April 25, 2017
Steve A. Linick
Inspector General
U.S. Department of State
2201 C Street NW
Room 8100, SA-3
Washington, DC 20520-0308
Dear Mr. Linick:
American Oversight respectfully requests that you immediately open an investigation into whether
employees of the State Department violated 5 C.F.R. § 2635.702 or any other ethics requirements
by promoting President Donald Trump’s commercial resort, Mar-a-Lago, on ShareAmerica and
other State Department websites.
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To date Mr. Trump has refused to divest himself of his business interests, creating clear conflicts
of interest and breaking decades of practice by his predecessors. The Office of Government
Ethics described Mr. Trump’s purported decision to cede operational control but not financial
control of his businesses as “meaningless from a conflict of interest perspective.” In addition to
Mr. Trump himself, members of the Trump family also appear to be benefitting directly and
indirectly from the president’s public service.
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Leigh Hartman, Mar-a-Lago: The Winter White House, SHAREAMERICA, Apr. 4, 2017,
https://share.america.gov/mar-a-lago-winter-white-house/.
U.S. Department of State: Economic & Business Affairs (@EconAtState), FACEBOOK (Apr. 5,
2017, 1:30 PM), https://www.facebook.com/EconAtState/posts/1386160144810068; U.S.
Embassy-Tirana, (@usembassytirana), FACEBOOK (Apr. 5, 2017, 1:00 PM),
https://www.facebook.com/usembassytirana/posts/10154547231765838; U.S. Mission to the
United Kingdom, Mar-a-Lago: The Winter White House, U.S. EMBASSY & CONSULATES IN THE
UNITED KINGDOM, Apr. 5, 2017, https://uk.usembassy.gov/mar-lago-winter-white-house/.
Alina Selyukh, In U.S. Ethics Chief, an Unlikely Gadfly to Trump, NPR (Jan. 19, 2017, 4:27
PM), http://www.npr.org/2017/01/19/510584962/in-u-s-ethics-chief-an-unlikely-gadfly-to-trump.
Christine Stenglein, OGE Director Warns Trump’s Business Plan Insufficient, THE BROOKINGS
INSTITUTION, Jan. 11, 2017, https://www.brookings.edu/blog/fixgov/2017/01/11/oge-directorwarns-trumps-plan-insufficient/.
See Ivanka Trump’s Fashion Sales Are Skyrocketing Despite Boycott Calls, FOXNEWS.COM,
Mar. 8, 2017, http://www.foxnews.com/entertainment/2017/03/08/ivanka-trumps-fashion-sales-areskyrocketing-says-company-president.html; Nick Penzenstadler et al., Trump Condos Worth $250
Million Pose Potential Conflict, USA TODAY (Apr. 20, 2017, 11:20 PM),
https://www.usatoday.com/story/news/2017/04/20/trump-owns-250m-condos-and-you-could-buyone/100566302/.
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1030 15th Street NW, Suite B255, Washington, DC 20005   AmericanOversight.org

 One of Mr. Trump’s ongoing financial and commercial entanglements is Mar-a-Lago—a private
club purchased by Mr. Trump in 1985. Mr. Trump “used the estate as a private residence until
1995,” when “Mar-a-Lago became established as The Mar-a-Lago Club.” In January 2017, the
Trump Organization raised membership fees to $200,000.
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It now seems that several components of the State Department are endorsing Mr. Trump’s Mar-aLago property in violation of the Standards of Ethical Conduct.
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On April 4, ShareAmerica posted an article titled “Mar-a-Lago: The Winter White House.” The
post referred to the property as Mr. Trump’s “Florida estate,” noted that Mr. Trump “opened the
estate to dues-paying members of the public,” and described Mr. Trump as “a real-estate
magnate.” On April 5, the story was reposted by several other components within State.
Moreover, it appears that the U.S. Mission to the United Kingdom even uses “Mar-a-Lago” as a
blog “tag.” On April 24, public attention was drawn to the State materials as Twitter posts began
to publicize the links.
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Endorsements of Mr. Trump’s property would seem to violate Section 2635.702 of the Standards
of Ethical Conduct, which states that “[a]n employee shall not use his public office . . . for the
endorsement of any product, service or enterprise, or for the private gain of friends, relatives,
or . . . persons with whom the employee has or seeks employment or business relations.”
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History, THE MAR-A-LAGO CLUB,
http://www.maralagoclub.com/Default.aspx?p=dynamicmodule&pageid=100013&ssid=100035&vn
f=1 (last visited Apr. 24, 2017).
Id.
Gina Cherelus, Trump’s Mar-a-Lago Resort Hikes Membership Fees to $200,000, REUTERS (Jan.
25, 2017, 3:40 PM), http://www.reuters.com/article/us-usa-trump-resort-idUSKBN1592NW.
“ShareAmerica is the U.S. Department of State’s platform for sharing compelling stories and
images that spark discussion and debate on important topics like democracy, freedom of
expression, innovation, entrepreneurship, education, and the role of civil society.” About Us,
SHAREAMERICA, https://share.america.gov/about-us/ (last visited Apr. 24, 2017).
Hartman, supra note 1.
Id.
U.S. Department of State: Economic & Business Affairs (@EconAtState), FACEBOOK (Apr. 5,
2017, 1:30 PM), https://www.facebook.com/EconAtState/posts/1386160144810068; U.S.
Embassy-Tirana, (@usembassytirana), FACEBOOK (Apr. 5, 2017, 1:00 PM),
https://www.facebook.com/usembassytirana/posts/10154547231765838; U.S. Mission to the
United Kingdom, Mar-a-Lago: The Winter White House, U.S. EMBASSY & CONSULATES IN THE
UNITED KINGDOM, Apr. 5, 2017, https://uk.usembassy.gov/mar-lago-winter-white-house/.
https://uk.usembassy.gov/tag/mar-a-lago/.
See Eric Lipton (@EricLiptonNYT), TWITTER (Apr. 24, 2017, 2:57 PM),
https://twitter.com/EricLiptonNYT/status/856582802560749568; Josh Schwerin, (@JoshSchwerin),
TWITTER (Apr. 24, 2017, 2:03 PM),
https://twitter.com/JoshSchwerin/status/856569274529435648; Ron Wyden (@RonWyden),
TWITTER (Apr. 24, 2017, 2:46 PM), https://twitter.com/RonWyden/status/856580066389708801.
5 C.F.R. § 2635.702.
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 American Oversight does not know the origin of the initial ShareAmerica story regarding Mar-aLago. It may be that, in a world where Mr. Trump’s financial conflicts are becoming normalized,
the ShareAmerica author simply took the initiative to draft the post in a lapse of judgement, not
fully appreciating that it was inappropriate to promote the president’s for-profit commercial resort.
If so, this would reflect a troubling absence of appropriate editorial controls over the content of
ShareAmerica. Alternatively, the White House or State Department leadership may have
encouraged the use of government resources to promote the commercial and financial interests of
the Trump family. If the idea for this story originated with the White House or the State
Department’s political leadership, this would raise more serious questions about whether ethical
rules and possibly prohibitions backed by criminal penalties were violated. No matter the genesis,
an inquiry by your office is necessary to identify the source and reasoning for publishing the article
on Mar-a-Lago on the State Department’s website and its subsequent promotion by embassies
abroad. An investigation is also necessary to remedy the situation and ensure that appropriate
safeguards are in place to avoid the further use of State Department resources to promote the
private business interests of Mr. Trump and his family.
As the Standards of Ethical Conduct set out, “[p]ublic service is a public trust, requiring employees
to place loyalty to the Constitution, the laws and ethical principles above private gain.” Violations
of this standard erode public confidence in the integrity of government operations and those
holding public office. This would not be the first time the administration has run afoul of ethical
standards.
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American Oversight is a non-partisan organization dedicated to accountability and ethics in
government. No doubt we share that commitment with you. We urge you to investigate the State
Department’s promotion of Mr. Trump’s properties, and, if you find a violation of the law,
recommend appropriate corrective or disciplinary action pursuant to 5 C.F.R. § 2635.106 or other
appropriate authority.
Sincerely,

Melanie Sloan
Senior Advisor
American Oversight
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5 C.F.R. § 2635.101(b)(1).
Letter from Walter M. Shaub, Jr., Director, Office of Government Ethics, to Stefan C.
Passantino, Deputy Counsel to the President and Designated Agency Ethics Official, The White
House (Feb. 13, 2017), available at https://app.box.com/s/46c4uggxa2osxj9znpfw6deizggh1ijx;
Letter from Walter M. Shaub, Jr., Director, Office of Government Ethics, to Senator Ron Wyden,
Ranking Member, Committee on Finance, U.S. Senate (Mar. 31, 2017), available at
https://www.oge.gov/web/OGE.nsf/Congressional%20Correspondence/282B38EF4C78AD208525
80F8004D2768/$FILE/Letter%20to%20R.%20Wyden.pdf?open.
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 cc:

Walter M. Shaub, Jr.
Director
U.S. Office of Government Ethics
1201 New York Avenue NW
Washington, DC 20005
Congressman Jason Chaffetz
Chairman
House Committee on Oversight
& Government Reform
2157 Rayburn House Office Building
Washington, DC 20515
Congressman Elijah E. Cummings
Ranking Member
House Committee on Oversight
& Government Reform
2157 Rayburn House Office Building
Washington, DC 20515
Senator Ron Johnson
Chairman
U.S. Senate Committee on Homeland Security
& Government Affairs
340 Dirksen Senate Office Building
Washington, DC 20510
Senator Claire McCaskill
Ranking Member
U.S. Senate Committee on Homeland Security
& Government Affairs
340 Dirksen Senate Office Building
Washington, DC 20510

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