The first year of President Donald Trump’s second administration featured consistent patterns of unethical behavior across the government, and little enforcement of ethics laws in response.
Campaign Legal Center (CLC) identified 27 violations of ethics norms and rules and impaired enforcement in just the first 100 days in office, while filing 10 complaints against executive branch officials in 2025. However, enforcement bodies in government meant to investigate potential violations of the law largely did not take action in response to these revelations.
As ethics violations become more common and enforcement of the law becomes rarer, it becomes more transparent that a comprehensive ethics code is meaningless without the accountability mechanisms to enforce it. Campaign Legal Center is calling on lawmakers to enact robust laws now that better insulate ethics enforcers from political interference and allow for meaningful accountability.
The Lack of Transparency and Accountability for Pending Ethics Complaints
Trump has removed numerous inspectors general (IGs) and the heads of the Office of Government Ethics (OGE) and the Office of Special Counsel (OSC), and directed the Department of Justice (DOJ) to deprioritize enforcing ethics laws.
The OGE is the office tasked with overseeing executive branch ethics, including preventing conflicts of interest and ensuring that agencies comply with ethics laws and regulations. If OGE becomes aware that an executive branch employee may have violated federal law, such as the criminal conflict of interest statute, they must refer the matter to the DOJ.
There is virtually no transparency surrounding the DOJ’s process for investigating complaints referred to them by other agencies. This lack of transparency means we do not know if the American people received the unimpeded investigations into whether officials used their public office for private gain they deserve.
At the same time, there are an increasing number of cases that require investigations. In fact, the OGE reports that agencies are referring potential violations of criminal conflict of interest laws to the DOJ at a similar level they were in previous years. These could include the following complaints CLC filed:
- A complaint with the Department of Transportation regarding the Federal Aviation Administration’s (FAA) business with Elon Musk’s Starlink that may violate the criminal conflict of interest law ;
- A complaint with the Department of Commerce and OGE regarding Commerce Secretary Howard Lutnick’s promotion of Tesla stock on Fox News in violation of federal ethics laws;
- A complaint with the Consumer Financial Protection Bureau (CFPB) and OGE regarding DOGE employee Gavin Kliger’s failure to divest from prohibited stock in violation of CFPB rules;
- A complaint with the Department of Homeland Security (DHS) regarding DHS Senior Advisor Mark Hall’s participation in contracting decisions involving his former employer that may violate recusal requirements under federal law;
- Two complaints with DOJ regarding whether: Deputy Attorney General Todd Blanche violated conflict of interest laws by changing investigation policies for crypto companies while holding potentially hundreds of thousands of dollars in crypto-related assets; and FBI Director Kash Patel violated federal travel regulations by failing to reimburse the government for at least 10 trips that apparently involved personal travel using government aircraft.
This is not the only avenue where the administration has sought to stifle ethics enforcement. The OSC — responsible for investigating complaints into prohibited practices for government employees, such as illegal partisan campaign activity — reported receiving more complaints than ever before during the 2025 fiscal year.
Rather than responding to such a caseload influx with additional resources, the Trump administration seeks to preclude certain employees from going to OSC, instead requiring them to bring their allegations to their agencies, the place where the violations occurred, despite the potential for retaliation.
Now Is the Time for Ethics Enforcement Reform
These examples of ethics enforcement bodies failing to execute their mission are just a small snapshot of the trickle-down culture of corruption that has festered in the second Trump administration, where Cabinet secretaries advertise stock options on air, foreign governments gift private jets to the White House, megadonors can influence industries they have major conflicts of interest in, and the president can decapitate the agencies meant to keep a watchful eye on his administration.
The numerous lingering and unresolved allegations of corruption exemplify the problem that even strong ethics laws are ineffective without enforcement that is robust, centralized, transparent and free from political interference.
Meaningful ethics enforcement reform requires the creation of an independent executive branch ethics body that centralizes the enforcement of laws under the jurisdiction of OGE, OSC, and the FEC with the following features so that ethics enforcement can be carried out effectively, efficiently, and in a nonpartisan manner without fear of political retribution unlike the current system:
- For Cause Removal: This body should be led by appointed officials who cannot be removed for arbitrary or political reasons.
- Expanded Investigative Authority: The independent body should have the authority necessary to conduct thorough and prompt investigations, including subpoena power, DOJ referrals, and extensive staff resources.
- Enhanced and Updated Transparency: The independent body should maintain a centralized website for all ethics-related public reports (e.g., financial disclosures, lobbying, campaign finance) in a searchable, sortable and downloadable format. Also, to prevent the DOJ from maintaining its current practice of providing no transparency into their investigative process, the independent enforcement body should be required to publicly release their report that led to the DOJ referral to the public if DOJ chooses not to take up a matter.
These ethics reform proposals are based on 2019 proposals for the creation of a Commission on Federal Ethics that was never pursued.
The public has a right to know that their government officials are acting in the public interest, not prioritizing their own wealth. Creating an independent enforcement body is the best way to make sure the government is upholding that right.
In the meantime, Campaign Legal Center will continue to shine a light on the eroding ethics enforcement across government and call for better accountability of the laws that still stand. Read more about how we’re upholding ethical standards in the second Trump administration here.