Did Trump keep his 19 promises to insulate himself from his business? Only he knows.

Days before he took office in January 2017, Donald Trump mounted a stage in New York flanked by a team of attorneys and stacks of manila envelopes to present his answer to a question no other modern president has confronted.

The papers and the lawyers were there to explain how Trump would simultaneously serve in the nation’s highest office and maintain his ownership of an international business empire emblazoned with his name. Trump declared that he was “turning over complete and total control to my sons,” then had his attorney detail a six-page plan to insulate the businessman-president from potential conflicts of interest.

It contained 19 promises to do with everything from Trump placing his assets in a revocable trust to walling himself off from information about his namesake company.

Two years later, Trump has kept at least eight of his promises – though sometimes in ways experts said did little to resolve the conflicts. But information about his business is so secretive that for nearly all the rest, the only way to know whether Trump kept his promise is to take his word for it.

That could change as federal prosecutors and congressional investigators press for more details about Trump’s businesses.

The House’s Democratic majority has said it plans to conduct wide-ranging examinations of the relationships between Trump’s business and his presidency. His promises – the extent to which they were kept, and the extent to which they skirted some of the thorniest intersections between his business and his administration – could provide one lens for conducting those inquiries.

“The president has turned the government of the United States into a money-making operation for his family, his friends and himself,” said Rep. Jamie Raskin, D-Md., a member of the House oversight committee. “This is a complete betrayal of the constitutional design.”

Meanwhile, the president’s business have sprouted new entanglements. Dozens of lobbyists and contractors still pay dues as members of his private clubs, and some have received favorable treatment from his administration. At least eight of his customers have been appointed to senior government roles. His companies have accepted payments from both the U.S. and foreign governments.

Trump faces lawsuits over his ownership of a hotel that caters to foreign guests. And his company has become a central subject in two criminal investigations that have loomed over his administration, one by special counsel Robert Mueller into Russian election interference and another examining illegal payments to two women who claim they’d had sex with Trump.

Rep. Gerry Connolly, D-Va., said Democrats on the Oversight and Reform Committee have been concerned about Trump’s business conflicts since before he was sworn in because they thought his steps to separate himself from his business were insufficient. “All of those fears have been borne out, and then some,” he said.

Former Office of Government Ethics director Walter Shaub, who denounced Trump's ethics plan the day it was announced, said Trump "still gets an F for ethics" even if he followed through on every one of his promises.

“In some ways, it’s like a bank robber saying from now on I will only wear a blue shirt and yellow tennis shoes when I rob banks, and then analyzing whether he did that when he robbed banks," he said. "It doesn’t alleviate the problem.”

Neither the White House nor the Trump Organization responded to questions about the president's promises.

USA TODAY tracked Trump’s 19 promises by reviewing state and federal records, documents assembled by prosecutors and other news organizations. Together, they offer the clearest picture to date of Trump’s efforts to separate his government from his business interests – though after two years, it remains surprisingly incomplete.

Here are all 19 of the promises:

No deals with foreign countries

1. The Trust Agreement prohibits The Trump Organization from entering into any new transaction or contract with a foreign country, agency, or instrumentality thereof, including a sovereign wealth fund, foreign government official, or member of a royal family, the United States government or any agency or instrumentality thereof, or any state or local government or any agency or instrumentality thereof, other than normal and customary arrangements already undertaken before the President-Elect’s election.

Status: Promise not kept. The Trump Organization has yet to publicly release the trust agreement, or any portions of the document showing that transactions with foreign governments are prohibited. The company hasn’t taken any new deals with foreign countries but has continued to work on several foreign deals that were arranged before Trump took office. Even without the new deals, Trump’s former business partners have continued working and an influx of deals could be on the table once Trump leaves the White House. One former partner told Forbes last year that Trump, since becoming president, had asked about plans for a potential tower in the country of Georgia.

Even without foreign deals, the company has continued to see an influx of business from foreign countries, most notably from Saudi Arabia.

So far throughout Trump’s presidency, two foreign heads of state stayed at Trump’s Washington hotel, the Kuwaiti Embassy booked the hotel for its 2019 National Day celebration, and lobbyists representing the Saudi government paid for blocks of rooms and catering services at the hotel. The lobbyists spent more than $270,000 for the rooms, which came as the country was fighting to roll back a U.S. terrorism law.

The Old Post Office Pavilion Clock Tower, which remains open during the partial government shutdown, above the Trump International Hotel, Jan. 4, 2019, in Washington.
The Old Post Office Pavilion Clock Tower, which remains open during the partial government shutdown, above the Trump International Hotel, Jan. 4, 2019, in Washington.

Trump faces a lawsuit brought by the District of Columbia and Maryland, and another brought by a group of more than 200 Democratic lawmakers, alleging that the arrangement with hotels violates the Constitution’s Foreign Emoluments clause, which they say should prohibit him from taking payments from a foreign government.

In January, the inspector general for the General Services Administration, which leases the Old Post Office Building where Trump’s Washington hotel is located to the Trump Organization, said the agency’s lawyers should have tried to determine whether letting Trump operate his namesake hotel as president violated that prohibition. Instead, it concluded, the agency “ignored the Constitution.”

In addition to the business with foreign governments, the Trump Organization has engaged in transactions involving state government entities since Trump took office. The Maine state government spent more than $22,000 to rent 40 rooms at the Trump hotel in Washington for then-Gov. Paul LePage and his staff over the past two years, The Portland Press-Herald reported. Florida’s departments of corrections and juvenile justice have spent more than $12,000 on travel and lodging at the Trump National Doral facility since Trump took office, according to a USA TODAY review of the state’s spending records.

No involvement in Trump Organization

2. Collectively – and unanimously – Allen, Don, and Eric will have the authority to manage The Trump Organization and have full decision-making authority for the duration of the Presidency, without any involvement whatsoever by President-Elect Trump.

Status: Unknown. A certification of trustee – essentially a summary of the legal documents setting the terms of the president's trust – does not contain any statements about who is managing the Trump Organization.

Trump’s most visible involvement with his business since taking office has been repeated visits to his properties, which experts say has brought valuable publicity to them. Trump has visited one of his branded properties on more than a quarter of his days in office, according to trackers maintained by NBC News and The New York Times.

Shaub, the former top ethics official for the executive branch, said in recent Congressional testimony that “the president has unfortunately done nothing” to discourage interested parties from visiting his properties to potentially curry favor with him.

“We have a situation now where people who seek to influence the government can funnel bags of cash to the president through his various properties,” Shaub told the House Committee on Oversight and Reform.

If nothing else, his private clubs offer one avenue for people seeking to influence the president. The founder of a chain of Florida day spas at the center of a series of prostitution arrests, Cindy (Li) Yang, also ran a consulting business offering Chinese clients access to Trump, Mother Jones reported.

People walk by Trump Tower in midtown Manhattan on December 10, 2018.
People walk by Trump Tower in midtown Manhattan on December 10, 2018.

In a recent interview with The New York Times, Trump suggested that he is monitoring the financial impact of his presidency on his businesses.

“I get a kick out of these people saying ‘Oh, a rich Arab stayed at his hotel,’” Trump said, according to a transcript. “You know, I’ll bet you between opportunity cost and actual cost, you know but I lost massive amounts of money doing this job. This is not the money. This is, this is one of the great losers of all time.”

Ethics adviser must approve all deals

3. Under the terms of the Trust Agreement, written approval of the Ethics Advisor is required for all actions, deals, and transactions that could potentially raise ethics or conflict-of-interest concerns.

Status: Unknown. If the Trump Organization has such a policy, it’s not reflected in any documents available to the public. The certification of trustee document makes no mention of any prohibition on foreign or domestic deals.

The Trump Organization has declined to make the full trust agreement public.

Terminate more than 30 pending deals

4. The President-Elect therefore directed The Trump Organization to terminate all pending deals – over 30 in number – which resulted in an immediate financial loss of millions of dollars, not just for President-Elect Trump but for Don, Ivanka, and Eric as well.

Status: Unknown. The Trump Organization has not produced any documentation that would verify the termination of pending deals prior to Trump taking office.

None of the Trump Organization records that have become public define exactly what the company and its lawyers mean by “deals” or identify which ones were pending at the time Trump took office.

Russian businessman and singer Emin Agalarov told Forbes magazine in 2017 that the Trump Organization had signed a letter of intent to build a Trump Tower in Moscow following the Miss Universe Pageant there in 2013, then in July 2017 emailed the magazine through a representative to deny that any documents were signed. The Trump Organization has not answered questions from USA TODAY about whether this letter of intent was signed, and whether it was ever canceled or rescinded.

No new foreign deals during his presidency

5. [T]he Trust Agreement prohibits – without exception – new foreign deals during the duration of President-Elect Trump’s Presidency. Specifically, the Trust and The Trump Organization will be prohibited at all times during the Presidency from engaging in any new deals with respect to the use of the “Trump” brand or any trademark, trade name, or marketing intangibles associated with The Trump Organization or Donald J. Trump in any foreign jurisdictions.

Status: Unknown. This policy has not been put in writing in any legal document available to the public. The certification of trustee makes no mention of any prohibition on foreign deals.

While there has been no evidence of new foreign business relationships formed during Trump’s presidency, it is unknown whether or not the Trump Organization has pursued new foreign deals during Trump’s presidency, and whether President Trump has helped lay the groundwork for future Trump Organization projects through diplomatic relationships formed while in office.

However, the Trump Organization has continued to push forward on early-stage development deals which were made before Trump was elected. Donald Trump Jr. has traveled to India to help launch residential development projects, The Washington Post reported. And while the Trump Organization continued to move forward with a pre-election deal to develop a residential building in the Philippines, the nation named the Trump Organization’s Philippine partner to the deal as its trade representative to the Trump Organization.

6. [N]ew domestic deals will go through a rigorous vetting process. At a minimum, new deals shall require: the unanimous vote of approval of the Trustees, and written confirmation from the Ethics Advisor that the proposed transaction is both substantively and procedurally an arm’s-length transaction, that it involves an appropriate counterparty, and that it does not raise potential conflicts of interest or similar ethics issues.

Status: Unknown. The Trump Organization declined to release to USA TODAY records demonstrating this process is in place.

USA TODAY revealed in 2017 that the president’s companies had sold dozens of condos for millions of dollars to secretive limited liability corporations, entities created in a way that conceal the identifies of all buyers or beneficial owners of the companies. The share of Trump real estate deals involving those shell companies shot up around the time Trump secured the Republican nomination in mid-2016.

Bobby Burchfield, the company's ethics adviser, told USA TODAY in November 2017 that the company uses a four-part test to evaluate deals: is it at fair market value or in the ordinary course of business; is it an appropriate counterparty; is there any indication the deal is intended to curry favor with the president and is there any likelihood the deal could compromise or diminish the Office of the President.

“If someone wants to do business with the Trump entities in the form of an LLC, we look behind the LLC to see who the owner of it is and where the funding is coming from,” Burchfield said. “If we can’t determine that, we won’t sign off on it.”

Trump Tower in the Midtown Manhattan neighborhood of
Trump Tower in the Midtown Manhattan neighborhood of

But those deep-dive identifications and financial disclosures are difficult and easily spoofed, said Ross Delston, a Washington attorney specializing in anti-money-laundering compliance, who said Burchfield’s test is largely subjective. “What we know of the Trump Organization’s past real estate deals is they never see deals they don’t like,” he said.

Burchfield wouldn’t say if he declined to sign off on any Trump real estate deals in 2017.

No say on Trump organization deals

7. President-Elect Trump will have no role in deciding whether The Trump Organization engages in any new deal…

Status: Unknown. It is not possible to verify whether Trump has had a role in any decision made by the Trump Organization since taking office. But since taking the White House, new business deals have been scarce.

Trump’s sons ended up scrapping a deal this month to open two hotels chains, citing the hostile political climate, The New York Times reported. Some of the hotels were planned in areas that favored Trump in the 2016 election.

No knowledge of the organization's decisions

8 …and he will be completely sequestered from any information regarding the Organization’s decisions.

Status: Unknown. Trump attorney Sheri Dillon conceded when she announced the conflict-of-interest plan that it was not feasible for Trump to completely sequester himself from information about the Trump Organization. Dillon observed that Trump will “know of a deal if he reads it in the paper or sees it on TV.”

Trump deals can be particularly obvious ones because they often involve products with his name plastered onto them.

Additionally, many of the Trump Organization’s deals are licensing deals which result in the “Trump” brand’s placement on buildings or products owned by others – making the deals plainly visible to President Trump.

There is no way of knowing whether the president’s sons run information or decisions by him, including during some of their many White House and campaign trail visits.

Last year, The Washington Post noted an appointment the president made that raised the question over whether Trump was in tune with the operations at the company. The paper reported that the company’s board, during a private meeting, discussed removing Trump’s name from his flagship hotel in Manhattan. New Jersey doctor Stephen Soloway was one of the board members who tried to halt the idea. Soloway was later nominated by the president to the President’s Council on Sports, Fitness and Nutrition, which includes a host of celebrities.

Limited information about the trust's assets

9. [T]he Trust Agreement will sharply limit the information that the President-Elect receives regarding the Trust’s assets. Reports transmitted to the President-Elect will only reflect the profit or loss of the Company as a whole. The reports will not include an accounting of the performance of each individual business within the Company.

Status: Unknown. The Trump Organization has yet to publicly release the trust agreement, or any portions of the document specifying the limits on the information Trump can receive about his businesses.

Eric Trump told Forbes Magazine that he plans to share profitability reports on the business with Trump “probably quarterly.”

Trump has repeatedly said becoming president has cost him financially.

Fred Tansill, an attorney near Washington who specializes in trusts, said it would be difficult to fully insulate Trump from the details because much of the information about how his business is performing could appear on his personal tax returns, which he must sign.

No sharing of nonpublic information

10. Conversely, the President-Elect will not share nonpublic information with The Trump Organization or the Trust, and the Trust will not make use of any nonpublic information, from any governmental source, to engage in financial transactions on the Company’s behalf.

Status: Unknown.

There is no way to know the contents of private discussions between Trump and executives of the Trump Organization. The company is run by his sons Donald Trump Jr. and Eric who say they speak with their father often and are high-profile political surrogates.

While Trump and his sons promised not to share new information, his son Eric said in a March 2017 interview with Forbes that he would continue to provide his father with Trump Organization updates “on the bottom line, profitability reports and stuff like that, but you know, that’s about it.”

Transfer assets into a trust

11. [A]ll of President-Elect Trump’s investment and business assets, commonly known as The Trump Organization – comprised of hundreds of entities – have been or will be conveyed to a Trust, which will be managed for the duration of his Presidency by his sons, Don and Eric, and a Trump executive, Allen Weisselberg.

Status: Promise kept. The Donald J. Trump Revocable Trust was created on April 7, 2014, and amended most recently on Jan. 17, 2017, and its trustees are Donald J. Trump Jr. and Allen Weisselberg. Another of the president’s sons, Eric Trump, is chairman of the trust’s advisory board.

Two “Certifications of Trustee” signed in January and February 2017 by Trump Jr. and Weisselberg, the documents summarize some – but not all – of the contents of the trust agreement. The Trump Organization has not released the trust agreement itself, which would include more information on how it operates. It allows Trump to retain his businesses and withdraw funds on request.

Tansill, the Washington-area attorney, said those terms do little to separate Trump from his business. “What he’s done here is exactly nothing,” he said. “He has all the control in the world over all of his assets.”

Northwestern University law professor Steven Harper said it’s “illusory window dressing of a trust, but that’s all it is.”

Resign from official positions

12. President-Elect Trump will resign from all official positions he holds with The Trump Organization entities.

Status: Promise kept. On Jan. 19, 2017, Trump resigned from 488 business entities, according to a list made public by the Trump Organization.

The list reflects the breadth of the Trump Organization’s sprawling international business empire, from the holding companies for his Mar-a-Lago resort and his domestic golf clubs to several corporations associated with planned developments in Saudi Arabia and Azerbaijan that never broke ground. The activities of other corporations from which Trump resigned his position, such as Chicago Unit Acquisition LLC, remain mysterious.

The Intercept in July 2017 reported that Trump had failed to resign from four of his businesses, months after his lawyers stated that his resignations were complete. Trump’s resignation from his positions at those four entities have since been finalized.

Appoint an ethics adviser

13. President-Elect Trump is appointing an Ethics Advisor to the management team.

Status: Promise kept. In January 2017 , the Trump Organization announced that Burchfield, who was the top lawyer on President George H.W. Bush’s 1992 re-election campaign, would be the company’s independent ethics adviser.

Ivanka Trump must resign from her businesses

14. As part of her family’s transition to Washington, D.C., President-Elect Trump’s daughter, Ivanka Trump will resign from all of her positions in The Trump Organization and the Ivanka Trump brand/fashion business and will have no involvement with the management or operations of either organization.

Status: Promise kept. Records in New York show the president’s daughter resigned from her positions in all of the business entities with which she was associated, though she remained an officer of an entity called IHOLDINGS CORP through May 2017.

Ivanka Trump, White House senior adviser and daughter of President Donald Trump, speaks during the inaugural meeting of the Presidents National Council for the American Worker in the Roosevelt Room of the White House on Sept. 17, 2018 in Washington, DC.
Ivanka Trump, White House senior adviser and daughter of President Donald Trump, speaks during the inaugural meeting of the Presidents National Council for the American Worker in the Roosevelt Room of the White House on Sept. 17, 2018 in Washington, DC.

The Ivanka Trump fashion brand closed in July 2018. The watchdog group Citizens for Responsibility and Ethics in Washington, or CREW, has noted the brand received trademarks from the Chinese government while the Ivanka Trump fashion line was still active and Trump was serving in the White House.

Dispose of easily liquidated investments

15. President-Elect Trump has already disposed of his investments in publicly traded or easily liquidated investments.

Status: Promise kept. Trump’s financial disclosure statement, filed in May 2018 with the Office of Government Ethics, lists the president’s assets and does not indicate he holds any publicly traded stocks or other investments.

Trust only holds two kinds of assets

16. The trust will hold only two kinds of assets: liquid assets, such as cash, obligations of the United States government, and positions in a government-approved diversified portfolio, and the President-Elect’s preexisting, illiquid, very valuable business assets.

Status: Promise kept. All assets held by the Donald J. Trump Revocable Trust should be listed in Trump’s financial disclosure statement. The document does not list assets other than those specified in the white paper.

Establish a new position of Chief Compliance Officer

17. To assist its employees in operating at the highest level of integrity and ethical standards, The Trump Organization has established the new position of Chief Compliance Officer. The sole responsibility of the Chief Compliance Officer is to ensure that The Trump Organization businesses are operating at the highest levels of integrity and are not taking any actions that actually exploit, or even could be perceived as exploiting, the Office of the Presidency.

Status: Promise kept. In late January 2017, the Trump Organization announced it had named one of its executives, George Sorial, to the position of chief compliance officer.

Restrictions on Trump Organization tweets

18. …[T]he Trump Organization has directed that no communications of the Organization, including social media accounts, will reference or otherwise be tied to President-Elect Trump’s role as President of the United States or the Office of the Presidency.

Status: Promise mostly kept. Social media sites for Trump Organization and its affiliates are largely free of any mentions of the president. But some vestiges remain. One tweet sent from the Trump Organization’s main Twitter account in March 2018 highlighted Trump’s skyscraper in Manhattan and included a photo of Trump standing next to a model of the tower. The photo was edited and cut out Trump’s head in an apparent effort to refrain from depicting the president.

While the social accounts are largely free of references to the presidency, Trump’s biography on the Trump Organization website does reference the office. And the president’s sons, who are Trump Organization executives, frequently mix discussions of the business and praise for the president in their personal social media posts.

At Trump’s Bedminster golf club in New Jersey, weddings were marketed with a brochure that the president “will likely stop in & congratulate the happy couple,” The New York Times reported.

And of course, Trump himself repeatedly refers to his south Florida Mar-a-Lago club as his winter White House. He often does presidential business there and is planning to host an upcoming summit with Chinese President Xi Jinping.

In the gift shop of Trump Tower which is run by an independent operator who leases the space from the Trump Organization, USA TODAY spotted items such as mugs bearing the presidential seal, red hats emblazoned with “Trump” that look similar to Trump’s Make American Great Again headwear and a multitude of American-flag items.

Donate profits from foreign governments to U.S. Treasury

19. The President-Elect is announcing he will donate all profits from foreign governments’ patronage of his hotels and similar businesses during his presidential term to the U.S. Treasury.

Status: At least partially kept, but full extent unknown.

The Trump Organization donated $191,538 to the government in 2018, and $151,470 in 2017. It said the donation “fulfills our pledge to donate profits from foreign government patronage at our hotels and similar businesses.”

The Trump Organization in May released a copy of its policy for donating foreign profits after USA TODAY reported that it had refused to do so. The policy specifies that only readily identifiable profits from foreign governments will be segregated and donated to the U.S. Treasury – but not “all profits,” as promised in January.

However, the policy released by the Trump Organization does not explain how it determines which hotel guests are paying for their stays with foreign government money.

To fully and completely identify all patronage at our properties by customer type is impractical in the service industry and putting forth a policy that requires all guests to identify themselves would impede upon personal privacy and diminish the guest experience of our brand,” the policy document says.

Contributing: Nick Penzenstadler and John Kelly

This article originally appeared on USA TODAY: Did Trump keep his 19 promises to insulate himself from his business? Only he knows.