Ending Corruption: A 120th Congress Oversight Plan

Corey J. Biazzo, Esq.

1 day ago

24 min read

Ending Corruption in Government: How the 120th Congress Can Lawfully Investigate, Build the Record, and Pass Lasting Anti-Corruption Reforms

By Corey J. Biazzo, Esq., Biazzo Law, PLLC — part of the Biazzo Law Government Oversight Program. Country over Party. Patriot over Partisan.

In short: Public office is a public trust. Since January 2025, courts, inspectors general, ethics offices, and major news organizations have documented a wide range of conduct that raises serious corruption and conflict-of-interest questions: foreign-government money flowing to businesses tied to the President's family, a $400 million aircraft from Qatar, a federal judge's finding that the President's $10 billion suit against the IRS was collusive, at least 85 public officials granted clemency after corruption charges or convictions, the unlawful firing of inspectors general, and allegations against cabinet officials and members of Congress. Some of these matters are findings; most are allegations that have not been proven. Either way, the 120th Congress has the constitutional duty and the legal tools to find out what happened. This post gives members a lawful, step-by-step investigative plan with a clear legislative purpose — how to preserve evidence, request and subpoena documents, photos, videos, and testimony, hold officials accountable through lawful channels, and enact reforms that apply to every President, every administration, and every member of Congress, of either party.

Key facts at a glance (as of November 13, 2026; findings and allegations are labeled)

Matter	What is reported	Type
Presidential income	The President's 2025 financial disclosure reported more than $2.2 billion in income, about $1.4 billion from crypto businesses (Los Angeles Times)	Official disclosure
Foreign stake in family crypto firm	An entity tied to UAE national security adviser Sheikh Tahnoon paid $500 million for 49% of World Liberty Financial; $263 million went to Trump family entities (CNBC). A shareholder suit filed Oct. 22, 2026 alleges a Foreign Emoluments Clause violation	Disclosure; pending allegation
Qatari 747	Defense Department accepted a Boeing 747-8 valued at about $400 million in May 2025; the White House says it will go to the President's library. No congressional consent vote has been reported	Reported fact; legal question
IRS lawsuit and $1.776 billion fund	Judge Kathleen Williams (S.D. Fla.) found the suit collusive and filed for an improper purpose and imposed sanctions (July 13, 2026); the Eleventh Circuit denied a stay; DOJ says it withdrew the fund and paid nothing	Court finding (on appeal)
Inspector general firings	Judge Ana Reyes (D.D.C.) found the January 2025 firings violated the Inspector General Act's 30-day notice and rationale requirements but declined to reinstate (Sept. 24, 2025)	Court finding
Clemency for public officials	Reuters identified at least 85 public officials charged with or convicted of corruption-related crimes who received clemency	Investigative reporting
Miami library land	Suit alleges Florida transferred land appraised at $67 million to the library foundation for $10, in violation of the Domestic Emoluments Clause (Sistrunk Seeds v. Trump, S.D. Fla.)	Pending allegation
Taxpayer-funded ads	Judge Jennifer Rochon (S.D.N.Y.) found a DHS ad campaign likely violated appropriations law and blocked it	Preliminary court finding
Senior officials	DHS inspector general referred its Corey Lewandowski investigation to DOJ; Labor Department IG found misconduct by former Secretary Lori Chavez-DeRemer	IG referral and finding

Disclosure: Biazzo Law, PLLC was granted leave by the court (ECF No. 64) and filed an amicus brief (ECF No. 65) supporting the plaintiffs' opposition to the motions to dismiss in Sistrunk Seeds v. Trump. Everyone named in this post is presumed innocent of any crime unless and until proven guilty.

What corruption and ethics concerns should Congress examine?

The record falls into eight areas. Each item below is labeled by its source so members and the public can tell what has been found (by a court, inspector general, or ethics office), what has been reported (by established news organizations), and what has been alleged (in lawsuits, complaints, or letters). Where subjects have responded or denied wrongdoing, their responses are noted.

1. Foreign money and the President's family businesses

Crypto ventures. Reuters' June 2026 investigation estimated the family made at least $2.3 billion from four crypto ventures, while outside investors lost about the same amount. World Liberty Financial (WLF) disputes parts of that calculation, and the White House denies any conflicts.
UAE connections. A Tahnoon-linked entity bought 49% of WLF days before the inauguration. MGX, an Abu Dhabi state-owned firm, settled a $2 billion Binance investment in WLF's USD1 stablecoin. The administration later approved advanced-chip sales to a Tahnoon-controlled company and, in July 2026, eased UAE export controls. CNBC reported the rule itself shows no evidence that WLF dealings influenced it. In August 2026 the Comptroller of the Currency granted preliminary conditional approval for a WLF national trust bank.
Meme coin dinners. The President hosted top $TRUMP coin holders in May 2025; CBS reported that many top holders for a second dinner set for November 22, 2026 used exchanges that bar U.S. customers, suggesting foreign buyers.
Foreign licensing. The President reported $59.5 million in foreign real-estate licensing income for 2025, more than 60% from Gulf projects, including a Qatari Diar development and an Omani government venture (CNBC). The Trump Organization says it follows ethics laws; CNBC found no evidence the payments influenced government decisions.
The Qatari 747. Qatar's royal family gave the aircraft to the Defense Department in May 2025. The Foreign Emoluments Clause requires "the Consent of the Congress" before any federal officer accepts a present from a foreign state. No consent vote has been reported.

2. The President's claims against his own government

IRS suit. The settlement of the President's $10 billion suit created a $1.776 billion "Anti-Weaponization Fund" from the Treasury's Judgment Fund and a provision shielding the family from audits. Judge Williams found the case collusive and sanctioned two private lawyers. DOJ withdrew the fund; it was reported the audit protection would remain. A bipartisan group of 35 former federal judges asked the court to examine possible fraud on the court.
$230 million DOJ claims. Administrative claims the President filed before taking office could be decided by officials who now report to him.

3. Corporate payments, settlements, and donations

Media settlements from ABC, Meta, Paramount, and X directed money toward the President's library foundation, which projects raising $950 million and has not disclosed its donors. Paramount's $16 million settlement came weeks before the FCC approved its merger.
The Washington Post identified about $333 million in donations for a White House ballroom, mostly from federally regulated companies; the Post found no evidence of a quid pro quo. CREW reported that most donors required to report the gifts on lobbying disclosures did not.
A "Gold Card" visa program offers residency for a $1 million personal gift; it is being challenged in court.

4. Pardons and clemency

Reuters counted at least 85 public officials charged with or convicted of corruption-related crimes who received clemency, most of them Republicans and four of them Democrats, including Rep. Henry Cuellar (D-TX). Reuters and CBS's 60 Minutes reported a paid pardon-advocacy market, with intermediaries reportedly charging up to $2 million. The White House says clemency corrects prosecutions by a "weaponized" prior Justice Department and that its review process is rigorous.

5. Dismantling of anti-corruption safeguards

The President fired 17 inspectors general in January 2025; a court found the process unlawful.
The Director of the Office of Government Ethics was removed, and the office went without a permanent director.
Protect Democracy reported the DOJ Public Integrity Section was cut from 36 lawyers to two.
The Justice Department disbanded its National Cryptocurrency Enforcement Team, and the SEC dropped or paused major crypto cases, including a fraud case against WLF adviser Justin Sun.
In the Eric Adams case, the prosecutor leading it reported that defense counsel proposed a quid pro quo; at least six officials resigned rather than dismiss the case.

6. Senior officials

DHS. A newly formed company received a $143 million no-bid DHS ad contract featuring then-Secretary Kristi Noem; on her last day, DHS agreed to buy aircraft from a company whose chairman had donated to her PAC. The DHS inspector general referred its Corey Lewandowski investigation to DOJ. All deny wrongdoing.
Tom Homan. Reuters reported that he accepted $50,000 in cash from an undercover FBI agent in 2024; the FBI and DOJ closed the case citing "no credible evidence" of wrongdoing.
Labor. The Labor Department inspector general found misconduct by former Secretary Lori Chavez-DeRemer, including unreported gifts.
Envoys. Steve Witkoff reported nearly $107 million in 2025 income from a WLF-affiliated company (the White House says he divested). CREW's suit alleges Jared Kushner negotiates for the U.S. without Senate confirmation or public financial disclosure while his firm manages billions from Gulf sovereign funds; Kushner says he is an unpaid volunteer who complies with ethics rules.
Other matters include the Commerce Secretary's family firm and tariff policy, FBI Director Kash Patel's use of the FBI jet, and Hatch Act complaints against cabinet members and senior aides. No findings have been reported in these.

7. The President's sons and federal money

CNN reported that companies backed by Donald Trump Jr.'s 1789 Capital received more than $1.6 billion in federal contracts and grants in the first 500 days, with a sharp rise in no-bid awards. CNN found no evidence that 1789 or Trump Jr. pushed for the funding.

8. Members of Congress

Corruption is not limited to one branch or one party. The Office of Congressional Conduct and House Ethics Committee have found "substantial reason to believe" or opened inquiries involving several members, including Reps. Andy Ogles, Cory Mills, Lance Gooden, Nancy Mace, and Tony Gonzales; Sen. Jim Justice was publicly rebuked for a late financial disclosure; and multiple members filed stock-trade disclosures late. These remain unproven unless the Ethics Committees have made findings.

What no one has found: Several investigations — including the Washington Post on the ballroom, CNN on 1789 Capital, CNBC on foreign licensing, and NBC on the April 2025 tariff pause — explicitly found no evidence of a direct quid pro quo. That is exactly why Congress needs subpoena power: the documents that would prove or disprove these concerns are in government and private files, not in public reporting.

What do the Constitution and federal law say about corruption?

The Framers wrote anti-corruption rules directly into the Constitution:

Foreign Emoluments Clause (Art. I, § 9, cl. 8): "[N]o Person holding any Office of Profit or Trust under them, shall, without the Consent of the Congress, accept of any present, Emolument, Office, or Title, of any kind whatever, from any King, Prince, or foreign State." The Clause gives Congress — not the President — the decision whether to consent.
Domestic Emoluments Clause (Art. II, § 1, cl. 7): the President receives a fixed compensation "and he shall not receive within that Period any other Emolument from the United States, or any of them."
Impeachment (Art. II, § 4): "The President, Vice President and all civil Officers of the United States, shall be removed from Office on Impeachment for, and Conviction of, Treason, Bribery, or other high Crimes and Misdemeanors."
Appropriations Clause (Art. I, § 9, cl. 7): "No Money shall be drawn from the Treasury, but in Consequence of Appropriations made by Law."
Discipline of members (Art. I, § 5, cl. 2): each House may "punish its Members for disorderly Behaviour, and, with the Concurrence of two thirds, expel a Member."
Take Care Clause (Art. II, § 3): the President "shall take Care that the Laws be faithfully executed."

Key federal statutes

Law	What it covers	Note
18 U.S.C. § 201	Bribery of and illegal gratuities to federal public officials	Requires an "official act" (McDonnell v. United States, 579 U.S. 550 (2016))
18 U.S.C. § 208	Officials acting on matters affecting their own financial interests	Does not apply to the President or Vice President (18 U.S.C. § 202(c))
18 U.S.C. § 666	Bribery involving programs receiving federal funds	Does not reach gratuities (Snyder v. United States, 603 U.S. 1 (2024))
18 U.S.C. §§ 1346, 1951	Honest-services fraud; extortion under color of official right	Honest services limited to bribes and kickbacks (Skilling v. United States, 561 U.S. 358 (2010))
5 U.S.C. §§ 13101–13111 (Ethics in Government Act)	Public financial disclosure for senior officials	Enforcement is largely civil and slow
5 U.S.C. § 7342 (Foreign Gifts and Decorations Act)	Gifts from foreign governments to federal employees	Accepting on behalf of the U.S. is a key question for the 747
STOCK Act (Pub. L. 112-105)	Insider-trading duties and periodic trade reports	Late-filing penalties are modest
5 U.S.C. §§ 7321–7326 (Hatch Act)	Political activity by federal employees	President and Vice President exempt
5 U.S.C. §§ 401–424 (Inspector General Act)	IG independence; 30-day notice and reasons to Congress before removal	No express remedy for violations
31 U.S.C. §§ 1301(a), 1304, 1341	Purpose Statute, Judgment Fund, Anti-Deficiency Act	Basis for the IRS-fund and DHS-ad challenges
2 U.S.C. § 1601 et seq.; 22 U.S.C. § 611 et seq.	Lobbying Disclosure Act; Foreign Agents Registration Act	Paid pardon advocacy is not clearly covered
44 U.S.C. §§ 2201–2209, 3101 et seq.	Presidential and Federal Records Acts	Govern preservation of official communications

Why existing law falls short

Over the past decade, the Supreme Court has narrowed federal corruption law — in McDonnell (official acts), Skilling (honest services), Kelly v. United States, 590 U.S. 391 (2020), Percoco v. United States, 598 U.S. 319 (2023), and Snyder (gratuities). In each case the Court read the statute Congress wrote; in each case Congress can write a clearer one. Emoluments suits have also struggled to reach the merits: the D.C. Circuit held that individual members of Congress lacked standing (Blumenthal v. Trump, 949 F.3d 14 (D.C. Cir. 2020)), and other first-term emoluments cases were vacated as moot after the term ended. And the pardon power is, under Ex parte Garland, 71 U.S. (4 Wall.) 333, 380 (1866) (the pardon power "is not subject to legislative control"), United States v. Klein, 80 U.S. (13 Wall.) 128, 147–48 (1872), and Trump v. United States, 603 U.S. 593 (2024), beyond Congress's power to limit by statute. These gaps are the legislative purpose for this investigation.

What the administration and the subjects say

Fairness requires stating the other side. The White House says the President and his family "have not engaged and will not engage in conflicts of interest," that the President's sons run the family businesses, and that outside advisers manage his investment accounts. It describes the Qatari aircraft as a lawful gift to the Air Force under the Foreign Gifts and Decorations Act, the ballroom donors as patriotic Americans, and clemency as a correction of politically motivated prosecutions. World Liberty Financial calls itself a private American company that has received no special treatment. Kushner says he is an unpaid volunteer who complies with ethics rules. Individual officials and members named above deny wrongdoing, and none has been convicted in these matters. These responses deserve to be tested under oath and against the documents — which is what a fair investigation does.

Does Congress have the authority to investigate corruption in the executive branch?

Yes — investigating corruption is one of the oldest uses of congressional power. McGrain v. Daugherty, the case that confirmed Congress's subpoena power, arose from the Teapot Dome bribery scandal.

The power exists. "[T]he power of inquiry — with process to enforce it — is an essential and appropriate auxiliary to the legislative function." McGrain v. Daugherty, 273 U.S. 135, 174 (1927).
It is broad. "[T]he scope of the power of inquiry . . . is as penetrating and far-reaching as the potential power to enact and appropriate under the Constitution." Eastland v. U.S. Servicemen's Fund, 421 U.S. 491, 504 n.15 (1975) (quoting Barenblatt v. United States, 360 U.S. 109, 111 (1959)). It includes probing "corruption, inefficiency or waste" in federal agencies. Watkins v. United States, 354 U.S. 178, 187 (1957). The Court also made clear that its limits on exposure did not concern "the power of the Congress to inquire into and publicize corruption, maladministration or inefficiency in agencies of the Government." Id. at 200 n.33.
It must serve a legislative purpose. There is no power "to expose for the sake of exposure," Watkins, 354 U.S. at 200, and Congress may not act as a law-enforcement agency or try anyone for a crime.
The President's information gets special treatment. Trump v. Mazars USA, LLP, 591 U.S. 848 (2020), requires courts to weigh separation-of-powers concerns when Congress subpoenas the President's information, "whether personal or official": whether the need could be met by other sources, whether the subpoena is no broader than reasonably necessary, how detailed the evidence of legislative purpose is, and the burden on the President. Records held by agencies, private companies, foundations, and former officials are governed by the ordinary standard.
Accommodation comes first. The branches have an "implicit constitutional mandate to seek optimal accommodation." United States v. AT&T, 567 F.2d 121, 127 (D.C. Cir. 1977).
Limits from Trump v. United States. The President has absolute immunity from criminal prosecution for acts within his "conclusive and preclusive" constitutional authority — including the pardon power — and presumptive immunity for other official acts, but no immunity for unofficial acts. That decision concerns criminal prosecution; it does not bar Congress from investigating how agencies, officials, and private parties behaved, or from legislating about the businesses, gifts, and payments surrounding the presidency. Reforms should be drafted to regulate private conduct, agencies, and officials rather than to restrict core presidential powers.

A model statement of legislative purpose

The Committee is investigating payments, gifts, investments, and other benefits from foreign governments, domestic governments, and private parties to federal officials, their families, their businesses, and affiliated foundations; the use of federal settlements and the Judgment Fund; the award of federal contracts and grants; clemency advocacy and payments for access; the removal of inspectors general and the weakening of federal anti-corruption units; and compliance with financial-disclosure, gift, lobbying, records, and appropriations laws — in order to determine whether existing law, including the Foreign and Domestic Emoluments Clauses, 18 U.S.C. §§ 201, 208, and 666, the Ethics in Government Act, the STOCK Act, the Foreign Gifts and Decorations Act, the Inspector General Act, the Lobbying Disclosure Act, and 31 U.S.C. §§ 1301 and 1304, is adequate; whether appropriated funds were spent as Congress directed; whether Congress should give or withhold consent under Article I, Section 9; and what legislation is needed to prevent public office from being used for private gain.

Linking each topic to Congress's powers

Topic	Constitutional and statutory hook	Legislation it informs
Foreign payments to family businesses; WLF and UAE	Foreign Emoluments Clause (Congress decides consent); Foreign Commerce Clause; export-control statutes	Emoluments disclosure and enforcement act; export-decision conflict screening
Qatari 747 and foreign gifts	Foreign Emoluments Clause; Foreign Gifts and Decorations Act; Property Clause (Art. IV, § 3, cl. 2)	Public consent votes; bar transfer of government property to private foundations
Miami land and state benefits	Domestic Emoluments Clause; Spending Clause	Bar state or federal gifts to a sitting President's library foundation
IRS suit and Judgment Fund	Appropriations Clause; 31 U.S.C. § 1304; 28 U.S.C. § 2414	Judgment Fund limits; recusal when the President or family is a party
DHS ads and contracts	Appropriations Clause; Purpose Statute; procurement law	Publicity and propaganda limits; no-bid contract transparency
Clemency advocacy market	Commerce Clause; Lobbying Disclosure Act; 18 U.S.C. § 201	Pardon-lobbying disclosure; criminal ban on paying for access to clemency
IG firings, OGE, Public Integrity Section	Necessary and Proper Clause; Appropriations	For-cause protection and remedies for IGs; funding floors for anti-corruption units
Officials' and members' stock trading and disclosure	Necessary and Proper Clause; Art. I, § 5	Stock-trading ban across all three branches
Envoys without confirmation or disclosure (CREW v. Kushner)	Appointments Clause; Ethics in Government Act	Function-based disclosure duties for anyone negotiating for the U.S.

What is a lawful five-phase investigative plan?

The 120th Congress convenes on January 3, 2027 (U.S. Const. amend. XX, § 2). Subpoenas from the 119th Congress expire when it ends, so the work starts over — and starts fast.

Phase 1 — Organize and preserve (January 2027). Adopt committee rules and a written authorizing resolution or chair's memorandum stating the legislative purpose above. Send preservation letters on day one. Assign bipartisan staff, a records custodian, and a forensic accountant; invite the minority into document review and interviews.

Phase 2 — Build the public record (days 1–60). Assemble what already exists: financial disclosures filed with the Office of Government Ethics; court opinions and filings (the IRS sanctions order, the IG ruling, Sistrunk Seeds, CREW v. Kushner, the DHS ad cases, the WLF emoluments suit); inspector general reports and referrals; OCC bank-charter filings; SEC dismissal orders; lobbying and FARA registrations; FEC records; and federal contract data from USAspending.gov. Ask the GAO for legal opinions (for example, whether the Judgment Fund could lawfully pay the anti-weaponization fund) and the Congressional Research Service for legal memoranda.

Phase 3 — Follow the money (days 30–120). Map each payment from source to recipient: foreign governments and sovereign funds, corporations and donors, family entities, the library foundation, and contracts and policy actions that followed. A timeline that places payments next to official decisions is the heart of any corruption inquiry. Request records voluntarily first, with reasonable deadlines and in-camera review for sensitive material, and document every exchange.

Phase 4 — Compulsory process. When requests are refused or slow-walked, issue narrow subpoenas tied to the stated purpose. Start with agencies, private companies, foundations, and banks, then career officials, then senior officials, and seek the President's own information last and only where Mazars can be satisfied. Use the enforcement options in our subpoena playbook: civil enforcement, criminal contempt referral under 2 U.S.C. §§ 192 and 194, and leverage through appropriations and nominations.

Phase 5 — Hearings, report, and action. Hold public hearings with documents in hand. Publish a report that separates findings from allegations. Make referrals to DOJ, state prosecutors, bar authorities, the Office of Special Counsel, or the Ethics Committees where the evidence supports them. Hold consent votes under the Foreign Emoluments Clause. Introduce and pass the reforms below.

Which committees have jurisdiction?

Chamber	Committee	Focus
House	Oversight and Government Reform	Government-wide corruption, emoluments, IGs, OGE, contracts, records
House	Judiciary	DOJ, clemency, Public Integrity Section, federal criminal law, impeachment
House	Financial Services	Crypto, stablecoins, OCC charters, SEC enforcement
House	Ways and Means	IRS, the IRS settlement, tax-audit protections
House	Foreign Affairs	Foreign gifts, envoys, Gulf deals, export controls
House	Homeland Security	DHS contracts and advertising
House	Ethics	Member conduct and House rules
Senate	Homeland Security and Governmental Affairs; Permanent Subcommittee on Investigations	Government-wide oversight, IGs, records, deep-dive investigations
Senate	Judiciary	DOJ, clemency, criminal law
Senate	Banking, Housing, and Urban Affairs	Crypto, OCC, SEC, export controls
Senate	Finance	IRS and tax matters
Senate	Foreign Relations	Foreign gifts, envoys, the Appointments Clause
Senate	Select Committee on Ethics	Senator conduct
Both	Appropriations	Funding conditions on every agency above

What can members in the minority or without a gavel do?

Write letters and requests for records; ask the GAO and inspectors general to open reviews; use the "seven-member rule" (5 U.S.C. § 2954), which lets seven members of the House Oversight Committee or five members of the Senate Homeland Security and Governmental Affairs Committee request agency information (its enforceability in court is unsettled); file FOIA requests; hold forums with former officials and experts; file amicus briefs; introduce bills; and file complaints with the Office of Special Counsel or the Ethics Committees.

How should Congress preserve evidence and what should it subpoena?

Preservation letters come first

Records are lost to auto-delete settings, personal devices, and ephemeral messaging apps. Before any request for production, committees should send preservation letters to:

Government: the White House Office and Office of the Counsel to the President; DOJ (Office of the Attorney General, Civil Division, Public Integrity Section, Office of the Pardon Attorney); Treasury, the IRS, and the Bureau of the Fiscal Service (Judgment Fund); Defense and the Air Force (the Qatari aircraft); State (foreign gifts, envoys); Commerce (export controls); DHS (contracts and advertising); the OCC and SEC; the Office of Government Ethics; and the National Archives.
Private parties: World Liberty Financial and affiliates, the Trump Organization, Trump Media, the Donald J. Trump Presidential Library Foundation, the White House ballroom fundraising entities, the inaugural committee, contractors named in the reporting, and relevant banks and crypto exchanges.

Letters should cite the Presidential Records Act, the Federal Records Act, and 18 U.S.C. §§ 1505 and 1519; cover texts, Signal and other encrypted or disappearing-message apps, personal email and devices used for official business, calendars, visitor logs, call logs, photos, videos, wallet addresses, and blockchain transaction records; and request written confirmation within 10 days. Because subpoenas expire with each Congress (Committee on the Judiciary v. Miers, 542 F.3d 909 (D.C. Cir. 2008)), early preservation protects the record for the full two years.

Documents, photos, and videos to request

Topic	Records
Foreign money	Ownership and capital records for WLF and affiliates; the Tahnoon-linked share purchase; MGX's USD1 settlement; distributions to family entities; communications with foreign officials; export-control decision files for the UAE and G42; OCC bank-charter application files
Qatari 747	Acceptance documents, legal opinions approving the gift, retrofit contracts and costs, security reviews, any agreement on transfer to the library
Library foundation	Donor lists, settlement agreements directing payments to the foundation, the Miami land transfer, commercial development plans
IRS settlement	Settlement negotiations, approval memos, Judgment Fund certification requests, communications between private counsel and DOJ, records of the audit-protection provision and dropped IRS examinations
Clemency	Pardon applications and who delivered them, communications with advocates and fundraisers, Office of the Pardon Attorney recommendations (or their absence), records tied to donations near the time of a grant
Contracts	Solicitations, sole-source justifications, and award files for the DHS ad and aircraft contracts and awards to companies tied to officials' families
Anti-corruption capacity	Records of the IG removals and notices to Congress, the Public Integrity Section reorganization, and dismissal decisions in corruption and crypto cases (including the Eric Adams case and the Justin Sun case)
Photos and video	Event photos and guest lists for the meme-coin dinners, ballroom donor events, and fundraisers; White House and Mar-a-Lago visitor logs; video of public events where official business and private business overlapped

Witnesses

Witness	Why	Approach
Career prosecutors and staff who resigned or were reassigned (Public Integrity Section; the Adams case; the Judgment Fund)	Firsthand knowledge of departures from normal practice	Voluntary interview with counsel; subpoena only if needed; whistleblower protections
Fired inspectors general	IG independence and what they were investigating when removed	Voluntary testimony
Office of the Pardon Attorney staff	How clemency decisions were made	Voluntary, then subpoena
Ethics officials (OGE, agency ethics officers)	Waivers, disclosures, and ethics agreements	Document request, then testimony
Compliance officers and executives of private entities	Who paid whom, when, and why	Subpoena if needed; private parties do not have executive privilege
Pardon advocates and fundraisers	Fees and access	Subpoena if needed; respect the Fifth Amendment privilege
Senior officials and envoys	Decisions and potential conflicts	Last, after the documentary record is built

For current and former federal employees, see our guide Whistleblowers and Congress. For claims of executive privilege by White House aides, see Stephen Miller, Executive Privilege, and What Congress Can Do. Executive privilege belongs to the President, must be specifically asserted, and does not cover private business records. District courts have rejected claims that senior advisers are absolutely immune from appearing (Committee on the Judiciary v. Miers, 558 F. Supp. 2d 53 (D.D.C. 2008); Committee on the Judiciary v. McGahn, 415 F. Supp. 3d 148 (D.D.C. 2019)).

The McGahn appeal ended without a final appellate ruling on immunity after the parties reached an agreement in 2021. Limits run the other way too: a committee seeking presidential communications must show the material is "demonstrably critical to the responsible fulfillment of the Committee's functions," Senate Select Committee on Presidential Campaign Activities v. Nixon, 498 F.2d 725, 731 (D.C. Cir. 1974) (en banc), while the separate deliberative-process privilege that agencies invoke "disappears altogether when there is any reason to believe government misconduct occurred," In re Sealed Case, 121 F.3d 729, 746 (D.C. Cir. 1997) (a grand-jury case whose reasoning committees often invoke).

How can Congress hold officials accountable — lawfully?

Congress cannot convict anyone of a crime. It can build a record that other lawful processes rely on, and it has accountability tools of its own.

Tool	Who it reaches	Notes
Criminal referral to DOJ or state prosecutors	Anyone	A referral is a recommendation, not a charge. The general federal limitations period is five years (18 U.S.C. § 3282), and the President's pardon power reaches only federal offenses
Impeachment (Art. I, § 2, cl. 5; Art. I, § 3, cl. 6–7; Art. II, § 4)	The President, Vice President, and civil officers	Judgment may extend to removal and "disqualification to hold and enjoy any Office of honor, Trust or Profit under the United States." See our model articles, investigative plan, and model articles against AG Todd Blanche
Ethics Committee action, censure, or expulsion (Art. I, § 5, cl. 2)	Members of Congress	Expulsion requires two-thirds of the chamber
Consent votes (Art. I, § 9, cl. 8)	Any federal officeholder offered a foreign present or emolument	Congress can decline consent and require return or payment to the Treasury
Power of the purse	Agencies and programs	Funding conditions and limitations on specific uses
Advice and consent	Nominees	The Senate can examine nominees' role in the matters above
Referrals to bar authorities and the Office of Special Counsel	Attorneys; Hatch Act violations by covered employees	Professional and administrative discipline
Public reports	Everyone	A documented public record deters future misconduct

Guardrails that keep the investigation lawful and fair

State the purpose and stay within it. Tie every request and subpoena to the written legislative purpose (Watkins; Mazars).
Protect career staff and whistleblowers. Career employees who followed lawful instructions are witnesses, not targets. Federal employees have a statutory right to communicate with Congress (5 U.S.C. § 7211); obstructing a congressional inquiry is a crime (18 U.S.C. § 1505); and whistleblower reprisal is prohibited (5 U.S.C. § 2302(b)(8)). Allow counsel and use voluntary interviews first.
Presume innocence and label carefully. Separate findings from allegations in every report. Use "allegedly" until facts are established, and include each subject's response.
Respect the Fifth Amendment. Witnesses may invoke the privilege against self-incrimination. Grants of use immunity (18 U.S.C. §§ 6002–6005) can make later prosecution very difficult (United States v. North, 910 F.2d 843 (D.C. Cir.), modified, 920 F.2d 940 (D.C. Cir. 1990)); consult DOJ as the statute requires and weigh public testimony against future accountability.
No legislative punishment. Reforms must be general rules that apply to any official in any administration, not measures that single out named people for punishment (United States v. Lovett, 328 U.S. 303 (1946)).
Know the limits of Speech or Debate protection. Committee work is protected, but press releases and newsletters are not (Hutchinson v. Proxmire, 443 U.S. 111 (1979)). Keep public statements accurate and measured.
Protect private information. Limit access to tax, bank, and personal records; follow 26 U.S.C. § 6103 for tax information; and do not publish personal data about private individuals.
Apply the same standard to both parties. Investigate members of Congress and officials of either party under the same rules. Corruption is a threat to the rule of law, not a partisan talking point.

What anti-corruption reforms should the 120th Congress pass?

Every reform below applies to every future President, administration, and Congress. Model text and veto strategy are in our model bills and veto-proof reforms guides.

#	Reform	Constitutional basis	What it does
1	Emoluments Enforcement and Disclosure Act	Art. I, § 9, cl. 8; Art. II, § 1, cl. 7; Necessary and Proper Clause	Requires quarterly public disclosure of payments from foreign and state governments (and entities they control) to businesses owned by the President, Vice President, and their immediate families; creates a cause of action and clear standing so disputes reach the merits; sets a public consent process so silence is never treated as consent
2	Presidential Library Integrity Act	Property Clause; Spending Clause; Domestic Emoluments Clause	Bars state and federal gifts of land, money, or tax benefits to a sitting President's library foundation; requires disclosure of donors above $1,000; bars directing litigation settlements to a sitting President's foundation; bars transfer of government aircraft or property to any private foundation
3	Crypto and Financial Conflicts Act	Commerce Clause; Necessary and Proper Clause	Bars the President, Vice President, members of Congress, senior officials, and their immediate families from issuing, promoting, or profiting from digital assets and stablecoins during their service; requires disclosure of foreign investment in businesses they own
4	Stock trading ban for all three branches	Necessary and Proper Clause; Art. I, § 5	Bans individual stock trading by members, the President and Vice President, senior officials, and federal judges, with family-account safeguards, diversified-fund exceptions, and real penalties
5	Judgment Fund integrity	Appropriations Clause	Bars Judgment Fund payments in suits brought by a sitting President or family members against the United States; requires court approval and public disclosure of large settlements; requires recusal of officials appointed by a party to the suit
6	Clemency transparency and anti-bribery	Commerce Clause; Necessary and Proper Clause	Requires registration and fee disclosure for anyone paid to seek clemency; makes it a crime to pay or accept payment for access to the clemency process; requires public listing of each grant with the advocates involved. These provisions regulate private conduct and do not limit the pardon power itself
7	Inspector General independence	Necessary and Proper Clause; Appropriations	Adds a judicial remedy for removals without the required 30-day notice and reasons; bars acting IGs drawn from political appointees; protects IG budgets
8	Public Integrity floor	Appropriations Clause	Sets minimum staffing and reporting for the DOJ Public Integrity Section and FBI public-corruption units, with annual reports to Congress on cases opened and closed
9	Restore the reach of bribery and fraud law	Necessary and Proper Clause	Clarifies "official act" after McDonnell, restores gratuity liability for state and local officials after Snyder, and defines honest-services fraud to cover undisclosed self-dealing
10	Function-based ethics disclosure	Appointments Clause; Necessary and Proper Clause	Requires anyone who negotiates for the United States, paid or unpaid, to file public financial disclosures and follow conflict rules
11	Contracting transparency	Spending Clause	Requires public posting of sole-source justifications, beneficial-ownership disclosure for contractors, and flags for awards to entities tied to officials' families
12	Pause the statute of limitations	Necessary and Proper Clause	Tolls the federal limitations period for offenses by a President while in office, prospectively (a revived expired period would raise Stogner v. California, 539 U.S. 607 (2003), concerns)
13	Strengthen OGE and the Hatch Act	Necessary and Proper Clause	Gives OGE subpoena and civil-penalty authority, requires ethics agreements to be public, increases penalties for late or false disclosures, and strengthens Office of Special Counsel enforcement of the Hatch Act
14	Records preservation	Necessary and Proper Clause	Requires official business on ephemeral apps to be captured within 20 days, with penalties for willful destruction

The 2012 STOCK Act passed with overwhelming bipartisan support. Anti-corruption reform can be bipartisan again when it is written as a rule for everyone.

Let's talk

Corruption is not a Republican or Democratic problem. It is a rule-of-law problem, and it costs every taxpayer, every honest business, and every public servant who plays by the rules. If you are a member of the 120th Congress, a committee staffer, an inspector general, or a career public servant who wants to build a lawful record and pass lasting reforms, the Biazzo Law Government Oversight Program can help with investigative plans, preservation letters, subpoena strategy, and model legislation. Contact us here.

Companion resources for the 120th Congress

Follow the money and emoluments

Taxpayer money and the Justice Department

DHS and senior officials

Abuse of power and the rule of law

Tools for the 120th Congress

Frequently asked questions

Can Congress investigate a sitting President's businesses? Yes, if the investigation serves a valid legislative purpose, such as writing emoluments, disclosure, or conflict-of-interest laws. Under Trump v. Mazars, subpoenas for the President's own information receive extra scrutiny; records held by companies, foundations, banks, and agencies are subject to the ordinary standard.

What is an emolument, and who decides whether one is allowed? An emolument is a profit, payment, or advantage. The Foreign Emoluments Clause bars federal officeholders from accepting presents or emoluments from foreign states "without the Consent of the Congress." Congress, not the President, decides.

Can Congress stop a President from pardoning someone? No. The pardon power cannot be limited by statute. But Congress can require disclosure from paid clemency advocates, criminalize paying for access, investigate how grants were made, and consider a constitutional amendment.

Can Congress prosecute corrupt officials? No. Congress can investigate, refer evidence to prosecutors, impeach and remove officers, discipline its own members, and pass laws. Prosecution belongs to DOJ and state prosecutors.

Do conflict-of-interest laws apply to the President? Some do and some don't. 18 U.S.C. § 208 does not apply to the President or Vice President, but the Emoluments Clauses, bribery law, financial-disclosure requirements, and securities laws do.

Why should every citizen care? Because corruption means government decisions are made for private gain instead of the public good — in contracts, taxes, prosecutions, and foreign policy. The rule of law only works if it applies to the powerful too.

Disclaimer

This post is for general informational and educational purposes only. It is not legal advice and does not create an attorney-client relationship. It compiles court rulings, official findings, investigative reporting, and allegations as of November 13, 2026; facts in pending matters may change. Allegations are not proof, and every person named is presumed innocent of any crime unless and until proven guilty in a court of law. Biazzo Law, PLLC was granted leave by the court (ECF No. 64) and filed an amicus brief (ECF No. 65) supporting the plaintiffs' opposition to the motions to dismiss in Sistrunk Seeds v. Trump.