Corruption, or the appearance of corruption, corrodes the public trust that serves as the very foundation of American government’s ability to function. That’s why, “when taking an official action (e.g., making decisions or recommendations), American public servants are expected to put the government’s interests ahead of their own.” To ensure this happens, safeguards to prevent unethical dealings and self-interested decisions – in addition to outright bribery – are fundamental to a healthy American government.

Unfortunately, during its first few months in office, the Trump Administration has effectively circumvented key anti-corruption safeguards in order to quickly install individuals with potentially major conflicts of interest into high-level government jobs. It has done so by transforming the discrete, limited government employment designation known as “Special Government Employee” (SGE) into a vehicle for an end run around ethics requirements, evading barriers against self-dealing and eliminating transparency.

A review of court documents, public records, and news stories sheds light on how extensively the Trump Administration has used the SGE designation. This report found that, in addition to Elon Musk, the Trump Administration has deployed the SGE designation to place at least a dozen others in high-level roles in three federal agencies (Treasury, Homeland Security, and the Office of Personnel Management), helping Musk run DOGE, and advising the White House on issues from global affairs to health care.

Since the SGE designation enables the appointed officials to be exempt from important conflict of interest rules and transparency requirements, these maneuvers create ethical minefields. “Public service is a public trust. In order to protect that public trust, it’s necessary to ensure that Government employees uphold the highest ethical standards.” This report finds that the Trump Administration’s misuse of the SGE designation fails the important public trust test, which requires urgent remedial action.