How did CREW quantify the 3,700 conflicts of interest attributed to Trump’s administration?
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Executive summary
CREW arrived at the figure of roughly 3,700 conflicts of interest by systematically cataloguing discrete interactions between the Trump Organization and the federal government—or actors seeking to influence it—and counting each documented interaction as a separate “conflict,” using news reports, FOIA productions, social media, public filings and other open-source evidence to build a running tracker updated daily [1] [2]. CREW’s tally is category‑based (visits, events, promotions, trademarks, policy actions, and miscellaneous interactions), accompanied by financial estimates in some categories, and accompanied by explicit caveats about data gaps and limits to comprehensiveness [3] [1].
1. How CREW defined a “conflict” and the categories it counted
CREW’s working definition treated any interaction between the Trump Organization and the government—or between the Trump Organization and people trying to influence the administration—as a conflict of interest; that broad definition allowed the organization to count events where government or foreign officials patronized Trump properties, administration officials promoted Trump businesses, patent/trademark awards to Trump businesses, visits by officials, and administration actions or policies with potential to benefit Trump properties [4] [2] [5]. CREW broke these interactions into categories—visits, events hosted at Trump properties, public promotions by officials, foreign trademarks and business developments, policy decisions with apparent benefit to Trump businesses, and a miscellaneous bucket for other documented interactions—and counted each qualifying instance as one conflict [3] [2].
2. The sources and methods CREW used to identify each item
To populate its tracker, CREW relied on publicly available documentary evidence: news reporting, social media posts, FOIA responses, agency records when obtainable, and public filings such as trademark grants; the group explicitly states that its tallies are based on publicly available information and that the tracker is updated continuously as new items surface [2] [3]. CREW also used definitional rules—such as relying on the State Department’s list to define foreign governments for tracking foreign visits and trademarks—to maintain consistency in categorizing foreign‑related interactions [2].
3. Examples that illustrate what CREW counted
The tracker includes granular examples: a presidential order that gave exclusive discounts at the Bedminster golf club to certain administration officials and a reported instance of an EPA official attempting to buy a mattress from the Trump Hotel—each treated as discrete conflicts [2]. CREW also counted many visits and events: for example, over 1,000 visits to the D.C. Trump hotel during the first term were tracked as individual conflicts, and CREW documented dozens to hundreds of events at Trump properties hosted by special interests, political groups, and foreign governments [3] [5].
4. How CREW converted interactions into headline numbers and dollar estimates
CREW’s headline count—more than 3,400 and presented elsewhere as about 3,700 after a full term—comes from summing the itemized events, visits, trademark awards, promotions, and policy instances that met their criteria [1] [6]. On top of counts, CREW sometimes estimated revenue or value tied to categories—reporting, for instance, that special‑interest events at Trump properties likely generated more than $13 million and that foreign governments likely paid about $13.6 million—by combining event counts with typical pricing and public tax/tax‑return analyses where available [3].
5. Limitations, omissions, and alternative trackers
CREW repeatedly warns the tracker is rigorous but not comprehensive: the organization acknowledges there are likely hundreds or thousands of additional conflicts it could not document because of unavailable records, withheld visitor logs, refusal to release tax returns, and other data gaps—meaning the headline number is a documented minimum, not a complete census [1] [7]. Other watchdogs maintain related trackers and databases—Campaign Legal Center and the Sunlight Foundation among them—using overlapping but not identical definitions and sources, so headline totals differ depending on methodology and inclusion rules [8] [9].
6. What the methodology implies—and what it does not prove
By design, CREW’s method demonstrates the scale and pattern of interaction between a presidency and a private business empire by counting each documented nexus as a conflict of interest; it is an evidence‑based catalogue of instances that create an appearance or risk of conflicted decision‑making, but CREW’s count does not by itself litigate intent or legal ultimate harms in each case and the organization excludes some categories—such as federal investigations into Trump businesses—from the tracker by policy [2] [1].