During Donald Trump’s first presidency, he engaged in unprecedented corruption and abuses of power, and surrounded himself with advisors and top appointees who had their own serious conflicts of interest. CREW frequently exposed these abuses and challenged many of them in court. As the second Trump administration begins, we took a look at some of the most notable abuses and ethical issues from last time, what’s already been happening this time around, and outline what we’ll be tracking this time:

Criminal associates and officials

What happened last time?

During Trump’s first term, multiple Trump associates were charged with or convicted of crimes, with several of them serving in the White House, including Michael Flynn and Steve Bannon. Since then, more former Trump associates and administration officials, including Mark Meadows, have been charged with or convicted of crimes, with several sentenced to prison time. Notably, Meadows and Rudy Giuliani were charged for actions they took as part of Trump’s scheme to overturn the 2020 election, which culminated in the January 6th insurrection, though neither have been convicted. 

What’s happening this time? 

This time, Trump has already named two convicted criminals to serve in his administration: Peter Navarro and Charles Kushner. Navarro, who Trump named as senior counselor for trade and manufacturing, served four months in prison last year for his contempt of Congress conviction, stemming from his failure to respond to congressional subpoenas for information about Trump’s scheme to overturn the 2020 election. 

Trump also nominated Charles Kushner, his daughter Ivanka’s father-in-law, to be his administration’s ambassador to France. Kushner, who was convicted and sentenced to two years in prison for campaign finance violations, tax evasion and witness tampering, was pardoned by Trump in 2020. 

What we’ll be watching for: 

  • Whether more insurrectionists and those who aided Trump in court in his attempt to overturn the 2020 election will be appointed, nominated or hired by the White House or other federal agencies 
  • Whether the Trump administration nominates or hires additional criminals to serve in the White House or other federal agencies

Corruption in Trump’s cabinet

What happened last time? 

Trump’s first term cabinet was the most ethically challenged in American history. Interior Secretary Ryan Zinke and Health and Human Services Secretary Tom Price both resigned after scandals, with Zinke racking up 18 investigations into lavish spending and travel as well as whistleblower retaliation, and Price facing backlash for using hundreds of thousands of taxpayer dollars on private jet travel. Commerce Secretary Wilbur Ross also faced multiple complaints of ethical misconduct, including a CREW-filed criminal complaint for possible violations of federal conflict of interest laws for participating in meetings with companies tied to his financial interests. 

What’s happening this time? 

Trump’s Cabinet is shaping up to be even wealthier than his first, with at least half a dozen billionaires picked for key roles, many of whom have holdings that could pose conflicts of interest. His nominee for Secretary of Commerce, Howard Lutnick, already has reportedly mixed his business interests with his role as Trump’s transition chair, raising concerns that he could do the same once in the Cabinet. His nominee for Energy Secretary, Chris Wright, is the chairman and CEO of Liberty Energy and likely has substantial financial interests relevant to his role that he must divest from. Doug Burgum, his pick for Secretary of the Interior, organized the infamous meeting at Mar-a-Lago this summer where Trump reportedly promised cuts to environmental regulations in exchange for $1 billion from Big Oil execs. And that’s just scratching the surface: Trump’s nominees for Cabinet posts and other top roles including multiple former lobbyists and several billionaires with extensive business interests.

What we’ll be watching for: 

  • Whether top appointees divest from their business interests as required
  • Whether Trump enacts an ethics pledge that will lay out clear requirements for recusal for former lobbyists 

The Hatch Act

What happened last time? 

During the last Trump administration, the Office of Special Counsel found that more than a dozen senior Trump aides, including Jared Kushner, Ivanka Trump, Stephen Miller, Mark Meadows, Kellyanne Conway and Kayleigh McEnany violated the Hatch Act by using their official position for partisan politics, with most originating from CREW complaints. 

In 2019, following multiple complaints by CREW, the Office of Special Counsel took the unprecedented step of recommending that Counselor to the President Kellyanne Conway be removed from public service for egregious and repeated violation of the Hatch Act. Despite a CREW lawsuit seeking to compel OSC to enforce the law against Conway, Conway faced no real consequences. Because the president has historically been responsible for imposing consequences for Hatch Act violations for White House staff, Conway and many of the violators from Trump’s last term faced no consequences for their violations. One notable exception is Lynne Patton, who as a HUD official was subject to the usual disciplinary processes, and who agreed to a four-year ban on federal employment after a Hatch Act investigation spurred by a CREW complaint. 

During the 2020 election, then-President Trump  and his staff stepped up their mixing of official government functions with campaign-style events including during the Republican National Convention, with numerous officials later found to have violated the Hatch Act during the months leading up to the election. 

What’s happening this time? 

With the Trump administration in its early days, no Hatch Act violations have yet occurred.  Given Trump’s failure to discipline violators and reports that violations were considered “a badge of honor” during his last administration, it’s likely that they will occur. If they do, OSC has a new policy that will make it substantially easier to take disciplinary action against White House officials who violate it. Rather than following the past practice of reporting violations by White House staff only to the president, the OSC will now pursue disciplinary action with the Merit Systems Protection Board, as they do for all other government employees. 

Addressing Hatch Act violations may be one of the rare bright spots in ethics during the next Trump administration, with new tools to hold top officials accountable. 

What we’ll be watching for: 

  • Whether White House officials and other administration officials abide by the Hatch Act and avoid using their official positions for political purposes 
  • If White House officials are found to have violated the Hatch Act, whether the OSC follows through on its new policy and refers violators to the MSPB for disciplinary action

Inspectors General

What happened last time?

Inspectors general are independent officials within agencies who are key to combating waste, fraud and corruption in their agencies through investigations, audits and other oversight functions. Over the course of his first term, Trump acted with increasing hostility towards IG offices across the executive branch. CREW identified at least 25 distinct actions Trump took to undermine IGs during his first term, not including anti-IG statements he made to the press or on social media. Trump left IG offices vacant for significant periods of time, removed IGs investigating his Cabinet officials and appointed unqualified political allies to IG posts. These actions intensified in 2020, Trump’s final full year in office.

What’s happening this time? 

During his first week in office, Trump fired 17 IGs across the federal government, leaving those agencies without a permanent internal watchdog. In doing so, he disregarded federal law, which requires the president to provide Congress 30-day notice and case-specific reasons for dismissal. Some members of Congress have objected to Trump’s failure to provide notice and justification, but others have defended Trump’s actions. Trump’s dismissal of so many IGs aligns with the aims of Project 2025, the conservative agenda shaped by many Trump administration officials which called for the mass replacement of IGs by Trump. 

What we’ll be watching for: 

  • Whether Trump fills vacant IG positions with political allies—or if he fills them at all
  • Whether Trump fires more IGs
  • Whether Congress more forcefully objects to IG firings

Emoluments Clause/Trump conflicts

What happened last time?

The degree to which Trump used the presidency for his personal financial gain during his first term was staggering. CREW found that Trump accumulated more than 3,400 conflicts of interest between his presidential duties and private business interests during that time. He broke more than 40 years of precedent by refusing to place his assets in a blind trust. And he violated the Constitution’s Domestic and Foreign Emoluments Clauses, including by receiving at least $13.6 million in payments from foreign governments through his businesses. 

Members of Congress, state and foreign officials and interest groups frequented Trump properties as they sought to curry favor with the president; every time they visited, Trump profited. Other potential egregious conflicts, such as Trump’s proposal to host the June 2020 G-7 Summit at one of his own properties, were stopped by public outcry and bipartisan backlash.

What’s happening this time? 

Because Trump is once again refusing to meaningfully divest from his businesses, he will once again be in violation of the Emoluments Clauses, posing serious and escalating corruption and national security threats. He may once again burden taxpayers by charging the Secret Service exorbitantly during frequent visits to his properties. Other public officials, foreign officials and industry leaders may again seek his favor by visiting, too. In addition to the conflicts which were present during Trump’s first term, additional conflicts and Emoluments Clause violations may arise from Trump’s majority ownership of Trump Media & Technology Group (which owns the social media platform Truth Social), his partnership with the Saudi-backed LIV Golf league, his meme coin launched in January 2025, Trump-endorsed crypto company World Liberty Financial and his planned real estate developments in Oman, Saudi Arabia and the United Arab Emirates.

What we’ll be watching for: 

  • How frequently Trump and allies visit Trump-owned properties
  • How often congressional, state, and foreign officials visit Trump-owned properties
  • Purchases of TMTG stock by foreign or domestic governments

Family separations and immigration enforcement

What happened last time?

Historically, the Department of Justice has not prioritized prosecuting asylum seekers for immigration-related offenses such as “improper entry.” However, in April 2017, a new directive issued by Trump’s then-Attorney General Jeff Sessions reversed this policy, instructing federal prosecutors to target asylum seekers, including families with children. This marked the beginning of a significant increase in family separations during the Trump administration.

CREW alleged in an October 2018 lawsuit against DHS that the department “failed to make and preserve adequate documentation of thousands of children and parents taken into its custody, and, consequently, has been unable to reunify each of the families it separated.” Despite the knowledge that hundreds of children would likely be lost to their families, the Trump administration expanded the pilot program nationwide. US officials estimate that over 4,000 children were separated from their families during Trump’s first term. According to the ACLU, hundreds of these children “will likely never be reunited with their parents.”

Trump’s aggressive immigration agenda was a “godsend” for private prison corporations like GEO Group and Core Civic that rely heavily on ICE contracts for revenue. Ahead of the 2016 Election, GEO Group donated hundreds of thousands of dollars to pro-Trump groups, and not for nothing. Shortly after being sworn in, Trump reversed the Obama-era policy to phase out contracts between private prisons and the Department of Justice. GEO Group eventually received the Trump administration’s first federal contract to build a new immigration detention center. Private prisons, which have been criticized for unsanitary and inhumane conditions, assumed an increasingly important role in the American immigration system under Trump. According to the ACLU, by January 2020, approximately 80 percent of people detained by ICE were held in private prison facilities. 

What’s happening this time? 

Trump has promised as president to deport undocumented immigrants en masse with the assistance of the National Guard. On his first day in office, Trump signed a series of immigration-related executive orders which, among other things, declare a national emergency at the border, challenge certain cases of birthright citizenship and halt refugee resettlement in the United States. So far, he has selected a number of immigration hardliners to join his second administration, including Stephen Miller, who helped create the original family separation policy, as homeland security advisor and deputy chief of staff for policy. Trump picked former ICE Director Tom Homan as his incoming “border czar.” Homan has previously stated that resurrecting the family separation policy in Trump’s upcoming term  “needs to be considered.” However, a lawsuit on behalf of families separated at the border resulted in an eight-year ban on the family separation policy (covering all of Trump’s second term), which would restrict the Trump administration’s ability to bring back family separations. 

In the first weeks of his second term, thousands of undocumented people have been arrested as part of Trump’s immigration crackdown. As was the case during the first Trump administration, private prison companies, some of which have been major donors to Trump reelection efforts, stand to gain enormously from the expected increase in migrant detentions during a second Trump term. 

What we’ll be watching for:

  • Increased deportation efforts and the involvement of the US military in such efforts
  • Changes in immigration enforcement policy to target undocumented immigrants who do not pose a public safety or national security risk
  • The expansion of private prisons to accommodate increases in detained migrants
  • Whether the Trump administration mounts a legal challenge against the eight-year ban on family separations or attempts to work around the ban 

Cronyism and nepotism

What happened last time?

During his first term, Trump defied White House ethics norms by engaging in brazen cronyism and nepotism, appointing unqualified family members and loyal donors to powerful government positions.  In 2017, Trump named his son-in-law Jared Kushner as senior White House advisor, and gave his daughter Ivanka Trump a similar advisory role in his administration. Kushner’s lack of experience proved problematic with the failure of his COVID-19 “shadow task force,” resulting in the country’s pandemic response being left primarily to the uncoordinated efforts of state and local officials.  Both Jared and Ivanka ignored ethics rules during their time in the White House, including refusing to divest from significant financial investments. Together, Jared and Ivanka made up to $640 million while working for President Trump’s administration. Trump also rewarded donors and loyalists with prestigious appointments, including mega-donor Louis DeJoy as US postmaster general and his wife, Aldona Wos as ambassador to Canada. 

What’s happening this time

The problem of cronyism in government will likely worsen given Trump’s executive order paving the way to convert potentially tens of thousands of merit-based civil servants to at-will employees, enabling political appointees to fire and replace them with loyalists. CREW has already sued, alongside Democracy Forward, to block the implementation of the plan.

There are also other worrying signs. In building his new administration, Trump has continued his pattern of elevating family members and generous donors to prominent government positions. Charles Kushner, Jared Kushner’s father, was selected to serve as the next ambassador to France and Kimberly Guilfoyle, reportedly the ex-fiancée of Donald Trump Jr. and close friend of President-elect Trump, has been picked as the ambassador to Greece.  Trump also named Massad Boulos, Tiffany Trump’s father-in-law, as a senior advisor on Arab and Middle Eastern Affairs. 

According to a CNN analysis, almost three dozen of Trump’s picks to work in his administration donated to his campaign or the organizations that helped get him elected. The same analysis found that eight of these cabinet picks and their spouses donated over $37 million dollars to Trump in total. This includes Trump’s pick for Secretary of Education, Linda McMahon, who has donated tens of millions of dollars to his campaigns.  

What we’ll be watching for: 

  • Whether Trump’s plan to fire government workers is blocked by the courts
  • Whether more of Trump’s donors and family members will be nominated to serve in his administration

FBI

What happened last time?

Trump clashed with the FBI repeatedly during his first term. Trump allegedly pressed for then-FBI Director James Comey’s “loyalty” at a private dinner in the first week of Trump’s presidency. Months later, Trump fired Comey, whose agency was investigating Russian interference in the 2016 presidential election and the Trump campaign’s possible involvement. Only once before in American history had an FBI director been fired before the conclusion of their 10-year term, a tenure length intended to insulate the director from partisan politics. Soon after Comey’s dismissal, Trump also reportedly ordered the firing of special counsel Robert Mueller, a  former FBI Director who had been appointed to oversee the FBI’s Russia investigation. Trump appointed Christopher Wray to replace Comey.

What’s happening this time? 

After his reelection, Trump announced that he would replace Wray with Kash Patel, a fierce Trump loyalist who has advanced conspiracy theories that the FBI helped plan January 6. If confirmed as FBI director, many current and former federal law enforcement officials fear Patel will use the Bureau’s resources to criminally investigate them and others. Following Trump’s lead, Patel has indicated that he intends to use federal law enforcement to seek retribution against Trump’s perceived political adversaries in both government and media, presumably including the approximately 60 individuals Patel included by name in a list of “deep state” members in his 2023 memoir. Trump and Congressional Republicans have called for the FBI to investigate former Rep. Liz Cheney for her work on the House January 6th Committee.

What we’ll be watching for: 

  • Whether the FBI initiates investigations of media members who have been critical of Trump
  • Whether the FBI initiates investigations of Trump’s political opponents 
  • Whether the FBI investigates prosecutors, judges or others who have criminally charged or investigated Trump

Mar-a-Lago

What happened last time?

During the last Trump administration, Mar-a-Lago served as a place to curry favor with Trump through membership (which doubled in early 2017 to a $200,000 initiation fee and has since risen to $700,000-$1 million), political events and fundraisers. Mar-a-Lago members were named as ambassadors, potentially gained special access to executive branch agencies and reportedly learned classified information about American nuclear submarines.

After Trump left office in 2021, Mar-a-Lago was infamously where Trump allegedly brought hundreds of classified documents and refused to return them to the federal government, with documents being found in a bathroom, ballroom and multiple other unsecured locations. Trump was charged in 2023 with 37 felony counts related to the handling of the documents.

Trump has also managed to profit off the federal government directly, by charging the Secret Service to stay at Mar-a-Lago as well as his other properties, in order to protect him. During his first term, the Secret Service likely paid Trump’s properties close to $2 million, and potentially much more. 

What’s happening this time?

This time, with no Trump Hotel in DC, Mar-a-Lago has become newly important, with Trump referring to it as “the Center of the Universe.”

Trump nominee for Secretary of Health and Human Services Robert F. Kennedy Jr., Meta CEO Mark Zuckerberg, and foreign leaders including Argentine President Javier Milei and then-Canadian Prime Minister Justin Trudeau have all been seen at Mar-a-Lago since the election, in many cases likely spending money that goes straight into Trump’s pocket. Billionaire Tesla and X owner Elon Musk, who Trump named to co-lead the so-called Department of Government Efficiency, was reportedly staying at a $2,000 per night cottage at Mar-a-Lago for weeks after election night. 

As during the last Trump administration, visitors to Mar-a-Lago are not publicly recorded or reported, meaning that the public has limited insight into those who would seek to curry favor or gain access to Trump. 

What we’ll be watching for: 

  • Whether Mar-a-Lago members are given special access or appointments
  • Whether foreign governments, federal, state or local officials and special interest groups spend money at Mar-a-Lago
  • Whether the Secret Service continues to pay  Trump thousands in order to protect him at his properties

 

Photo of Pete Navarro by Gage Skidmore under Creative Commons license

Photo of Rudy Giuliani by Gage Skidmore under Creative Commons license

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