Turkey is a nation in crisis, scarred by government crackdowns after a failed coup attempt and on a potential collision course with the West. It is also home to a valuable revenue stream for the president-elect’s business empire: Trump Towers Istanbul.

Donald Trump’s company has been paid up to $10 million by the tower’s developers since 2014 to affix the Trump name atop the luxury complex, whose owner, one of Turkey’s biggest oil and media conglomerates, has become an influential megaphone for the country’s increasingly repressive regime.

That, ethics advisers said, forces the Trump complex into an unprecedented nexus: as both a potential channel for deal-makers seeking to curry favor with the Trump White House, and a potential target for attacks or security risks overseas.

The president-elect’s Turkey deal marks a harrowing vulnerability that even Trump has deemed “a little conflict of interest”: A private moneymaker that could open him to foreign influence and tilt his decision-making as America’s executive in chief.

But the ethics experts eyeing Trump’s empire are now warning of many others, found among a vast assortment of foreign business interests never before seen in past presidencies. At least 111 Trump companies have done business in 18 countries and territories across South America, Asia and the Middle East, a Washington Post analysis of Trump financial filings shows.

The business interests range from sprawling, ultra-luxury real estate complexes to one-man holding companies and branding deals in Azerbaijan, Indonesia, Panama and other countries, including some where the United States maintains sensitive diplomatic ties.

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Some companies reflect long-established deals, while others were launched as recently as during Trump’s campaign, including eight that appear tied to a potential hotel project in Saudi Arabia, the oil-rich Arab kingdom that Trump has said he “would want to protect.”

Trump has refused calls to sell or give his business interests to an independent manager or “blind trust,” a long-held presidential tradition designed to combat conflicts of interest. Now, policy and ethics experts are scrambling to assess the potential dangers of public rule by a leader with a vast web of private business deals.

“There are so many diplomatic, political, even national security risks in having the president own a whole bunch of properties all over the world,” said Richard Painter, a former chief White House ethics lawyer under President George W. Bush.

“If we’ve got to talk to a foreign government about their behavior, or negotiate a treaty, or some country asks us to send our troops in to defend someone else, we’ve got to make a decision. And the question becomes: Are we going in out of our national interest, or because there’s a Trump casino around?” Painter said.

The Post analysis is based on the most recent financial-disclosure reports filed by Trump’s campaign in May. The self-reported data was unverified by regulators, meaning the reports may not have shown all of Trump’s foreign deals or assets.

The disclosures offer a glimpse at how extensive Trump’s empire has become, including five-star hotels in Canada and Panama, elite golf courses in Ireland and Scotland, and a luxury-resort project now under development in Indonesia, home to more Muslims than any country in the world.

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But the filings, the most comprehensive public documents of Trump’s business empire, largely lack details for many of the companies’ status or ambitions. Trump has refused to allow for a closer accounting of his investments or to release documents, such as his tax returns, that could provide more detail on his foreign accounts.

The companies have helped spread the Trump brand internationally and injected millions of dollars into the president-elect’s umbrella company, the Trump Organization, which continues to launch and invest in new deals for projects around the globe.

Most government officials must follow strict conflict-of-interest regulations designed to block public servants from making decisions in their own private interest. But presidents are largely exempt from those rules for fear they could impede on their wide-ranging constitutional duties.

Many modern presidents and major nominees – including Ronald Reagan, both Bushes, Bill Clinton and Mitt Romney – have nevertheless committed to selling or divesting their interests into a blind trust run by an independent overseer with unassailable control.

Trump has said he plans to give control of the Trump companies to his children, and the company has said the final arrangement “will comply with all applicable rules and regulations.” Alan Garten, the Trump Organization’s executive vice president and general counsel, said in an interview in September, “His focus is going to be solely on improving the country.”

But congressional researchers and ethics advisers say leaving the company’s management to Trump’s children would not truly separate Trump’s private and public work. Even Trump has voiced confusion on the point: At a January debate, he said, “I don’t know if it’s a blind trust if Ivanka, Don and Eric run it but – is that a blind trust? I don’t know.”

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Trump’s global business interests also make him vulnerable to legal risks, including a passage in the Constitution, known as the emoluments clause, that forbids government officials from receiving gifts from a foreign government.

A payment from a foreign official or state-owned company to a Trump hotel or other branded company could potentially violate that clause, constitutional experts said.

A group of ethics advisers, including former chief White House ethics lawyers during Democratic and Republican administrations, wrote Trump a letter Thursday urging him to sequester his business in a genuine blind trust or commit to a “clear firewall” between his Oval Office and his family.

“You were elected to the presidency with a promise to eliminate improper business influence in Washington,” they wrote. “There is no way to square your campaign commitments to the American people – and your even higher, ethical duties as their president – with the rampant, inescapable conflicts that will engulf your presidency if you maintain connections with the Trump Organization.”


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