The travels of Treasury Secretary Steven Mnuchin
When Treasury Secretary Steven Mnuchin and his wife Louise Linton deplaned in Lexington, Kentucky on August 21, 2017 – a trip that coincided with the solar eclipse – the tableau became an almost instant meme for government excess. Many responded to the tone-deaf descriptions Ms. Linton offered on Instagram of the head-to-toe designer clothing she was wearing and how fiercely she lashed out to critics. But for CREW the focal point was their mode of transportation: a military jet. As part of an administration supposedly committed to draining the swamp, why did the treasury secretary need a military jet to transport himself and his wife, when a readily available commercial flight would have saved thousands of dollars in taxpayer money and likely gotten them to their destination just as quickly?To find out more, CREW filed a Freedom of Information Act (FOIA) request with the Treasury Department for Secretary Mnuchin’s travel records. Hearing nothing, CREW sued and only then, months later, did CREW receive the requested documents, many with redactions. Those records make clear that Secretary Mnuchin has legitimately earned a place in the rogues’ gallery of cabinet secretaries who have abused their all too easy access to military and other non-commercial aircraft for both business travel and what, upon closer inspection, appears to sometimes include personal travel.Rich Delmar, counsel to the Treasury Department’s Office of Inspector General also conducted an inquiry into Secretary Mnuchin’s travel and summarized his findings in an October 4, 2017 memorandum (“IG Memo”). While Mr. Delmar concluded Secretary Mnuchin violated no law, he noted the “disconnect between the standard of proof” the governing policy requires “and the actual amount of proof provided by Treasury and accepted by the White House in justifying these trip requests.”
GOVERNING LAWS AND POLICIES
The lawfulness and propriety of Secretary Mnuchin’s travel are best understood in the context of governing laws, regulations, and policies. The starting point is OMB Circular A-126, issued on May 22, 1992, which addresses the use of government aircraft. Intended to “restrict the operation of government aircraft to defined official purposes,” the circular applies “to all government-owned, leased, chartered and rental aircraft and related services operated by Executive Agencies” except aircraft the president and vice president use. The guidance defines “official travel” as travel that falls into one of three categories: “(i) travel to meet mission requirements, (ii) required use travel, and (iii) other travel for the conduct of agency business.” The OMB guidance expressly excludes from “mission requirements” “official travel to give speeches, to attend conferences or meetings, or to make routine site visits.” “Required use” is further defined as where “government aircraft is required because of bona fide communications or security needs of the agency or exceptional scheduling requirements.”
Under the OMB guidance, only “official travel” and travel made “on a space available basis” are permitted on government aircraft, subject to enumerated conditions. For official travel, there must be “no commercial airline or aircraft (including charter) service . . . reasonably available,” which is defined as none that can meet the traveler’s departure and arrival needs within a 24-hour period, absent demonstrated “extraordinary circumstances[.]” For family members travelling on a “space available” basis, the agency must certify in advance that the aircraft is performing “a bona fide mission activity” for which the minimum mission requirements have not been exceeded. Use of government aircraft to transport family members must be authorized in advance.
On February 10, 1993, then President Bill Clinton issued a memorandum on the restricted use of government aircraft that updated OMB Circular A-126 (“Clinton Memo”). The Clinton Memo notes at the outset: “The taxpayers should pay no more than absolutely necessary to transport Government officials. The public should only be asked to fund necessities, not luxuries, for its public servants.” The Clinton Memo authorizes the use of government aircraft only if commercial aircraft is not “reasonably available” unless: (1) “highly unusual circumstances present a clear and present danger”; (3) “an emergency exists”; (3) using government aircraft is more cost-effective than using commercial aircraft; or (4) “other compelling operational considerations make commercial transportation unacceptable.”
The Federal Travel Regulation (“FTR”) echoes these requirements for when government aircraft may be used. It also defines “required use travel” as travel for which there is a “bona fide communications (e.g., 24 hour secure communications) or security reasons (e.g., highly unusual circumstances that present a clear and present danger) or exceptional scheduling requirements (e.g., a national emergency or other compelling operational considerations).” The IG Memo also notes that “the FTR does not apply to use of military aircraft on ‘White House Support Missions,’” which is governed by the “longstanding approval process in place since at least 2005.”
The most recent iteration of that “long-standing approval process” is spelled out in a memorandum from then White House Chief of Staff William Daley dated April 4, 2011, concerning the use of military aircraft on White House support missions (“Daley Memo”). As described by the IG Memo, the Daley Memo defines White House support missions as those for which the president has “specifically directed that the travel occur” and which differ from “[t]ravel that is simply in general furtherance of a Presidential initiative[.]” Further, “that the President is aware of, or agrees with, the need for a trip” does not “necessarily make it a White House Support Mission.” Instead, “[t]he President must have specifically directed the government employee to undertake the assignment that requires the travel,” although the authorization for a particular means of travel may come from the White House deputy chief of staff for operations. The president, however, need not personally approve each requested designation as a White House support mission. Instead, under a process the White House has implemented, the White House deputy chief of staff is empowered to approve such requests.
The Daley Memo also requires that one or more of four designated circumstances be met in order for a trip to be properly designated as a White House support mission: (1) “Commercial airline or aircraft service (including charter) is not reasonably available” (i.e., “unable to meet the traveler’s departure or arrival requirements within a 24-hour period”); (2) using government aircraft is more cost effective than using commercial aircraft; (3) government aircraft is necessary to “meet emergency needs or national security concerns” (including, inter alia, the need for “24-hour secure communications”); or (4) there are other “compelling operational considerations” that “make commercial transportation unacceptable.”
On September 29, 2017, in the wake of revelations about the extensive use by Secretary Mnuchin and other cabinet secretaries of non-commercial aircraft, Office of Management and Budget (OMB) Director Mick Mulvaney issued a memorandum reminding all agency heads of the administration’s travel policies (“Mulvaney Memo”). The memo notes:
beyond the law and formal policy, departments and agencies should recognize that we are public servants. Every penny we spend comes from the taxpayer . . . Even when the criteria of Circular A-126 and FTR [Federal Travel Regulation] allow for the use of Government-owned, rented, leased, or chartered aircraft, departments and agencies should still consider whether commercial air travel is a more appropriate use of taxpayer resources.
SECRETARY MNUCHIN’S TRIPS
Measured against these requirements, many of Secretary Mnuchin’s trips fall short. The documents CREW obtained show that between the spring and fall of 2017, he took eight separate trips on military aircraft at a total cost of nearly $1 million. (UST 00003; UST 000037-000152). These numbers do not include any reimbursements made by non-governmental personnel such as members of the media or Secretary Mnuchin’s wife. None of the requests for White House Mission designation explicitly states or otherwise explains how they are at the explicit direction of the president. The IG Memo suggests “[t]his may be a limitation of the format of the request form,” and notes the White House Counsel’s Office had advised Treasury that approval by the White House deputy chief of staff “signifies that the necessary conditions for conducting a White House Support Mission have been met.”
Secretary Mnuchin’s trips included a June 9, 2017 one-day trip to Ottawa, Canada that initially was estimated to cost $15,486.60 (UST 000006) on an FAA-provided aircraft pursuant to a 2014 Memorandum of Understanding between Treasury and the FAA to provide reimbursable air transportation on an as-needed basis (“2014 MOU”). (UST 000014-000017). When additional passengers were added to the manifest, Treasury instead opted for a military aircraft at a cost of $16,350. Of note, the manifest listed 20 individuals, including Secretary Mnuchin’s now wife, Louise Linton, and several members of the media. (UST 000060).
When requesting a White House Mission designation for this trip, the secretary’s chief of staff described its purpose as follows:
to hold a bilat and press conference with Canadian Finance Minister, Bill Morneau; participate in a Ministerial roundtable with 5-7 Ministerial departments; and participate in a round-table discussion with Canadian business leaders. Due to scheduling, logistics, costs, and secure communications needs, the use of reimbursable military aircraft, preferably the C-40B, is requested.
(UST 000059). The need for a plane with secure communications during the one and one-half hour flight was justified by “the potential for developments during travel related to a number of issues.” (UST 000061) (emphasis added).
On its face, this request does not appear to meet the requirements set out in the Daley Memo for a White House Mission designation. Nowhere does Treasury state the trip is one for which the president has “specifically directed that the travel occur” or indicate the trip is anything more than “[t]ravel that is simply in general furtherance of a Presidential initiative[.]” In evaluating the propriety of Secretary Mnuchin’s use of a military plane, the OIG noted there was “[n]o detailed analysis provided” to justify the designation, nor was “further detail” provided to justify the need for an aircraft with “secure communications capabilities[.]”
Moreover, that request was made with full knowledge that the 20 names on the manifest included individuals with no security clearances, such as the Secretary’s wife and six members of the media. When Secretary Mnuchin encountered a similar situation related to a Miami trip (discussed below), scheduled passengers who lacked the appropriate clearance level were removed from the manifest. (UST 000063). With the Ottawa trip, however, Treasury made no such adjustments.
The secretary also used a military aircraft to fly to Miami, Florida on June 15, 2017. Initially, Treasury sought the use of an FAA plane for this trip pursuant to the 2014 MOU at an estimated cost of $26,953.33. (UST 000017). After receiving the request, Treasury’s travel office noted in an internal memo: “for your awareness, the cost per person on commercial air is approx.: $688 roundtrip.” (UST 00001).
Treasury requested that the Miami trip be designated as a White House Mission trip, which it justified because of “scheduling, logistics, and secure communications needs during the return flight[.]” (UST 000064). The request for approval describes the purpose of the trip as follows:
Secretary Mnuchin will travel on June 15th to Miami, Florida to participate in the Conference on Prosperity and Security in Central America and to host a bilateral meeting with Mexico’s Finance Minister José Antonio.
Missing from the justification, however, is any statement or indication that Secretary Mnuchin’s Miami trip was one “specifically directed” by the president, or anything more than a trip that was “simply in general furtherance of a Presidential initiative[.]” The IG Memo (Trip No. 4) notes the absence of any detailed justification.
Two days before the scheduled departure, Treasury advised the FAA that “due to a new need to access to secured comms during this mission, which cannot be accommodated on the available aircraft, we are going to have to pull this mission down and will have to utilize another means of transport.” (UST 00024). The call was scheduled during the two and one-half hour return flight (UST 000063). The use of a military aircraft increased the cost of the approximately two-hour flight to $45,136 (UST 00003). In other words, a scheduling conflict that the Secretary apparently did nothing to avoid cost the government an additional $18,000. Of note, the five listed individuals on the manifest could have made the same trip on a commercial aircraft for approximately $3,440 (or $688 per person, UST 00001).
LOUISVILLE AND FORT KNOX, KENTUCKY
On August 21, 2017, Secretary Mnuchin and his wife took a now infamous trip on a military aircraft to Louisville and Fort Knox, Kentucky at a cost of $33,046 (UST 00003). Initially, the one-day trip was scheduled for August 8, 2017 to just Fort Knox, and the cost of an FAA aircraft for that trip was estimated to be $17,486.29 (UST 000033). The flight from Louisville to Fort Knox alone was estimated to cost approximately $2,000 (UST 000029; UST 000034 (estimate without Fort Knox portion)). When the Senate pushed back its August recess, Treasury informed the FAA the August 8 trip was cancelled, to be rescheduled for sometime in the last two weeks of August (UST 000036). The FAA responded that the requested aircraft was “heavily scheduled” at the end of August, but offered it for August 31 or September 1 (UST 000036).
Even though the FAA offered aircraft for alternative dates, Secretary Mnuchin instead opted for a military aircraft for an August 21, 2017 trip, a date for which Treasury knew an FAA aircraft was not available. (UST 000035). According to the IG Memo (Trip No. 6) the trip on that aircraft cost $26,900.25, but a different Treasury document (UST00003) lists the cost as $33,046, and nothing in the IG Memo explains this discrepancy.
The two separate requests for White House approval describe the purpose of the trip as follows:
Secretary Mnuchin will travel on August 21st to Louisville, KY and Fort Knox, KY for official events with Majority Leader McConnell, U.S. Representative Guthrie, and other potential officials. Due to scheduling, logistics, and communications needs, the use of reimbursable military aircraft, preferably a C-40, is requested. (UST 000069, UST 000073).
This description is noteworthy for several reasons. First, travel for “official events” involving members of Congress seems far removed from travel specifically directed by the president and does not even appear to relate to travel in pursuit of a presidential directive. Indeed, according to public reports, Secretary Mnuchin travelled to Lexington, Kentucky to present remarks along with Senate Majority Leader Mitch McConnell at a luncheon sponsored by the Louisville Chamber of Commerce. Even more troubling, the original request for authorization concerned a trip solely to Fort Knox, with a half-hour mechanical stop at the Louisville airport. (UST 000031).
Second, none of the previous requests for aircraft from the FAA mentioned any specific communications needs. In fact, the IG Memo (Trip No. 6) notes “[t]here is internal communication suggesting that secure communications would not be needed on this trip.” Third, it is unclear what transferred this trip from one that would take place sometime in the last few weeks of August to one that had “scheduling” and “logistics” needs requiring a military aircraft. Fourth, the original trip’s manifest, as set forth in the August 3, 2017 memo seeking White House authorization, did not include Louise Linton, while the August 16, 2017 request did. Finally, the request omits any explanation for the trip to Fort Knox. We know from a Facebook posting from Majority Leader McConnell, however, that he along with Secretary Mnuchin and Ms. Linton viewed the solar eclipse from that location, which placed them closer to the eclipse’s path of totality.
PARKERSBURG, WEST VIRGINIA AND LAS VEGAS, NEVADA
On August 28, 2017, Secretary Mnuchin commenced a two-day trip, traveling first to Parkersburg, West Virginia and from there that evening to Las Vegas, Nevada (UST 000080). In seeking to have the request designated as a White House Mission, Treasury explained its purpose as follows:
Secretary Mnuchin will travel August 28-29 to Parkersburg, WV and Las Vegas, NV for official events with Senator Shelley Moore Capito, Senator Joe Manchin, and Congressman David McKinley in WV and Senator Dean Heller in NV. Due to scheduling, logistics, and communications needs, the use of reimbursable military aircraft, preferably a C-40, is requested.
(UST 000080). The IG Memo and one Treasury document list the cost as $94,100.50 (UST 000087), and there is no indication Treasury considered using a less expensive FAA aircraft.
As the IG Memo (Trip No. 7) notes, in justifying the trip Treasury used “[s]tandard language[.]” The IG Memo also notes “[r]ecords show two hours of official events in Parkersburg and two hours of official events in Las Vegas,” but nowhere is the exact nature of those “official events” explained. Once again, however, Secretary Mnuchin was approved to use a military aircraft notwithstanding this omission, at a cost of between approximately $93,000 and $94,000 for a total of four hours of “official events” with members of Congress.
NEW YORK, NEW YORK
Although not included in the documents provided CREW in response to its FOIA request, the IG Memo (Trip No. 5) discusses a trip Secretary Mnuchin made to New York on August 15, 2017. Secretary Mnuchin apparently made the trip to Trump Tower at the request of President Trump “to discuss pending issues regarding tax reform and tariffs.” Like the other trips, Treasury provided no detailed analysis and it is unclear who was on the manifest. According to the IG Memo, while there was some discussion about other cabinet members flying with Secretary Mnuchin “for cost savings,” a subsequent internal email suggests two cabinet officials accompanied Secretary Mnuchin on the outbound flight only, “apparently because Secretary Mnuchin was planning on conducting a classified phone discussion with the Secretary of State, and the others lacked the necessary clearances[.]” The cost for the 358-mile round trip flight was 15,112.50.
UNITED KINGDOM AND GERMANY
In March 2017, Secretary Mnuchin took a three-day trip to the U.K. and Germany. In requesting authorization for the trip to be designated as a White House Mission, Treasury noted Secretary Mnuchin would be serving “as the president’s principal US representative at the G-20 Finance Ministers Meeting in Baden-Baden, Germany March 17-18, 2017.” (UST 000040). He also had meetings in London with the finance minister and the central bank governor, and in Berlin with the German finance minister. (UST 000040). As with other requests, this one justified a military aircraft because of “scheduling, logistics, and secure communication needs,” but also noted: “Preference is for an aircraft with secure communication capabilities to allow for the secretary and treasury delegation to conduct sensitive business during transit.” (UST 000043). The trip was estimated to cost $301,167.20. (UST 000044).
As the IG Memo (Trip No. 1) notes, the justification contained “no detailed analysis” and its “conclusory statements . . . do not provide the level of detailed analysis clearly called for in the Daley Memo framework.” Nevertheless, the trip was granted the White House Mission designation. To be sure, similar trips by past Treasury secretaries in 2014, 2014, and 2016 “used the same summary justification” and they also were approved.
In May 2017, Secretary Mnuchin travelled to Bari, Italy for a two-day G-7 Finance Ministers meeting as the president’s principal U.S. representative (UST 000047). The trip was estimated to cost nearly $314,000. (UST 000050; UST 00003). In evaluating this trip, the IG Memo (Trip No. 2) noted the absence of any “detailed analysis” justifying the use of military aircraft.
The request for authorizing the trip as a White House Mission included a request for a “C-40B/C if aircraft is available.” (UST 000049). In authorizing the trip, the deputy White House chief of staff stated it was approved and “reimbursable and C40B based on availability.” (UST 000053). According to the IG Memo (Trip No. 2), the trip was actually conducted on a C-32, a smaller and presumably less expensive aircraft that can transport up to 45 passengers. But the initial request for the larger C-40 that can accommodate 120 passengers (or 8 pallets of cargo/some combination therein) for a trip with a manifest that included 24 names (UST 000052-53) is puzzling at best.
In October 2017, Secretary Mnuchin went on a one-week Middle East trip to Riyadh, Saudi Arabia; Manama, Bahrain; Jerusalem, Israel; Abu Dhabi, United Arab Emirates; and Doha, Qatar “to hold bilats and press conferences with government officials and participate in business roundtables with local/international business leaders.” (UST 000093). On each leg of the trip he was to be accompanied by Assistant to the President Jared Kushner and then Deputy National Security Adviser Dina Powell, among others (UST 000095-98). The documents CREW obtained contain no explanation for their participation.
In an August 31, 2017 request to have the trip designated as a White House Mission, Treasury requested a military aircraft “[d]ue to complexities of scheduling, logistics, costs, and secure communications needs during travel[.]” (UST 000093). The IG Memo (Trip No. 8) notes the issue of this “[s]tandard language,” references an email stating “secure communications is ‘preferred,’” “and that presently available C-40 lacks secure communication suite.”
On October 24, 2017, the day of the secretary’s departure and following the issuance of the Mulvaney Memo, Treasury amended this request. Significantly, the amended request includes the following language:
Following an in depth review of commercially available flights for the routes/days required for this trip, [redaction] and time requirements of those commercial options, and the lack of secure communications [redacted] during commercial travel within the region, the reimbursable use of military aircraft is requested.
(UST 000144). The amended request also included “[a]dditional supporting information . . . and historical Secretarial travel[.]” (UST 000144). The manifest for the amended request did not include Jared Kushner, although Dina Powell was included for the first leg to Riyadh, Saudi Arabia. (UST 000146-148). Per UST00003, the cost of this trip was $183,646.
According to news reports, Jared Kushner went to Riyadh, Saudia Arabia at the same time, but travelled separately on a commercial flight. Further, he and Dina Powell purportedly were engaged in secret peace talks. None of the documents Treasury provided CREW explain why Mr. Kushner was removed from the manifest for Secretary Mnuchin’s trip while Ms. Powell was not, or whether the entire Treasury delegation also was engaged in the peace talks or were instead travelling for separate reasons. Information about the requested aircraft is redacted from the documents Treasury provided CREW (UST 000090-92) and labelled as “WH records”; this information may fill in some of these blanks.
The updated manifest for this trip also included Louise Linton, who was not listed on the original manifest. (UST 000146-147). In addition to noting each non-governmental passenger would reimburse Treasury $6,138.03 (if also stopping in Dubai) for the travel costs (UST 000151), the amended request justifies Ms. Linton’s participation as follows:
In each country, Louise will host coffees or luncheons for embassy spouses as a thank you to their continued service. She will attend the Secretary’s keynote address in Saudi Arabia. In Israel, Louise, accompanied by Tammy Deborah Sand, Ambassador Friedman’s spouse, plans to visit a children’s cancer ward at a local hospital or the Shalva Children’s Center for Jewish and Arab-Israeli kids with special needs, participate in the wreath-laying ceremony at Yad Vashem, and Shabbat Dinner at the Ambassador’s residence.
(UST 000152). The only mention of these events and Ms. Linton’s participation in the Middle East trip are in the request for White House Mission designation submitted on the day the trip commenced.
PROPOSED HONEYMOON TRIP
In August 2017, Treasury requested authorization for Secretary Mnuchin and his wife to use a military aircraft for a personal junket to Edinburgh, Great Britain; Paris, France; Gargnano, Italy; and Milan, Italy that was, in fact, their honeymoon trip (UST 000101). Treasury offered the justification that Secretary Mnuchin needed to have access to secure communications during his trip and claimed using a military aircraft was “the most cost-effective means to secure communications during this trip – both on-the-ground and in-transit.” (UST 000101). Although Secretary Mnuchin was requesting a military aircraft, which is governed by the Daley Memo, Treasury made the request pursuant to the “required use” provision of the Federal Travel Regulation, which authorizes the use of government aircraft for “bona fide communications” even when the travel is for personal use. Treasury subsequently claimed reference to this trip as a White House Mission was an error.
In evaluating this requested authorization, the author of the IG Memo notes, “I was advised that the Secretary is among the senior government officials who are required by applicable authority and policy to have access to secure communications at a high level of classification at all times – including both official and personal travel.” What is not discussed is how previous Treasury secretaries, who apparently did not use military aircraft for domestic trips and even some overseas trips (discussed below), met this requirement.
Secretary Mnuchin claimed publicly he ultimately withdrew the request “after finding another option.” Beyond the IG Memo, the documents Treasury provided CREW do not reflect this development. They do show that some individual, whose name and workplace are redacted, provided Treasury officials with a copy of the Federal Travel Regulation governing the use of government aircraft for travel in response to Secretary Mnuchin’s initial request. (UST 000106-107).
TRAVEL BY PREVIOUS TREASURY SECRETARIES
Treasury included in its production to CREW documents concerning travel requests from previous secretaries that reflect both the costs of their trips and the justifications they offered for designating their trips as White House Missions. The amount or detail and justification they provided bear a remarkable similarity to that submitted on behalf of Secretary Mnuchin, suggesting that for Secretary Mnuchin Treasury may have been proceeding on the not-unreasonable belief it had offered sufficient justification for using a military aircraft.
The one area where Secretary Mnuchin appears to have parted company from his predecessors is his use of military aircraft for domestic flights at a cost of nearly $200,000. Dating back to 2006, Treasury secretaries used military aircraft for only three wholly domestic flights. (UST 000153-000156). During that same period, Treasury secretaries made at least seven trips in whole or in part on commercial aircraft, while the documents Treasury provided CREW show that to date Secretary Mnuchin apparently has not made a single trip on a commercial aircraft.
Secretary Mnuchin is one of a host of cabinet secretaries who collectively have incurred millions of dollars of airfare expenses just during the first year of the Trump administration. Only once this abuse came to light did the administration attempt to institute a more rigorous approval process. But the public still has no reasonable explanation for why Secretary Mnuchin apparently has never used commercial aircraft, while his predecessors did; why his travel is not designed to minimize costs by, for example, scheduling confidential calls when he is not on a short domestic flight; or why he needs military aircraft that can accommodate 120 passengers when his travel manifests contain far fewer names. From the documents Treasury provided CREW, it appears Secretary Mnuchin considers first and foremost his own comfort and ease, leaving the protection of taxpayer monies far down on his list of priorities.
 See, e.g., Maggie Haberman and Mikayla Bouchard, Mnuchin’s Wife Mocks Oregon Woman Over Lifestyle and Wealth, The New York Times, Aug. 22, 2017, available at https://www.nytimes.com/2017/08/22/us/politics/mnuchin-louise-linton-treasury-instagram.html.
 The August 23, 2017 FOIA is available at https://s3.amazonaws.com/storage.citizensforethics.org/wp-content/uploads/2017/08/23170335/FOIA-8-23-17.pdf.
 Complaint, CREW v. U.S. Dep’t of the Treasury, available at https://s3.amazonaws.com/storage.citizensforethics.org/wp-content/uploads/2017/09/11164823/1-main.pdf.
 The FOIA production received on November 30, 2017 is available at https://s3.amazonaws.com/storage.citizensforethics.org/wp-content/uploads/2018/03/14140234/2017-11-30-Treasury-Production.pdf. The December 21, 2017 FOIA production is available at https://s3.amazonaws.com/storage.citizensforethics.org/wp-content/uploads/2018/03/14140020/2017-12-21-Treasury-Production.pdf. The February 15, 2018 production is available at https://s3.amazonaws.com/storage.citizensforethics.org/wp-content/uploads/2018/03/14140349/2018-2-15-Production-redactions-applied.pdf.
 The IG Memo is available at https://www.treasury.gov/about/organizational-structure/ig/Audit%20Reports%20and%20Testimonies/Treasury%20OIG%20Travel%20Inquiry%20To%20Inspector%20General%20Thorson.pdf.
 IG Memo.
 OMB Circular A-126 ¶ 3.
 Id. ¶ 4.
 Id. ¶ 5(c).
 Id. ¶ 5(b).
 Id. ¶ 5(d).
 Id. ¶ 8.
 Id. ¶ 8(a).
 Id. ¶ 10(c).
 Id. ¶ 11(c).
 The Clinton Memo is available at https://www.gpo.gov/fdsys/pkg/WCPD-1993-02-15/pdf/WCPD-1993-02-15-Pg168.pdf.
 41 C.F.R. §§ 301-10.260–301-10-266.
 41 C.F.R. § 301-10.261(b).
 IG Memo.
 The Daley Memo does not appear to be publicly available. References herein are to the IG Memo, which quotes from and describes the Daley Memo in detail.
 IG Memo.
 The Mulvaney Memo is available at https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/memoranda/2017/m-17-32.pdf.
 As discussed below, the documents omit a trip from New York to Washington, D.C. that, according to the IG Memo, he took on August 15, 2017. While the IG Memo states that Secretary Mnuchin was on two legs to this trip, a New York Times report noted that he was only on the return leg. Katie Rogers and Karen Yourish, How Much Money Could White House Officials Save Taxpayers by Flying Commercial? A Lot., The New York Times, Oct. 26, 2017, available at https://www.nytimes.com/interactive/2017/10/26/us/politics/white-house-travel-mnuchin-flights.html?smid=tw-share&mtrref=t.co.
 An analysis by The New York Times revealed that the costs of Secretary Mnuchin’s trips to five countries on military aircraft totaled $631,959, while those same trips on commercial aircraft would have cost a total of $19,265. Rogers and Yourish, The New York Times, Oct. 26, 2017. For domestic trips to Miami, New York, Louisville, Fort Knox, West Virginia, and Los Vegas Secretary Mnuchin used military aircraft at a total cost of $172, 283, while those same trips on commercial aircraft would have cost $3,402. Id.
 IG Memo (Trip No. 1), n.4.
 The MOU is found at UST 000018-00023.
 See UST 000062 (estimated flight costs using Department of Defense reimbursement rate); IG Memo (Trip No. 3) (“Air Force indicated direct aircraft costs were $16,350”). That number may include costs incurred by Ms. Linton and the media, for which Treasury would have been reimbursed, thereby explaining the cost discrepancy between the IG Memo and Treasury records produced in response to CREW’s FOIA request, which list the cost at $14,443 (UST 00003).
 IG Memo, quoting Daley Memo.
 IG Memo (Trip No. 3).
 In that instance, Secretary Mnuchin had switched from an FAA aircraft to a military aircraft because of his stated need to be on a secure call during the return portion of the trip. See UST 000063 (“due to the nature of the call during the return flight, we have removed all passengers not rated for the security clearance level of the call”).
 Grace Schneider, GOP Tax Report Will Spur Wage Increases, Sen. McConnell and Treasury Secretary Mnuchin Say, Courier-Journal, Aug. 21, 2017, available at http://www.courier-journal.com/story/news/2017/08/21/mcconnell-mnuchin-talk-economic-policies/557156001/.
 According to the IG Memo (Trip No. 6), “[t]his trip had been under discussion for some time,” and once the original date was cancelled “[s]ix dates in mid-August were proposed to Leader McConnell and August 21 worked for everyone.”
 Compare UST 000070 with UST 000074.
 Brooke Seipel, Mnuchin and Wife Viewed Eclipse from Fort Knox: Report, The Hill, Aug. 25, 2017, available at http://thehill.com/homenews/administration/347920-mnuchin-and-wife-viewed-eclipse-from-fort-knox-roof-report.
 Another Treasury document (UST 00003) states the cost as $92,992.
 IG Memo, Trip No. 5. According to The New York Times, Secretary Mnuchin was on the return leg only at a cost of $7,556. Rogers and Yourish, The New York Times, Oct. 26, 2017.
 IG Memo (Trip No. 1).
 See also UST 000089.
 Annie Karni, Kushner Took Unannounced Trip to Saudi Arabia, Politico, Oct. 29, 2017, available at https://www.politico.com/story/2017/10/29/jared-kushner-saudi-arabia-244291.
 Jack Moore, Jared Kushner and Trump Officials Made a Secret Visit to Saudi Arabia Last Week, Newsweek, Oct. 30, 2017, available at http://www.newsweek.com/jared-kushner-trump-officials-made-secret-visit-saudi-arabia-695859.
 41 C.F.R. §§ 301.10.261, 301-10.262(a)(1).
 IG Memo.
 Madeline Conway, Mnuchin: Honeymoon Plane Request Was ‘Not About Convenience’, Politico, Sept. 14, 2017, available at https://www.politico.com/story/2017/09/14/mnuchin-honeymoon-plane-request-was-about-national-security-not-about-convenience-242735.
 See, e.g., UST 000113-000119 (China trip by then-Secretary Jacob J. Lew to attend a G 20 ministerial in Shanghai, China, with side trips to Beijing and Hong Kong.