In January, then-President-elect Donald Trump announced a "complete separation" from his global business empire. Under siege by critics who charged that his organization represented a maze of potential conflicts of interest, Trump said his sons would manage it in a trust and that he would "completely isolate himself" from the company's day-to-day operations. The plan fell short of what the U.S. government's own ethics watchdog has insisted Trump must do: a total divestment of his business holdings. But just how far has the president gone to fulfill his promise? Two months into his presidency, interviews with government watchdogs and a VOA review of state records and documents filed by the Trump Organization show that while Trump has taken some steps he promised in January, he's failed to fully implement his own trust agreement. That has exposed him to persistent conflict-of-interest charges from critics on Capitol Hill and elsewhere. "There are a lot of things that even within the totally inadequate framework that he's set out seem to be falling short of what he promised," said Noah Bookbinder, executive director of Citizens for Responsibility and Ethics in Washington, a left-leaning government watchdog that has sued the president over alleged business conflicts. In the face of calls for divestment, Trump has held his ground, arguing that the American people knew all along about his vast business interests when they elected him and that conflict-of-interest laws don't apply to him. And he has a cadre of lawyers who say Trump has gone the extra mile to steer clear of potential conflicts. Business interests vs. national interests To ethicists, the conflicts issue boils down to this question: In conducting his presidential duties, will Trump consider his business interests or America's? Trump has said he wants to focus on running the country, but ethics watchdogs say that as long as he remains tethered to his global business, every action he takes, whether it's banning travel from a foreign country or warming up to another, will be seen through that prism of his business interests. "You cannot have the president of the United States in a position even where it appears that he may be making a foreign policy decision to help another country and disfavors other countries because of the financial relationships his business has with the benefited country," said Fred Wertheimer, president of Democracy 21, a nonprofit government watchdog. The White House didn't respond to an emailed request for information on ethics policies. The Trump Organization did not respond to questions, either. The foundation of Trump's self-described "simple solution" to avoid conflicts of interest in office was turning over management of his company to his sons. To follow through, he signed two sets of documents the day before his January 20 inauguration. One included 19 pages of resignations from nearly 500 Trump-owned or -branded companies. The other amended a three-year-old trust to appoint his eldest son, Donald Jr., and Trump Organization Chief Financial Officer Allen Weisselberg as sole trustees of the organization. Among the 488 companies in the resignation papers are major properties like the Mar-a-Lago Club, the Palm Beach, Florida, resort that Trump has designated his "winter White House." Also included are shell companies created for businesses that never panned out, such as THC Jedda Hotel Manager LLC, set up to explore a hotel venture in Saudi Arabia. But handing over a global business isn't as easy as signing a resignation document. A longer and more cumbersome process involves the new Trump management team filing documents with state agencies to assume management of each company. State records show that the management team has started doing that, including listing Donald Jr. as president of the Mar-a-Lago Club and the company that runs the Trump hotel in Washington, D.C. Although dozens of companies have been re-registered, it's unclear how far the process has advanced, according to ethics watchdogs that track the information. The Trump Organization released the resignation document in January but has not provided details of the re-registration process. The company and the White House did not respond to VOA's questions about the processes to police Trump's conflicts. New ethics advisers In announcing the new structure, Trump lawyer Sheri A. Dillon said in January that the president-elect had appointed a chief compliance counsel to his company and would soon name a second lawyer as an ethics adviser to the Trump Organization management team. The goal, she said, was to allow the company to "continue to operate at the highest legal and ethics standards." The appointments came January 25: Veteran Republican lawyer Bobby Burchfield was appointed as a Washington-based ethics adviser responsible for vetting and approving new deals, and longtime Trump Organization Executive Vice President George Sorial was named the company's in-house chief compliance officer. Separately, Stefan C. Passantino, another Republican lawyer, was named deputy White House counsel for ethics. Passantino and Burchfield are prominent lawyers with close links to the Republican establishment. Passantino, until recently a partner at Dentons, a global law firm with offices in Washington and Atlanta, is an expert on "political law" and counts former Republican House Speakers Newt Gingrich and Dennis Hastert among his coterie of high-profile clients. Burchfield is a partner in King & Spalding, another international law firm in Washington. He served as general counsel of former President George H.W. Bush's unsuccessful 1992 re-election campaign and chairs Crossroads GPS, a nonprofit created by former White House adviser Karl Rove. Little has come to light about the process they are using to police conflicts. One exception: Passantino's decision last month to "counsel" Trump White House adviser Kellyanne Conway for endorsing Ivanka Trump's clothing and jewelry line during a TV appearance. Walter Shaub, director of the Office of Government Ethics, who earlier this year criticized Trump's refusal to divest his business holdings, faulted Passantino for not taking any disciplinary action against Conway. There are no standardized disciplinary actions prescribed for violations of the kind Conway was accused of; each agency determines its own punishment. While former White House ethics czar Richard Painter said Trump has "good people working for him," he and other government ethics experts say that as long as Trump retains ownership of his company, the ethics issues will remain insurmountable for his lawyers. "Whether the ethics advisers give good advice or not to his sons and the officials who are running the business is irrelevant to the fundamental problem he's created by insisting on continuing to own his business," Wertheimer said. No new deals? Trump's pledge that "no new deals will be done during my term(s) in office" has drawn close scrutiny as a test of the president's commitment to avoid conflicts. In January, Dillon sought to expand on what the president's pledge meant: While "no new foreign deals will be made whatsoever" during Trump's presidency, she said, domestic deals would be allowed as long as they received ethics adviser Burchfield's written approval. To that end, the Trump Organization has canceled licensing deals in Azerbaijan, Georgia and Brazil and dissolved a number of foreign entities. And Trump Hotels CEO Eric Danziger said in January that he would not be pursuing any China ventures while Trump was in office. However, the "no new deal" pledge has allowed the company wiggle room. Case in point: the Trump Organization's recent interest in reviving a long-dormant licensing deal with the Dominican Republic's wealthy Hazoury family. The 2007 deal initially involved the sale of Trump-branded luxury estates at Cap Cana and was to extend to condos and a golf course. After the 2008 financial crisis, the deal languished, according to the Associated Press, leading Trump to sue the Hazoury family in 2012 over alleged hidden land sales. But the Trump Organization's interest in restarting the project emerged after Eric Trump visited the resort last month and was photographed meeting with erstwhile partners. Trump Organization General Counsel Alan Garten confirmed preliminary talks had taken place with the family, telling AP the deal was never dead. In a sector where big players such as the Trump Organization often explore dozens of deals simultaneously, the no-new-deals pledge is meaningless, said Painter, who served as White House ethics czar in the administration of former President George W. Bush and is now a law professor at the University of Minnesota. "There will be new deals," Painter predicted in an interview with VOA. Burchfield, the current White House ethics adviser, did not respond to requests for comment. Payments from abroad Under most licensing deals, the Trump Organization gets to keep a cut of the profit. For example, in his 2016 financial disclosures, Trump reported $1 million to $5 million in royalties from Trump International Hotel & Tower Panama. Trump lawyers see hotel payments made by foreign governments as a "fair value exchange" and not an income proscribed by the U.S. Constitution's emoluments clause, which prohibits federal officials from receiving gifts and payments from foreign governments. Nevertheless, Trump promised in January to go above and beyond the legal proscription, donating all hotel profits generated from foreign government payments to the U.S. Treasury. Whether a mechanism has been set up for transfer of foreign government profits to the Treasury remains unclear. Nor is it known how foreign government profits would be calculated. For example, if the Trump Organization decides to donate only 10 percent of a $10,000 hotel bill paid by a foreign government, "it's questionable whether it's fair market value," said Aaron Sherb of liberal watchdog group Common Cause in Washington. Sherb added that even if the Trump Organization paid all net income to the U.S. Treasury, the president could still run afoul of the Constitution's emoluments clause. "It's a foreign entity potentially giving the president money," he said. Whether real or perceived, conflicts of interest have continued to dog Trump in the two months since his inauguration. For instance, Trump's reported warming up to Presidents Recep Tayyip Erdogan of Turkey and Rodrigo Duterte of the Philippines — countries with poor human rights records where the Trump Organization has lucrative property deals — has raised criticism from human rights organizations. And China's recent approval of 38 Trump trademarks renewed questions about Trump's conflicts even though there is no evidence that the approvals were made to gain favor with Trump. "I can't say what actually motivates him," said Bookbinder of Citizens for Responsibility and Ethics in Washington. "Maybe those kinds of things will never enter his mind, but as long as he has those business interests that stand to benefit from actions of the Chinese government, we're going to have to doubt whether he's making decisions on pure policy grounds or being influenced by what is in his business interests." In its lawsuit against Trump, which several prominent ethics lawyers including Painter have joined, Bookbinder's organization alleges the president's business interests violate the Constitution's emoluments clause. Eric Trump called the case "purely harassment for political gain." Pressed by lawmakers On Capitol Hill, Democrats continue to press for an investigation into Trump's business dealings. "President Trump has exposed his administration to possible conflicts of interest on an unprecedented scale," Democratic Senator Bob Casey of Pennsylvania wrote in a letter to the Office of Government Ethics on Monday. Utah Representative Jason Chaffetz, the Republican chairman of the House Committee on Oversight and Government Reform and a Trump supporter, has dismissed the conflicts controversy as a "nonissue," saying the conflict-of-interest laws don't apply to the president. But he recently joined Democrats in scolding Conway for her on-air endorsement of the Ivanka clothing line and has said his committee will be looking at Trump's conflicts of interest on a case-by-case basis.