The seven nations targeted for new visitation restrictions by President Donald Trump on Friday all have something in common: They are places he does not appear to have any business interests.
The executive order he signed Friday bars all entry for the next 90 days by travelers from Syria, Iran, Iraq, Yemen, Sudan, Somalia and Libya. Excluded from the lists are several majority-Muslim nations where the Trump Organization is active and which in some cases have also faced troublesome issues with terrorism.
According to the text of the order, the restriction applies to countries that have already been excluded from programs allowing people to travel to the United States without a visa because of concerns over terrorism. Hewing closely to nations already named as terrorism concerns elsewhere in law might have allowed the White House to avoid angering some more powerful and wealthy majority Muslim allies, such as Egypt.
But without divesting from his company, as bipartisan ethics experts had advised, Trump is now facing questions about whether he designed the new rules with his own business at least partly in mind.
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"He needs to sell his businesses outside his family and place the assets in a blind trust, otherwise every decision he makes people are going to question if he's making the decision in the interests of the American people or his own bottom line," said Jordan Libowitz, the spokesman for Citizens for Responsibility and Ethics in Washington, a liberal watchdog group. The group has filed a lawsuit arguing that Trump is already in violation of a constitutional provision barring federal officials from accepting payments from foreign officials.
Earlier in the week, Norm Eisen, the group's chairman and a former ethics adviser to Barack Obama, tweeted: "WARNING: Mr. Pres. your Muslim ban excludes countries where you have business interests. That is a CONSTITUTIONAL VIOLATION. See u in court."
Stephanie Grisham, a White House spokeswoman, said, "The high-risk territories are based on Congressional statute and nothing else."
Trump has said he has handed management of his real estate, licensing and merchandising business over to his adult sons to avoid the perception that he is making presidential decisions to boost his own business. But he has retained ownership of the company, meaning that if it thrives during his presidency, he will personally profit.
The new executive order points to the complications that are likely to arise from the arrangement.
Trump's order makes no mention of Turkey, which has faced several terrorist attacks in recent months. On Wednesday, the State Department updated a travel warning for Americans visiting Turkey, noting that "an increase in anti-American rhetoric has the potential to inspire independent actors to carry out acts of violence against US citizens."
Trump has licensed his name to two luxury towers in Istanbul. A Turkish company also manufactures a line of Trump-branded home furnishings. Trump's most recent financial disclosure, filed in May when he was a presidential candidate, showed that he had earned as much as $6 million in the previous year from the deals.
"I have a little conflict of interest 'cause I have a major, major building in Istanbul," he said in a December 2015 interview with Breitbart News. More recently, he has insisted that he has no conflicts because laws making conflicts illegal do not apply to the president.
Also untouched by Friday's executive order is the United Arab Emirates, a powerful Muslim ally with whom the United States nevertheless has complicated relations. Trump has licensed his name to a Dubai golf resort, as well as a luxury home development and spa.
Trump has seemed particularly disinclined to divorce himself of interests in the project. Its developer, Hussain Sajwani, attended a New Year's Eve party at Trump's Florida estate, Mar-a-Lago, where a video showed Trump singling him out for praise, calling him and his family "the most beautiful people."
Trump returned to the topic of his Dubai partnership again in mid-January at a news conference intended to demonstrate how he was separating from his business.
"Over the weekend, I was offered $2 billion to do a deal in Dubai with a very, very, very amazing man, a great, great developer from the Middle East – Hussein, Damac, a friend of mine, great guy. And I was offered $2 billion to do a deal in Dubai – a number of deals and I turned it down," Trump said then, referring to Sajwani's development company.
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His point was that he was voluntarily turning aside new projects that could raise ethical questions. An attorney for the company announced at the same event that the Trump Organization will embark on no new foreign deals while Trump is in office. But the comment also served as a reminder that Trump's business, included the personal relationships he forged with wealthy partners around the world, was still very much on his mind as he entered the presidency.
The executive order makes no mention of Saudi Arabia, home of 15 of the 19 terrorists involved in the 9/11 attacks. The Trump Organization had incorporated several limited liability companies in preparation for an attempt to build a hotel in Saudi Arabia, showing an interest in expansion in the country. The company canceled those incorporations in December, indicating that no project is moving forward.
Excluded as well is Indonesia, the world's largest majority-Muslim nation, where there are two large Trump-branded resorts underway, built in partnership with powerful local interests.
"To be blunt, we really don't know what to make of which motives are driving this president's decisions," said Kamal Essaheb, director of policy and advocacy for the National Immigration Law Center. "From what we could tell from his campaign and his actions since he became president, what seems to be first and foremost on his mind is his own self-interest and an obsession with his brand."