Center for American Progress

Tracking the Return on Investment of Trump’s Backers
Report

Tracking the Return on Investment of Trump’s Backers

The individuals and entities who financially supported President Trump’s political operations and personal projects have reaped immense benefits through his administration’s actions since his return to office.

In this article
U.S. President Donald Trump leaves the stage after speaking at Trump National Doral Miami on March 9, 2026. (Getty/Roberto Schmidt)
Key findings
  • This report identifies more than 75 individuals and entities that have contributed nearly $1.7 billion to President Trump’s political operations; personal projects, including his inauguration and the White House East Wing ballroom; and family-owned companies. These individuals and entities have reaped or will reap benefits conservatively estimated at approximately $183 billion.

  • Individuals and entities related to eight crypto and digital finance firms donated more than $161 million to Trump-affiliated political entities, projects, and businesses. The industry has seen dropped lawsuits and investigations that, had the companies been found liable, would have cost an estimated $216 million in potential fines and disgorgements on the low end—and $1.9 billion on the high end.

  • Eleven entities and individuals related to the fossil fuel industry have donated approximately $65 million to Trump-affiliated political entities, projects, and businesses, reaping a conservative $31.2 billion in benefits from Trump administration policies—including the OBBBA—with some benefits accruing over the next decade. These entities and individuals have also been given key appointments to administration positions that regulate and advise on their industry.

  • This report highlights that three corporations not in the fossil fuel or crypto industries donated a total of $2.5 million to Trump-affiliated entities and activities, ultimately benefiting from the administration’s decisions to drop enforcement actions that could have resulted in an estimated more than $500 million in penalties if liability were found and disgorgement required. If companies owned by Elon Musk are included, as well as his political spending, the benefits from dropped enforcement actions leap to nearly $3 billion in potentially avoided penalties if liability were found.

  • Medical industry and nursing home donations from just two identified entities to Trump-associated political entities and projects totaled nearly $18 million. The entities ultimately saw the administration delay or roll back rules that resulted in significant financial benefits—in the case of the nursing home industry, up to $55.1 billion in savings over the next decade.

  • Tobacco industry donations from the four identified entities to Trump-associated political entities and projects totaled $30 million. These entities benefited from the administration’s policy decisions related to menthol cigarettes and flavored nicotine products at a conservative estimate of $6 billion.

  • Relating to government contracts, the eight entities identified across multiple industries identified in this report donated or contributed $112 million to Trump-associated political entities or projects. They are projected to benefit through new, expanded, or consolidated government contracts by upward of an estimated $57.5 billion over the next decade.

Introduction and summary

Since Donald Trump has retaken the office of the presidency, much has been written about the financial gains that have profited the president and his family, now exceeding $2,935,000,000.1 These profits and significant unrealized benefits have come from crypto ventures in which investors lost billions while the Trump family gained billions,2 ongoing domestic and overseas businesses,3 and as yet uncalculated gains from newly created businesses that struck sizable deals with the federal government through contracts, loans, or other support.4

An issue that has gone largely unaddressed, though, is how much the people and entities financially supporting Trump personally or politically are benefiting from their largesse. It appears that they are benefiting substantially—through government contracts, grants or loans flowing to their companies; through plum appointments within the administration; through investigations and enforcement actions being dropped; through criminal pardons; and through beneficial regulatory interventions. Policy alignment between political donors and politicians is to be expected so long as political campaigns continue to be funded through private donations and support. However, it is worth examining how political donors likewise benefit as their preferred policies are enacted.

The legal definition of political corruption is narrow and has been further truncated by recent U.S. Supreme Court decisions.5 Yet a record-high share of Americans (89 percent) believe that government corruption is widespread. This belief is seemingly based on a common, rather than legal, understanding of what constitutes corruption: financial support that results in policy benefits.6

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Legal scholars have long sought to address this common understanding of corruption, which is neither norm-defying nor tacitly illegal. One scholar argued that corruption may arise when public officials “blur public-private boundaries, such as reciprocity with constituent pressure groups and lobbyists” or “groom themselves for lucrative positions in the private sector.”7 Another has dubbed this common understanding—a “fusion of economic and political power [that] threatens to corrupt both economic and political competition”—as “systematic corruption.”8 Systematic corruption is not criminal quid pro quo corruption but legal acts by which political actors seek to secure loyalty and thereby entrench their power through the manipulation of economic privileges in favor of their supporters.9 In the early days of the republic and through the 19th century, this was accomplished through the grant of corporate charters, a spoils system providing government jobs, and other valuable benefits.10

Later, this system of corruption was combated through government reforms, such as the creation of a career-based and meritocratic civil service, independent agencies with protections from dismissal for senior officials, and campaign finance reform.11 The early reforms did not eliminate systematic corruption but placed limits on the ability of politicians and powerful special interests to game the system in their favor. However, many of these protections have been significantly diminished in the modern era through Supreme Court decisions.12 In modern times, systematic corruption—which can be seen across presidential administrations of both parties—largely pertains to decisions related to agency enforcement or nonenforcement; government employment and political appointments; government contracting; regulatory licensing, permission, and exemption structures; and grant funding.13

This report does not purport to allege criminal quid pro quo corruption through these transactions, as political donations and financial support are not inherently corrupt practices; rather, they are commonplace in the American political arena and a well-recognized means of gaining access to policymakers.14 Likewise, access to policymakers in and of itself is not indicative of legal corruption but can inform the link between the influence political donors may have on the policymaking process within legal boundaries. Together, though, they may give rise to the common—not legal—understanding of the appearance of corruption described above. This report intends to make more transparent the benefits received by individuals, entities, and industries—through policies and decisions implemented by this administration—that financially supported President Trump’s political and personal projects and, where appropriate, business entities owned by him and his family.

The Center for American Progress has identified more than 75 instances of individuals or entities who have financially supported President Trump, his family, his businesses, his political operations, or his administration’s vanity projects and have benefited either from direct decisions and actions of the president or through policy decisions implemented by his administration that align with donors’ priorities or interests, including the One Big Beautiful Bill Act (OBBBA). These individuals and entities have backed Trump with approximately $1.7 billion in financial support. This includes $686.8 million for support of his political operations, including Elon Musk contributing $389 million through his America PAC; $466 million for his presidential library, including the value of the Qatari 747 jet; approximately $55 million for the inaugural committee; and $148 million for the White House East Wing ballroom, as well as more than $360 million in payments to the Trump family or their business entities.15 These donations and contributions have resulted in a conservative estimate of benefits of approximately $183 billion. This total includes some benefits that are expected to accrue over the next decade, but it does not include prospective profits from rolled-back regulations on environmental protections, securities laws, and antitrust enforcement that will allow corporations to obtain greater profits.16 Removing outlier benefits, such as $44.8 billion in defense contracts to Lockheed Martin and tariff exemptions on electronic components allowing Apple to avoid $21 billion in costs, the financial benefits received by the identified individuals and entities would exceed $117 billion. Corporate entities associated with Elon Musk alone received more than $14 billion in benefits.

See also
Trump’s Take
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Trump’s Take

Center for American Progress


This report will focus specifically on publicly sourced data reflecting donations and contributions to Trump-associated political action committees (PACs) and super PACs—such as Trump’s main super PAC last cycle, Make America Great Again Inc., and his main super PAC this cycle, MAGA Inc., as well as Never Surrender, Save America, Right for America, America First Action Fund, Elon Musk’s America PAC, and Turnout for America. In addition, the report covers donations and contributions to Trump’s presidential library, his presidential inaugural committee (PIC), and the White House East Wing ballroom project. The report will also address various gifts and business-related boons received by Trump-associated entities, such as World Liberty Financial (WLFI), a cryptofinance business that the Trumps control along with the family of Steve Witkoff, who serves as Trump’s special envoy to the Middle East and Russia.

CAP has identified 10 categories in which providing financial support for President Trump, in some capacity, has conferred significant benefits on donors:

  • Crypto and digital finance industries
  • Fossil fuel industries
  • Governmental and ambassadorial appointments and nominations
  • Dropped investigations and enforcement actions
  • Criminal pardons or clemency
  • Regulatory rollbacks or approvals
  • Merger and deal approvals
  • Government contracts
  • Tariff and trade exemptions
  • Foreign emoluments and entanglements

The crypto/digital finance and fossil fuel industries top the list, as the scope of their benefits cuts across several categories. Importantly, this is an incomplete list, and many of the benefits accrued to financial supporters may extend beyond publicly identifiable or quantifiable measures.

Crypto and digital finance industries

The Trump family’s deep involvement in the crypto and digital finance industry may, in part, influence the policy decisions made by the administration, including ending or easing enforcement actions and regulations and otherwise deemphasizing its focus on potential wrongdoing in the industry. However, it is also worth noting that major entities in the crypto and digital finance industry have supported Trump politically and personally and have subsequently reaped significant benefits. Individuals and entities that profit from eased enforcement and regulatory regimes have given more than $161 million to Trump’s PIC, the White House East Wing ballroom project, and various Trump-affiliated PACs. This does not include revenues accrued to Trump-affiliated business gained through the close ties that many of the entities have established with WLFI or the purchase of hundreds of millions of dollars’ worth of WLFI-issued stablecoins.17 Additionally, most crypto and digital finance entities identified in this report gave significant donations after Trump’s second inauguration in 2025.

The benefits that crypto entities and related individuals garnered from Trump administration policy decisions are estimated at between $216 million and $1.9 billion in avoided fines, penalties, and restitution—had the government successfully prosecuted civil actions in the lawsuits and investigations that they ultimately dropped against these companies.

During Trump’s second term, the administration has largely ceased enforcement actions against the crypto and digital finance industry, dropping or pausing nearly 60 percent of ongoing crypto cases.18 The U.S. Department of Justice (DOJ) also disbanded its cryptocurrency crimes enforcement unit and issued a new directive, “Ending Regulation by Prosecution,” that benefited the crypto and digital finance industry.19 Conversely, between April 2021 and December 2024, the U.S. Securities and Exchange Commission (SEC) “initiated 125 cryptocurrency-related enforcement actions, resolving 98 with $6.05 billion in penalties.”20 The penalties varied between companies—ranging from $4.3 billion for Binance to $13 million for Blockchain Credit Partners.21 Removing the outlier of Binance, the average penalty or settlement was in the range of $18 million.22

The cessation of adverse government actions against individuals and corporations is financially beneficial in that they no longer must pay legal fees, face regulatory compliance costs, or pay remedies in findings against them or settlements. The entirety of the crypto industry’s growth in the past 18 months cannot solely be attributed to this administration’s policies, but those policies cannot likewise be discounted as a global leader in financial enforcement largely stands down. These affirmative benefits—including token valuation, increased profits, increased adoption, and profits made through trading volume—are not quantified here, but it is not unreasonable to estimate they could be valued in the billions of dollars.23 Indeed, U.S. crypto activity grew by 50 percent in the first half of 2025;24 Bitcoin reached a record-high valuation of $126,000 in October 2025, though it has since decreased to $80,523 as of October 28, 2026;25 the number of Americans who own crypto increased to 30 percent;26 stablecoin market capitalization grew by $102.1 billion, or 48.9 percent; and perpetual futures trading increased by 47.4 percent to reach a record high of $86.2 trillion.27

Dropped investigations

In total, the individuals and entities identified in this section donated more than $161 million to Trump-affiliated PACs, his PIC, or the East Wing Ballroom Trust. Applying the average penalty of $18 million to the 12 crypto and digital finance cases the Trump administration dropped in the first three months of the term indicates that, had liability been found, the industry avoided at least $216 million in potential fines and restitution.28 In addition, the cryptocurrency firm Ripple Labs and the government dropped cross-appeals in which the government was seeking an additional $1.7 billion in penalties, effectively ending the enforcement action.29 Had the government prevailed on appeal against Ripple, this would have accounted for a high-end total of $1.9 billion in potentially avoided penalties and benefits accrued through nonenforcement of federal securities law. This does not account for the unquantifiable financial benefits that a lax enforcement regime for an industry now largely unencumbered may pursue.

Among the crypto and digital finance players that saw investigations and enforcement actions dropped by the SEC and DOJ, many gave significant donations to Trump-related entities after his second term began.

Foris Dax Inc., parent company of Crypto.com: $36 million in total donations

Foris Dax donated $35 million to MAGA Inc., including $15 million after the election, as well as $1 million to the PIC.30 A month after Foris Dax’s February 14, 2025, $10 million donation to MAGA Inc., the SEC closed its investigation against Crypto.com with no action taken.31 After the most recent $5 million donation to MAGA Inc., the Trump administration’s Commodity Futures Trading Commission (CFTC) filed an amicus brief in support of Crypto.com in its lawsuit against the Nevada Gaming Control Board, which is attempting to regulate sports prediction market platforms as a form of sports betting.32 The chairman of the CFTC also penned an op-ed for The Wall Street Journal and posted a video supporting Crypto.com’s position.33

Ripple Labs: $9.9 million in total donations

Ripple donated nearly $5 million in XRP crypto tokens to Trump’s PIC and an additional $5 million to the ballroom fund.34 After the donation was made, the SEC dropped the appeal of a four-year-long case seeking an additional $1.7 billion in penalties from Ripple for securities law violations.35 Trump’s SEC attempted to refund Ripple $75 million of a $125 million penalty imposed by court order, but the judge refused to do so.36 Had the appeal been successful, Ripple could have faced an additional $1.7 billion in penalties and disgorgement.

Cameron and Tyler Winklevoss, co-founders of Gemini Trust: $26.9 million in total donations

Together, the Winklevoss brothers gave $21 million to MAGA Inc. and $5 million to the ballroom while also investing in a cryptomining firm co-founded by Eric Trump.37 The SEC dropped a lawsuit against Gemini that could have resulted in significant penalties.38 In a separate matter, the CFTC joined the brothers in their effort to reverse a $5 million settlement against Gemini, which a court rejected.39 Subsequent to the CFTC filing, the brothers donated $10 million in bitcoin to MAGA Inc.40 Some government watchdogs have asserted that these types of donations may be like a “thank you after a favorable regulatory or enforcement action.”41

Ondo Finance: $3.1 million in total donations

Ondo’s donations to MAGA Inc. and Trump’s PIC occurred following the 2024 election.42 Ondo also entered into a strategic partnership with Trump’s WLFI in February 2025.43 In December 2025, the SEC dropped its two-year investigation into whether Ondo violated securities laws in tokenizing U.S. Treasury products—without charges or penalty.44

Kraken: $2.1 million in total donations

Kraken and its founder Jesse Powell’s donations, including $1 million to Trump’s PIC, came after the 2024 election.45 In March 2025, the SEC dropped its action against Kraken that alleged it had violated U.S. securities laws; nothing more was required of the company.46 The agency had sought to enjoin Kraken’s operations and disgorgement of unlawful gains—potentially billions of dollars.47

Coinbase: $6 million in total donations

Coinbase gave $1 million to Trump’s PIC and $5 million to the White House ballroom project.48 The SEC sued Coinbase in 2023 for securities law violations, seeking disgorgement of unlawful proceeds, which could have totaled in the billions, but dropped the case.49 Kevin Hassett, director of the National Economic Council, held between $1 million and $5 million in Coinbase during the development and rollout of the administration’s new crypto and digital finance policies but reportedly recused himself from crypto-related decisions.50

Robinhood Securities and Robinhood Financial: $2 million in total donations

Robinhood’s $2 million donation to Trump’s PIC came after the 2024 election.51 On January 13, 2025, prior to Trump’s inauguration, Robinhood reached a $45 million settlement with the SEC for violations related to failure to report suspicious activity and identity theft protections, among other securities law violations.52 In February 2025, the SEC dropped a second investigation into Robinhood’s cryptocurrency operations without further action.53

Justin Sun, founder of Tron Foundation: $75 million purchase of WLFI tokens

Billionaire Sun purchased the WLFI tokens after the 2024 presidential election while facing SEC fraud charges.54 In 2025, the SEC paused its action against Tron, and Sun-affiliated Rainberry Inc. ultimately settled the case in 2026 when it paid a $10 million civil penalty, which included no admission of wrongdoing.55 Charges against Sun were dropped, as were efforts to disgorge $31 million in restitution.56

Pardons

In 2023, Binance and Changpeng “CZ” Zhao—a Canadian national who owns an estimated 90 percent of Binance and served as its CEO—pled guilty to violations of the Bank Secrecy Act for failing to maintain an effective anti-money-laundering program, and Binance pleaded to charges related to sanctions violations.57 Binance was required to pay more than $4 billion in fines and restitution after it failed to prevent and report suspicious transactions with terrorists—including Hamas, Islamic Jihad, al-Qaida, and ISIS—and with “sanctioned jurisdictions like Iran, North Korea, Syria, and the Crimea region.”58 Subsequent to the plea and settlement, Binance partnered with Trump’s WLFI and built its underlying technology.59 In May 2025, Binance also facilitated a $2 billion deal with a United Arab Emirates-backed investment firm MGX using WLFI’s stablecoin USD1.60 The use of the WLFI-issued stablecoin “effectively gave [WLFI] $2 billion to invest in U.S. government-backed money markets” and “boosted USD1’s market cap, helping it gain legitimacy and scale.”61 This deal would also garner the Trump family an estimated $30 million in profits.62 Zhao received a full presidential pardon on October 23, 2025,63 a day after which the value of Binance’s token jumped 4 percent.64

Fossil fuel industries

Trump’s animosity toward clean energy is well-known. During the 2024 campaign, Trump told top oil executives in a private meeting at Mar-a-Lago that they should raise $1 billion for his campaign, “vow[ing] to immediately reverse dozens of President Biden’s environmental rules and policies and stop new ones from being enacted.”65 The second Trump administration has significantly rolled back environmental protections that affect the fossil fuel industry.66 A source from that meeting denied the promise was framed as a quid pro quo.67

Of the 11 cases identified in this report, individuals and entities related to the fossil fuel industry donated a total of $65.7 million to Trump, including $8 million to his PIC. Notably, CAP was able to identify between $2.5 billion and $2.9 billion in direct and indirect short-term benefits to just three of these entities—not including increased revenues from policy shifts. Furthermore, the fossil fuel industry writ large will conservatively benefit by at least $31.2 billion through the Trump administration’s policy initiatives and tax benefits from the OBBBA, which includes an estimated $13.2 billion in savings over the next decade. Again, this does not include increased revenues garnered by the industry as a result of policy shifts, which would result in a significantly higher total. Indeed, a recent report by the Senate Committee on Environment and Public Works Democrats estimated that the entire fossil fuel industry will accrue $190 billion in benefits over the next decade.68

See also

These benefits arrive in the form of regulatory rollbacks and approvals, tax breaks, and government contracts as well as the reach that industry insiders have within the administration. The OBBBA gave the fossil fuel industry an additional $18 billion in new and expanded tax benefits on top of the $30.8 billion in annual subsidies the industry already receives.69 It will also reduce the royalties paid by the fossil fuel industry to the federal government by an estimated $6 billion over the next decade, or $600 million per year.70 The president of the American Petroleum Institute said that the legislation would provide drilling access on “federal lands and federal waters” and “includes almost all of our priorities.”71 Fossil fuel companies also received $7.2 billion in savings from delaying fees on excess methane emissions for 10 years.72

Individual donors and benefits

Kelcy Warren, chairman of the board of Energy Transfer LP: $40 million in donations during the 2024 election cycle

Warren personally donated $17.5 million to MAGA Inc. and Make America Great Again Inc., along with an additional $7.5 million to Turnout for America. Energy Transfer, meanwhile, donated $12.5 million to MAGA Inc. and $2.5 million to Turnout for America.73 Trump reversed a Biden-era pause on liquefied natural gas (LNG) exports, and his administration granted a three-year extension on an LNG project.74 “Warren’s personal wealth grew nearly 10 percent after the administration greenlit the project,” and he presently has a net worth of $9 billion.75

John Hess, Chevron board member and former CEO of Hess Corporation: $2 million in total donations

John Hess is an oil executive who—along with his wife Susan—donated $2 million to MAGA Inc. in 2025.76 Prior to Trump retaking office, Hess had been barred by the Federal Trade Commission (FTC) from joining Chevron’s board after it acquired Hess Corporation due to allegations of oil production coordination with the Organization of the Petroleum Exporting Countries (OPEC).77 Trump’s FTC reopened the order and permitted Hess to join Chevron’s board.78

Alex Cranberg, chairman of Aspect Holdings: $1 million in total donations

Cranberg, chair of Aspect Holdings, a privately held energy exploration and production company, donated $1 million to Trump’s PIC.79 In July 2026, Cranberg was appointed for a two-year term to the Secretary of Energy Advisory Board (SEAB), which advises the U.S. Department of Energy on issues related to energy exploration and production.80

Cody Campbell, co-CEO of Double Eagle Energy Holdings: $533,200 in total donations

Campbell, who heads an oil exploration firm, donated $500,000 to MAGA Inc. in 2025.81 He has since been appointed to the SEAB as well as the President’s Council on Sports, Fitness, and Nutrition.82 His company, Double Eagle, also stands to benefit significantly from the Trump administration’s fossil fuel policies.

Harold Hamm, chairman emeritus of Continental Resources: $9.1 million

Harold Hamm individually gave MAGA Inc. $1.2 million, and Continental, a petroleum and natural gas exploration company, donated $3 million—including $1 million in 2025, just before the OBBBA was enacted.83 Hamm also gave $4.9 million to the White House ballroom project.84 According to a news article, the same day that Hamm met with Secretary of the Interior Doug Burgum at a hotel in Oklahoma City in April 2025, Burgum announced plans to open more federal lands to extraction industries and speed up permitting processes—policies Hamm reportedly had been pushing.85 The U.S. Department of the Interior has granted Continental 71 drilling permits in Converse County, Wyoming, since the beginning of the second Trump administration, despite a court 2024 court order prohibiting new drilling.86

Michael Dorrell, co-founder of the private equity infrastructure firm Stonepeak: $1 million in total donations

Dorrell donated $1 million to Trump’s PIC.87 Thereafter, the Trump administration entered into a $1.2 billion settlement with Germany-based RWE to cancel offshore wind leases. In this settlement, there is a stipulation that the company invest $900 million in conventional energy.88 RWE is using those funds to purchase a stake in a Louisiana natural gas project tied to Dorrell, though the company and the administration deny any wrongdoing.89

Corporate or mixed donors and benefits

ConocoPhillips: $1 million in total donations to the PIC

As Alaska’s largest oil producer, ConocoPhillips stands to benefit from Trump’s first-day executive order to boost oil and LNG production in Alaska’s wilderness and waters, weaken environmental protections, and ease the drilling permitting process.90 The administration is also fast-tracking winter oil exploration in Alaska by paring down environmental reviews and requirements.91

Chevron: $2 million in total donations

Chevron donated $2 million to Trump’s PIC.92 Not included in this total is a $5 million donation to Trump’s Freedom 250 project.93 Chevron is the only major U.S. oil company with a Treasury Department license to operate in Venezuela and has been granted a broader license to operate there.94 Chevron is attempting to grow its Venezuela production with further U.S. government authorization, which could increase the company’s cash flows by $400 million to $700 million per year, meaning that much more money will be flowing into the company as the result of these activities.95

Exxon Mobil: $1 million in total donations to the PIC

Similar to Chevron, Exxon Mobil receives the financial benefits stemming from Trump’s fossil fuel policies. 96

Occidental Petroleum: $1 million in total donations to the PIC

Under the OBBBA, Occidental will receive an additional $25 per ton of captured carbon dioxide—which it uses to extract more oil—compared with under the prior regime.97 Occidental expects to save between $700 million and $800 million in tax breaks.98 The Trump administration also continued honoring a $500 million grant to an Occidental subsidiary’s South Texas carbon capture project while eliminating other clean energy funding.99

Venture Global LNG: $1 million in total donations to the PIC

Trump’s first-day executive order reversing a Biden-era pause on LNG exports benefited LNG companies such as Venture.100 Three days after Trump’s inauguration, Venture issued its initial public stock offering, netting its two co-founders, who own 80 percent of the company, approximately $24 billion each in gains on paper at that time.101 On March 6, 2025, Venture announced an expansion of a Louisiana LNG export terminal, at which Interior Secretary Burgum and Energy Secretary Chris Wright were present. The following week, the co-founders each purchased an additional 1.2 million shares of Venture stock. On March 19, 2025, Secretary Wright granted an LNG export license to Venture that had been paused by the Biden administration.102 The stock is currently trading north of $12 per share.103 All parties deny any wrongdoing.104

John Addison, senior trader and executive team member at global oil trading firm Vitol: $6 million in total donations

In 2024, Addison personally donated $5 million to MAGA Inc. as well as $1 million to Turnout for America.105 Within days of the U.S. military capturing Venezuelan President Nicolás Maduro, the U.S. government began brokering deals to sell millions of barrels of seized Venezuelan oil, with half of the first sale going to Geneva-based Vitol.106 Addison is viewed as the architect of the U.S.-Venezuela export deal, which allowed Vitol to purchase $250 million worth of Venezuelan oil to which it previously did not have access, with the opportunity to profit from the sale.107 Addison reportedly retired from Vitol to focus on policy and politics and was also appointed to the SEAB.108

Governmental and ambassadorial appointments and nominations

Political appointments and nominations

Providing political support or personal services to President Trump has garnered some of his backers significant roles in government, either through high-level administration appointments or ambassadorial positions. Of the thousands of political nominations and appointments Trump has made during his second administration, this report will focus on 11 individuals who contributed a total of $91.5 million to the president’s various interests. That amount excludes the $25 million donation that Commerce Secretary Howard Lutnick reportedly pledged to the Trump presidential library.

Howard Lutnick, commerce secretary: $14.5 million in total donations (excluding his $25 million pledge to the presidential library)

Lutnick made donations totaling nearly $9 million to MAGA Inc., nearly $2 million to Turnout for America, and more than $2.5 million to the ballroom, with his sons’ company, Cantor Fitzgerald, donating another $1 million to Trump’s PIC.109 After starting his role in the Trump administration, Lutnick reportedly also pledged $25 million for Trump’s presidential library.110 The Lutnick and Trump families have interests in 14 companies that have “either benefited directly from offers of financial assistance from the Trump administration or have pending permit applications before the Commerce Department.”111 These companies have received or are under consideration to receive more than $8.9 billion in funding from the Trump administration.112 Lutnick also played a key role in shaping the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, which regulates stablecoins, while his former company—now controlled by his sons—reportedly holds a 5 percent interest valued at $10 billion in Tether, the world’s largest stablecoin issuer.113

Linda McMahon, secretary of education: $22.2 million in total donations

McMahon donated more than $20 million to MAGA Inc., $1 million to America First Action, and $1 million to Trump’s PIC.114 She was confirmed as secretary of education despite having no experience in the classroom or in school administration.115

Konstantin Sokolov, chairman of U.S. State Department Entrepreneurship Fund for Armenia: $14 million in total donations

Sokolov, a Russian-born private equity investor, donated $13 million to MAGA Inc. in 2025 and 2026 and $1 million for the White House ballroom.116 Though Sokolov has not previously held a government job, he is now directing the State Department’s $201 million Entrepreneurship Fund for Armenia while being a “major shareholder in Armenia’s largest telecommunications company, Viva Armenia.”117 Sokolov also purchased an Armenian copper mine from a sanctioned Russian bank after receiving a sanctions waiver from the Trump administration.118 This raises the specter of significant conflicts of interest, as Sokolov could enrich himself through this role.119

Steve Witkoff, special envoy to the Middle East: $261,600 in total donations

Prior to his appointment, Witkoff was a real estate developer with ties with Qatar.120 During his tenure as special envoy, Witkoff’s son Alex has sought billions in investments from Qatar, and his other son, Zach, has pursued investments from the Gulf states into World Liberty Financial, co-owned by Witkoff and the Trumps.121

Anthony Lomangino, Board of Governors of the U.S. Postal Service nominee, and Lynda Lomangino, Kennedy Center Board of Trustees: $9.27 million in total donations

Anthony Lomangino, a waste management magnate, and his wife donated $400,000 to Make America Great Again Inc., in addition to $8.8 million to other Trump-supporting PACs, including Right for America and Save America.122 Lynda Lomangino was one of the new appointees to the Kennedy Center Board of Trustees, replacing 18 purged members who were appointed by Democrats; she later voted to confirm Trump as chair of the Kennedy Center board.123

Patricia Duggan, Kennedy Center Board of Trustees: $7.4 million in total donations

Duggan is a billionaire philanthropist and was part of the board that elected Trump as chair of the Kennedy Center board.124

Josh Lobel, President’s Intelligence Advisory Board: $273,200 in total donations

Lobel and his wife donated $250,000 to MAGA Inc. after the election and before being appointed to the Intelligence Advisory Board.125 He is a finance executive.

Jared Isaacman, NASA administrator: $7 million in total donations

Isaacman donated $2 million to Trump’s PIC.126 Elon Musk “requested that his ‘close friend’ Isaacman” lead NASA, but his nomination was withdrawn apparently due in part to past donations to Democratic politicians.127 He donated $2 million to MAGA Inc. and was renominated and confirmed.128 Isaacman has since donated an additional $3 million to MAGA Inc.

David MacNeil, Federal Trade Commission nominee: $264,692 in total donations

MacNeil founded WeatherTech.129

Kelly Loeffler, U.S. Small Business Administration administrator: $15.2 million in total donations

Loeffler and her husband donated $9.2 million to Trump’s political entities, $1 million to the PIC, and $5 million to the White House ballroom project.130

Nxum and co-founder Bo Hines, executive director of the President’s Council of Advisors on Digital Assets: $1 million in total donations

Hines’ working group advocated for policies like the GENIUS Act, which helped “create a regulatory regime for dollar-pegged cryptocurrencies known as stablecoins … that could pave the way for the digital assets to become an everyday way to make payments and move money.”131 After leaving the White House, Hines became the CEO of the U.S. division of Tether, the world’s largest stablecoin, which is partially owned by the Lutnick family.132

Ambassadorial appointments and nominations

The appointment of political donors rather than career diplomats to serve as U.S. ambassadors has been a problem dogging the administrations of both parties. Indeed, seven of President Joe Biden’s ambassadors contributed more than $1 million to Democratic politicians and political committees over the 10 years preceding their appointment, totaling $13.5 million.133 However, these amounts pale in comparison to the largesse provided to President Trump and his political operations. Per The Washington Post’s analysis, Trump’s ambassadorial appointees contributed more than $35 million to Trump-affiliated PACs in the election cycle immediately preceding their appointment and into this term. Likewise, approximately 90 percent of Trump’s ambassadors are political appointees rather than career foreign service officers, compared with nearly 40 percent of Biden’s ambassadors at this stage of his presidency.134 The following 14 individuals who were nominated to ambassadorial positions—along with their family members—donated $42 million to Trump’s political PACs, PIC, or ballroom project.

Warren Stephens, ambassador to the United Kingdom: $9.5 million in total donations

Stephens, a finance executive, donated $4 million to the PIC and $5.5 million to Trump’s political PACs.135

Tilman Fertitta, ambassador to Italy and San Marino: $1.02 million in total donations

Casino and hospitality magnate Fertitta donated $1 million to Trump’s PIC.136

Charles Kushner, ambassador to France and Monaco: $1.16 million in total donations

The father of Trump’s son-in-law, Charles Kushner also received a pardon from Trump in 2020 for convictions for tax evasion, witness tampering, and illegal campaign contributions.137

Benjamin Leon, ambassador to Spain: $4.7 million in total donations

Prior to his ambassadorship, Leon was a health care executive who bred racehorses.138

Joe Popolo, ambassador to the Netherlands: $1.26 million in total donations

Popolo, a finance executive, donated $1 million to the ballroom and $250,000 to the PIC.139

Melinda Hildebrand, ambassador to Costa Rica: $1 million in total donations

Hildebrand donated $1 million to Trump’s PIC with her husband, oil billionaire Jeffery Hildebrand.140

Howard Brodie, ambassador to Finland: $5 million in total donations

The family of Ambassador to Finland Howard Brodie donated $1.5 million to Trump-associated PACs and $1 million to the inaugural fund. Moreover, Brodie’s father, Stefan, contributed $2.5 million for the East Wing ballroom project.141

Anjani Sinha, ambassador to Singapore: $1 million in total donations

Introduced by the late Sen. Lindsey Graham (R-SC) during his nomination hearing as a “friend of President Trump for over a decade,” orthopedic surgeon Sinha has no apparent expertise in Singapore.142 He used a private dinner to fundraise for the embassy’s July Fourth celebration.143

Nick Oberheiden, nominee for ambassador to Egypt: $511,600 in total donations

Oberheiden donated to Trump-supporting PACs, and his law firm defended January 6 defendants.144

Bernie Navarro, ambassador to Peru: $1 million in total donations

Navarro, the founder of private equity firm and mortgage lender Benworth Capital Partners,145 donated $1 million to the inaugural fund.146

Melissa Argyros, ambassador to Latvia: $3 million in total donations (including $2 million to Trump’s PIC)

Argyros was a real estate investor and co-CEO and co-chair of the Argyros Family Foundation.147

Benjamin Landa, nominee for ambassador to Hungary: $5.25 million in total donations

A nursing home executive, Landa donated $5 million to MAGA Inc. and $250,000 to Trump’s PIC.148 A nursing home he co-owns is also suing the federal government to prevent the recoupment of $31.2 million in Medicare overpayments made to the company.149

Ken Howery, ambassador to Denmark: $2 million

In addition to his political donations to Trump and the PIC, Howery donated $1 million to Elon Musk’s pro-Trump America PAC.150

Daniel J. Newlin, ambassador to Colombia (nomination withdrawn): $5.88 million in total contributions

Newlin’s donations included $2.55 million to MAGA Inc., $2.1 million to Turnout for America, and $1 million to the PIC.151

Dropped investigations and enforcement actions

It is difficult to affirmatively quantify the financial benefits that individuals and their companies received from federal enforcement agencies and the DOJ dropping investigations, enforcement actions, and lawsuits. However, this analysis estimates that the following companies faced potential enforcement actions totaling upward of $583 million in possible liabilities, while Musk-related entities conceivably faced up to $2.37 billion in penalties.152 These companies, excluding Musk-related entities, donated $2.5 million to Trump’s PIC; the $388.9 million Musk has expended operating America PAC is counted separately and included in the topline numbers above, while the $6 million Musk donated to Trump political entities will not be counted in future sections to avoid double-counting.

Toyota: $1 million in total donations

Toyota donated $1 million to Trump’s PIC but had not donated to past presidential inaugurals.153 In 2023, the company entered into a consent decree with the Consumer Financial Protection Bureau (CFPB) requiring it to refund $48 million to consumers along with a $12 million civil penalty.154 In May 2025, the CFPB terminated the consent decree, allowing Toyota to avoid paying $42 million in reimbursements still owed to consumers.155

JPMorgan Chase: $1 million in total donations

JPMorgan Chase donated $1 million to Trump’s PIC but had not donated to other presidents’ inaugurals in the past.156 In 2024, the CFPB sued JPMorgan Chase for allegedly violating consumer protection laws by failing to address fraud being committed against consumers through Zelle, a money transfer system it partially owned and operated.157 The CFPB alleged 320,000 JPMorgan Chase customers complained of fraudulent inducement, costing them more than $251 million in total.158 The CFPB sought refunds, restitution for consumers, disgorgement for unjust enrichment, damages, and a civil monetary penalty.159 Yet on March 4, 2025, the agency voluntarily dismissed the case with prejudice.160

Bank of America: $500,000 in total donations

Bank of America was another named defendant in the CFPB Zelle fraud case that allegedly affected 210,000 customers—who complained of $290 million in fraud losses.161 This case was also dismissed from the complaint with prejudice.162

Elon Musk: $6 million in total donations

The $6 million Musk donated to MAGA Inc. and the PIC through his various entities does not include the $388.9 million spent to fund the pro-Trump America PAC.163 Musk became the ostensible head of the Department of Government Efficiency (DOGE) at a time when he and his companies were reportedly facing “at least 65 actual or potential actions by 11 different federal agencies” and “at least $2.37 billion in potential liability.”164 The DOJ dropped a discrimination case against SpaceX with prejudice;165 the SEC settled a suit involving Musk’s purchase of Twitter for $1.5 million despite allegations that investors lost $150 million in the transactions;166 the National Highway Traffic Safety Administration closed an investigation into Tesla’s “actually smart summon” feature;167 the U.S. Department of Agriculture’s investigation into Neuralink for animal testing effectively ended when the agency inspector general was fired;168 the Federal Aviation Administration proposed letting companies, including SpaceX, avoid environmental laws to expedite launches;169 and the federal government interceded in Musk’s challenge of the European Commission’s ruling that fined X $140 million for deceptive behaviors on the platform.170 It further appears that governmental enforcement actions against Musk’s companies have largely stopped, even if they have not been formally dismissed.

Gautam Adani: $10 billion investment pledge in the United States by the Adani Group

India’s richest man with a net worth of $112 billion, Adani was charged in a $250 million bribery, fraud, and obstruction scheme in 2024.171 While under investigation, he pledged to invest $10 billion in the United States. Adani, who reportedly met privately with Donald Trump Jr. before his case was dismissed,172 later admitted in a sworn declaration before the court that his lawyers told the DOJ that the $10 billion pledge “might be part of a resolution of these matters.”173 While chastising U.S. acting Deputy Attorney General Trent McCotter for unilaterally dismissing the case without considering the opinions of investigators or line prosecutors, the court stated: “It is up to the public to decide what effect offers of this kind have on the equal administration of justice and the rule of law.”174

Criminal pardons or clemency

During his second term, Trump has granted clemency or criminal pardons to more than 1,700 individuals, including more than 1,500 January 6 defendants.175 A recent report reflects that 96 percent of clemency recipients during this term “didn’t fulfill longstanding DOJ guidelines for such requests.”176 Trump has granted clemency to at least 85 former public officials who were convicted of or charged with corruption-related crimes.177 Fifty-five of those individuals were either elected or appointed Republican officials, an additional nine campaigned for or publicly supported Trump, and four were Democrats.178 Some convicted individuals who have themselves, or through their families, financially supported Trump’s political operations to the amount of $7 million have also received clemency, including the waiver of upward of $700.6 million in penalties and restitution and of prison time.

Paul Walczak, nursing home executive: $1 million in total donations from his mother, Elizabeth Fago

Walczak was convicted of evading more than $10 million in employee withholding, Social Security, and Medicare taxes, instead using company funds to purchase a yacht and pay himself.179 He was sentenced to 18 months in prison and ordered to pay $4.4 million in restitution.180 On April 3, 2025, Walczak’s mother, Elizabeth Fago, attended a $1 million per-person fundraiser at Mar-a-Lago.181 Walczak received a full presidential pardon on April 23, 2025.182

Julio Herrera Velutini, Venezuelan billionaire and banker: $6 million in total donations

Herrera was facing bribery and fraud charges involving a bank he owned doing business in Puerto Rico. His daughter, Isabela Herrera, donated $3.5 million to MAGA Inc. shortly after Trump had won the 2024 election and $2.5 million to the ballroom.183 In mid-2025, the DOJ allowed Herrera to enter into a lenient plea deal for a lone misdemeanor. He subsequently received a full pardon from Trump in 2026.184 While not related directly to political giving to Trump, the Herrera family also hired Trump’s former personal attorney, Alina Habba, to serve as general counsel to a newly created company on a $50 million contract while Habba was still serving as acting U.S. attorney for New Jersey. Notably, Habba started in the position while acting as a senior adviser to Attorney General Pam Bondi.185

Adam Kidan, president of Empire Workforce Solutions: $16,600 in total donations

Kidan, a former business partner of lobbyist Jack Abramoff, who pled guilty to “conspiracy, honest services fraud and tax evasion charges,” pleaded guilty to conspiracy and wire fraud in 2005 for his role in the fraudulent scheme to purchase SunCruz Casinos for $147.5 million.186 Though Kidan gave only $16,600 to the Trump-associated political entities tabulated in this report, he donated an additional $282,000 to Trump’s joint fundraising committees.187 Kidan was pardoned by Trump in July 2026, wiping away the $21 million in restitution he was ordered to pay his victims—of which he reportedly paid very little over the past 20 years.188

Trevor Milton, founder and CEO of Nikola Corporation: $22,870 in total donations

Though Milton and his wife Chelsey donated only $22,870 to the Trump-associated political entities tabulated in this report, he and his wife donated an additional $1.84 million to the Trump 47 joint fundraising committee.189 The founder of electric vehicle startup Nikola, Milton was pardoned for his four-year prison sentence for fraud—which Milton was appealing before the pardon. The pardon additionally extinguished claims for $675 million in restitution.190

Regulatory rollbacks and approvals

As examined in the above sections addressing the fossil fuel and crypto and digital finance industries, regulatory rollbacks and approvals are a significant source of benefits to donors when they are aligned with the policy priorities of politicians. The affirmative benefits accrued by entities that benefit from regulatory actions can be difficult to quantify, but this report attempts to do so where possible. This report identifies three categories of entities—the health care industry, the tobacco industry, and a single foreign-based company—that donated more than $97 million to Trump’s political entities and projects, including $50 million to his library. These entities will reap at least an estimated $61.1 billion over a decade.191

Health care industry

Just two health care industry entities donated nearly $18 million to Trump-associated entities and projects. One company received significant financial benefits through delayed implementation of a rule—though CAP was unable to quantify such—and the nursing home industry is set to benefit from an estimated $55.1 billion over the next decade due to the rescission of a rule.192

Extremity Care (co-founders Oliver Burckhardt and Scott Madden): $13 million in total donations

Extremity Care, purveyor of “skin substitute” bandages, received $1.4 billion in revenues from Medicare in 2024–2025.193 The Biden administration attempted to implement a rule to crack down on waste and abuse that would have limited Medicare reimbursement for two of Extremity Care’s products, which sell for more than $7,000 per square inch, because they “lack scientifically proven benefits.”194 Burckhardt, Madden, and companies related to them and Extremity Care donated a combined $5 million to MAGA Inc. the week before Burckhardt met with Trump at a donor dinner at Mar-a-Lago on March 1, 2025.195 One month later, the administration announced that it would delay the Biden-era rule until the following year.196 This delay allowed Extremity Care to continue billing Medicare at higher rates than would apply under the caps until the end of the year.197

Nursing home industry: $4.8 million in total donations

In 2025, more than 40 entities in the nursing home industry donated $4.8 million to MAGA Inc.198 Donors met with Trump at one of his golf clubs to address concerns related to a minimum staffing rule at nursing homes.199 The administration subsequently stopped defending the rule in court and then repealed the minimum staffing standards, saving the industry an estimated $5.5 billion annually and $55.1 billion over a decade.200

Tobacco industry

The tobacco industry, including e-cigarette producers, donated $10 million in support of Trump’s reelection bid and continued their donations to MAGA Inc. into the new presidential term.201 All told, the tobacco industry entities identified in this report donated more than $30 million to Trump and associated organizations and received an estimated $6 billion in benefits as the result of policy changes executed by his administration. The second Trump administration reversed course from the first term, when it combated flavored tobacco products, by easing restrictions on flavored tobacco and nicotine products and rolling back a Biden-era effort to ban menthol cigarettes.202 Indeed, tobacco lobbyists representing Reynolds American and Altria met with Trump at his Jupiter, Florida, golf course two days after a $5 million donation to MAGA Inc. According to reports, during that meeting, the president placed calls to senior Food and Drug Administration (FDA) and Department of Health and Human Services (HHS) officials decrying the regulatory treatment of tobacco companies.203 One week later, the FDA rolled out new guidance easing restrictions on flavored e-cigarettes.204 The former director of the FDA’s Center for Tobacco Products said: “Some of what we’re seeing here is really a byproduct of political interference into the regulatory process, which is highly problematic.”205 Subsequently, FDA Commissioner Marty Makary resigned from his post in part because of the new flavored tobacco directive.206

Reynolds American: $20.5 million in total donations

Reynolds Tobacco gave Trump political entities $18 million, including $8 million in 2025, and donated an additional $2.5 million or more to the White House ballroom.207 With the rescission of the Biden-era menthol cigarette ban effort, Reynolds is free to continue sales of Newport—America’s top-selling menthol cigarette brand, which sold roughly 1 billion packs in 2024.208 Prohibiting the sale of Newport would have eliminated an estimated $6 billion in revenue for Reynolds.209 The 2025 U.S. e-cigarette market was estimated to be $8.4 billion and expected to grow to $9.4 billion in 2026.210 Reynolds will benefit from the easing of restrictions on flavored nicotine products as the market continues to grow.

Altria: $7 million in total donations

The same e-cigarette benefits realized by Reynolds apply to Altria as well.211

JUUL: $1 million in total donations

E-cigarette company JUUL donated $1 million to MAGA Inc. four months after the FDA authorized the company to market its menthol-flavored products, reversing a Biden-era 2022 ban.212

Vapor Technology Association: $1.55 million in total donations

The Vapor Technology Association includes members throughout the production and distribution chain of e-cigarettes, all of whom benefit financially from the administration’s policy shift. As noted above, the market for e-cigarettes is anticipated to grow from $8.4 billion to $9.4 billion between 2025 and 2026.

Data centers

SoftBank: $50 million in total donations

Japan’s SoftBank donated $50 million to Trump’s presidential library in January 2026, the largest known donation.213 Within two months, the Trump administration announced a public-private partnership with SoftBank allowing the company to build what will be the world’s largest artificial intelligence (AI) data center on federal land in Ohio, benefiting from expedited permitting and federal review.214

Merger and deal approvals

The Trump administration has instituted a pro-corporate agenda, reversing Biden-era policies that imposed stricter reviews to enforce antitrust laws on corporate mergers and acquisitions.215 This change in direction has resulted in “what may be the most favorable regulatory environment for businesses in years,” allowing major corporations to “complete deals that might have been unlikely under previous presidencies.”216

Several corporations that made substantial donations to Trump’s political vehicles or PIC—and, in one case, settled a personal lawsuit—received merger approvals during his second term, from which they will derive substantial benefits. In total, the money donated or paid to Trump or Trump-related entities by the three companies identified in this report totals $18 million. The revenues derived from the mergers are speculative without dissecting the companies’ financials, but the total valuation of the mergers identified herein totals $174 billion.

Skydance-Paramount merger and Paramount-Warner Bros. merger: $16 million paid

Skydance was founded and is run by David Ellison, son of Larry Ellison, one of the 10 richest men in the world.217 Larry Ellison reportedly donated $45 million to a political nonprofit supporting Trump, but as disclosure is not mandated for the group, that amount is not included in this total.218 While the merger between Skydance and Paramount, which owns CBS, was pending, there was an ongoing lawsuit brought by Trump against CBS seeking $10 billion in damages.219 The Federal Communications Commission (FCC) review of the $8 billion merger deal was dragging on, and some executives feared that a settlement of the Trump lawsuit “could be interpreted as bribery for the F.C.C. to clear the Skydance deal.”220 The merger was approved three weeks after Paramount agreed to settle the lawsuit for $16 million to be paid to Trump’s presidential library.221 Skydance then sought to acquire Warner Bros. in a $111 billion deal, at the outset of which Trump suggested he would personally weigh in.222 Though Trump later denied involvement, the DOJ approved the merger.223 The DOJ also did not join the 12 states that sued to stop the merger, a case that was ultimately settled.224

Verizon-Frontier Communications merger: $1 million in total donations

Verizon’s purchase of Frontier Communications in a $20 billion deal allowed Verizon to expand its fiber network’s reach from 30 million to 50 million passings—or homes passed—and save $1 billion in costs by 2028.225 The FCC approved the deal one day after Verizon agreed to end its diversity, equity, and inclusion (DEI) programs.226 The OBBBA tax benefits also boosted Verizon’s free cash flow by $1.5 billion to $2 billion.227

Capital One-Discover merger: $1 million in total donations

In 2024, Capital One and Discover announced a $35 billion merger to acquire the latter credit card processing company.228 Biden’s DOJ was investigating potential antitrust violations, and early reports indicated that the Trump DOJ would issue a finding that the merger would harm competition.229 However, after less than three months of handling the matter, Trump’s DOJ announced its approval of the merger.230

Government contracts

Federal law prohibits government contractors from making political contributions, and it is likewise illegal to solicit contributions from such persons or firms.231 However, nothing prohibits awarding contracts to entities that previously made political contributions or contributions from noncontracting subsidiaries. Nor does the law prohibit donations to entities in which politicians have an interest but in and of themselves are not political in nature. Corporate entities and individuals with government contracts have long donated to presidential inaugural committees and other governmental programs. Indeed, many of the entities that made contributions to Trump’s PIC and other related projects also made contributions to Biden’s inaugural committee. Furthermore, several of the entities receiving government contracts have been long-standing government contractors over multiple administrations.

The individuals and entities identified below contributed $112 million to Trump’s political entities and his various projects and will receive up to an estimated $57.4 billion in new or expanded government contracts during his second term. Not counting outlying contracts given to Lockheed totaling $44.8 billion, this constitutes $12.7 billion—including Musk—in new or expanded contracts benefiting a handful of companies that donated $84 million. The $394.9 million Musk has expended in donations and operating America PAC is counted separately and included in the topline numbers above.

Elon Musk/SpaceX: $6 million in total donations (not including $388.9 million to operate America PAC

SpaceX received a $1.6 billion contract from U.S. Space Force for rocket launches, $4.16 billion to build satellites for the “Golden Dome” missile defense system, and $2.29 billion for a communications network.232 SpaceX also obtained a $946 million contract from NASA for three manned missions.233 Meanwhile, xAI received a contract worth up to $200 million when its chatbot Grok was a last-minute addition to a government AI program.234

Amazon: $34.8 million in total donations, contributions, and payments

Contributions from Jeff Bezos and Amazon to President Trump, his family, and Trump-affiliated entities are multifaceted and include a $1 million donation to his PIC; an $888,000 in-kind contribution for streaming the inauguration on Amazon Prime; $28 million in licensing fees constituting Melania Trump’s reported 70 percent share of Amazon’s documentary about her; and $5 million to the White House ballroom project.235 Between December 2025 and May 2026, Amazon received $255.7 million in new or expanded federal contracts.236

OpenAI: $33.5 million in total donations

OpenAI’s donations are aggregated from personal and corporate giving to Trump’s PIC and MAGA Inc.237 The Pentagon entered into a $200 million prototype contract with OpenAI while at the same time declaring rival Anthropic’s AI systems a supply chain risk and barring them from certain government uses.238 There have also been reports that the U.S. government will take an ownership stake in OpenAI.239 OpenAI did not receive revenues from the U.S. government during the Biden administration but did enter into a safety research agreement.240

Lockheed Martin: $16 million in total donations

Lockheed donated $1 million to Trump’s PIC and reportedly contributed $10 million to the White House ballroom, while its subsidiary Sikorsky contributed $5 million for the White House helipad.241 In addition, Lockheed was a corporate sponsor of Trump’s Freedom 250 initiative and donated $10 million to the Pentagon Memorial Visitor Education Center—neither of which is included in the above total.242 During the second Trump administration, Lockheed has received $44.8 billion in new or expanded contracts, including a $9.8 billion order for Patriot missiles—the largest in company history—and up to $35 billion for a Golden Dome missile defense program contract.243 Lockheed also benefits from Trump executive orders that streamline defense acquisitions and sales of weapon systems to foreign nations.244

Palantir: $12 million

Palantir, an analytics software company, and its executives donated $1 million each to Trump’s PIC and MAGA Inc., along with $10 million for the White House ballroom.245 Between December 2025 and May 2026, Palantir received at least $1.032 billion in new federal contracts.246 The company also received a $127 million contract from the U.S. Army to develop a new Tactical Intelligence Targeting Access Node (TITAN) targeting system as well as a $244 million no-bid Department of Defense (DOD) contract for undisclosed products through March 2027.247 The Army consolidated dozens of software contracts with Palantir into a single 10-year deal worth up to $10 billion.248

GEO Group: $7.1 million in total donations

A subsidiary of GEO Group—a private prison contractor without government contracts—donated $6.4 million to MAGA Inc. from 2025 through 2026, and GEO Group’s executives gave smaller amounts to Trump-affiliated PACs as well as $500,000 to the PIC.249 In fiscal year 2024, GEO Group received $641 million in federal contracts;250 in FY 2025, that amount increased to $791 million;251 and in FY 2026, it increased to $1.059 billion,252 reflecting a total increase in federal contract obligations of $568 million between the Biden and Trump administrations. The federal government also purchased the Adelanto detention facility from GEO Group for $950 million while contracting with the company to continue operating the facility.253

Comcast: $8.5 million in total donations

Comcast contributed $1 million to Trump’s PIC and made a $7.5 million donation to the White House ballroom. Between December 2025 and May 2026, Comcast received new or increased federal contracts worth $13.4 million.254

John J. Cafaro of Greenwater Services: $108,300 in total donations

John Cafaro, a Mar-a-Lago member, donated $108,300 to Trump-affiliated or Trump-supporting PACs in 2024.255 Cafaro’s company, Greenwater Services, received a $1.7 million no-bid contract to help renovate the Lincoln Memorial Reflecting Pool on the National Mall.256

Tariff and trade exemptions

Trump has spent significant time and effort during his second administration imposing tariffs on America’s foreign trading partners. In April 2025, he imposed a minimum 10 percent tariff on all global trading partners under his purported emergency powers.257 Though the initial round of tariffs was deemed illegal by the Supreme Court, he reinstituted new tariffs ranging between 10 and 12.5 percent on 60 countries that account for 99 percent of America’s imports.258 However, some products have received exemptions from these tariffs—for which there are undoubtedly legitimate policy considerations—and the companies that deal in those goods are benefited by extension, including companies that financially supported Trump in substantial ways. In that sense, the entities identified below—excluding Elon Musk, so as not to double-count—provided Trump $70.7 million in donations.259 The benefits they derived from trade decisions made by the Trump administration conservatively total $27.34 billion.260

Examples of tariff exclusions and trade benefits include the following:

Elon Musk: $6 million in total donations (not including $388.9 million to operate America PAC)

In implementing tariffs for auto manufacturers, the administration set a standard that vehicles containing at least 85 percent domestically made components would be exempt—a standard that, of all U.S. auto manufacturers, only Tesla met. Economists estimated that Tesla would avoid $2.5 billion in tariffs through this move.261

Apple: $26 million in total donations

Apple CEO Tim Cook donated $1 million to Trump’s PIC, and Apple donated $25 million to his ballroom and also met with him personally.262 Less than a week after their meeting, the administration issued an exemption to the 145 percent tariff on Chinese components of smartphones, laptops, and other similar electronics—which saved Apple upward of $21 billion that would have been absorbed or passed on to the consumer.263 After the waiver and Trump stating that he “helped Tim Cook recently,” Apple’s stock rebounded 7 percent.264

José “Pepe” Fanjul, sugar magnate: $5 million in total donations

The Fanjul family and their companies have donated more than $7 million to Trump’s political ambitions since 2016, with $4 million coming in the last election cycle and $1 million to the White House ballroom.265 The Trump administration rescinded a 2022 ban on sugar imports from the partially Fanjul-owned Central Romana company that was initially imposed because of allegations of forced labor; this was done despite evidence of continued abuses.266 In 2021, the year before the importation ban was enacted, Central Romana imported 200 million pounds of sugar per year to the United States.267 At a current cost of $0.18 to $0.20 per pound of sugar on the commodities futures market, this accounts for $36 million to $40 million in revenue per year.

Automakers Ford, GM, Toyota, Stellantis: $3.7 million in total donations

Major automakers contributed a combined $3.7 million to Trump’s PIC.268 This was the first such contribution reported from Stellantis. The administration announced that it would provide “credits for up to 15% of the value of vehicles assembled domestically” that could be applied against the value of imported parts.269 This credit could amount to approximately $3.8 billion in savings for Ford alone based on its approximately 1.8 million vehicles likely eligible for the credit.270

ArcelorMittal: $37 million in total donations

ArcelorMittal, a Luxembourg-based steel manufacturer with operations in Canada, donated $37 million worth of steel for construction of the White House East Wing ballroom project.271 Shortly after announcing acceptance of the steel donation, the White House “made adjustments to its tariffs that could benefit ArcelorMittal, by cutting in half the tariffs applied to exports of automotive steel from its Canadian plant.”272 A White House official later denied ArcelorMittal received any benefits for its donation.273

Foreign emoluments and entanglements

The U.S. Constitution specifically states that “[N]o Person holding any Office of Profit or Trust under them, shall, without the Consent of the Congress, accept of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State.”274 This has traditionally been interpreted to mean that a president may not accept anything of any value from a foreign government. Historically, presidents have gone to Congress to request acceptance of a gift,275 or given state gifts to the National Archives for preservation.276 Presidents may also pay the fair market value for gifts from foreign governments to retain them upon leaving office.277 Adhering to this code of ethics is no longer the norm for the current Trump administration.

President Trump has accepted gifts from foreign states; his businesses have profited from doing business with foreign countries, which also profits Trump personally; and the president appears to have wielded American domestic and foreign policy to benefit himself and his foreign business partners.

Qatar: $400 million in total donations in kind

The emirate of Qatar gifted President Trump a Boeing 747 luxury jet worth an estimated $400 million. The jet will not remain in the presidential fleet, but ownership will reportedly be transferred to the Trump presidential library when he leaves office.278 The security upgrades to the plane cost an undisclosed amount, but the aircraft’s retrofitting was initially estimated to cost $400 million in taxpayer dollars.279 Subsequently, the U.S. government entered into an agreement to build a facility for Qatari F-15 fighter jets—delivered under the first Trump administration—in Idaho.280

Sheikh Tahnoon bin Zayed Al Nahyan and the United Arab Emirates: $263 million in total payments

Sheikh Tahnoon is a UAE national security adviser who purchased 49 percent of WLFI for $500 million, $263 million of which went to Trump’s family business.281 The Trump administration subsequently loosened restrictions on sales of sensitive AI chips to the UAE, against the recommendations of career staff who noted national security concerns.282

Vietnam: Fast-tracking Trump golf course

In April 2025, as part of his global tariffs scheme, President Trump instituted worldwide tariffs, issuing steep 46 percent tariffs on goods imported from Vietnam.283 The nation then fast-tracked development of a $1.5 billion Trump golf course project, skipping environmental reviews and a public comment period and displacing hundreds of individuals and families residing on the land.284 The Trump administration subsequently lowered the proposed tariffs on Vietnamese goods to 20 percent.285

See also

Conclusion

As evidenced above, making significant monetary political contributions and having access to government officials—including to the president—are likely key drivers that enable special interests to advance policy priorities and influence government action that benefits them personally or financially. Again, this report is not intended to assert quid pro quo corruption on the part of any individuals or entities—or, for that matter, the Trump administration—as political donations and access to government officials are part of the firmament of how American politics and government function. However, it further shows the influence of money in U.S. politics and is indicative of how the levers of governmental power can create a symbiotic form of real or perceived systematic corruption where politicians and special interests entrench each other’s power and financial well-being through donations and government benefits.286 This may explain why nearly 90 percent of Americans believe government corruption is widespread.287

We must begin the work of building a government that benefits everyday Americans rather than political and personal backers.

It has long been clear that money buys access to and influence with government officials—generally in legal ways—making it exceedingly difficult for everyday Americans to compete with wealthy special interests in driving a beneficial policy agenda. Those concerned about restoring faith in government should seriously consider ways to address the outsize influence of money in the policymaking arena and put the interests of the American people above those of the rich, powerful, and well-connected.

CAP has proffered new ideas about tackling the corrupting influence of money in politics, most recently and notably through the “Corporate Power Reset,” which would use state corporate law to limit the ability of corporations to spend directly on political campaigns.288 Though a strong first step, the Corporate Power Reset would not be able to stem the influence of other political spending through super PACs and 501(c)(4) “issues” organizations that do not have to disclose their donors. As such, additional reforms are necessary to address the type of systematic corruption inherent to American politics today. Key first steps include implementing campaign finance reform that can withstand strict scrutiny from the Supreme Court and legislation that will prohibit governmental self-dealing, close the door to governmental capture by special government employees, enhance conflicts of interest laws for all executive branch officials, and reestablish an independent Department of Justice that is not subject to control by the White House.

In the coming weeks, CAP will be issuing an affirmative agenda that aims to tackle the systematic corruption and conflicts of interest now inherent to the American system of government, proposing novel means by which the American people and Congress can fight back. Though overcoming the hurdles now entrenched in the system is a difficult task, policymakers can start by enhancing statutory and regulatory safeguards to stem the influence of special interests in politics, prevent self-enrichment by government officials, and begin the work of building a government that benefits everyday Americans rather than political and personal backers.

Endnotes

  1. Center for American Progress, “Trump’s Take,” available at https://www.americanprogress.org/feature/trumps-take/ (last accessed October 2026).
  2. Marco Quiroz-Gutierrez, “Close to a million investors of the Trump memecoin lost a collective $3.8 billion, even as the president disclosed $636 million in earnings,” Fortune, July 7, 2026, available at https://fortune.com/2026/07/07/donald-trump-meme-coin-world-liberty-financial-finance-politics/; Tom Bergin, Koh Gui Qing, and Douglas Gillison, “Trump reports over $1.4 billion in income from crypto ventures,” Reuters, June 30, 2026, available at https://www.reuters.com/world/us/trump-reports-over-14-billion-income-crypto-ventures-2026-06-30/.
  3. Jesús Súrvulo González, “Trump’s other businesses: From hotels and golf clubs to watches and Bibles,” El País, July 2, 2026, available at https://english.elpais.com/usa/2026-07-02/trumps-other-businesses-from-hotels-and-golf-clubs-to-watches-and-bibles.html; Eric Lipton and John Yoon, “Trump Paid $2 Million by South Korean Company Facing Trade Investigation,” The New York Times, July 14, 2026, available at https://www.nytimes.com/2026/07/14/us/politics/trump-south-korea-aluminum.html; Damien Cave, “Why Vietnam Ignored Its Own Laws to Fast-Track a Trump Family Golf Complex,” The New York Times, May 25, 2025, available at https://www.nytimes.com/2025/05/25/world/asia/trump-vietnam-golf-project.html.
  4. Robert Faturechi, “The White House Intervened to Get a $620 Million Deal for Company Tied to Donald Trump Jr.,” ProPublica, May 28, 2026, available at https://www.propublica.org/article/donald-trump-jr-vulcan-deal-white-house; Eric Lipton, “Trump’s Son Is Poised to Profit From Pentagon Drone Proposal,” The New York Times, October 24, 2025, available at https://www.nytimes.com/2025/10/24/us/politics/trump-drones-pentagon.html; Paul Sonne and Eric Lipton, “Trump Cut a Billion-Dollar Mining Deal. His Sons Stand to Profit,” The New York Times, June 28, 2026, available at https://www.nytimes.com/2026/06/28/world/europe/trump-lutnick-sons-kazakhstan.html.
  5. Legal Information Institute, “18 U.S.C. § 201,” available at https://www.law.cornell.edu/uscode/text/18/201 (last accessed October 2026); Legal Information Institute, “18 U.S.C. § 666,” available at https://www.law.cornell.edu/uscode/text/18/666 (last accessed October 2026). For more on how acceptance of rewards for past policy acts does not constitute a criminal offense, see Snyder v. United States, 603 U.S. 1 (June 26, 2024), available at https://supreme.justia.com/cases/federal/us/603/23-108/. For more on how fraudulent government actions that may harm the public are not a criminal offense unless the object was to obtain money or property, see Kelly v. United States, 590 U.S. 391 (May 7, 2020), available at https://www.supremecourt.gov/opinions/19pdf/18-1059_e2p3.pdf. For more on how personal receipt of goods or money by a public official is not a criminal offense unless directly correlated to the procurement of an official government act, see McDonnell v. United States, 579 U.S. 550 (June 27, 2016), available at https://www.law.cornell.edu/supct/pdf/15-474.pdf.
  6. Benedict Vigers, “Record High 89% in U.S. Say Government Corruption Widespread,” Gallup, September 2, 2026, available at https://news.gallup.com/poll/713933/record-high-say-government-corruption-widespread.aspx.
  7. Jacob Eisler, “Conceptualising Corruption and the Rule of Law,” The Modern Law Review 85 (4) (2022), available at https://ir.law.fsu.edu/cgi/viewcontent.cgi?article=1781&context=articles.
  8. Reilly Steel, “Systematic Corruption,” Columbia Law Review (forthcoming), available at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=6293758.
  9. Ibid.
  10. Ibid.
  11. Ibid.
  12. Ibid. For more on limiting Congress’ ability to protect lesser executive officers from removal by the president except in cases of inefficiency, neglect, or malfeasance, see Seila Law LLC v. Consumer Financial Protection Bureau, 591 U.S. 197 (June 29, 2020), available at https://www.supremecourt.gov/opinions/19pdf/19-7_n6io.pdf. For more on eliminating congressionally enacted protections from removal for independent agency commissioners, see Trump v. Slaughter, 609 U.S. __ (June 29, 2026), available at https://supreme.justia.com/cases/federal/us/609/25-332/. For more on prohibiting bans on unlimited independent corporate political spending so long as it did not go directly to candidates or parties, see Citizens United v. Federal Election Commission, 558 U.S. 310 (January 21, 2010), available at https://supreme.justia.com/cases/federal/us/558/310/. For more on applying Citizens United to permit anonymous, unlimited political spending, giving rise to super PACs and what is now known as “dark money” political expenditures, see SpeechNow.org v. Federal Election Commission, appeal, U.S. Court of Appeals for the District of Columbia Circuit, 599 F.3d 686 (March 26, 2010), available at https://law.justia.com/cases/federal/appellate-courts/cadc/08-5223/08-5223-1236837-2011-03-24.html.
  13. Steel, “Systematic Corruption.”
  14. See Joshua L. Kalla and David E. Broockman, “Evidence That Legislators Grant Special Access to Donors” (Boston: Scholars Strategy Network, 2016), available at https://scholars.org/contribution/evidence-legislators-grant-special-access; Pranav Goel and others, “Donor activity is associated with US legislators’ attention to political issues,” PLoS One 18 (9) (2023): e0291169, available at https://pmc.ncbi.nlm.nih.gov/articles/PMC10511130/.
  15. These totals are calculated through tallying the information set forth below.
  16. Ibid.
  17. This total includes the purchase of WLFI tokens by Justin Sun but does not include any revenues garnered through business dealings with Binance.
  18. Amin Ayan, Cryptonews, “SEC Drops Nearly 60% of Crypto Cases Under Trump Administration: Report,” Yahoo Finance, December 16, 2025, available at https://finance.yahoo.com/news/sec-drops-nearly-60-crypto-064316054.html. See also, Rick Claypool, “Trump’s Cascade of Canceled Corporate Enforcement” (Washington: Public Citizen, 2026), available at https://www.citizen.org/wp-content/uploads/canceled-enforcement-200-corporations-trump-october-2026.pdf.
  19. Devlin Barrett, “Justice Dept. Disbands Cryptocurrency Enforcement Unit,” The New York Times, April 8, 2025, available at https://www.nytimes.com/2025/04/08/us/politics/doj-disbands-crypto-unit.html; U.S. Deputy Attorney General Todd Blanche, “Ending Regulation by Prosecution,” U.S. Department of Justice, April 7, 2025, available at https://www.justice.gov/dag/media/1395781/dl?inline.
  20. Akshay S. Ralhi, “Beyond Enforcement: The SEC’s Shifting Playbook on Crypto Regulation,” Georgetown Law Center on Transnational Business and the Law, May 9, 2025, available at https://www.law.georgetown.edu/ctbl/blog/beyond-enforcement-the-secs-shifting-playbook-on-crypto-regulation/.
  21. U.S. Department of Justice, “Binance and CEO Plead Guilty to Federal Charges in $4B Resolution,” Press release, November 21, 2023, available at https://www.justice.gov/archives/opa/pr/binance-and-ceo-plead-guilty-federal-charges-4b-resolution; U.S. Securities and Exchange Commission, “SEC Charges Decentralized Finance Lender and Top Executives for Raising $30 Million Through Fraudulent Offerings,” Press release, August 6, 2021, available at https://www.sec.gov/newsroom/press-releases/2021-145.
  22. The authors recognize that this is an average based on the total in fine accrued against the number of cases concluded or settled and is not indicative of any individual penalty levied against any one company.
  23. T.J. Pyzyk, “Crypto Surge: Trump’s SEC to Boost Industry and Bank Involvement,” Capstone, January 2, 2025, available at https://capstonedc.com/insights/crypto-2025-preview/.
  24. TRM Labs, “2025 Crypto Adoption and Stablecoin Usage Report” (San Francisco: 2025), available at https://www.trmlabs.com/reports-and-whitepapers/2025-crypto-adoption-and-stablecoin-usage-report.
  25. Rafael Nam, “Crypto soared in 2025 — and then crashed. Now what?”, NPR, January 1, 2026, available at https://www.npr.org/2026/01/01/nx-s1-5642654/trump-crypto-winter-bitcoin; CoinGecko, “Bitcoin Price,” available at https://www.coingecko.com/en/coins/bitcoin (last accessed October 2026).
  26. Brett Cruz and Gene Petrino, “2026 Cryptocurrency Adoption and Sentiment Report,” Security.org, September 17, 2026, available at https://www.security.org/digital-security/cryptocurrency-annual-consumer-report/.
  27. CoinGecko, “2025 Annual Crypto Industry Report,” May 2, 2026, available at https://www.coingecko.com/research/publications/2025-annual-crypto-report.
  28. Coin Edition, “SEC’s Regulatory Policy Shift: 12 Crypto Cases Dropped This Year,” April 16, 2025, available at https://coinedition.com/secs-regulatory-policy-shift-12-crypto-cases-dropped-this-year/.
  29. MacKenzie Sigalos, “SEC will keep $50 million of Ripple fine and refund the rest to wrap case, legal officer says,” CNBC, March 25, 2025, available at https://www.cnbc.com/2025/03/25/sec-will-keep-50-million-of-ripple-fine-and-refund-the-rest.html.
  30. Federal Election Commission, “Receipts: ‘Foris Dax, Inc.’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=FORIS+DAX+INC&contributor_name=Marszalek%2C+kris&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); Federal Election Commission, “Schedule 13-A Itemized Donations Accepted, Trump Vance Inaugural Committee, Inc., Transaction ID: F132.147748083,” January 2, 2025, available at https://docquery.fec.gov/cgi-bin/fecimg/?202508079789419531.
  31. Crypto.com, “SEC Closes Crypto.com Investigation with No Action,” Press release, March 27, 2025, available at https://crypto.com/en/company-news/sec-closes-crypto-com-investigation-with-no-action.
  32. Judd Legum, “Days after $5M donation, Trump administration backs Crypto.com in lawsuit,” Popular Information, February 23, 2026, available at https://popular.info/p/days-after-5m-donation-trump-administration.
  33. Ibid.
  34. Federal Election Commission, “Schedule 13-A Itemized Donations Accepted, Trump Vance Inaugural Committee, Inc., Filing FEC-1910509,” January 2, 2025, available at https://docquery.fec.gov/cgi-bin/forms/C00894162/1910509/f132; Jon Golinger, Eileen O’Grady, and Rick Claypool, “Ballroom Billions: Trump Ballroom Donors Devour Taxpayer Dollars,” Public Citizen, June 4, 2026, available at https://www.citizen.org/article/ballroom-billions/.
  35. Jonathan Stempel and Niket Nishant, “Ripple Labs says US SEC ends appeal over crypto oversight,” Reuters, March 19, 2025, available at https://www.reuters.com/legal/ripple-ceo-says-us-sec-will-drop-appeal-against-crypto-firm-2025-03-19/; Dan Ennis, “Ripple to pay $125M penalty in XRP case against SEC,” Banking Dive, August 8, 2024, available at https://www.bankingdive.com/news/ripple-xrp-125-million-penalty-sec-securities-ruling/723747/.
  36. Sigalos, “SEC will keep $50 million of Ripple fine and refund the rest to wrap case, legal officer says”; Dan Ennis, “Judge denies move to reduce Ripple’s penalty in SEC case,” Banking Dive, May 16, 2025, available at https://www.bankingdive.com/news/ripple-sec-motion-reduce-penalty-denied-analisa-torres-alderoty/748360/; Securities and Exchange Commission v. Ripple Labs Inc., order, U.S. District Court for the Southern District of New York, 1:20-cv-10832 (May 15, 2025), available at https://www.courtlistener.com/docket/19857399/984/securities-and-exchange-commission-v-ripple-labs-inc/.
  37. Federal Election Commission, “Receipts: ‘Winklevoss, Tyler’ and ‘Winklevoss, Cameron’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00892471&committee_id=C00825851&committee_id=C00762591&committee_id=C00828541&committee_id=C00867036&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00891549&contributor_name=WINKLEVOSS%2C+TYLER&contributor_name=WINKLEVOSS%2C+CAMERON&two_year_transaction_period=2024&two_year_transaction_period=2026 (last accessed October 2026); Sharon LaFraniere, “How the Winklevoss Twins Won Big in Trump’s Pro-Crypto Washington,” The New York Times, December 15, 2025, available at https://www.nytimes.com/2025/12/15/us/politics/trump-crypto-winklevoss.html?ref=levernews.com.
  38. Ben Protess and Sharon LaFraniere, “S.E.C. Drops Case Against Cryptocurrency Firm Founded by Winklevoss Twins,” The New York Times, January 23, 2026, available at https://www.nytimes.com/2026/01/23/us/politics/sec-crypto-winklevoss.html; Securities and Exchange Commission v. Gemini Inc., joint stipulation to dismiss and releases, U.S. District Court for the Southern District of New York, No. 1:23-cv-287 (January 23, 2026), available at https://www.sec.gov/files/litigation/litreleases/2026/joint26465.pdf.
  39. Adam Cancryn, “US regulator tries to withdraw penalty against Trump donors’ crypto company,” CNN, May 28, 2026, available at https://www.cnn.com/2026/05/28/politics/winklevoss-trump-donor-penalty; Commodity Futures Trading Commission, “CFTC Joins Gemini Trust Company LLC in Motion for Relief from Judgment,” Press release, May 27, 2026, available at https://www.cftc.gov/PressRoom/PressReleases/9236-26; Mike Scarcella, “Judge rejects CFTC, Gemini bid to vacate $5 million settlement,” Reuters, October 16, 2026, available at https://www.reuters.com/business/judge-rejects-cftc-gemini-bid-vacate-5-million-settlement-2026-10-16/.
  40. Federal Election Commission, “Schedule A Itemized Receipts, MAGA Inc.,” available at https://docquery.fec.gov/cgi-bin/forms/C00892471/2000587/sa/ALL (last accessed September 2026).
  41. Liam “Akiba” Wright, “Winklevoss twins gave Trump’s super PAC $10 million 23 days after CFTC joined Gemini relief bid,” CryptoSlate, July 21, 2026, available at https://cryptoslate.com/winklevoss-twins-gave-trumps-super-pac-10-million-23-days-after-cftc-joined-gemini-relief-bid/; Freddy Brewster and Katya Schwenk, The Lever, “Crypto Investor Twins Gave MAGA Inc. PAC $10 Million After Regulatory Win,” Truthout, July 23, 2026, available at https://truthout.org/articles/crypto-investor-twins-gave-maga-inc-pac-10-million-after-regulatory-win/.
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  43. Ondo Finance, “Trump-Backed World Liberty Financial Collaborates with Ondo Finance to Advance Adoption of Tokenized Real-World Assets,” Press release, February 12, 2025, available at https://ondo.finance/blog/world-liberty-financial-ondo.
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  46. U.S. Securities and Exchange Commission, “SEC Charges Kraken for Operating as an Unregistered Securities Exchange, Broker, Dealer, and Clearing Agency,” Press release, November 20, 2023, available at https://www.sec.gov/newsroom/press-releases/2023-237; Securities and Exchange Commission v. Payward Inc., complaint, U.S. District Court for the Northern District of California, No. 3:23-civ-6003 (November 20, 2023), available at https://www.sec.gov/files/litigation/complaints/2023/comp-pr2023-237.pdf; Securities and Exchange Commission v. Payward Inc., joint stipulation to dismiss and releases, U.S. District Court for the Northern District of California, No. 3:23-civ-6003 (March 27, 2025), available at https://www.sec.gov/files/litigation/litreleases/2025/lr-26278-joint-stipulation.pdf; Mehab Qureshi, The Street, “SEC officially drops cases against Kraken, Consensys, and Cumberland,” Yahoo Finance, March 27, 2025, available at https://finance.yahoo.com/news/sec-officially-drops-cases-against-223036788.html.
  47. Securities and Exchange Commission v. Payward Inc., complaint.
  48. Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 61; Jonathan O’Connell, Sarah Blaskey, and Aaron Schaffer, “Secret documents reveal donors behind $330 million for Trump’s ballroom,” The Washington Post, October 15, 2026, available at https://www.washingtonpost.com/investigations/2026/10/15/secret-documents-reveal-donors-behind-330-million-trumps-ballroom/.
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  51. Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 99.
  52. U.S. Securities and Exchange Commission, “Two Robinhood Broker-Dealers to Pay $45 Million in Combined Penalties for Violating More than 10 Separate Securities Law Provisions,” January 13, 2025, available at https://www.sec.gov/newsroom/press-releases/2025-5.
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  61. Ibid.
  62. Zeke Faux, Muyao Shen, and Anthony Cormier, “Binance Aided Trump Crypto Firm Before Founder CZ Sought Pardon,” Bloomberg, July 11, 2025, available at https://www.bloomberg.com/news/features/2025-07-11/trump-s-crypto-link-with-binance-raises-conflict-of-interest-questions.
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  64. Crystal Kim, “President Trump Pardons Binance Founder. Which Tokens are Getting a Lift?”, Investopedia, October 23, 2025, available at https://finance.yahoo.com/news/president-trump-pardons-binance-founder-200140535.html.
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  70. Ibid.; Brian C. Prest, “If/Then: New Cuts to Oil and Gas Royalty Rates in Budget Reconciliation Will Reduce Federal Revenues,” Resources for the Future, May 9, 2025, available at https://www.resources.org/common-resources/if-then-new-cuts-to-oil-and-gas-royalty-rates-in-budget-reconciliation-will-reduce-federal-revenues/.
  71. Spencer Kimball, “Trump megabill gives the oil industry everything it wanted and ends key support for solar and wind,” CNBC, July 3, 2025, available at https://www.cnbc.com/2025/07/03/trump-one-big-beautiful-bill-oil-gas-coal-solar-wind-ira-tax-incentive-repeal.html.
  72. Taxpayers for Common Sense, “Big Beautiful Bill Delays Commonsense Fee on Wasted Methane,” July 14, 2025, available at https://www.taxpayer.net/energy-natural-resources/big-beautiful-bill-delays-commonsense-fee-on-wasted-methane/.
  73. Federal Election Commission, “Receipts: ‘Warren, Kelcy L.’ and ‘Energy Transfer LP’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00891549&committee_id=C00892471&contributor_name=WARREN,+KELCY&contributor_name=WARREN,+KELCY+L&contributor_name=ENERGY+TRANSFER+LP&contributor_name=WARREN,+KELCY+L.+MR.&contributor_name=ENERGY+PARTNERS+LP&contributor_name=LE+GP+LLC&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026).
  74. Dhana Noor, “Trump promised riches from ‘liquid gold’ in the US. Now fossil fuel donors are benefiting,” The Guardian, June 18, 2025, available at https://www.theguardian.com/us-news/2025/jun/18/trump-oil-gas-industry-donors.
  75. Owen Bacskai, “Fossil Fuel Industry Donors See Major Returns in Trump’s Policies,” Brennan Center for Justice, September 15, 2025, available at https://www.brennancenter.org/our-work/analysis-opinion/fossil-fuel-industry-donors-see-major-returns-trumps-policies; Forbes, “Profile: Kelcy Warren,” available at https://www.forbes.com/profile/kelcy-warren/ (last accessed October 2026).
  76. Federal Election Commission, “Receipts: ‘Hess, John’ and ‘Hess, Susan’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=Hess%2C+john&contributor_name=hess+susan&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed October 2026).
  77. Federal Trade Commission, “FTC Reopens and Sets Aside Chevron-Hess Final Order,” Press release, July 17, 2025, available at https://www.ftc.gov/news-events/news/press-releases/2025/07/ftc-reopens-sets-aside-chevron-hess-final-order.
  78. Ibid.
  79. Federal Election Commission, “Receipts: ‘Cranberg, Alex M’ and ‘Cranberg, Cathy’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=aspect+holdings&contributor_name=cranberg%2C+alex&contributor_name=cranberg%2C+cath&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026).
  80. U.S. Department of Energy, “Secretary of Energy Chris Wright Announces Newly Appointed Members of the Secretary of Energy Advisory Board,” Press release, July 9, 2026, available at https://www.energy.gov/articles/secretary-energy-chris-wright-announces-newly-appointed-members-secretary-energy-advisory; National Conservatism Conference, “Alex Cranberg,” available at https://nationalconservatism.org/natcon-5-2025/presenters/alex-cranberg/ (last accessed September 2026).
  81. Federal Election Commission, “Receipts: ‘Campbell, Cody’ and ‘Campbell, Tara’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00892471&committee_id=C00825851&committee_id=C00762591&committee_id=C00828541&committee_id=C00867036&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00891549&contributor_name=CAMPBELL%2C+CODY&contributor_name=CAMPBELL%2C+TARA&two_year_transaction_period=2024&two_year_transaction_period=2026 (last accessed September 2026).
  82. U.S. Department of Energy, “Secretary of Energy Chris Wright Announces Newly Appointed Members of the Secretary of Energy Advisory Board.”
  83. Federal Election Commission, “Receipts: ‘Hamm, Harold G.’ and ‘Continental Resources’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=hamm%2C+harold&contributor_name=continental+resources&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026).
  84. Monica Alba and Amanda Terkel, “Here’s the list of donors paying for Trump’s new White House ballroom,” NBC News, October 23, 2025, available at https://www.nbcnews.com/politics/white-house/list-donors-trump-new-white-house-ballroom-east-wing-rcna239481.
  85. Revolving Door Project, “Oligarchs and the Trump Administration: Harold Hamm,” April 21, 2025, available at https://therevolvingdoorproject.org/harold-hamm-trump-billionaires-and-the-admin/. Hamm also donated $250,000 to Secretary Burgum’s Best of America PAC and $50 million to the Theodore Roosevelt Presidential Library; in addition, Continental Resources has a deal to drill on Burgum-owned land and pay Burgum royalties. See also, Eric Lipton and Rebecca F. Elliott, “The Oilman Who Pushed Trump to Go All In on Fossil Fuels,” The New York Times, December 12, 2025, available at https://www.nytimes.com/2025/12/12/business/energy-environment/trump-harold-hamm-oil-gas.html; Jimmy Tobias and Julia Kane, “Emails show Interior delivered new drilling permits for Burgum’s billionaire ally,” High Country News, May 7, 2026, available at https://www.hcn.org/articles/emails-show-interior-delivered-new-drilling-permits-for-burgums-billionaire-ally/.
  86. Ibid.
  87. Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc.,” Form 13.
  88. Evan Halper, “$900 million from a cancelled wind deal will benefit a Trump donor,” The Washington Post, August 27, 2026, available at https://www.washingtonpost.com/business/2026/08/27/how-wind-projects-got-replaced-by-900-million-payday-trump-donors-firm/.
  89. Ibid.
  90. Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 62; ConocoPhillips Alaska, “Committed to Alaska for More than 50 Years,” available at https://alaska.conocophillips.com (last accessed September 2026); Executive Office of the President, “Executive Order 14153: Unleashing Alaska’s Extraordinary Resource Potential,” January 20, 2025, available at https://www.federalregister.gov/documents/2025/01/29/2025-01955/unleashing-alaskas-extraordinary-resource-potential.
  91. Ian M. Stevenson, “Interior plans fast track for oil exploration in Alaska’s North Slope,” E&E News, August 27, 2026, available at https://www.eenews.net/articles/interior-plans-fast-track-for-oil-exploration-in-alaskas-north-slope/.
  92. Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 57.
  93. Daniel Barnes, “New disclosures reveal $9M in corporate donations to Trump’s Freedom 250,” Politico, July 31, 2026, available at https://www.politico.com/news/2026/07/31/disclosures-corporate-donations-trump-freedom250-01020551.
  94. Zacks Equity Research, “Chevron Bets on Venezuela Oil to Unlock Up to $700M in Cash Flow,” Finviz, January 12, 2026, available at https://finviz.com/news/273921/chevron-bets-on-venezuela-oil-to-unlock-up-to-700m-in-cash-flow.
  95. Ibid.; Office of the Advocate for Small Business Capital Formation, “What is a statement of cash flows?”, available at https://www.sec.gov/files/cash-flow-statement-bblocks.pdf (last accessed October 2026).
  96. Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 86.
  97. Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 203; Corbin Hiar, “Trump reshaped a climate program to extract more oil. This company stands to profit.,” E&E News, August 4, 2025, available at https://www.eenews.net/articles/trump-reshaped-a-climate-program-to-extract-more-oil-this-company-stands-to-profit/.
  98. James Osborne, “Texas oil companies forecast billions in tax breaks from Trump’s ‘Big Beautiful Bill’,” Houston Chronicle, September 5, 2025, available at https://www.houstonchronicle.com/politics/texas/article/oil-companies-taxes-trump-21029196.php.
  99. Valerie Volcovici, “US Energy Department restores funding to carbon removal projects,” Reuters, April 17, 2026, available at https://www.reuters.com/legal/litigation/us-energy-department-restores-funding-carbon-removal-projects-2026-04-17/.
  100. Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 300; Executive Office of the President, “Executive Order 14154: Unleashing American Energy,” January 20, 2025, available at https://www.govinfo.gov/content/pkg/DCPD-202500121/pdf/DCPD-202500121.pdf; U.S. Department of Energy, “U.S. Department of Energy Reverses Biden LNG Pause, Restores Trump Energy Dominance Agenda,” January 20, 2025, available at https://www.energy.gov/articles/us-department-energy-reverses-biden-lng-pause-restores-trump-energy-dominance-agenda.
  101. Andy Rowell and Nina Lakhani, “Fossil-fuel billionaires bought up millions of shares after meeting with top Trump officials,” The Guardian, December 4, 2025, available at https://www.theguardian.com/business/2025/dec/04/venture-global-shares.
  102. Ibid.
  103. Yahoo Finance, “Venture Global, Inc. (VG),” available at https://finance.yahoo.com/quote/VG/ (last accessed September 2026).
  104. Rowell and Lakhani, “Fossil-fuel billionaires bought up millions of shares after meeting with top Trump officials.”
  105. Federal Election Commission, “Receipts: ‘Addison, John, C.’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00618371&committee_id=C00825851&committee_id=C00867937&committee_id=C00883520&committee_id=C00892471&contributor_name=Addison%2C+J&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026).
  106. Matthew Olay, “Trump Announces U.S. Military’s Capture of Maduro,” U.S. Department of Defense, January 3, 2026, available at https://www.war.gov/News/News-Stories/Article/Article/4370431/trump-announces-us-militarys-capture-of-maduro/; Anatoly Kurmanaev, “U.S. Races to Sell Venezuelan Oil, Transforming Ties With Former Foe,” The New York Times, January 14, 2026, available at https://www.nytimes.com/2026/01/14/world/americas/venezuela-oil-us-deal.html; Jake Johnson, Common Dreams, “First US Sale of Seized Venezuelan Oil Goes to Company of Trump Megadonor,” Truthout, January 19, 2026, available at https://truthout.org/articles/first-us-sale-of-seized-venezuelan-oil-goes-to-company-of-trump-megadonor/.
  107. The other half of the $500 million deal went to Trafigura. See Kurmanaev, “U.S. Races to Sell Venezuelan Oil, Transforming Ties With Former Foe”; Johnson, Common Dreams, “First US Sale of Seized Venezuelan Oil Goes to Company of Trump Megadonor”; Shariq Khan, “Vitol Trader Addison, architect of U.S.-Venezuela export deal set to retire, sources say,” Reuters, March 31, 2026, available at https://www.reuters.com/business/energy/vitol-trader-addison-architect-us-venezuela-export-deal-set-retire-sources-say-2026-03-31/.
  108. Khan, “Vitol Trader Addison, architect of U.S.-Venezuela export deal set to retire, sources say”; U.S. Department of Energy, “Secretary of Energy Chris Wright Announces Newly Appointed Members of the Secretary of Energy Advisory Board.”
  109. Federal Election Commission, “Receipts: ‘Lutnick, Howard W.’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00892471&committee_id=C00825851&committee_id=C00762591&committee_id=C00828541&committee_id=C00867036&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00891549&contributor_name=LUTNICK%2C+BRANDON+G&contributor_name=LUTNICK%2C+HOWARD+W&two_year_transaction_period=2024&two_year_transaction_period=2026 (last accessed September 2026); Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 45.
  110. Tim Balk, “A President Using Super Glue and Irked About Epstein: Takeaways From a New Trump Book,” The New York Times, June 18, 2026, available at https://www.nytimes.com/2026/06/18/us/politics/trump-regime-change-book-haberman-swan.html.
  111. Sonne and Lipton, “Trump Cut a Billion-Dollar Mining Deal. His Sons Stand to Profit.”
  112. Ibid.
  113. Anthony Cormier, David Kocieniewski, and Annie Massa, “How Tether Benefited as Trump Insiders Shaped First US Crypto Law,” Bloomberg, July 22, 2026, available at https://www.bloomberg.com/features/2026-howard-lutnick-bo-hines-trump-tether-crypto-law/; Spencer Woodman, “The $200 billion company you can’t look inside,” International Consortium of Investigative Journalists, August 7, 2026, available at https://www.icij.org/investigations/coin-laundry/the-200-billion-company-you-cant-look-inside/; Angus Berwick, “Cantor Fitzgerald Holds Tether Convertible Bond, Howard Lutnick Says,” The Wall Street Journal, January 29, 2025, available at https://www.wsj.com/livecoverage/fed-interest-rate-tesla-meta-earnings-01-29-2025/card/sen-warren-presses-howard-lutnick-on-tether-ties-before-confirmation-hearing-cEvRGcskZwmj7N8FuOjk?eafs_enabled=false.
  114. Federal Election Commission, “Receipts: ‘McMahon, Linda E.’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00892471&committee_id=C00825851&committee_id=C00762591&committee_id=C00828541&committee_id=C00867036&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00891549&contributor_name=MCMAHON%2C+LINDA+E&contributor_name=MCMAHON%2C+LINDA&two_year_transaction_period=2024&two_year_transaction_period=2026 (last accessed September 2026); Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 186.
  115. Ali Schalop, “The Plan to Abolish the Education Department—One Year Later,” NEA Today, March 20, 2026, available at https://www.nea.org/nea-today/all-news-articles/plan-abolish-education-department-one-year-later.
  116. Federal Election Commission, “Receipts: ‘Sokolov, Konstantin’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=sokolov%2C+k&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); Kate Brown, “A Trump ballroom donor will lead state department’s $200m Armenia fund,” The Guardian, July 14, 2026, available at https://www.theguardian.com/us-news/2026/jul/14/trump-ballroom-donor-central-asia-tripp.
  117. Ibid.
  118. Josh Kovensky, “A Ballroom Donor, a Sanctions Waiver, $201 Million in Public Money: The Mystery of Konstantin Sokolov,” Talking Points Memo, October 13, 2026, available at https://talkingpointsmemo.com/news/a-ballroom-donor-a-sanctions-waiver-201-million-in-public-money-the-mystery-of-konstantin-sokolov.
  119. Brown, “A Trump ballroom donor will lead state department’s $200m Armenia fund.”
  120. Haaretz, “U.S. Envoy Steve Witkoff’s Son Attempts to Raise Billions from Israel-Hamas Cease-Fire Mediator Qatar, Report Says,” September 27, 2025, available at https://www.haaretz.com/israel-news/2025-09-27/ty-article/report-witkoffs-son-attempts-to-raise-billions-from-israel-hamas-mediator-qatar/00000199-8a12-daea-adff-bff3c9e70000.
  121. Debra Kamin and Bradley Hope, “Where Mideast Envoy Pitched Peace, His Son Pitched Investors,” The New York Times, September 26, 2025, available at https://www.nytimes.com/2025/09/26/business/witkoff-son-qatar-gaza.html.
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  123. Neda Ulaby, “New Board Elects President Trump as Chair of the Kennedy Center,” NPR, February 12, 2025, available at https://www.npr.org/2025/02/12/nx-s1-5294697/trump-kennedy-center-chairman.
  124. Federal Election Commission, “Receipts: ‘Duggan, Patricia J.’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00770941&committee_id=C00825851&committee_id=C00867937&committee_id=C00883520&committee_id=C00892471&contributor_name=duggan%2C+patricia&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); Ulaby, “New Board Elects President Trump as Chair of the Kennedy Center.”
  125. Federal Election Commission, “Receipts: ‘Lobel, Joshua Adam’ and ‘Lobel, Michelle’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00770941&committee_id=C00825851&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=lobel%2C+josh&contributor_name=lobel%2C+michelle&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); NTD Newsroom, “Trump Names New Members of President’s Intelligence Advisory Board,” February 11, 2025, available at https://www.ntd.com/trump-names-new-members-of-presidents-intelligence-advisory-board_1047038.html.
  126. Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 143, available at https://docquery.fec.gov/pdf/295/202508079789419295/202508079789419295.pdf.
  127. Mike Wall, “Trump explains why he pulled Jared Isaacman’s nomination for NASA chief,” Space.com, July 8, 2025, available at https://www.space.com/space-exploration/trump-explains-why-he-pulled-jared-isaacmans-nomination-for-nasa-chief.
  128. Federal Election Commission, “Receipts: ‘Isaacman, Jared’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=isaacman%2C+jared&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026).
  129. Federal Election Commission, “Receipts: ‘MacNeil, David’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867937&committee_id=C00883520&committee_id=C00888172&committee_id=C00892471&contributor_name=macneil%2C+david&contributor_name=weathertech&max_date=12%2F31%2F2026 (last accessed September 2026); Monica Hunter-Hart, “WeatherTech Founder and Trump’s Federal Trade Commission Pick Is Worth Over $4 Billion,” Forbes, January 21, 2026, available at https://www.forbes.com/sites/monicahunter-hart/2026/01/21/meet-trumps-new-ftc-pick-one-of-americas-richest-entrepreneurs/.
  130. Federal Election Commission, “Receipts: ‘Loeffler, Kelly’ and ‘Sprecher, Jeffrey C.’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00892471&committee_id=C00825851&committee_id=C00762591&committee_id=C00828541&committee_id=C00867036&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00891549&contributor_name=LOEFFLER%2C+KELLY&contributor_name=SPRECHER%2C+JEFFREY+CRAIG&contributor_name=SPRECHER%2C+JEFFREY+C.&contributor_name=SPRECHER%2C+JEFFERY+CRAIG&two_year_transaction_period=2024&two_year_transaction_period=2026 (last accessed October 2026); Federal Election Commission, “Schedule 13-A Itemized Donations Accepted, Trump Vance Inaugural Committee, Inc., Filing FEC-1910509”; Karen Yourish, Kenneth P. Vogel, and Charlie Smart, “Hundreds of Big Post-Election Donors Have Benefited From Trump’s Return to Office,” The New York Times, December 22, 2025, available at https://nytimes.com/interactive/2025/12/22/us/politics/trump-donors-fundraising-benefits.html.
  131. Kanishka Singh, “White House crypto adviser Bo Hines announces departure,” Reuters, August 9, 2025, available at https://www.reuters.com/world/us/white-house-crypto-adviser-bo-hines-announces-departure-2025-08-09/.
  132. Ibid.; Leo Schwartz and Ben Weiss, Fortune, “Tether hires Trump’s top crypto official Bo Hines to help lead U.S. stablecoin expansion,” Yahoo Finance, August 19, 2025, available at https://finance.yahoo.com/news/tether-hires-trump-top-crypto-103000538.html; Angus Berwick, “Cantor Fitzgerald Holds Tether Convertible Bond, Howard Lutnick Says,” The Wall Street Journal, January 29, 2025, available at https://www.wsj.com/livecoverage/fed-interest-rate-tesla-meta-earnings-01-29-2025/card/sen-warren-presses-howard-lutnick-on-tether-ties-before-confirmation-hearing-cEvRGcskZwmj7N8FuOjk?eafs_enabled=false.
  133. Roger G. Wieand and Delaney Marsco, “The Donor-To-Ambassador Pipeline: Why America’s Key Diplomats Are Often Wealthy Political Donors” (Washington: Campaign Legal Center, 2023), available at https://campaignlegal.org/sites/default/files/2023-05/DTA_Report_Final.pdf.
  134. American Foreign Service Association, “Appointments – Donald J. Trump (2nd Term),” available at https://afsa.org/appointments-donald-j-trump-2nd-term (last accessed October 2026); American Foreign Service Association, “Appointments – Joseph R. Biden,” available at https://www.afsa.org/appointments-joseph-r-biden (last accessed October 2026); Taylor, Mahajan, and Ye, “Under Trump, 90% of ambassador nominations have gone to political supporters,” The Washington Post, August 6, 2026, available at https://www.washingtonpost.com/national-security/2026/08/06/trump-fills-ambassador-posts-with-more-donors-loyalists-than-any-recent-president/.
  135. Federal Election Commission, “Receipts: ‘Stephens, Warren A.’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=stephens%2C+warren&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); Federal Election Commission, “Report of Donations Accepted, Trump Vance Inaugural Committee, Inc., Form 13,” p. 268.
  136. Federal Election Commission, “Receipts: ‘Fertitta, Tilman’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=fertitta%2C+tilman&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 90.
  137. Federal Election Commission, “Receipts: ‘Kushner, Charles’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=Kushner%2C+Charles&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); Amita Kelly, Ryan Lucas, and Vanessa Romo, “Trump Pardons Roger Stone, Paul Manafort and Charles Kushner,” NPR, December 23, 2020, available at https://www.npr.org/2020/12/23/949820820/trump-pardons-roger-stone-paul-manafort-and-charles-kushner.
  138. Federal Election Commission, “Receipts: ‘Leon, Benjamin Jr.’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00891549&committee_id=C00892471&contributor_name=leon%2C+benjamin&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); C.A. Bridges, USA Today, “Benjamín León Jr., Trump’s pick for ambassador to Spain, has Marion County connections,” Yahoo Finance, January 4, 2025, available at https://www.yahoo.com/news/benjam-n-le-n-jr-161149683.html.
  139. Federal Election Commission, “Receipts: ‘Popolo, Joseph, Victor, Jr.’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=popolo%2C+joseph&two_year_transaction_period=2026&two_year_transaction_period=2024; Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 224.
  140. Federal Election Commission, “Receipts: ‘Hildebrand, Melinda’ and ‘Hildebrand, Jeffery’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=hildebrand%2C+jeffrey&contributor_name=hildebrand%2C+melinda&two_year_transaction_period=2026&two_year_transaction_period=2024; Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 15.
  141. Federal Election Commission, “Receipts: ‘Brodie, Elizabeth W.,’ ‘Brodie, Howard W.,’ and ‘Brodie, Stefan E.’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00825851&committee_id=C00828541&committee_id=C00867937&committee_id=C00883520&committee_id=C00888172&committee_id=C00892471&contributor_name=brodie%2C+elizabeth&contributor_name=brodie%2C+howard&contributor_name=brodie%2C+stefan&max_date=12%2F31%2F2026 (last accessed September 2026); Yourish, Vogel, and Smart, “Hundreds of Big Post-Election Donors Have Benefited From Trump’s Return to Office.”
  142. Federal Election Commission, “Receipts, ‘Sinha, Anjani’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00883520&committee_id=C00888172&committee_id=C00892471&contributor_name=Sinha%2C+Anjani&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed October 2026); Tom Latchem, “Trump’s ‘Unqualified’ Friend Humiliated During Senate Confirmation to Key Ambassador Post,” The Daily Beast, July 10, 2025, available at https://www.thedailybeast.com/trumps-unqualified-friend-anjani-sinha-humiliated-during-senate-confirmation-to-key-ambassador-post/. For Sen. Lindsey Graham’s statement, see Senate Committee on Foreign Relations, “Nominations” (Washington: 2025), available at https://www.foreign.senate.gov/download/07-09-25-nominations__sinha-bartos-blanchard-guilfoyle-locettapdf.
  143. Alexandra Stevenson, River Akira Davis, and Kenneth P. Vogel, “Like Trump, U.S. Embassies Are Raising Cash for Lavish July Fourth Parties,” The New York Times, February 15, 2026, available at https://www.nytimes.com/2026/02/15/business/trump-july-fourth-singapore-japan.html.
  144. Taylor, Mahajan, and Ye, “Under Trump, 90% of ambassador nominations have gone to political supporters.”
  145. Yourish, Vogel, and Smart, “Hundreds of Big Post-Election Donors Have Benefited From Trump’s Return to Office”; Benworth Capital Partners, “Bernie Navarro,” available at https://benworthcapital.com/wp-content/uploads/2025/03/Bernie-Navarro-Bio-2025.pdf (last accessed October 2026).
  146. Congressional Record—Senate 171 (202) (2025): S8478, available at https://www.congress.gov/119/crec/2025/12/03/171/202/CREC-2025-12-03-pt1-PgS8478.pdf.
  147. Federal Election Commission, “Receipts: ‘Argyros, Melissa’ and ‘Melissa Argyros Revocable Trust’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=argyros%2C+melissa&contributor_name=melissa+argyros+revocable+trust&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” pp. 125–126; U.S. Embassy in Latvia, “Ambassador Melissa Argyros,” available at https://lv.usembassy.gov/ambassador-melissa-argyros/ (last accessed October 2026).
  148. Federal Election Commission, “Receipts: ‘Landa, Benjamin’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=landa%2C+benjamin&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 160.
  149. Office of Inspector General, “Nearly All Skilled Nursing Services Provided by Pinnacle Multicare Nursing and Rehabilitation Center Did Not Meet Medicare Payment Requirements” (Washington: U.S. Department of Health and Human Services, 2025), available at https://oig.hhs.gov/reports/all/2025/nearly-all-skilled-nursing-services-provided-by-pinnacle-multicare-nursing-and-rehabilitation-center-did-not-meet-medicare-payment-requirements; Eli Cahan, “Nominee for Ambassador to Hungary Co-Owns a Nursing Home That’s Suing the Trump Administration Over Medicare Payments,” ProPublica, March 23, 2026, available at https://www.propublica.org/article/benjamin-landa-ambassador-company-lawsuit.
  150. Federal Election Commission, “Receipts: ‘Howery, Kenneth’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=howery%2C+ken&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 133.
  151. Federal Election Commission, “Receipts: ‘Newlin, Daniel J.’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=Newlin%2C+Dan&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 199.
  152. This amount does not include any benefits accrued to Gautam Adani, as he did not make payments directly to Trump-affiliated entities or projects, but rather provides an additional example of legal means by which the ultrawealthy may wield influence.
  153. Federal Election Commission, “Report of Donations Accepted, Trump Vance Inaugural Committee, Inc., Form 13,” p. 284.
  154. Toyota Motor Credit Corporation, consent order, Consumer Financial Protection Bureau, No. 2023-CFPB-0015 (November 20, 2023), available at https://files.consumerfinance.gov/f/documents/cfpb_toyota-motor-credit-corporation-consent-order_2023-11.pdf.
  155. Toyota Motor Credit Corporation, order terminating the consent order, Consumer Financial Protection Bureau, No. 2023-CFPB-0015 (May 12, 2025), available at https://files.consumerfinance.gov/f/documents/cfpb_toyota-motor-credit-corp_order-terminating-consent-order_2025-05.pdf.
  156. Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 284.
  157. Consumer Financial Protection Bureau v. Early Warning Services, LLC, complaint, U.S. District Court for the District of Arizona, No. 2:24-cv-03652-SMB (December 20, 2024), available at https://files.consumerfinance.gov/f/documents/cfpb_Zelle-Complaint_2024-12.pdf.
  158. Ibid.
  159. Ibid.
  160. Consumer Financial Protection Bureau v. Early Warning Services, LLC, order of dismissal with prejudice, No. 2:24-cv-03652-SMB (March 5, 2025), available at https://files.consumerfinance.gov/f/documents/cfpb_early-warning-order-dismissal-prejudice_2025-03.pdf.
  161. Consumer Financial Protection Bureau v. Early Warning Services, LLC, complaint.
  162. Consumer Financial Protection Bureau v. Early Warning Services, LLC, order of dismissal with prejudice.
  163. Federal Election Commission, “Report of Donations Accepted: Trump Vance Inaugural Committee, Inc., Form 13,” p. 315; Federal Election Commission, “Receipts: ‘Musk, Elon’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00883520&committee_id=C00891549&committee_id=C00892471&contributor_name=MUSK%2C+ELON&contributor_name=EUROPA+100+LLC&contributor_name=GROUP+AMERICA+LLC&contributor_name=UNITED+STATES+OF+AMERICA+INC&contributor_name=EXCESSION+LLC&contributor_name=ELON+MUSK+REVOCABLE+TRUST&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed October 2026).
  164. Permanent Subcommittee on Investigations Minority Staff, “Memorandum: Calculating Risk: Estimating the Legal Liability Elon Musk May Avoid Through His Government Takeover,” U.S. Senate Committee on Homeland Security and Governmental Affairs, April 27, 2025, available at https://www.hsgac.senate.gov/wp-content/uploads/2025-04-27-Minority-Staff-Memorandum-Elon-Musk-Conflicts.pdf.
  165. Ivana Saric, “DOJ moves to drop discrimination suit against Musk’s SpaceX,” Axios, February 21, 2025, available at https://www.axios.com/2025/02/21/doj-spacex-lawsuit-elon-musk-refugees-trump.
  166. Ana-Maria Stanciuc, “Judge approves Musk’s $1.5m SEC Twitter settlement despite ‘red flags’,” The Next Web, July 9, 2026, available at https://thenextweb.com/news/musk-sec-twitter-settlement-approved-red-flags.
  167. Julia Shapero, “Regulator closes investigation into Tesla ‘actually smart summon’ feature,” The Hill, April 6, 2026, available at https://thehill.com/policy/technology/5817880-nhtsa-tesla-smart-summon-investigation-closed/.
  168. Celine McNicholas and Margaret Poydock, “Corruption in plain sight,” Economic Policy Institute, May 8, 2025, available at https://www.epi.org/blog/corruption-in-plain-sight-how-elon-musk-has-benefited-from-the-first-100-days-of-the-trump-administration/.
  169. Molly Duerig, “FAA wants to let commercial space industry skirt 13 environmental laws,” The Miami Herald, August 24, 2026, available at https://www.miamiherald.com/news/local/environment/climate-change/article316991528.html.
  170. David McCabe, “U.S. Intercedes for Elon Musk’s X Over European Fine,” The New York Times, September 24, 2026, available at https://www.nytimes.com/2026/09/24/technology/us-x-elon-musk-europe-fine.html.
  171. Anu Raghunathan and Phisanu Phromchanya, “India’s Richest 2026,” Forbes, September 30, 2026, available at https://www.forbes.com/sites/anuraghunathan/2026/09/30/indias-100-richest-2026-tycoons-wealth-holds-firm-at-1-trillion-gautam-adani-reclaims-no1-spot/; Luc Cohen, “US judge dismisses criminal case against Indian billionaire Adani,” Reuters, August 10, 2026, available at https://www.reuters.com/legal/government/us-judge-dismisses-criminal-case-against-indian-billionaire-adani-2026-08-10/; United States v. Adani, indictment, U.S. District Court for the Eastern District of New York, No. 24-CR-433 (October 24, 2024), available at https://www.justice.gov/usao-edny/media/1377806/dl?inline.
  172. Siladitya Ray, “Trump Jr. Reportedly Met Indian Billionaire Adani Before DOJ Dropped Fraud Charges Against Him,” Forbes, June 23, 2026, available at https://www.forbes.com/sites/siladityaray/2026/06/23/trump-jr-reportedly-met-indian-billionaire-adani-before-doj-dropped-fraud-charges-against-him/.
  173. Luc Cohen, “US judge dismisses criminal case against Indian billionaire Adani,” Reuters, August 10, 2026, available at https://www.reuters.com/legal/government/us-judge-dismisses-criminal-case-against-indian-billionaire-adani-2026-08-10/.
  174. Ibid.
  175. Reuters, “Trump grants clemency to 30 people, White House pardon czar says,” September 4, 2026, available at https://www.reuters.com/world/us/trump-grants-clemency-30-people-white-house-pardon-czar-says-2026-09-05/; Katherine Pompilio, “The Jan. 6 Pardons: How Many Clemency Recipients Have Faced Other Charges?”, Lawfare, June 4, 2026, available at https://www.lawfaremedia.org/article/the-jan-6-pardons–how-many-clemency-recipients-have-faced-other-charges.
  176. Marisa Taylor and others, “How to get a Trump pardon: Forget the DOJ, call ‘Bobby’ and other influencers,” Reuters, June 11, 2026, available at https://www.reuters.com/investigations/forget-doj-trump-pardon-call-bobby-other-influencers-2026-06-11/.
  177. Marisa Taylor, Chris Prentice, and Mark Spector, “In Trump’s pardons for public officials, Republicans win most of the mercy,” Reuters, October 13, 2026, available at https://www.reuters.com/investigations/trumps-pardons-public-officials-republicans-win-most-mercy-2026-10-13/.
  178. Ibid.
  179. U.S. Department of Justice, “Owner of Florida Health Care Companies Sentenced for Employment Tax Crimes,” Press release, April 11, 2025, available at https://www.justice.gov/opa/pr/owner-florida-health-care-companies-sentenced-employment-tax-crimes.
  180. Ibid.
  181. Federal Election Commission, “Receipts: ‘Fago, Elizabeth’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=fago%2C+elizabeth&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026); Kenneth P. Vogel, “Trump Pardoned Tax Cheat After Mother Attended $1 Million Dinner,” The New York Times, May 27, 2025, available at https://www.nytimes.com/2025/05/27/us/politics/trump-pardon-paul-walczak-tax-crimes.html.
  182. Nick Viviani, “Trump pardons Palm Beach Gardens tax cheat days after sentencing,” CBS12 News, April 30, 2025, available at https://cbs12.com/news/crime/president-donald-trump-pardons-palm-beach-gardens-tax-cheat-days-after-sentencing-paul-walczak-irs-withholding-tax-palm-health-wednesday-april-30-2025.
  183. Federal Election Commission, “Receipts: ‘Herrera, Isabela’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=herrera%2C+isabela&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026).
  184. Colin Kalmbacher, “‘Corrupt bargain:’ Foreign billionaire used illegal ‘straw donor’ scheme to purchase pardon from Trump by donating to leading MAGA super PAC, federal complaint says,” Law & Crime, February 18, 2026, available at https://lawandcrime.com/high-profile/corrupt-bargain-foreign-billionaire-used-illegal-straw-donor-scheme-to-purchase-pardon-from-trump-by-donating-to-leading-maga-super-pac-federal-complaint-says/.
  185. Tyler Pager, “A Billionaire Wanted a Trump Pardon. His Family Gave Alina Habba a $50 Million Deal.,” The New York Times, October 20, 2026, available at https://www.nytimes.com/2026/10/20/us/politics/julio-herrera-pardon-alina-habba.html.
  186. NPR, “Abramoff Sentenced to Five Years in Fraud Case,” WUTC, March 29, 2006, available at https://www.wutc.org/2006-03-29/abramoff-sentenced-to-five-years-in-fraud-case.
  187. Federal Election Commission, “Receipts, ‘Kidan, Adam,’” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00883520&committee_id=C00891549&committee_id=C00892471&contributor_name=kidan%2C+adam&two_year_transaction_period=2026&two_year_transaction_period=2024; Empire Workforce Solutions, “Vision and Mission,” available at https://www.empirecommercialstaffing.com/about/ (last accessed October 2026).
  188. Chris Walker, “Trump Pardons Mega-Donor Days After Contribution to GOP Candidate,” Truthout, July 29, 2026, available at https://truthout.org/articles/trump-pardons-mega-donor-days-after-they-contributed-to-gop-candidate/.
  189. Federal Election Commission, “Receipts: ‘Milton, Trevor R,’ and ‘Milton, Chesley Virginia’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=worldquant&contributor_name=milton%2C+chelsey&contributor_name=milton%2C+trevor&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed September 2026).
  190. Cláudio Afonso, “Nikola Founder Trevor Milton Ordered to Pay $168 Million to Former Company,” EV, September 11, 2024, available at https://eletric-vehicles.com/nikola/nikola-founder-trevor-milton-ordered-to-pay-168-million-to-former-company/; Nicolas Roos, “Re: United States v. Trevor Milton, S1 21 Cr. 478 (ER),” U.S. Department of Justice, March 14, 2025, available at https://storage.courtlistener.com/recap/gov.uscourts.nysd.564174/gov.uscourts.nysd.564174.361.0.pdf.
  191. U.S. Department of Health and Human Services, “Medicare and Medicaid Programs; Repeal of Minimum Staffing Standards for Long-Term Care Facilities,” Federal Register 90 (230) (2025): 55687–55698, available at https://www.federalregister.gov/documents/2025/12/03/2025-21792/medicare-and-medicaid-programs-repeal-of-minimum-staffing-standards-for-long-term-care-facilities.
  192. Ibid.
  193. Federal Election Commission, “Receipts: ‘Madden Scott,’ ‘Burckhardt, Oliver,’ ‘Extremity Care, LLC,’ ‘Buco One, LLC,’ and ‘Collie Paw Holding LLC’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00892471&committee_id=C00825851&committee_id=C00762591&committee_id=C00828541&committee_id=C00867036&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00891549&contributor_name=EXTREMITY+CARE+LLC&contributor_name=BURKHARDT%2C+OLIVER&contributor_name=MADDEN%2C+SCOTT+ANDREW&contributor_name=BUCO+ONE%2C+LLC&contributor_name=BURCKHARDT%2C+OLIVER&contributor_name=COLLIE+PAW+HOLDING+LLC&contributor_name=MADDEN%2C+SCOTT&two_year_transaction_period=2024&two_year_transaction_period=2026 (last accessed October 2026); Kenneth P. Vogel, Sarah Kliff, and Katie Thomas, “Trump Delayed a Medicare Change After Health Company Donations,” The New York Times, August 7, 2025, available at https://www.nytimes.com/2025/08/07/us/politics/trump-medicare-bandages-donors.html.
  194. Judd Legum, “Days after $5 million donation to MAGA Inc., Trump freezes Medicare waste crackdown,” Popular Information, August 4, 2025, available at https://popular.info/p/days-after-5-million-donation-to.
  195. Vogel, Kliff, and Thomas, “Trump Delayed a Medicare Change After Health Company Donations”; Federal Election Commission, “Receipts: ‘Madden Scott,’ ‘Burckhardt, Oliver,’ ‘Extremity Care, LLC,’ ‘Buco One, LLC,’ and ‘Collie Paw Holding LLC’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00892471&committee_id=C00825851&committee_id=C00762591&committee_id=C00828541&committee_id=C00867036&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00891549&contributor_name=EXTREMITY+CARE+LLC&contributor_name=BURKHARDT%2C+OLIVER&contributor_name=MADDEN%2C+SCOTT+ANDREW&contributor_name=BUCO+ONE%2C+LLC&contributor_name=BURCKHARDT%2C+OLIVER&contributor_name=COLLIE+PAW+HOLDING+LLC&contributor_name=MADDEN%2C+SCOTT&two_year_transaction_period=2024&two_year_transaction_period=2026 (last accessed October 2026).
  196. Ibid.; Sarah Kliff and Katie Thomas, “Trump Administration Delays Plan to Limit Pricey Bandages,” The New York Times, April 11, 2025, available at https://www.nytimes.com/2025/04/11/health/skin-substitutes-medicare-policy-delay.html.
  197. Although the scheduled payment rate rule went into effect in January 2026, the local coverage determination rule that would have established more uniform coverage criteria for how skin substitutes are covered was ultimately withdrawn in December 2025. See Nick Hut, “Medicare skin substitute reimbursement changes have raised provider risks,” Healthcare Financial Management Association, July 13, 2026, available at https://www.hfma.org/payment-reimbursement-and-managed-care/medicare-skin-substitute-reimbursement/; Centers for Medicare and Medicaid Services, “Final Local Coverage Determinations (LCDs) for Certain Skin Substitutes Withdrawn,” December 24, 2025, available at https://www.cms.gov/newsroom/fact-sheets/upcoming-update-final-local-coverage-determinations-lcds-certain-skin-substitutes.
  198. Kenneth P. Vogel and Christina Jewett, “After Donations, Trump Administration Revoked Rule Requiring More Nursing Home Staff,” The New York Times, January 27, 2026, available at https://www.nytimes.com/2026/01/27/us/politics/after-donations-trump-administration-revoked-rule-requiring-more-nursing-home-staff.html?smid=nytcore-ios-share.
  199. Ibid.
  200. Ibid.; U.S. Department of Health and Human Services, “Medicare and Medicaid Program; Repeal of Minimum Staffing Standards for Long-Term Care Facilities.”
  201. Joseph Choi and Nathaniel Weixel, “FDA drops guardrails on vaping industry in major Trump pivot,” The Hill, May 18, 2026, available at http://thehill.com/policy/healthcare/5880802-flavored-vapes-fda-guidance/; Federal Election Commission, “Receipts: ‘RAI Services Company’,” available at https://www.fec.gov/data/receipts/?data_type=processed&contributor_name=rai+services+company&two_year_transaction_period=2024&min_date=01%2F01%2F2023&max_date=12%2F31%2F2024 (last accessed October 2026).
  202. Choi and Weixel, “FDA drops guardrails on vaping industry in major Trump pivot”; Sriparna Roy and Juveria Tabassum, “Trump administration withdraws FDA plan to ban menthol cigarettes,” Reuters, January 24, 2025, available at https://www.yahoo.com/news/trump-administration-withdraws-fda-plan-161513112.html.
  203. Kenneth P. Vogel and Christina Jewett, “A $5 Million Donation From Big Tobacco Preceded F.D.A. Vape Decision,” The New York Times, May 20, 2026, available at https://www.nytimes.com/2026/05/20/us/politics/donation-big-tobacco-vaping.html.
  204. Ibid.; Christina Jewett, “With Commissioner Under Pressure, F.D.A. Opens Door to Flavored Vapes,” The New York Times, May 10, 2026, available at https://www.nytimes.com/2026/05/10/science/fda-flavored-vapes.html; Matthew Perrone, Associated Press, “FDA move allowing more e-cigarettes and nicotine pouches into U.S. blindsides officials,” PBS News, May 22, 2026, available at https://www.pbs.org/newshour/health/fda-move-allowing-more-e-cigarettes-and-nicotine-pouches-into-u-s-blindsides-officials.
  205. Choi and Weixel, “FDA drops guardrails on vaping industry in major Trump pivot.”
  206. Beth Mole, “FDA chief resigns after Trump admin forced approval of e-cigs,” Ars Technica, May 12, 2026, available at https://arstechnica.com/health/2026/05/fda-chief-resigns-after-trump-admin-forced-approval-of-fruity-e-cigs/.
  207. Federal Election Commission, “Receipts: ‘RAI Services Company’”; O’Connell, Blaskey, and Schaffer, “Secret documents reveal donors behind $330 million for Trump’s ballroom.”
  208. Roy and Tabassum, “Trump administration withdraws FDA plan to ban menthol cigarettes”; Tobacco Insider, “Newport,” December 24, 2024, available at https://tobaccoinsider.com/newport/.
  209. The average ex-tax price of a pack of cigarettes in the United States is $6.80 according to Tobacco Insider; the average retail markup on a pack of cigarettes is 10.79 percent. Applying that discount to the $6.80 average results in an estimated average wholesale price of $6.07 per pack. Based on a sale of 1 billion packs per year, wholesale revenue is an estimated $6.07 billion. See Tobacco Insider, “USA: Cigarette Prices,” August 26, 2026, available at https://tobaccoinsider.com/usa-cigarette-prices/.
  210. VynZ Research, “U.S. E-Cigarette Market Size & Share Growth Forecast Report (2026-2035),” available at https://www.vynzresearch.com/semiconductor-electronics/us-e-cigarette-market (last accessed October 2026).
  211. Federal Election Commission, “Receipts, ‘Altria Client Services Inc’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=Altria&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed October 2026).
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  216. Lauren Hirsch, “Companies Rush to Close Daring Deals Under Trump,” The New York Times, July 31, 2026, available at https://www.nytimes.com/2026/07/31/business/corporate-mergers-deals-trump.html.
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  219. John R. Puri, “All the President’s Mergers,” National Review, April 16, 2026, available at https://www.nationalreview.com/magazine/2026/06/all-the-presidents-mergers/.
  220. Ibid.; Benjamin Mullin and Lauren Hirsch, “Shari Redstone Wants a Resolution of Trump Lawsuit Ahead of Skydance Deal,” The New York Times, February 28, 2025, available at https://www.nytimes.com/2025/02/28/business/dealbook/redstone-paramount-skydance-deal.html.
  221. Ibid.; Puri, “All the President’s Mergers”; David Bauder, “Paramount will pay $16 million in settlement with Trump over ‘60 Minutes’ interview,” Associated Press, July 2, 2025, available at https://www.ap.org/news-highlights/spotlights/2025/paramount-will-pay-16-million-in-settlement-with-trump-over-60-minutes-interview/.
  222. Allie Canal, “Trump Says He’ll Stay Out of the Netflix-Paramount Fight Over Warner Bros.,” NBC News, February 4, 2026, available at https://www.nbcnews.com/business/media/trump-netflix-paramount-fight-warner-bros-rcna257476.
  223. Ibid.; Yasmin Khorram, “Justice Department approves Paramount’s acquisition of Warner Bros.,” Politico, June 12, 2026, available at https://www.politico.com/news/2026/06/12/paramount-acquisition-warner-bros-approved-00960300.
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  255. Federal Election Commission, “Receipts: ‘Cafaro, John’.”
  256. Arden Farhi and Joe Walsh, “Company owned by Trump donor won $1.7 million no-bid Reflecting Pool cleaning contract,” CBS News, June 22, 2026, available at https://www.cbsnews.com/news/company-trump-donor-cafaro-reflecting-pool-no-bid-contract/.
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  259. This total does not include the $1 million donated by Toyota, as that is counted in the section on dropped investigations and enforcement actions.
  260. The authors do not include tariff exemptions related to any automaker other than Ford and were unable to quantify benefits incurred by ArcelorMittal.
  261. Canadian Auto Dealer, “Tesla wins big on Trump’s easing of auto tariffs,” May 2, 2025, available at https://canadianautodealer.ca/2025/05/tesla-wins-big-on-trumps-easing-of-auto-tariffs/. Lora Kolodny, “Tesla reports 418,227 deliveries for the fourth quarter, down 16%,” CNBC, January 2, 2026, available at https://www.cnbc.com/2025/10/02/tesla-tsla-q3-2025-vehicle-delivery-production.htmlhttps://www.cnbc.com/2026/01/02/tesla-tsla-q4-2025-vehicle-deliveries.html.
  262. Golinger, O’Grady, and Claypool, “Ballroom Billions”; Federal Election Commission, “Schedule 13-A Itemized Donations Accepted, Trump Vance Inaugural Committee, Inc., Filing FEC-1910509”; Mike Crisolago, Moneywise, “Apple, Nvidia each gave $25M to Trump’s White House ballroom — but the president’s own name is nowhere on the donor list,” Yahoo Finance, October 17, 2026, available at https://finance.yahoo.com/economy/policy/articles/apple-nvidia-gave-25m-trumps-150000953.html.
  263. Apple reported paying $3.3 billion in tariff costs between April 2025 and December 2025, whereas Morgan Stanley had estimated that the original tariffs would have cost Apple $33 billion for the year. This calculation accounts for potential savings from the past three quarters only. See William Gallagher, “Hits from tariffs continue, Apple to pay $1.4 billion more in 2025 holiday quarter,” Apple Insider, October 30, 2025, available at https://appleinsider.com/articles/25/10/30/hits-from-tariffs-continue-apple-to-pay-14-billion-more-in-2025-holiday-quarter; William Gallagher and Mike Wuerthele, “Apple will take a $33 billion hit to its bottom line because of Trump tariffs,” Apple Insider, April 4, 2025, available at https://appleinsider.com/articles/25/04/04/apple-will-take-a-33-billion-hit-to-its-bottom-line-because-of-trump-tariffs.
  264. Livemint, “Apple share price jumps 7% on tariff exemption, iPhone shipments up 10% in Q1 to clinch top spot globally,” April 14, 2025, available at https://www.livemint.com/market/stock-market-news/apple-share-price-jumps-7-on-tariff-exemption-iphone-shipments-up-10-in-q1-to-clinch-top-spot-globally-11744643578921.html.
  265. Chloe Sorvino and Giacomo Tognini, “Meet The Florida Sugar Barons Worth $4 Billion And Getting Sweet Deals From Donald Trump,” Forbes, October 17, 2025, available at https://www.forbes.com/sites/chloesorvino/2025/10/16/fanjul-family-sugar-barons-worth-4-billion-donald-trump-coca-cola/; Federal Election Commission, “Receipts: ‘Fanjul’ and ‘Florida Crystals Corp’,” available at https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00762591&committee_id=C00770941&committee_id=C00825851&committee_id=C00828541&committee_id=C00867036&committee_id=C00867937&committee_id=C00878801&committee_id=C00879510&committee_id=C00883520&committee_id=C00892471&contributor_name=FLORIDA+CRYSTALS+CORP&contributor_name=Fanjul&two_year_transaction_period=2026&two_year_transaction_period=2024 (last accessed October 2026); Alba and Terkel, “Here’s the list of donors paying for Trump’s new White House ballroom.”
  266. Ana Swanson and James Wagner, “Trump Administration Quietly Lifted Ban on Dominican Sugar Company Over Forced Labor,” The New York Times, March 19, 2025, available at https://www.nytimes.com/2025/03/19/business/economy/trump-sugar-forced-labor-ban-lifted.html; Corporate Accountability Lab, “Bitter Empire: Labor Exploitation in the Dominican Sugar Sector and the Trump-Billionaire Alliance Behind It” (Chicago: 2026), available at https://corpaccountabilitylab.org/bitter-empire.
  267. Sandy Tolan and Euclides Cordero Nuel, “The High Human Cost of America’s Sugar Habit,” Mother Jones, September 17, 2021, available at https://www.motherjones.com/politics/2021/09/sugar-central-romana-fanjul-dominican-republic/.
  268. Federal Election Commission, “Schedule 13-A Itemized Donations Accepted, Trump Vance Inaugural Committee, Inc., Filing FEC-1910509”; Robert S. Miller, “Stellantis Plays Nice: $1M Donation to Trump’s Inauguration,” Mopar Insiders, January 17, 2025, available at https://moparinsiders.com/stellantis-plays-nice-1m-donation-to-trumps-inauguration/.
  269. Andrea Shalal and David Lawder, “Trump set to soften auto tariffs after industry pushback,” Reuters, April 29, 2025, available at https://www.reuters.com/business/autos-transportation/trump-reduce-impact-auto-tariffs-officials-say-2025-04-28/.
  270. The savings estimate is based on Ford’s reported 1.8 million vehicles sold and assembled in the United States. It uses the estimated average manufacturer’s suggested retail price (MSRP) of a Ford light vehicle ($55,000) based on the average industry ratio of average transaction price to MSRP. See Jim Farley, “Another Year of Ford’s Commitment to America,” April 13, 2026, available at https://www.fromtheroad.ford.com/us/en/articles/2026/another-year-of-fords-commitment-to-america; Cox Automotive, “Data Tables for June 2025 Kelley Blue Book Average Transaction Prices Report,” available at https://www.coxautoinc.com/wp-content/uploads/2025/07/June-2025-Kelley-Blue-Book-Average-Transaction-Price-tables.pdf (last accessed September 2026); Kelley Blue Book, “Kelley Blue Book Report: New-Vehicle Costs Rise in June, Outpacing Transaction Prices as Sales Slow, Incentives Tick Up,” Press release, July 14, 2025, available at https://mediaroom.kbb.com/2025-07-14-Kelley-Blue-Book-Report-New-Vehicle-Costs-Rise-in-June,-Outpacing-Transaction-Prices-as-Sales-Slow,-Incentives-Tick-Up; International Trade Administration, “The Department of Commerce Announces New Auto Tariff Offset Process,” Press release, June 12, 2025, available at https://www.trade.gov/press-release/department-commerce-announces-new-auto-tariff-offset-process.
  271. Ana Swanson and Luke Broadwater, “White House Secures Foreign Steel for Ballroom Project,” The New York Times, April 8, 2026, available at https://www.nytimes.com/2026/04/08/us/politics/white-house-foreign-steel-ballroom.html; Rijuta Dey, “ArcelorMittal confirms steel supply for White House ballroom project,” May 3, 2026, available at https://eurometal.net/arcelormittal-confirms-steel-supply-for-white-house-ballroom-project/.
  272. Swanson and Broadwater, “White House Secures Foreign Steel for Ballroom Project.”
  273. Ibid.
  274. Constitution Annotated, “Article I, Section 9, Clause 8,” available at https://constitution.congress.gov/browse/essay/artI-S9-C8-1/ALDE_00013203/ (last accessed October 2026).
  275. Constitution Annotated, “Artl.S9.C8.2 Historical Background on Foreign Emoluments Clause,” available at https://constitution.congress.gov/browse/essay/artI-S9-C8-2/ALDE_00013205/ (last accessed October 2026).
  276. Congressional Research Service, “Gifts to the President of the United States” (Washington: 2012), available at https://www.everycrsreport.com/files/20120816_R42662_7f639447b6bcabe1b3bb86eb2927c158cde643b7.pdf.
  277. See Ronald Reagan Presidential Library and Museum, “Presidential Gifts,” available at https://www.reaganlibrary.gov/reagans/reagan-administration/presidential-gifts (last accessed October 2026).
  278. Connor Greene, “What to Know About the Controversy and Security Questions Surrounding Trump’s Qatari-Gifted Air Force One,” Time, July 20, 2026, available at https://time.com/article/2026/07/20/trump-air-force-one-qatar-controversy-security-questions/.
  279. Eric Lipton, Tyler Pager, and Maggie Haberman, “Inside the Rushed Effort to Get Trump His New Air Force One,” The New York Times, July 25, 2026, available at https://www.nytimes.com/2026/07/25/us/politics/trump-air-force-one-security.html.
  280. Jaroslav Lukiv, “Qatar to build air force facility in Idaho, US says,” BBC, October 10, 2025, available at https://www.bbc.com/news/articles/c75q2y92090o.
  281. Parshwa Turakhiya, Benzinga, “Inside The $187M Deal Between The Trump Family And The UAE’s ‘Spy Sheikh’,” Yahoo Finance, February 3, 2026, available at https://finance.yahoo.com/news/inside-187m-deal-between-trump-003116654.html; Luke Fountain, “UAE ‘spy sheikh’ backs 49% stake in Trump family’s crypto bank venture, WSJ reports,” CNBC, August 27, 2026, available at https://www.cnbc.com/2026/08/27/uae-spy-sheikh-trump-family-crypto-bank.html.
  282. Ari Hawkins and Ben Johansen, “Staff warned of major security risks from giving UAE new tech access. The White House went ahead anyway.,” Politico, July 22, 2026, available at https://www.politico.com/news/2026/07/21/uae-tech-security-risks-white-house-01006866.
  283. Ana Swanson and others, “Trump Announces Preliminary Trade Pact with Vietnam,” The New York Times, July 2, 2025, available at https://www.nytimes.com/2025/07/02/business/economy/trump-vietnam-trade-deal.html.
  284. Damien Cave, “Why Vietnam Ignored Its Own Laws to Fast-Track a Trump Family Golf Complex,” The New York Times, May 25, 2025, available at https://www.nytimes.com/2025/05/25/world/asia/trump-vietnam-golf-project.html.
  285. Trevor Hunnicutt and Khanh Vu, “Trump says he will put 20% tariffs on Vietnam’s exports,” Reuters, July 3, 2025, available at https://www.reuters.com/world/asia-pacific/trump-says-he-has-struck-trade-deal-with-vietnam-2025-07-02/.
  286. See, generally, Steel, “Systematic Corruption.”
  287. Vigers, “Record High 89% in U.S. Say Government Corruption Widespread.”
  288. Center for American Progress, “The Corporate Power Reset,” available at https://www.americanprogress.org/series/the-corporate-power-reset/ (last accessed October 2026).

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Senior Director, Courts and Legal Policy

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Senior Director, Research

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Senior Policy Analyst, Democracy and Legal Policy

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