Trump’s business has expanded since 2016 — and so have his potential conflicts

Former president Donald Trump told cryptocurrency fans at a national bitcoin conference this summer that if elected to a second term, he would turn the United States into the "crypto capital of the planet" and adopt policies "written by people who love your industry."

Less than one month later, he began plugging his newest business venture: a cryptocurrency enterprise.

"For too long, the average American has been squeezed by the big banks and financial elites. It's time we take a stand—together," Trump wrote in an online post, linking to the new crypto operation and a photograph of himself, face bloodied and fist raised to the sky after he survived an assassination attempt in Pennsylvania.

Trump stands to benefit financially if the enterprise is successful, with 75 percent of net revenue flowing to a company he owns, according to terms of the arrangement released this week.

Trump's vow to use the presidency to support an industry in which he has a significant personal stake shows how recent shifts in his business activities could give rise to what ethics experts describe as new and unprecedented potential conflicts of interest in a second Trump term.

When Trump first ran for president in 2016, he was a reality television star who had invested much of his fortune in real estate. Prior to his inauguration, he held a news conference with his tax attorney and pledged to put the presidency ahead of his own financial interests. He resigned from the companies he owned, put his sons in charge of the family business and took other steps he said were meant to address ethics concerns.

Nevertheless, during his first term in office, Trump's portfolio of hotels and golf courses was a constant source of controversy and litigation, much of it over spending at his properties by foreign governments and corporate interests with an interest in White House policy.

Now Trump is not only the chief hypeman for and a top financial beneficiary of a crypto company that is actively seeking investors, but also the founder of a social media platform and the majority owner of its publicly traded parent company, with a stake of more than $3.5 billion at Wednesday afternoon's stock price — more than the estimated value of all his commercial real estate combined.

Both ventures open up new avenues that people — including those seeking to influence White House decision-making — could use to enrich Trump personally. Few rules would restrict investors seeking to win Trump's favor, whether they be citizens of the United States or another nation.

Trump also would probably face policy decisions in these areas that could directly affect his own financial interests. Congress is debating major reforms to crypto and social media, giving the next president an opportunity to shape two industries in which Trump has a personal stake. By comparison, the U.S. president has comparatively little role in commercial real estate.

Trump, his company and his campaign have not made any commitments about how he would handle his business interests in a second term.

The opportunities for conflicts between Trump's personal interests and the country's would be "massive," said John Pelissero, director of government ethics at Santa Clara University's Markkula Center for Applied Ethics.

Foreign governments and corporations spent millions of dollars at Trump's hotels and golf courses during his first term, sometimes booking dozens of rooms at his D.C. hotel – a business he has since sold – when their leaders were in town to meet with him.

"Just as people went to his hotels to curry influence with him, people who want to have some influence over him will probably find ways to invest in the social media company or this new crypto venture," Pelissero said.

Trump ally Cynthia Lummis, a Republican senator from Wyoming and a crypto champion, also raised questions about the optics of the former president's foray into the industry, saying in an interview that it has made her "a little uncomfortable." She suggested Trump should consider putting his crypto assets in a blind trust, in which an independent trustee is named to manage the businesses and the president is barred access.

"It just kind of takes the argument away that he might be subject to questioning for being involved in a digital asset project while he's running for president," she said.

Trump still owns an array of hotels, resorts and golf courses in the United States and abroad, plus other New York City real estate including office space, storefronts and luxury apartments. He has also pulled in millions of dollars selling Trump-branded merchandise to fans, the disclosures show. His current offerings include books, Bibles, hats, flags, sneakers and $100,000 watches .

A Trump Organization attorney declined to comment on how it would operate if Trump returns to the White House. The Trump campaign issued a statement from Karoline Leavitt, national press secretary, saying: "President Trump removed himself from his multi-billion-dollar real estate empire to run for office and forewent his government salary, becoming the first President to actually lose net worth while serving in the White House. Unlike most politicians, President Trump didn't get into politics for profit – he's fighting because he loves the people of this country and wants to make America great again."

Representatives of Trump Media & Technology Group — the parent company of Trump's social media platform, Truth Social — and of the crypto venture, World Liberty Financial, did not respond to requests for comment.

Nearly all presidents since the 1970s have put their assets into a blind trust.

During his 2016 campaign, Trump committed to putting his assets into a trust run by his eldest sons, Donald Trump Jr. and Eric Trump, and his then-chief financial officer, Allen Weisselberg.

After Trump's election, the Trump Organization committed to making "no new foreign deals" during his presidency. Trump's sons, having taken over the company, hired an outside ethics adviser and vowed to give profits from foreign governments to the U.S. Treasury, eventually donating hundreds of thousands of dollars.

Though the arrangement removed Trump from day-to-day business operations, it fell well short of a blind trust structure, creating an unprecedented political battle over presidential ethics. The government's top ethics official resigned after six months, criticizing Trump on his way out the door. Democrats in Congress, state attorneys general and private business owners filed lawsuits alleging that Trump was illegally profiting from the office and violating the emoluments clause of the Constitution, which bars presidents from accepting some payments from foreign governments.

At least 20 governments collectively spent more than $7.8 million at his properties while he was in the White House, among them China, Saudi Arabia, the United Arab Emirates, Qatar, Kuwait and Malaysia, according to a report by congressional Democrats using documents from Trump's former accounting firm. One of the watchdog groups that sued Trump, Citizens for Responsibility and Ethics in Washington (CREW), has claimed the foreign payments probably totaled more than $13 million.

After years of litigation, three key cases were dismissed with no resolution from the courts on how the emoluments clause should be enforced. The Trump Organization eventually sold its D.C. hotel and exited a contract with New York City to run a Bronx golf course.

Since then, the Trump Organization has continued to ink deals in foreign countries such as Oman, Saudi Arabia and Vietnam, according to press announcements and his financial disclosures, and the company was in serious talks to open hotels in Israel until last year's Oct. 7 attack by Hamas , Eric Trump told the New York Times last week.

Trump's most valuable asset After the Jan. 6 , 2021, attack on the U.S. Capitol, Trump was suspended from Facebook and Twitter, now known as X. But barely a year later, in October 2021, he announced his own social network, Truth Social.

Former contestants on Trump's "The Apprentice" offered to run the operation and give Trump the bulk of the shares in exchange for his brand and limited participation. In a candidate financial disclosure this year, Trump reported $5.3 million in "business income" for Trump Media but did not provide further detail on what portion of that he may have received.

Trump Media went public earlier this year, minting billions for the former president — at least on paper. In August, Trump Media told the Securities and Exchange Commission that Trump owned nearly 115 million shares, or more than 56 percent of the company.

When Trump Media debuted on the stock market, its share price surged. But the company has lost tens of millions of dollars annually, and last year it reported revenue of $4 million, less than the average Chick-fil-A franchise .

After topping out at $6 billion, the value of Trump's stake has fallen by roughly half. But it remains his most valuable single asset, according to a review of his financial disclosures and the estimated values of his real estate holdings, and is simpler to liquidate than his properties.

An agreement that barred Trump from selling his shares for six months expired in late September. As the deadline approached, Trump said he had no intention of selling.

"People think that I'm leaving, that's why they're down, because if I leave, it's different if I leave. But I'm not leaving. I love it," he said of the shares. "They're worth billions of dollars. But I don't want to sell my shares. I'm not going to sell my shares. I don't need money."

If Trump changed his mind, a buyer could purchase a large quantity of his shares without much oversight either on the open market or through a brokered agreement with Trump.

Buyers must disclose large stock purchases when they amount to more than 5 percent of a company's shares, per the SEC's public-company rules. That disclosure requirement would be triggered only for a purchaser who accumulates about 10 million shares in Truth Social, worth about $312 million at Wednesday's stock price. That figure is 24 times the foreign spending at all Trump properties during his entire first term, according to CREW's assessment.

While government ethics forms require sitting presidents to disclose any sale of stock, they do not require disclosure of details about those sales — including the identities of buyers.

Advertising on Truth Social — much of which is currently for right-wing political merchandise — is Trump Media's main income stream from business operations, according to securities filings. No conflict-of-interest rules would prevent the president benefiting from ad-sale income.

Truth Social remains a relatively tiny player in the social media industry: The platform had 13 million visits last month, less than 1 percent of the roughly 4 billion visits to X, according to estimates from the analytics firm Similarweb. But the former president's fans have encouraged Trump to designate Truth Social as the official communications platform for the White House and federal agencies, a move that could boost traffic and advertising rates.

Trump campaign leaders have not discussed the idea, according to a person familiar with the inner workings of the campaign who spoke on the condition of anonymity to share private conversations.

In the next four years, Washington is widely expected to continue to debate the enormously consequential question of how to regulate social media companies.

During Trump's first term — before Truth Social existed — Trump called for the repeal of Section 230, a bedrock protection for social media companies that largely shields them from being sued for their users' posts. Section 230, however, also protects Truth Social, and whether Trump remains committed to repealing it is unclear.

Trump could also face decisions about several existing proposals to restrict social media use by minors. The proposals, if enacted, could benefit Truth Social by limiting growth for competitors with younger user bases.

"If the president has a strong financial interest in a particular platform, I'm very concerned that that would go against the public interest in creating the rules of the road that are good for democracy," said Archon Fung, a professor at Harvard University's John F. Kennedy School of Government who has extensively studied government ethics.

"What's good for Truth Social may not be good for the United States of America," he added.

'Chief crypto advocate' Trump and his two eldest sons officially announced World Liberty Financial, their new crypto venture, during a live-stream promotion on Sept. 16. In a half-hour interview from his Mar-a-Lago estate, Trump explained that he had come to support cryptocurrency after learning about it from his sons.

"Barron knows so much about this," he said of his youngest son.

Trump's presence served as a valuable endorsement of a company seeking to build buzz and attract investment. The company lists him as "chief crypto advocate" and his three sons as part of the project's supporting team.

Cryptocurrency tokens can be used like money or held as longer-term investments. They are typically not issued or controlled by governments, and transactions can be completed without banks. There are now numerous different currencies, or tokens, as well as exchanges, which facilitate crypto transactions for a fee.

World Liberty Financial has said it intends to build a platform that will allow users to trade, borrow and lend cryptocurrencies. It has said that its mission is to advance "decentralized finance" by leveraging "the global reach and recognition of the Trump brand" to attract users.

On Tuesday morning, World Liberty Financial began selling governance tokens, which grant holders a say in how the project takes shape. The company offered 20 billion tokens for 11⁄2 cents each, with a goal of raising $300 million. By Wednesday afternoon, thousands of buyers had purchased about 825 million tokens for just over $12 million, according to World Liberty Financial's website.

World Liberty Financial released a document this week showing that its top financial beneficiary is DT Marks DEFI LLC. The document refers to multiple "owners and principals" of that company, but only Trump is named. On his candidate disclosure form earlier this year, Trump reported that through a trust he owned virtually all of the company, then called DT Tower II.

DT Marks DEFI is slated to receive 22.5 percent of World Liberty Financial's tokens and 75 percent of revenues once expenses and reserves are met, according to the document. In exchange, Trump has agreed to make promotional appearances and allow the company to use his name and likeness in advertising. Neither he nor his family members are managers, owners or operators of World Liberty Financial, the document shows.

The launch of the Trump-backed crypto venture has underscored deepening ties between the former president and the crypto industry, years after he described bitcoin as a "scam."

The future of crypto depends on how Washington decides to regulate it. To influence those decisions, crypto companies and executives have aggressively lobbied policymakers from both parties, launching a trio of super PACs that have run ads touting crypto-friendly 2024 candidates for Congress and attacking foes. By mid-October, these groups had spent about $134 million, according to the political research firm AdImpact.

Some crypto executives and investors are also pouring money into the race for the White House, whose next occupant will play a critical role in setting crypto policy and selecting key personnel.

A central issue is whether cryptocurrencies should be tightly regulated as securities or as commodities, a question that has divided federal agencies and that will ultimately have to be answered by Congress or the courts. Another key question is how far the government should go in protecting investors from implosions like that of the FTX crypto exchange.

Under Chairman Gary Gensler, the SEC has largely treated cryptocurrencies as securities and cracked down on crypto companies for fraud, false claims and failure to register with the commission. Commodities are regulated by a different agency under different rules.

Trump has pledged to fire Gensler. "The SEC has been extremely hostile and really going after people," Trump said on the live stream.

At the July conference, Trump vowed to create a crypto advisory council to design regulatory guidance to "benefit" the industry. He also said he would block the Federal Reserve from creating its own digital currency — a move that could raise the values of all cryptocurrencies.