The Trump International Hotel in Washington, pictured in December. (Alex Brandon/AP)

Despite President Trump’s promise to donate all profits from foreign-government sources at his Washington hotel and other businesses, recently released internal documents reveal that Trump’s private company has made only a limited effort at identifying foreign funds.

An undated document sent throughout the Trump Organization, called “Donations of Profits from Foreign Government Patronage,” says asking guests to identify whether they are connected to a foreign government would be “impractical” and “impede upon personal privacy and diminish the guest experience of our brand.”

“It is not the intention nor design of this policy for our properties to attempt to identify individual travelers who have not specifically identified themselves as being a representative of a foreign government entity,” the document says.

The company pamphlet shows the ease with which foreign money could be paid into the president’s business interests. Ethics advisers have warned that such payments could be used to curry favor with the president and could run afoul of a constitutional ban.

Trump Tower in New York. (Mike Segar/Reuters)

The Trump Organization said it would track foreign-state money by reviewing three sources: direct billings to foreign governments; group, banquet and catering business with foreign governments; and payments from a “reasonably identifiable foreign government entity.” But that description was similarly loose. The company said state-owned and state-controlled entities in industries such as banking and defense “may not be reasonably identifiable” and would not be included in profit donations.

Lawyers and ethics experts have said foreign-government payments to the Trump International Hotel, a few blocks from the White House, would violate the Constitution’s rarely litigated emoluments clause, which forbids foreign gifts or payments to the president. Trump’s attorneys have said the constitutional ban should not apply to fair-market transactions such as stays at the hotel.

The White House on Wednesday referred questions to the Trump Organization. The company said through a spokeswoman: “We take these matters seriously and are fully committed to complying with all of our legal and ethical obligations.”

In a letter Wednesday to company executives, Rep. Elijah E. Cummings (D-Md.), the top Democrat on the House Oversight Committee, said the pamphlet showed the company had little interest in identifying foreign funds.

“Complying with the United States Constitution is not an optional exercise, but a requirement for serving as our nation’s President,” Cummings said. “If President Trump believes that identifying all of the prohibited foreign emoluments he is currently receiving would be too challenging or would harm his business ventures, his options are to divest his ownership or submit a proposal to Congress to ask for our consent.”

Trump has refused to divest his assets and instead placed much of his real estate empire into a trust managed by his sons and a longtime employee. The president can pull money from that trust whenever he likes, documents show.

The company sent the nine-page pamphlet to lawmakers in response to an April request for details on how the company was complying with Trump’s promise, which he delivered in a January news conference at Trump Tower addressing potential conflicts of interest. In that conference, Trump attorney Sheri Dillon said he would donate foreign profits to the U.S. treasury because “he wants to do more than what the Constitution requires.”

The pamphlet was included as part of a Wednesday letter from Cummings seeking more information on top of the “meager response” the Oversight Committee received from the Trump company. Cummings urged the company to provide more documents to Congress by June 2.

Democrats on the House Judiciary Committee on Wednesday also sent a letter to Trump, urging the president to provide a detailed accounting of any potential presents, or “emoluments,” he or his business had received from foreign governments.

The Democrats’ letter, according to an advance copy provided to The Washington Post, also sought additional information on whether Trump’s business had recently had transactions with foreign agents or engaged in any new foreign deals.

The pamphlet said the company would not closely track foreign-government profits but would estimate them based on its internal revenue calculations. The money, it said, will be paid to the treasury in an annual lump sum.

Some ethics experts acknowledged the difficulty of identifying foreign cash but said the issue would continue to plague Trump if left unresolved.

“While it will be difficult for the president to demonstrate compliance with [the] agreement to donate hotel profits earned from foreign governments, he needs to do so in a transparent way to help dispel the continuing concerns about conflicts of interest and the emoluments clause,” said Ken Gross, a lawyer and former elections enforcement official who has advised presidential candidates from both parties. “Otherwise this issue will continue to cast a cloud.”

Norm Eisen, a chief ethics adviser to President Barack Obama who has joined a landmark emoluments lawsuit against Trump, said the “new document demonstrates that President Trump is not even living up to the inadequate commitment that he made to segregate foreign profits at his hotels.”

“This comes nowhere near the standard set by the Constitution, and we look forward to litigating this matter,” Eisen added. “Even the defective standard they set forth is not being followed. It is another example of the contempt this administration has for American law.”

Lawrence Noble, general counsel of the Campaign Legal Center, a nonprofit watchdog group, said the Trump company’s response “shows a complete disregard for the seriousness of the issues raised by President Trump’s earning money through his hotel.”

“This is not a question of what is convenient for the business; it is a question of what the Constitution requires,” Noble added. “While the president’s promise to turn over any emoluments arising from the hotel’s business was totally inadequate . . . this shows that even that weak promise was a sham.”

Trump’s business partners have voiced their own skepticism about the pledge in recent months. Phil Ruffin, the billionaire investor who co-owns the Trump International Hotel Las Vegas with the president, said in a Forbes interview in March he did not “know anything about” handing over foreign profits from their hotel. “They’re not going to do that,” he said.

The disclosure comes amid signs of an intensifying struggle between Trump and ethics officers and advocates inside and outside the federal government. On Monday, it was revealed that White House officials are seeking to stop the federal government’s top ethics officer from getting details about waivers granted to lobbyists and other appointees working in the Trump administration.

Documents released by the Office of Government Ethics included a May 17 letter from Mick Mulvaney, director of the Office of Management and Budget, who questioned whether the Office of Government Ethics has legal jurisdiction to get information about waivers that have been granted.

In addition to the questions asked by the Oversight Committee, Democrats on the House Financial Services Committee on Wednesday asked Deutsche Bank, Trump’s top lender, to supply information on whether loans made to the president and his family were tied to Russia.

“Congress remains in the dark on whether loans Deutsche Bank made to President Trump were guaranteed by the Russian Government, or were in any way connected to Russia,” the members wrote in a letter to John Cryan, the German mega-bank’s chief executive. “It is critical that you provide this Committee with the information necessary to assess the scope, findings and conclusions of your internal reviews.”

The letter was signed by the committee’s top Democrat, Rep. Maxine Waters (D-Calif.), and the top Democrats of key Financial Services subcommittees. The Democrats complained that the GOP chair of the Financial Services Committee, Rep. Jeb Hensarling (R-Tex.), has not responded to requests to use the committee’s full power to investigate Deutsche Bank and the work of its Moscow office.

“Deutsche Bank’s pattern of involvement in money laundering schemes with primarily Russian participation, its unconventional relationship with the President, and its repeated violations of U.S. banking laws over the past several years, all raise serious questions about whether the Bank’s reported reviews of the mirror trading scheme and Trump’s financial ties to Russia were sufficiently robust,” the Democrats wrote in their letter.

Deutsche Bank spokeswoman Renee Calabro declined to comment on the letter Wednesday.

Trump’s Washington hotel has this year hosted a number of events sponsored by or linked to foreign governments. In February, the hotel was the site of the Kuwait Embassy’s National Day celebration, bringing more than 600 visitors to the hotel’s ballroom. The event probably earned the Trump Organization tens of thousands of dollars in revenue, based on prevailing rates for luxury ballroom space in Washington.

A communications firm working on behalf of the Saudi Arabian government also booked guest rooms at the hotel in January, according to Politico.

This week, the Trump hotel in Washington hosted the Annual Conference on U.S.-Turkey Relations, sponsored by U.S. and Turkish defense and aerospace firms, some of which are state-supported.

The event this year featured speeches from Turkish government officials, including the country’s ambassador to the United States, who defended Turkey’s record on free expression and the response to demonstrators in Washington protesting against Turkish President Recep Tayyip Erdogan during his recent visit.

The Trump company’s acceptance of foreign payments also extends far beyond hotels. The Industrial and Commercial Bank of China, a state-owned entity, rents space at New York.