Unlike Mr. Trump, who is exempt from conflict of interest laws, both Mr. Kushner and Ms. Trump -- who took a formal White House position this past week -- are forbidden under federal criminal and civil law to take any action that might benefit their particular financial holdings.


Mr. Kushner did resign from more than 200 positions in the partnerships and limited liability companies that make up the family-run multibillion-dollar real estate business. But the financial disclosure report shows that Mr. Kushner will remain a beneficiary of most of those same entities.

Jamie Gorelick, who served as deputy attorney general at the Justice Department during the Clinton administration and is now advising Mr. Kushner and Ms. Trump on government ethics issues, said that the couple could continue to hold on to so many of their assets because most of the value is tied up in buildings.

"The real estate assets that Kushner is holding on to are unlikely to pose the kinds of conflicts that would trigger the need to divest," Ms. Gorelick, a partner at WilmerHale, the law firm, said in a statement on Friday. "The remaining conflicts, from a practical perspective, are pretty narrow and very manageable."

But real estate projects like the Kushner Companies' deals have become a magnet for opaque foreign money -- often from parts of the world that present thorny policy questions, such as China, where Mr. Kushner's company has actively sought investors, as well as the Middle East and Russia. As part of his exceptionally broad portfolio in the White House, Mr. Kushner has been a crucial figure in arranging the visit of the Chinese leader, Xi Jinping, on Thursday in Florida.

The mystery behind many real estate investments involving foreigners prompted the Treasury Department last year to push for additional disclosures as a way to combat money laundering.


Mr. Kushner, by contrast, continues to hold multimillion-dollar lines of credit from institutions such as Citigroup and Deutsche Bank, while companies he is still a beneficiary of have billions of dollars in additional loans from heavily regulated institutions.

Richard W. Painter, who served as a White House ethics lawyer in the Bush administration, said that Mr. Kushner's financial holdings would complicate any interactions he might have with such banks. "The one thing Jared really ought to stay completely away from is anything having to do with Dodd-Frank," Mr. Painter said, referring to the 2010 law that increased capital reserve requirements and instituted many other regulatory changes that affected the nation's banks.

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