On July 1, the White House released a report detailing its employee salaries. Media attention paid to the report, which is required to be sent to Congress annually, has focused largely on identifying the top earners. But less attention has been paid to those who aren’t earning a salary at all—and the potential ethics issues that raises. 

According to the report, eight employees are working for the White House without taking a salary from it. At least two of them, Marco Rubio and Richard Goldberg, also hold other positions in executive branch agencies outside of the White House from which they are likely earning a salary. According to reported comments from the White House, Steve Witkoff may also be employed by the State Department, but it is unclear in what capacity and whether or not he is accepting a salary from the Department. Five others don’t appear to be collecting a government paycheck at all. But if they aren’t earning a salary from the White House, what might they be gaining instead?

Forgoing a government salary may seem like a noble choice, and in some cases it can be. But it can also be a way to take advantage of loopholes in our government ethics laws. Under 18 U.S.C. § 209, most government employees are prohibited from earning money from non-governmental sources. This is a commonsense ethics law that helps prevent conflicts of interest and corruption opportunities that arise when a government employee has private business ties. But the law creates exceptions from some ethics rules for Special Government Employees and other employees who are not taking a salary from the government. This means that if a White House employee forgoes their salary, they can earn outside income while working in powerful roles. 

During Trump’s first term, this loophole enabled Jared Kushner and Ivanka Trump to work in the White House while earning millions from outside sources, creating massive conflicts of interest. While Jared and Ivanka may not officially be serving in the White House this term, it seems like others in the Trump Administration have followed their lead by not accepting a White House salary and potentially continuing to earn non-governmental income, creating potential conflicts of interest. 

Here are some of the most concerning instances:

David Sacks is serving as the White House AI and Crypto Czar and is a co-founder and general partner of Craft Ventures, a venture capital firm. Sacks reportedly sought a part-time role in the White House in part so that he could continue work at Craft Ventures, which as of March 14, had a minority stake in 19 crypto startups. According to a memo issued by White House Counsel David Warrington, Sacks’ work for the White House will “likely require” his “substantial involvement” on matters affecting his financial interests. However, Warrington granted him an ethics waiver (under 18 U.S.C. § 208) to allow him to participate in those matters despite the clear conflict of interest. Sacks’ role in the White House tasks him with significantly shaping the president’s agenda and the future regulation of the AI and crypto industries. Given both his past and current financial stake in these industries, his actions are almost certain to impact his personal profits.

Steven C. Witkoff is serving as the Assistant to the President and Special Envoy for Peace Missions according to the White House report, and was also announced by Trump to be the Special Envoy to the Middle East (a role which was held by Kushner in Trump’s first term). Witkoff has no international relations or diplomacy experience. Instead, he is a real estate investor and developer. He is also a co-founder of World Liberty Financial, the crypto exchange company of which President Trump is a partial owner. Following President Trump’s announcement about Witkoff’s role as Special Envoy to the Middle East, Witkoff promoted World Liberty in Dubai and met with leaders of sovereign wealth funds in Saudi Arabia, the UAE and Qatar. Witkoff’s ability to earn outside income from his real estate investments and involvement with the president’s businesses suggests that, like Kushner, he may stand to profit from his work in the White House in sums that far exceed that of a government salary.

Paula White is serving as Senior Advisor to the White House Faith Office. White is a pastor and Chair of the Center for American Values at the America First Policy Institute. In 2007, White’s ministry was investigated by the Senate Finance Committee (led by Senator Chuck Grassley), which found that White used tax-exempt ministry funds to pay for a jet which she chartered for personal use, to compensate her relatives and to pay for a waterfront mansion. White was also a White House employee in Trump’s first term, during which she continued to solicit donations for her ministry, Paula White Ministries. White has earned money outside of the ministry in several ways, including from the books she has written, by allegedly offering prayers for $1,000 and selling “resurrection seeds” for $1,144 each. Earlier this week, Trump suggested that White could oppose political candidates from her pulpit without threatening its tax-exempt status. 

Calley Means is serving as an Advisor in the White House and is an entrepreneur, former lobbyist and consultant for pharmaceutical, food and beverage companies and the co-founder of Truemed, a company that aims to make it easier for people to use HSA/FSA money to buy wellness products. Means has been referred to as “RFK Jr.’s right hand” and helped coordinate a report by the Make America Healthy Again Commission that cited studies that were later determined to be fabricated. Means’ financial stake in the health industry runs the risk of clouding his judgment as he seeks to influence health policy. 

Reporting indicates that Witkoff, Sacks, White and Means are all serving as Special Government Employees. Not all Special Government Employees are required to file public financial disclosures, so it is difficult to know the full extent of these individuals’ financial conflicts of interest. 

Two other White House employees are not taking a salary for their role according to the report. David P. Donaldson is serving as a Special Assistant to the President and Grant Coordinator and Tracy L. Johnson is serving as a Senior Advisor. Less information is publicly available about these individuals and their potential conflicts of interest.

As these four White House advisors’ financial entanglements illustrate, these loopholes in ethics rules need to be closed. Congress must pass legislation to increase transparency and accountability for Special Government Employees and prohibit other government employees from earning outside income. Doing so will help ensure that government employees are motivated by public service, not maximizing their own profits. 

Kira Tretiak contributed to this piece.

Photo of Paula White , Calley Means and Steve Witkoff by Gage Skidmore under Creative Commons license