CREW’s conflicts tracker is located here.
For purposes of this project, CREW defines a conflict of interest as any interaction between the Trump Organization and the federal government, U.S. state governments, and foreign governments, as well as interactions between the Trump Organization and special interests that try to influence the federal government. CREW identifies these interactions through targeted daily monitoring of social media, news reports, White House press pool reports, speech transcripts, Freedom of Information Act requests, and other sources. CREW systematically reviews each potential entry for inclusion to its tracking, and fact-checks those that are added.
CREW’s count of administration officials who have visited Trump properties includes nominees and appointees awaiting confirmation. It also includes a minority number of entries based on reports that an official is going to visit a Trump property, but where we lack subsequent reporting that confirms the official followed through on his or her plan. CREW defines every day that Trump spends at an individual property as a visit. For example, if he spends three days at Mar-a-Lago, this is three visits. If he golfs at one of his courses and has dinner at a different property that evening, that counts as two visits. If he makes two separate visits to a property he isn’t staying at on the same day, that counts as two visits.
Special interests include groups that lobby the federal government according to the Senate Lobbying Disclosure Act Database or that can be shown to advocate for or against particular policy issues at the federal level but are not registered to lobby. CREW’s count of special interest events include events that are hosted or sponsored by a special interest group. Foreign government events include those hosted or sponsored by a foreign government or a group with close ties to a foreign government. Political events include those hosted by officeholders’ or candidates’ campaigns as well as by any other group registered as a political committee with the FEC or IRS.
CREW’s count of instances where the Trump administration has promoted the president’s properties includes both mentions of and reference to them by President Trump and other White House officials. CREW’s count of trademarks for Trump businesses approved by foreign governments includes both preliminary and final approval actions. To determine which foreign governments are countries for purposes of tracking foreign visits, events, and trademarks, CREW relies on the State Department’s list of Independent States of the World—with the exception of Scotland, which is a part of the United Kingdom, but merits being highlighted on its own.
There are many events that fit our definition of a conflict of interest but do not fall into any of these categories. These are tracked as miscellaneous conflicts. While many of these are singular in nature, this category includes things like non-White House officials promoting Trump businesses, known government spending at Trump properties not captured by CREW’s tracking of events, and Trump nominating members of his clubs to government positions.
Though federal investigations into President Trump’s businesses meet CREW’s definition of a conflict of interest, these are excluded from CREW’s tracking.
This methodology was last updated December 3, 2019.