Environmental Protection Agency Administrator Scott Pruitt at a June Cabinet meeting. He resigned the next month. (AP)

Even though Washington has seen the last of beleaguered ex-Environmental Protection Agency head Scott Pruitt, the Trump administration remains the most ethically challenged in recent decades. With new revelations in recent days, the race to replace Pruitt as the next official to be taken down by allegations of misconduct is on — and three front-runners have emerged.

The first is Interior Secretary Ryan Zinke, whom media outlets have begun calling Pruitt’s “scandal clone” as a result of allegations that have led to at least 11 investigations of him and counting. Last week, news broke that Zinke routinely does not accurately disclose — or disclose at all — potentially embarrassing meetings on his public calendar. In multiple cases, Zinke’s calendar reportedly did not represent whom he met with (for example, appointments might list a member of Congress or a mayor, but not the lobbyists or representatives of Interior Department vendors who also attended the meeting), redacted details about the meetings or represented a business meeting as “Hold” or “Personal.”

The concealment or destruction of any such records could be a violation of the Federal Records Act. To the extent that the Interior Department is failing to create records that accurately document the agency’s business, it could also be held to be an FRA violation, if a lawsuit we’re involved in is successful. Our watchdog organization, Citizens for Responsibility and Ethics in Washington, is suing the EPA and raising this issue — arguing that an agency has an obligation to create records — for the first time.

There is more. The Interior Department’s own deputy inspector general issued a rare public rebuke of Zinke in November for failing to properly report a $12,000 chartered flight with a campaign donor. Like Pruitt, Zinke has also been accused of being inappropriately close to members of the industries he regulates. In June, reports surfaced of Zinke’s close relationship with Halliburton Chairman David Lesar, whose firm conducts a sizable amount of business — including drilling for oil — on Interior-regulated public land. Zinke’s foundation, which is run by his wife, Lola, reportedly donated a large plot of land to a construction project on which Lesar plans to build, according to the Whitefish, Mont., city planner, a microbrewery that the Zinkes would own (a passion project of Zinke’s since he entered city politics). This scandal continues to plague Zinke. Rep. Raul Grijalva (Ariz.), the ranking Democrat on the House Natural Resources Committee, and the ethics watchdog Public Citizen have both called for a probe.

A second front-runner in the race to become the next Pruitt is Secretary of Commerce Wilbur Ross. The Office of Government Ethics recently sent Ross a letter criticizing him for failing to fully divest his stocks as he had agreed on Jan. 15, 2017 — and citing transactions the secretary only fully disclosed this month, 18 months later. The normally soft-spoken ethics agency said that Ross’s “failure to divest created the potential for a serious criminal violation . . . and undermined public confidence.”

This letter comes on the heels of months of reporting that unearthed dozens of meetings that Ross had conducted with companies in which he had financial interests, with foreign leaders that have regulatory oversight of businesses he owned, and with representatives of sovereign wealth funds that had pumped millions of dollars into the private equity fund that Ross ran before entering government.

The most pressing ethical issues surround Ross’s decision not to immediately divest himself of his equity interest in the shipping company Navigator Holdings, which specializes in transporting energy supplies. Among Navigator’s largest clients is a Russian energy company with close ties to the Kremlin. This was originally discovered by the International Consortium of Investigative Journalists in its investigation into the “Paradise Papers,” a leak of documents from offshore registries and tax havens.

Perhaps the most damning development in the Navigator story to date is the recent report that Ross may have made stock market decisions based on information only he was privy to (a charge he denies). Hours after a journalist informed Ross about the fact that his name had surfaced in the Paradise Papers in connection with Navigator (and before the media outlet published), Ross made a number of short sales of Navigator stock. The share price dropped by about 4 percent before Ross closed his position. Senate Democrats have focused on these trades in demanding the Securities and Exchange Commission investigate Ross for alleged insider trading.

But it is the third contender for Pruitt’s dubious title who, after last week, seems to have the greatest exposure: President Trump. Like Pruitt, Trump has endured in the face of mounting investigations and litigation. Between special counsel Robert S. Mueller III’s inquiry into Russian interference in the 2016 election, Trump’s performance in Helsinki, his attorney Michael Cohen’s potentially impending cooperation with the government and a raft of civil cases, the president surely knows that the legal flood around him is rising.

For example, news has broken that Cohen taped conversations with Trump about making potentially illegal payments to women that the president had had affairs with. This increases the likelihood that Trump may have committed a criminal violation in the signing and filing of his Form 278, the financial disclosure form that candidates must file under the Ethics in Government Act. Federal law makes it a crime to knowingly and willfully falsify or fail to report information that officials are required to report to the Office of Government Ethics. We already know of one such instance: The president clearly failed to report his debt to Cohen for a payment to porn star Stormy Daniels. (Trump denies it was required, but OGE disagrees and has made a referral to the Justice Department.) The existence of the new tape appears to corroborate that Trump knew what Cohen was up to — and suggests that the lawyer may be poised to reveal additional debts and payments that the president also did not disclose on his Form 278.

Also ominous for the president is the fact that Cohen is an inside eyewitness to Trump’s complex financial dealings. For months now, investigative reporters have been digging into the construction and financing of Trump Tower Toronto and have unearthed a number of questionable aspects, including a secret $100 million payment authorized by the president’s business partner to a Moscow-based fixer representing Kremlin-linked investors in the deal. That wouldn’t be the first Trump building to be linked to a complex web of corrupt Russian-related interests: Trump Tower SoHo, for example, was allegedly used to launder money through apartment sales by a Kazakh criminal network; and Russian oligarchs invested nearly $100 million in Trump properties in southern Florida. Then there is the question of whether Cohen witnessed any alleged Trump collusion with Russia — a persistent question rekindled by the president’s bizarre performance in Helsinki and dizzying clarifications and reversals since.

Trump is an astute politician, and he knows that when cracks in ethical foundations of administrations appear, they can take the entire building down with them. Perhaps, as we have suggested previously, that is why Trump kept Pruitt around as long as he did: to avoid calling attention to the ethical crumbling of his entire administration. Zinke and Ross may be soon to follow the former EPA chief. Or perhaps the next Pruitt is sitting in the Oval Office. But if so, for how long?

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