Use-Case Playbook: Researching Conflicts of Interest
Overview
This playbook guides journalists, researchers, and accountability advocates through the process of identifying, documenting, and verifying conflicts of interest involving public officials, government contractors, and politically connected individuals.
Definition: A conflict of interest exists when a public official’s personal financial interests, outside relationships, or prior employment could improperly influence their exercise of official duties.
Quick Reference
| Type of Conflict | Primary Sources |
|---|---|
| Stock holdings while regulating an industry | Financial disclosure filings (OGE Form 278) |
| Government contracts to connected companies | USASpending.gov + OpenCorporates |
| Foreign government payments | FARA filings (justice.gov/nsd-fara) |
| Political donations to appointing officials | OpenSecrets, FEC.gov |
| Revolving door (regulated industry to regulator) | OpenSecrets.org revolving door database |
| Real estate transactions with government | Property records + federal procurement |
Step-by-Step Research Process
Step 1: Start with the Money
Read: Follow the Money: The Economic Interests Behind the Trump Administration
The foundational “follow the money” framework: how to identify who benefits from government decisions, where the money flows, and what financial relationships create conflicts. Covers the Trump administration’s specific financial entanglements as case studies.
Step 2: The Conflicts of Interest Matrix
Read: Conflicts of Interest Matrix — Trump 2.0 Administration & Movement Network
The Patriot University conflicts of interest matrix: a structured analysis of conflicts across Trump administration officials organized by official, type of conflict, and status of disclosure or remediation.
Step 3: Financial Disclosure Research
Federal Executive Branch Officials:
- OGE (Office of Government Ethics) Form 278 (public financial disclosure): oge.gov
- Covers investments, income, liabilities, outside positions, and agreements
- Search by official name at: ethics.gov/financial-disclosure
Members of Congress:
- House: disclosures.house.gov
- Senate: sfodp.senate.gov
- Covers investments, income, and transactions
What to look for:
- Stock in companies regulated by their agency or committee
- Recusal waivers (or lack thereof)
- Undisclosed holdings
- Year-over-year changes suggesting trading on non-public information
Step 4: Beneficial Ownership Tracing
Read: Tutorial — Beneficial ownership tracing
How to trace who actually owns companies that receive government contracts or engage with officials. LLC structures, nominee arrangements, and offshore entities often obscure the true beneficiary.
Step 5: Sanctions and Foreign Connections
Read: Tutorial — OpenSanctions screening
Screen officials, their family members, and connected companies against OpenSanctions to identify foreign connections, PEP status, and sanctions exposure.
Step 6: Trump Family Financial Network (Case Study)
Read: Trump Family Financial Network — Cross-Cutting Analysis
A detailed analysis of the Trump family’s financial network: business interests, foreign sovereign wealth fund investments, real estate deals in authoritarian states, and the intersection of family business with government policy.
Step 7: Lobbying and Procurement
Consult:
knowledgebase/investigative-tools/tool-catalog/by-category/lobbying.md— lobbying disclosure databasesknowledgebase/investigative-tools/tool-catalog/by-category/procurement.md— government contracting databases
Map which companies receive government contracts and simultaneously lobby officials who make or influence procurement decisions.
Step 8: Document and Preserve Evidence
Read: Methodology — Evidence Preservation Read: Methodology — Timeline Construction
Build a timeline linking official decisions to financial benefits. Preserve all source materials with chain of custody documentation.
Related Accountability Resources
- Trump Mega-Donors and Funder Network — donors with business interests before the administration
- Trump-Aligned PACs and Super PACs — PAC funding analysis
- Relevant individual profiles in
knowledgebase/accountability/for the official under investigation