During Donald Trump’s first presidency, he engaged in unprecedented corruption and abuses of power, surrounding himself with advisors and top officials who had serious conflicts of interest. CREW (Citizens for Responsibility and Ethics in Washington) frequently exposed these abuses and challenged many in court. As Trump’s second administration begins, we looked at some of the most notable abuses and ethical issues from last time, what’s already happening now, and what we’ll be tracking moving forward.
Criminal Associates and Officials
What happened last time?
During Trump’s first term, multiple associates were charged or convicted of crimes, including several who served in the White House, such as Michael Flynn and Steve Bannon. Later, more former associates and administration officials, including Mark Meadows, were charged or convicted, with some sentenced to prison. Notably, Meadows and Rudy Giuliani were charged for actions connected to Trump’s scheme to overturn the 2020 election, culminating in the January 6th insurrection, though neither has been convicted.
What’s happening this time?
Trump has already appointed two convicted criminals to his administration: Peter Navarro and Charles Kushner. Navarro, named senior counselor for trade and manufacturing, served four months in prison last year for contempt of Congress, stemming from his failure to respond to subpoenas regarding Trump’s efforts to overturn the 2020 election.
Charles Kushner, Ivanka Trump’s father-in-law, was nominated to serve as U.S. ambassador to France. He was previously convicted and sentenced to two years in prison for campaign finance violations, tax evasion, and witness tampering but was pardoned by Trump in 2020.
What we’ll be watching:
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Whether more January 6 insurrectionists or those who aided Trump in court are appointed, nominated, or hired by the federal government
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Whether additional individuals with criminal records are nominated or hired
Corruption in Trump’s Cabinet
What happened last time?
Trump’s first-term Cabinet was among the most ethically challenged in U.S. history. Interior Secretary Ryan Zinke and Health and Human Services Secretary Tom Price resigned after scandals—Zinke faced 18 investigations for lavish spending and whistleblower retaliation, while Price faced backlash for using hundreds of thousands of taxpayer dollars on private jet travel. Commerce Secretary Wilbur Ross faced multiple ethical complaints, including a CREW-filed criminal complaint for possible federal conflict-of-interest violations.
What’s happening this time?
Trump’s Cabinet appears even wealthier, with at least half a dozen billionaires in key roles, many with holdings that could pose conflicts of interest. Commerce Secretary nominee Howard Lutnick has reportedly mixed his business interests with his role as Trump’s transition chair, raising concerns for the future. Energy Secretary nominee Chris Wright, chairman and CEO of Liberty Energy, likely has significant financial interests relevant to his position. Doug Burgum, Trump’s pick for Interior Secretary, organized the Mar-a-Lago meeting where Trump reportedly promised $1 billion from Big Oil in exchange for environmental deregulation. Other nominees include former lobbyists and billionaires with extensive business interests.
What we’ll be watching:
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Whether top appointees divest from business interests as required
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Whether Trump enacts a clear ethics pledge for recusal of former lobbyists
The Hatch Act
What happened last time?
During Trump’s first administration, the Office of Special Counsel (OSC) found more than a dozen senior aides—including Jared Kushner, Ivanka Trump, Stephen Miller, Mark Meadows, Kellyanne Conway, and Kayleigh McEnany—violated the Hatch Act by using their official positions for partisan politics, largely based on CREW complaints. In 2019, OSC recommended that Kellyanne Conway be removed from public service for repeated violations, but Trump imposed no consequences.
During the 2020 election, Trump and staff increasingly mixed government functions with campaign events, leading to more Hatch Act violations.
What’s happening this time?
So far, no violations have been reported, but given Trump’s past behavior, they are likely. The OSC has a new policy that allows for easier disciplinary action through the Merit Systems Protection Board (MSPB).
What we’ll be watching:
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Whether White House officials comply with the Hatch Act
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Whether OSC enforces its new policy and refers violators to MSPB
Inspectors General (IGs)
What happened last time?
IGs are independent officials who investigate waste, fraud, and corruption within agencies. During Trump’s first term, he increasingly undermined IG offices: leaving positions vacant, removing IGs investigating Cabinet officials, and appointing unqualified political allies.
What’s happening this time?
In his first week, Trump fired 17 IGs across the federal government without providing legally required 30-day notice or justification. These actions align with Project 2025, a plan advocating mass replacement of IGs with Trump allies.
What we’ll be watching:
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Whether IG vacancies are filled with political allies or left unfilled
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Whether Trump fires more IGs
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Whether Congress pushes back more strongly
Emoluments Clause / Trump Conflicts
What happened last time?
Trump used the presidency for personal financial gain on a massive scale. CREW identified over 3,400 conflicts between his official duties and business interests. Trump refused to place assets in a blind trust and violated the Domestic and Foreign Emoluments Clauses, receiving at least $13.6 million from foreign governments via his businesses.
Officials frequently visited Trump properties to curry favor, generating profit for Trump. Potential conflicts, such as hosting the 2020 G-7 summit at a Trump property, were blocked due to public backlash.
What’s happening this time?
Trump again refuses to divest, risking Emoluments Clause violations, and could charge the Secret Service for stays at his properties. New conflicts arise from majority ownership of Trump Media & Technology Group, the Saudi-backed LIV Golf league, his meme coin, crypto ventures, and real estate projects in Oman, Saudi Arabia, and the UAE.
What we’ll be watching:
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Frequency of Trump and allies visiting Trump-owned properties
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Visits by congressional, state, and foreign officials
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Purchases of TMTG stock by foreign or domestic governments
Family Separations and Immigration Enforcement
What happened last time?
Trump reversed prior DOJ policy on prosecuting asylum seekers, expanding family separations. CREW alleged DHS failed to track thousands of children and parents, leaving hundreds unlikely to reunite. Private prison companies like GEO Group and CoreCivic benefited greatly from increased detention.
What’s happening this time?
Trump promises mass deportations with National Guard support and has signed executive orders declaring a border emergency, challenging birthright citizenship, and halting refugee resettlement. He appointed hardliners like Stephen Miller and former ICE Director Tom Homan. An ongoing lawsuit bans family separations for eight years, limiting reinstatement of the policy.
What we’ll be watching:
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Increased deportations and military involvement
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Policy changes targeting non-dangerous undocumented immigrants
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Expansion of private prisons
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Legal challenges or workarounds to the family separation ban
Cronyism and Nepotism
What happened last time?
Trump appointed unqualified family members and donors, including Jared Kushner, Ivanka Trump, Louis DeJoy, and Aldona Wos. Jared and Ivanka earned up to $640 million while serving in the administration.
What’s happening this time?
Trump continues to promote family members and donors: Charles Kushner (ambassador to France), Kimberly Guilfoyle (ambassador to Greece), and Massad Boulos (senior advisor on Arab and Middle Eastern Affairs). CNN analysis shows nearly three dozen picks donated to Trump campaigns, with eight giving over $37 million collectively.
What we’ll be watching:
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Whether Trump’s plan to convert civil servants to at-will employees is blocked by courts
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Whether more family members and donors are nominated
FBI
What happened last time?
Trump clashed with the FBI, pressuring Director James Comey, firing him, and appointing Christopher Wray. He also reportedly considered firing Special Counsel Robert Mueller.
What’s happening this time?
Trump intends to replace Wray with Kash Patel, a loyalist who supports January 6 conspiracy theories and may use the FBI to target perceived political enemies, including media, prosecutors, judges, and government officials.
What we’ll be watching:
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Whether the FBI investigates journalists critical of Trump
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Whether the FBI targets Trump’s political opponents or legal adversaries
Mar-a-Lago
What happened last time?
Mar-a-Lago was a hub for influence, fundraising, and membership fees, and served as a venue where Trump allegedly brought hundreds of classified documents post-presidency. The Secret Service paid Trump’s properties millions for protection.
What’s happening this time?
Without a Trump hotel in DC, Mar-a-Lago has become “the Center of the Universe.” High-profile visitors—including Robert F. Kennedy Jr., Mark Zuckerberg, and foreign leaders—have stayed there, likely generating revenue for Trump. Elon Musk reportedly stayed in a $2,000-per-night cottage for weeks. Visitors are not publicly tracked, limiting transparency.
