The release of Trump’s 2019 financial disclosures continue to raise questions around Rudy Giuliani’s pro-bono legal counsel to Trump and a £40.6 million personal loan Trump made to his own resort in Aberdeen, Scotland. At the Office of Government Ethics’s (OGE) request, Trump disclosed receiving counsel from Giuliani, but failed to provide a value for it and refused to describe it as a gift. Additionally, Trump failed to disclose his personal loan to Aberdeen for the third year in a row, which could indicate either that Aberdeen did not continue holding the loan in 2019 or that Trump is continuing his pattern of resisting transparency.

CREW has requested OGE records on any guidance the agency provided Trump that would have informed him addressing these gaps in disclosure.

The public deserves to know to what extent Trump is evading transparency measures or to what extent OGE is complicit in enabling him to avoid transparency. Trump’s financial disclosures provide only a narrow snapshot into his finances and earnings, and still questions abound. The president holding onto his assets has continued to make him vulnerable to undue influence from special interests, foreign governments, and others. Trump’s failure to divest and be transparent about his finances will continue to breed ethical issues, and at 3,200 conflicts and counting, there’s certainly no lack of concerns. At the very least, the public deserves more insight into these two ethical questions and OGE’s role in reigning in Trump’s boundless ethical issues.


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