On January 11, 2017, President-elect Donald Trump announced to the American public that he would not divest from his businesses—including hotels, golf courses, trademarks, office buildings, and other assets—before being sworn in as the 45th president of the United States. The move was met with widespread concern, as former executive branch ethics officials, government watchdog groups, and the then-head of the Office of Government Ethics warned that the Trump presidency risked being compromised by massive conflicts of interest. As CREW Executive Director Noah Bookbinder explained, “[e]very decision [Trump] will make as president will be followed by the specter of doubt, and will be questioned as to whether his decision is in the best interest of the American people or the best interest of his bottom line.”
During President Trump’s first year in office, CREW worked to monitor, log, and categorize every instance in which government and special interests interacted with the president’s private businesses. The results were posted on the interactive timeline Trump Inc.: A Chronicle of Presidential Conflicts. Ultimately, CREW recorded more than 500 timeline entries related to potential conflicts of interest. While it would be almost impossible to adequately summarize the full collection, we can offer three broad takeaways from this effort:
FIRST, President Trump and other government officials have routinely visited Trump properties and promoted them throughout the past year, signaling to those seeking to influence the government that the president’s commercial properties are important new centers of power and influence.
-President Trump spent a full third of the first year of his administration—121 days—visiting his commercial properties.
-Seventy-two executive branch officials, more than 35 members of Congress, and over a dozen state officials visited Trump Organization properties during the first year of the Trump administration.
-President Trump and his White House staff promoted the Trump brand by mentioning or referring to one of the president’s private businesses on at least 54 different occasions during the president’s first year in office.
SECOND, far from this signaled access to power being an empty promise, those who patronize President Trump’s businesses have, in fact, gained access to the president and his inner circle. Indeed, it appears that at least some of those guests are trying to use that access to exert influence.
THIRD, the promotion of the president’s businesses as centers of power and influence appears to be paying off: During President Trump’s first year in office, a variety of industry groups, foreign governments, and political committees patronized his businesses.
-There have been more than 40 instances of special interest groups holding events at Trump properties since January 20, 2017.
-Eleven foreign governments have paid Trump-owned entities during the president’s first year in office, and at least six foreign government officials have made appearances at Trump Organization properties.
-Political groups spent more than $1.2 million at Trump properties during the president’s first year in office. Prior to President Trump’s 2016 campaign, annual spending by political committees at Trump properties had never exceeded $100,000 in any given year going back to at least 2002.
Taken together, the 500+ entries on the Trump Inc. timeline present a clear picture of a presidency being used to turn a profit and the president’s businesses serving as points of access to the corridors of power. As many feared, President Trump is not only making money in spite of his official position—in many cases, he’s making money because of it.
Government Officials Patronizing Trump Properties
Over the past year, President Trump and other government officials have routinely visited Trump properties and promoted them in the public sphere. This type of free promotion sends a clear message to groups seeking to influence the federal government that the president’s commercial properties are important new centers of power and influence.
President Trump has spent a full third of the first year of his administration—121 days—visiting his properties. Mar-a-Lago—the president’s private club in Palm Beach, Florida—was the most common destination. President Trump’s “Winter White House” accounted for 49 days’ worth of visits, including Easter, Thanksgiving, and Christmas.
President Trump was often spotted conducting official government business during these visits. Perhaps most infamously, President Trump and Japanese Prime Minister Shinzo Abe reportedly discussed how to respond to a North Korean missile launch in public view of Mar-a-Lago’s club members. Then-White House Press Secretary Sean Spicer later denied this report, explaining that President Trump was instead briefed in a SCIF (Sensitive Compartmented Information Facility) in the resort.
Mar-a-Lago was host to other key events during the first year of the Trump presidency as well: In February 2017, President Trump announced his choice for national security adviser from the resort. In April, he hosted Chinese President Xi Jinping, and ordered an airstrike against Syria while the two leaders ate their dessert.
While staying in Florida, President Trump also visited the Trump International Golf Club – West Palm Beach 33 times, and the Trump International Golf Club – Jupiter twice. President Trump apparently used the Palm Beach club for government business as well; while the press was not allowed access onto the property, they were continually informed by White House spokespeople that the president planned to take phone calls and have meetings.
President Trump’s affinity for his own properties has not been lost on those seeking access to the president. As a former Palm Beach County GOP chair noted, the Palm Beach golf course “has the ultimate perk—the president is going to show up.”
Once Mar-a-Lago closed for the season, President Trump took to what his staff has referred to as the “Summer White House,” visiting the Trump National Golf Club – Bedminster, N.J. 40 times, often holding meetings and press conferences. For example, during his 17-day “working vacation” over the summer, he attended a meeting to discuss the opioid crisis, held a press conference after a security meeting, and signed a bill into law.
Even when in residence at the actual White House, the president would regularly visit his nearby properties. According to CREW analysis, President Trump dined at Trump International Hotel – Washington, D.C. seven times during the first year of his administration (in fact, he did not eat at any D.C. restaurants he did not own). He golfed at Trump National Golf Club – D.C. in Potomac Falls, Virginia 23 times, often with members of Congress. In March, he held a “working lunch” at the club, where he was joined by then-White House Press Secretary Sean Spicer, then-White House Chief of Staff Reince Priebus, Treasury Secretary Steven Mnuchin, then-Secretary of Homeland Security John F. Kelly, Commerce Secretary Wilbur Ross, Secretary of Veterans Affairs David Shulkin, and then-White House Chief Strategist Steve Bannon.
Since taking office, the president has not yet traveled to any of his foreign properties, but he did make a point of stopping at the Trump International Hotel – Waikiki, Hawaii on his way to Japan in early November 2017. Sarah Huckabee Sanders defended the president’s visit while plugging the business, stating, “It has been a tremendously successful project and he wanted to say hello and thank you to the employees for all their hard work.”
Other Federal Officials
Where President Trump traveled, key members of his administration followed. CREW recorded over 70 executive branch officials making 200 visits to Trump Organization properties in the first year of the Trump administration.
Since the president spent a full third of his first year in office at his properties, many of these staff visits were a logistical necessity. For example, a host of staff members, including White House Director of Strategic Communications Hope Hicks, then-White House Press Secretary Sean Spicer, Senior Adviser Jared Kushner, and Assistant to the President Ivanka Trump, were seen at Mar-a-Lago when Chinese President Xi Jinping visited the property.
In other cases, high-ranking administration officials visited Trump properties in order to appear with the president during official government events. For example, Veterans Affairs Secretary David Shulkin went to the Trump National Golf Course – Bedminster, N.J. when the president signed the Harry W. Colmery Veterans Educational Assistance Act of 2017. When President Trump held a press conference at Trump Tower – New York City to announce a new executive order rolling back permitting regulations, Treasury Secretary Steven Mnuchin and Transportation Secretary Elaine Chao flanked him at the podium.
While federal government officials sometimes visited Trump properties in order to accompany the president, in other cases, they went to attend industry events. For example, a manufacturing industry conference in October kicked off at Trump International Hotel and Tower – Chicago, IL, where Department of Homeland Security Deputy Assistant Secretary for Infrastructure Protection David Wulf was a keynote speaker. At the the Trump International Hotel – Washington, D.C., Environmental Protection Agency Administrator Scott Pruitt attended the American Petroleum Institute’s Executive Committee and Board of Directors dinner, and Energy Secretary Rick Perry, Interior Deputy Secretary David Bernhardt, Commerce Secretary Wilbur Ross, and Labor Secretary Alexander Acosta all spoke during the National Mining Association’s board of directors’ two-day meeting.
Administration staff also visited Trump properties outside of their official capacities. As has been well documented, the Trump International Hotel – Washington, D.C. has become a frequent watering hole for employees and friends of the Trump administration. Politico noted in July that “[i]f there is a social hub of Trump’s Washington, it’s his own business establishment.” A “Republican operative” explained that “[o]n a Friday night, you’re pretty much guaranteed to run into senior staff.” In the early days of the administration, at least three senior staff—Treasury Secretary Steven Mnuchin, National Economic Council Director Gary Cohn, and Small Business Administration head Linda McMahon—stayed at the property on weekdays while commuting from New York City to D.C. During his ten-day tenure as White House communications director, Anthony Scaramucci was spotted at the hotel on at least two occasions.
Over the past year, the D.C. hotel has also been the go-to party venue for President Trump’s senior staff. Treasury Secretary Steven Mnuchin’s wedding reception and then-Assistant to the President and Director of Communications for the Office of Public Liaison Omarosa Manigault’s wedding ceremony both took place at the Old Post Office. Assistant to the President Ivanka Trump and Department of Housing and Urban Development (HUD) Regional Administrator Lynne Patton both had birthday parties at the hotel.
Members of Congress
While members of Congress do not work directly for the president, many have nevertheless embraced Trump properties as new centers of power and influence. Over the president’s first year in office, CREW recorded more than 30 members of Congress making a combined 47 appearances at Trump Organization properties. Sen. Lindsey Graham (R-SC) was spotted at Trump properties most frequently, with three visits to the president’s golf courses: twice at Trump National Golf Club – D.C. in Potomac Falls, Virginia, and once at his course in West Palm Beach. Other members of Congress honing their putting skills at Trump courses over the past year included Sen. David Perdue (R-GA), Sen. Rand Paul (R-KY), and Sen. Bob Corker (R-TN).
Members of Congress also visited President Trump’s D.C. hotel for a variety of events. Sen. Marco Rubio (R-FL) spoke at a conference at the Trump International Hotel – Washington, D.C. on the “persecution of Christians in the Holy Lands and Middle East.” Sens. Lisa Murkowski (R-AK), John Barrasso (R-WY), and Rep. Paul Gosar (R-AZ) all spoke at a National Mining Association event at the D.C. hotel. On December 7th, former Trump campaign officials Corey Lewandowski and David Bossie appeared at an event celebrating the release of their new book, “Let Trump Be Trump: The Inside Story of His Rise to the Presidency” at the D.C. hotel. Rep. Steve King (R-IA), Rep. Mark Meadows (R-NC), Rep. Louie Gohmert (R-TX), Rep. Roger Williams (R-TX), Rep. Ron DeSantis (R-FL), and Rep. Billy Long (R-MO) were spotted at the event. The same day, pro-Trump super PAC America First Action and the Republican Jewish Coalition (RJC) co-hosted a “Hanukkah Nightcap” event at the D.C. hotel. Rep. Lee Zeldin (R-NY), Rep. David Kustoff (R-TN), Rep. Ed Royce (R-CA), Rep. Don Bacon (R-NE), Rep. Raul Labrador (R-ID), Rep. Claudia Tenney (R-NY), Rep. Brian Mast (R-FL), Rep. Mike Gallagher (R-WI), Rep. Scott Taylor (R-VA), and Rep. Joe Wilson (R-SC) were seen at the party.
While most members of Congress that have patronized Trump properties over the past year have been members of the president’s Republican Party, some Democrats have been spotted as well. For example, Senator Joe Manchin (D-WV) was seen dining at BLT Prime inside of Trump International Hotel – Washington, D.C. in January 2018.
State Government Officials
CREW recorded over a dozen state officials visiting Trump businesses. In May 2017, ten Republican governors met at Trump National Doral – Miami for a Republican Governors Association event. Florida Governor Rick Scott (R) dined with the president at his properties on three separate occasions — in February at the Trump International Hotel – D.C., in August at the Trump National Golf Club – Bedminster, N.J., and on New Year’s Eve at the Trump International Golf Club – West Palm Beach. Maine Governor Paul LePage (R) made headlines by spending thousands of state dollars at President Trump’s D.C. hotel during a visit to Washington. Documents from Maine’s State Police showed that the state paid $2,250 for members of Gov. LePage’s security team to stay at the hotel for four nights.
Government Officials Promote Trump Businesses
According to CREW analysis, President Trump and his White House staff promoted the Trump brand by mentioning or referring to one of the president’s private businesses on at least 54 different occasions during the president’s first year in office. For example, as noted previously, administration officials have publicly referred to the president’s Mar-a-Lago and Bedminster clubs as the “Winter White House” and “Summer White House” respectively. In January 2017, then-White House Press Secretary Sean Spicer referred to Mar-a-Lago as “the Winter White House” for the first time. Before long, a federal agency, a special interest group, and the American embassy in Japan had all used the nickname. In August, when the president started spending weekends at Trump National Golf Club – Bedminster, N.J., White House Director of Social Media Dan Scavino, Jr. referred to the club as “the Summer White House” on his official White House Twitter account. These public statements serve to identify these private businesses as centers of power and influence.
President Trump mentioned or referred to his own businesses in speeches, during interviews, and on Twitter 33 times during his first year in office. In the wake of violent protesting by white supremacists in Charlottesville, VA, the president, speaking at Trump Tower – New York City, plugged Trump Vineyard Estates, which is near Charlottesville. “I own a house in Charlottesville…I own actually one of the largest wineries in the United States. It’s in Charlottesville,” President Trump said. President Trump also plugged Trump World Tower – New York City during a speech to the United Nations (U.N.), Trump National Golf Club – Bedminster, N.J. during an address to the South Korean National Assembly, and described Trump International Golf Club – West Palm Beach as “one of the great courses of the world” while golfing with members of the Coast Guard.
Other members of President Trump’s administration have followed suit by publicly praising the president’s businesses. In May 2017, then-White House Press Secretary Sean Spicer effusively praised the Trump National Golf Club – D.C. in Potomac Falls, Virginia during a fundraiser when he said, “[Y]ou look around this place — the quality of the people, the quality of the establishment, the quality of the food, it’s what Trump’s all about.” Similarly, in June 2017, White House Counselor Kellyanne Conway noted the popularity of the Trump International Hotel – Washington, D.C., commenting that visitors “look at it as a piece of the president.”
Nor is the promotion of the Trump brand exclusive to the White House. Federal agencies and members of Congress also gave President Trump’s businesses a boost during his first year in office. For example, in April, the State Department posted a story on its ShareAmerica website promoting Mar-a-Lago as the “winter White House.” In November, E&E News reported that Shenandoah National Park was selling wine from the Trump Winery in its gift shop. And in December, Sen. Lindsey Graham (R-SC) praised the Trump International Golf Club – West Palm Beach using his official Twitter account, commenting, “Trump International Golf Club is a spectacular golf course.”
Trump Club Members and Patrons Gain Access to the President
As one might expect from all the visits and public statements catalogued above, the evidence suggests that those who patronize President Trump’s businesses do, in fact, gain access to the president and his inner circle. Indeed, it appears that at least some of those guests are trying to use that access to exert influence.
Just three weeks into the Trump presidency, a visitor to President Trump’s Mar-a-Lago club posted a picture of the government official who carries the nuclear football on Facebook. The incident was an early sign of the closeness the president’s paying customers would have to the Trump administration.
President Trump made no secret of his appreciation for his paying customers during his first year in office, nor were his patrons shy about identifying themselves as contributors to the president’s massive wealth. During an aviation industry meeting with the president in February, an Airports Council International – North America lobbyist identified himself as a member of Trump National Golf Club – D.C. in Potomac Falls, Virginia. “I’m a member of your club, by the way,” he said. “Very good, very good,” President Trump replied. The next day, President Trump stopped by a wedding taking place at Mar-a-Lago, bringing along Japanese Prime Minister Shinzo Abe, and made unscripted remarks. “They’ve been members of this club for a long time. They’ve paid me a fortune,” the president said, referring to the groom’s family. In June, White House officials even invoked Chinese businessman Guo Wengui’s Mar-a-Lago membership as part of efforts to dissuade President Trump from deporting him.
On at least one occasion, the Trump Organization seemed to explicitly offer club members access to the president. A marketing brochure for Trump National Golf Club – Bedminster, N.J. advertised the possibility of a presidential run-in. “If he is on-site for your big day, he will likely stop in & congratulate the happy couple,” the brochure said. While a spokesperson for the Trump Organization claimed that the brochure was discontinued, the president made good on the promise during visits to his Bedminster club in June, August, and September.
On several occasions, members of President Trump’s clubs were offered access or solicited for advice on administration policy. During a February visit to Mar-a-Lago, for example, President Trump asked developer and club member Richard LeFrak if he’d be interested in building a border wall with Mexico. A second Mar-a-Lago member, Christopher Ruddy, told RealClearPolitics that President Trump had asked him “to make recommendations for appointments.” Finally, USA Today reported that President Trump has appointed or nominated five members of his clubs to administration positions.
Moreover, there is evidence to suggest that guests at Trump properties have indeed used their access to try to influence the president. For example, over Thanksgiving, guests at Mar-a-Lago reportedly gave the president news clips as he mingled with patrons. A former White House official confirmed that customers were trying to exploit President Trump’s accessibility while he visited his properties. “At Mar-a-Lago, anyone who can get within eyesight changes the game… Everyone who is angling for something knows to be there,” the former official told The Washington Post. No wonder Mar-a-Lago raised its membership fee, as well as the price of attending its annual New Year’s Eve party.
Despite Trump club members’ heightened access to the president, both the administration and Trump Organization have refused to publicly identify them. An analysis by USA Today, however, determined that Trump golf club members include at least 21 trade group officials and lobbyists, and 50 company executives whose businesses have federal contracts. Two-thirds of these members were confirmed to have been at Trump golf clubs while the president was there.
Special Interest and Foreign Government Influence-seeking
The promotion of the president’s businesses as new centers of power and influence appears to be paying off in many cases: during President Trump’s first year in office, a variety of industry groups, foreign governments, and political committees patronized his businesses.
Patronage by Special Interest Groups
Since January 20, 2017, CREW has recorded 40 instances of special interests holding events at Trump properties. For example, Trump National Doral – Miami was the site of conferences for retail bankers, the national trade association for abstract and title insurers, and the industrial metals industry. The GEO Group, the country’s second largest private prison contractor, also held its annual leadership conference at Trump National Doral – Miami.
Patronizing the Trump International Hotel – Washington, D.C. in particular often provided special interest groups with access to government decision-makers, as these events were regularly attended by members of the Trump administration, Congress, or both. In February, Politico reported that a lobbying firm employed by the Saudi government rented rooms at the Trump International Hotel – Washington, D.C. The National Funeral Directors Association hosted a fundraiser for its political action committee at the D.C. hotel. Other special interest groups hosted at the Trump International Hotel – Washington, D.C., including the National Mining Association, the Louisiana Association of Business and Industry, and the National Railroad Construction and Maintenance Association.
Mar-a-Lago was also a site for special interest group events, though these tended to be charity galas; as a major donor to one such charity told the local Palm Beach Post, “[p]eople will pay huge amounts of money to have access to the president. If you can donate to a charity and have access, that’s a win in my book.” Sure enough, President Trump made personal appearances at those galas that coincided with his trips to Mar-a-Lago. He dropped in during events hosted by the Bascom Palmer Eye Institute, the Gateway for Cancer Research, and the International Red Cross ball, where he stayed for three hours.
Special interest groups have also wasted no time in booking Trump properties for 2018. Groups as varied as the National Confectioners Association, conservative state legislative group the American Legislative Exchange Council (ALEC), and the Community Financial Services Association of America have already announced events at Trump Organization venues for later this year.
Patronage by Foreign Governments
The evidence collected over the past year suggests that 11 foreign governments have patronized Trump businesses—possibly as a way to curry favor with the Trump White House.
Eleven countries have paid a Trump-owned entity. For example, a month after President Trump’s inauguration, the Embassy of Kuwait celebrated its National Day at the Trump International Hotel – Washington, D.C. It had moved the event from Four Seasons, where it had made a reservation in the early fall. The move was allegedly at the suggestion of members of the Trump Organization, though Kuwait’s ambassador denied being pressured. Nevertheless, as one diplomat noted shortly after President Trump’s election, “Why wouldn’t I stay at his hotel blocks from the White House, so I can tell the new president, ‘I love your new hotel!’ Isn’t it rude to come to his city and say, ‘I am staying at your competitor?’”
In addition to booking official events, numerous foreign government officials have made appearances at Trump Organization properties. Ambassadors from Russia, the United Arab Emirates, and Turkey have been spotted at the Trump International Hotel – Washington, D.C. Romanian President Klaus lohannis ate at the hotel, and Malaysian Prime Minister Najib Razak stayed there during his trip to Washington to meet with President Trump at the White House. In November, at least six countries sent envoys to an event held at the hotel that the host said was “to gather Trump aides in one place so foreign government representatives could meet them.”
While some foreign governments have been patronizing Trump properties in the U.S., others have been working to ensure that President Trump’s business investments abroad pay off. In January 2018, McClatchy reported that several foreign governments have aided in the development of properties in which the Trump Organization maintains some commercial interest. In Indonesia, for example, plans are underway to shorten the drive time between Bali’s main airport and Trump International Hotel and Tower Bali. And in Panama, the federal government ensured that sewer and water pipes built to benefit of the new Trump Ocean Club International Hotel and Tower would be completed, after the company that initially won the contract went out of business.
President Trump’s foreign business partners in the U.A.E., Uruguay, and India all report a commercial boost that they attribute to the Trump presidency. Hussain Sajwani, the Trump Organization’s business partner in Dubai said, “Mr. Trump getting elected definitely enhanced the profile of his organization’s brand.” In Uruguay, a businesswoman who sells units in the Trump Tower Punta del Este said she “[has] no doubt that [the Tower] is going to be finished and even more so because he’s going to be president of the United States.” An affiliate of Trump Tower – Mumbai commented, “Enquiry levels have gone up since last couple of months [sic] post US presidential elections.”
Foreign governments have also been quick to approve President Trump’s trademark applications since his election, providing lucrative legal protection to Trump branded goods in key foreign markets. In February 2017, Mexico approved three Trump Organization trademarks filed during President Trump’s campaign. China has cleared dozens of trademarks for the Trump Organization, giving President Trump preliminary approval of 38 trademarks shortly after his inauguration. In the words of a D.C. trademark lawyer, this “was a gift…Getting the exclusive right to use that brand in China against everyone else in the world? It’s like waving a magic wand.” In June, the Chinese territory Macau granted four trademarks to a business linked to President Trump.
Patronage by Political Campaigns
In addition to foreign government and special interest spending, President Trump personally profited from political spending at his properties. Political groups spent more than $1.2 million at Trump properties during the president’s first year in office. Prior to Trump’s 2016 campaign, annual spending by political committees at Trump properties had never exceeded $100,000 in any given year going back to at least 2002.
President Trump’s reelection campaign was his own best customer during his first year in office, spending more than half a million dollars at numerous Trump businesses, including at four Trump hotels. The next highest spender was the Republican Governors Association, which spent $408,588 for a “Corporate Policy Summit” at Trump National Doral – Miami. The Republican National Committee (RNC) was the third top spender. According to CREW analysis, the RNC spent $176,813, almost all of it at Trump International Hotel – Washington, D.C.
Republican members of Congress were also loyal Trump-brand customers: political committees connected to 32 Republican members of Congress spent $65,310 through political committees at President Trump’s businesses during his first year in office. The top spenders were Reps. Tom MacArthur (R-NJ, $15,221), Dana Rohrabacher (R-CA, $12,545), and Bill Shuster (R-PA, $9,277). No Democratic officeholders or Democratic campaign committees reported spending money at Trump businesses in the last year.
President Trump and his administration promoted his businesses as centers of power and influence, and for political campaigns that were willing to pay the price of admission, they delivered. President Trump himself appeared at three campaign events held at his properties during his first year in office. In June, he appeared as a “special guest” at a fundraiser for Rep. Tom MacArthur (R-NJ), held at the Trump National Golf Club – Bedminster, N.J. The event raised more than $800,000. Later that month, the president spoke at a joint Trump 2020-RNC fundraiser at the Trump International Hotel – Washington, D.C.
President Trump wasn’t the only member of his administration to attend a political event at one of his properties. In May, then-White House Press Secretary Sean Spicer was the guest of honor at a Republican Party of Virginia fundraiser at the Trump National Golf Club – D.C. in Potomac Falls, Virginia. In December, the pro-Trump super PAC America First Action held three holiday events at Trump International Hotel – Washington, D.C. Likewise in these cases, patronage of a Trump property coincided with a bevy of A-list attendees, including Vice President Mike Pence, Senior Adviser Jared Kushner, Assistant to the President Ivanka Trump, and 14 members of Congress.
CREW’s attempt to track and catalogue all of President Trump’s conflicts of interest during his first year in office has been a difficult one. The Trump Organization is not tracking all foreign payments to the president’s businesses, and the Trump administration has declined to release visitor logs showing who has had access to the president when he has been at the White House, or at his private clubs. Nevertheless, looking across more than 500 entries logged since January 20, 2017, one thing becomes disturbingly clear: President Trump not only continues to profit from his businesses while serving as president; in many cases he is profiting as a result of his presidency. By promoting his businesses in his official capacity, and by offering access and influence to patrons of those businesses, President Trump sends a message to special interests and foreign governments alike that his administration is for sale. The remaining years of Trump’s presidency are unlikely to be any different unless the American people and their representatives in Congress demand better.
Note: This report is based on a more conservative method of counting conflicts than used in subsequent reports and in CREW’s ongoing conflicts tracking. During President Trump’s first year in office, CREW published a timeline of Trump conflicts to its site. This report counts each entry on that timeline as one conflict, but many of those entries contain multiple conflicts, according to how CREW tracks them now. For example, a single entry might have described a special interest event that was attended by two administration officials. We would now count that as three separate conflicts–the event and two officials’ visits. The conflicts of interest in this report have since been converted to match how we track them now and are included in CREW’s ongoing tracking.