Since Donald Trump declared his candidacy for president in late 2015, at least $16.1 million has poured into Trump Organization-managed and branded hotels, golf courses and restaurants from his campaign, Republican organizations, and government agencies. Because Trump’s business empire is overseen by a trust of which he is the sole beneficiary, he profits from these hotel stays, banquet hall rentals and meals.

To arrive at the total, we compiled campaign finance reports from the Federal Election Commission; state government spending gleaned from dozens of state websites and portals; and federal agency expenditure records obtained by the Washington-based transparency organization Property of the People. For this project, Property of the People filed Freedom of Information Act requests with 15 federal agencies and sued four of them to obtain records. (The organization is also attempting to procure comparable records for the Obama era.)

The vast majority of the money — at least $13.5 million, or more than 84 percent of what we tracked — was spent by Trump’s presidential campaign (including on Tag Air, the entity that operates Trump’s personal airplane). Republican Senate and House political committees and campaigns have shelled out at least another $2.1 million at Trump properties. At least $400,000 has been spent by federal, state and local agencies. (For example, the Florida Police Chiefs Association held its summer conference last year at the Trump National Doral Miami.) The state and local tally appears to be a gross undercount because of the agencies’ spotty disclosures and reporting.

The use of taxpayer dollars at Trump hotels is under scrutiny in a closely watched lawsuit in Maryland federal court. The District of Columbia and the state of Maryland sued Trump, citing a venerable anti-corruption provision of the U.S. Constitution known as the Emoluments Clause. It prohibits any financial gift, or emolument, from benefiting a sitting public official, including the president.

The judge in that case, Peter Messitte, is expected to make a final ruling by the end of July. Last month, he allowed the case to proceed, concluding in his opinion that a trip to the Trump International Hotel in Washington by Maine Gov. Paul LePage “rather clearly suggests that Maryland and the District of Columbia may very well feel themselves obliged, i.e., coerced, to patronize the Hotel in order to help them obtain federal favors.” The nonprofit group Citizens for Responsibility and Ethics in Washington, or CREW, which is co-counsel in the Maryland/D.C. case, is also the plaintiff in a separate emoluments suit, which was dismissed; an appeal of that decision is pending.

One of Trump’s lawyers, Sheri Dillon, has argued in the past that paying a hotel bill would never have qualified as an emolument when the Constitution was written; “instead, it would have been thought of as a value-for-value exchange.” (Countered Norman Eisen, chairman of CREW and a former ethics chief under President Obama, “all of these competing interests are openly and nakedly trying to buy off a president…. Obviously, the government spending, whether it’s federal, state, or local, is a domestic emolument.”)

The Trump Organization and the White House did not respond to requests for comment.

There are few ways to avoid the implication that the use of Trump properties is endorsed by the federal government, said Don Fox, the former acting director of the U.S. Office of Government Ethics, which oversees the government’s ethics rules. One way to avoid the problem, Fox suggested, would be a public statement by Trump along the following lines: “Stay where you need to stay. Basically, do what’s best for the taxpayer.”

But Trump has sent a very different signal with his actions. In his 18 months in office, he has stayed at his hotels or Mar-a-Lago, his Palm Beach, Fla., estate and club, nearly a third of the time: 161 days and counting.

“Trump appears to be commandeering federal resources in order to maximize revenues at Trump properties, and he does this by visiting properties close to the White House,” said Kathleen Clark, a law professor at Washington University in St. Louis and an expert in legal ethics. “And when he travels to the golf courses in Florida, Virginia and New Jersey, other agencies that are involved in supporting the president end up spending money.”

There are no rules barring federal employees from patronizing Trump properties. Employees can be reimbursed for expenditures according to federal travel regulations, including the cost of a hotel room or the price of a meal. There are limits to these per diems — employees cover any cost beyond the reimbursable amount — but rates at many Trump properties are within that range, reimbursement records show. (The General Services Administration provides a handy calculator to figure out what the per diems are depending on where an employee is traveling and when.)

But even if a stay at a Trump property falls within federal travel regulations, it’s hard to escape the fact that the president is personally benefiting from taxpayer dollars — and that federal employees have a potential incentive to curry favor with their ultimate boss.

Consider a trip last year by Matthew Snyder, who works for the Commerce Department’s National Institute of Standards and Technology, or NIST, in Colorado. Snyder traveled to Washington, D.C., for 11 days in April 2017 to attend managerial training. He stayed first at a Marriott in Gaithersburg, Md. (where NIST is headquartered), and then at the Trump International Hotel in Washington. Both rooms cost $242 per night, and both were covered by his per diem for lodging. (According to federal guidelines, $242 is the maximum nightly amount the government will reimburse for visits to the D.C. area in the spring season.)

The Trump International Hotel appeared to cultivate at least some federal business, offering a discounted rate for government employees at the time. (A hotel staffer told us that the Trump International no longer offers a government discount.) Snyder benefitted from such a lowered price. His receipt shows a “room type” code of SK1, which refers to a suite, and a rate plan listed as “DISGOV.” The typical suite at the hotel starts at $740, according to its website.

Matthew Snyder's Trump International Hotel Washington receipt

Receipts from Matthew Snyder's stay at the Trump International Hotel Washington, D.C. show room and rate type.

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Snyder said in an interview that he chose to stay at the Trump hotel because it was within walking distance of a conference he attended, and that its proximity allowed him to save the cost of renting a car.

But several hotels in a six-block radius provide cheaper rates, including the Hotel Harrington, which sits only a block north of the Trump hotel and charges $175 for a single room. And receipts show that Snyder rented a car and racked up $336 in valet parking charges during his stay at the Trump International.

When asked about cheaper nearby hotels and the parking costs, Snyder wrote in an email: “I could offer clarity, but I choose not to.” In the end, Snyder charged about $2,740 to a government charge card at the Trump International over five days, including room service and valet parking.

In response to questions, the Commerce Department said that records it reviewed “appear to show that a handful of career employees at the Department of Commerce who patronized Trump-owned properties complied with federal travel regulations.” Other Commerce Department employees asked about their spending at Trump properties explained that it was the most affordable option (in one instance involving a hotel in Las Vegas) or that the visit was made while off-duty (in the case of a trip to Los Angeles).

Other federal agencies offered a variety of responses. A statement from the Defense Department, whose employees spent nearly $150,000 at Trump properties between January and June 2017, said its staff are “free to choose where they stay, with the understanding that the government will reimburse no more than the lodging portion of the established per diem limit for the place of temporary duty. There are no plans to change or create guidance at this time.”

The Secret Service also patronized Trump properties while agents were protecting the president or his family. In March 2017, for example, the agency paid $27,724.32 at the Trump golf course and resort in Doonbeg, Ireland. The stay was to “support E. Trump Visit,” receipts note, which took place in April, when Eric Trump went to the resort for two days of business meetings, the Irish press reported at the time.

The State Department, which is listed as the federal agency reimbursing the costs of the Ireland trip, said the Secret Service is in charge of its own travel expenses when it relates to presidential security. For other stays at Trump properties, the State Department said it does “not afford the Trump Organization preferential treatment,” adding that its employees are “routinely counseled on federal ethics law and on the importance of avoiding even the appearance that department resources are misused for the benefit of any outside organizations or private interests.”

The State Department doesn’t receive any preferential treatment when employees stay at Mar-a-Lago, receipts show. For an April 2017 trip by then-Secretary of State Rex Tillerson, his chief of staff and another aide for meetings with Chinese President Xi Jinping, each room cost $546 per night, which was described by the Trump Organization as a “rack rate,” or a non-discounted, standard room. The spending was approved by State Department officials, who noted that the trip was to “meet with POTUS for a high level meeting.”