization.

But in February, owners made a show of announcing Eric Trump had toured the project, saying "we are excited to be working with the Trump Organization in the future phases of the project".

A Trump Organization lawyer has described the deal as "never dead" and said discussions were "very preliminary" but some investors were surprised to find the firm was still technically involved in the project.


The Trump Organization cancelled a licensing deal to build a condo tower in the resort town of Batumi, Georgia, shortly after Mr Trump won the election.

The deal had been originally inked in 2011 but stalled amid slow growth in the country.

One of the business partners involved in the deal told Forbes the firm had expressly told him the reason the deal was cancelled was concerns over the Emoluments Clause, despite a Trump lawyer's earlier statement the cancellation was "not part of a strategy to reduce potential conflicts of interests".


Trump has a licensing deal for buildings in Mumbai and Pune.

One of his deals is with the Lodha Group, whose founder, Mangal Lodha, is also a vice-president in the ruling government party, BJP.

Shortly after Mr Trump won the presidency, some of his Indian business partners flew to the US to congratulate Mr Trump, who took time out of transition meetings to discuss "US-India relations".


Two building projects with Trump licensing and management deals have not begun construction in earnest but the Trump Organization continues to be part of the venture.

Mr Trump's partner on the resort projects is Hary Tanoesoedibjo, who ran for vice-president and is well-connected politically in Indonesia. Mr Hary is forming a political party in anticipation of the 2019 elections, the New York Times reports.

In addition, one of Trump's advisers, Carl Icahn, is a major shareholder of Freeport, which is looking to extend a mining contract with the Indonesia government.

Media caption,

Is Hary Tanoesoedibjo Indonesia's answer to Donald Trump?


Ivanka Trump sat in with a meeting with her father and Japanese Prime Minister Shinzo Abe. Ms Trump's own firm is currently finalising a licensing deal with Japanese clothing company Sanei International, although she has now stepped down from the firm as well as the Trump Organization.

The firm's largest shareholder is the Japanese government through the Development Bank of Japan. Ms Trump's company says the deal has been in the works for a while, and the terms were agreed before the election.


Philippines' newest trade envoy to the United States is the same man who is building Trump Tower Manila. Like many of Trump's branding projects, Mr Trump does not own the building himself, but licenses his name to the building in return for regular payments.

Trump family members have previously promoted the project, including a promotional video.

The trade envoy/business partner reportedly flew to US to hold a private meeting with Mr Trump after the election.

Saudi Arabia

During the course of the campaign, Trump created eight business ventures tied to a potential real estate deal in Saudi Arabia.

Mr Trump told Fox News earlier this year, he "would want to protect Saudi Arabia. But Saudi Arabia is going to have to help us economically".

Update: A Trump Organization lawyer has told the AP the eight firms have been dissolved or shut and that there is "no deal" in Saudi Arabia. However, the firm could easily re-establish business ties there.


In September, a woman claiming to be an envoy for the Trump Organization discussed potential real estate developments in Taiwan with the mayor of Taoyuan.

The Trump Organization has denied any plans for expansion there and said there were no "authorised visits" to discuss business in the country. The Taoyan mayor's office said the woman had "authorisation documents" but did not specify what kind, the New York Times reported.

A month after his election, Trump called the president of Taiwan directly, breaking decades of existing US foreign policy. It still unclear if the woman is connected with the Trump Organization


Image source, Getty Images

In 2008, Trump entered a licensing partnership with Turkish conglomerate Dogan Holdings, who were planning to build two residential and business towers in Istanbul's business district.

Relations between Dogan Holdings and Turkish Prime Minister Tayyip Erdogan have turned sour since the towers opened in 2012.

The Dogan family, also own a paper critical of Mr Erdogan.

An earlier story from Newsweek argues the poisoned relationship between Mr Erdogan and the Dogans means Mr Trump would have a direct conflict between his business interests and his relationship with a US ally.

Turkey's importance in the fight against IS and the Syrian civil war makes the stakes much higher.

UK golf courses

Image source, Getty Images
Image caption,
Trump visits the golf course he owns in Aberdeen, Scotland

Mr Trump owns two golf courses in Scotland and has recently asked Nigel Farage to oppose wind farms, not because he believed they were bad for the UK or contradicted US energy goals, but because a wind project would potentially lower the value of one of his golf courses.

"He did not say he hated wind farms as a concept; he just did not like them spoiling the views," Andy Wigmore, the Leave.EU communications director at the meeting told the New York Times and the Express.

The golf courses could also be affected as part of Brexit negotiations or a second Scottish independence referendum.