The Cabinet Nominee's Old Client List

Every nominee fills out the same form. OGE Form 278e, Part 4: list every source that paid you more than $5,000 in the last two years. Todd Blanche filled it out on January 18, 2025, to become Deputy Attorney General. Nineteen months later the Senate made him Attorney General by one vote.

The form is still online. It lists nine clients he described as "active" the week before he walked into the Justice Department. One is a political committee that paid him to defend Donald Trump. One is a Dubai crypto firm that pleaded guilty to federal wire fraud three days after he signed. One is a person he could not name because a federal grand jury was investigating them.

You are supposed to read that list and think "that's a lot of conflicts." Read it again and think about what happened to each one after he got the job.

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Start with the crypto client, because it is the cleanest case. In October 2024, federal prosecutors in Massachusetts charged CLS Global, a UAE "market maker," with running wash trades to fake trading volume. Blanche's form, signed January 18, 2025, lists CLS Global as "Blanche Law - active." On January 21, DOJ announced the company had agreed to plead guilty. On April 2, it was sentenced.

Five days after that sentencing, Blanche signed a memo dissolving the department's crypto enforcement unit. The memo says DOJ would "no longer target virtual currency exchanges, mixing and tumbling services, and offline wallets for the acts of their end users." Six Democratic senators wrote him on January 28, 2026, asking whether anyone issued a written conflict determination before he did that, because he still held $158,000 to $470,000 in crypto at the time. He did not sell until May 31.

What is proven: the client, the plea, the memo, the holdings, the dates. What nobody has shown: that Blanche touched the CLS case from inside DOJ. That is the point. Nobody can show it because the office that would check was hollowed out.

The first client on his list is the one that matters most. Save America PAC paid Blanche Law to represent Trump in the hush-money case, the classified-documents case, and the election case. His ethics pledge, signed February 10, 2025, bound him for one year from matters involving former clients. In March 2025, per CNN, the career ethics chief handed him a slide deck saying: recuse from Trump personally.

Then Trump sued his own government. In January 2026 he filed Trump v. IRS in Miami seeking $10 billion over the leak of his tax returns. On May 18, 2026, with Blanche as Acting Attorney General, DOJ announced a settlement: a $1.776 billion "Anti-Weaponization Fund," financed by taxpayers, plus audit and prosecution immunity for Trump, his sons, and the Trump Organization.

That same day, Senators Schiff, Durbin, and Blumenthal sent twelve questions to DOJ's ethics official asking, in plain terms, whether Blanche had recused from lawsuits his former client filed for personal money. A DOJ spokeswoman told CNN he was recused from "any cases that are still ongoing where he previously represented someone." A lawsuit by the same man, for the same man's money, was apparently a different case.

On July 13, 2026, Judge Kathleen Williams voided the deal. Her order says "there was never a case or controversy" and that the litigation was an attempt "to use the Court to provide some legitimacy to an agreement to confer immunity." She referred Blanche to the New York and D.C. bars, calling his congressional explanation "misleading and, at worst, disingenuous." Two days later he sat for his confirmation hearing and said, out loud, "I'm his lawyer — was his lawyer." That lawsuit, the settlement, and the audit shield that survived it get their own issue this Sunday. Today is about the form.

Trump pushed Bondi out on April 2, 2026, with a post calling her "a Great American Patriot" headed to "the private sector." Blanche was acting AG the same day. The Judiciary Committee advanced him 12-10 on August 4. Senator Cassidy provided the deciding floor vote, explaining that "the choice is not between perfection and Mr. Blanche."

Ask yourself who that logic serves. A senator's job at confirmation is exactly to compare the nominee to the standard, and the standard was sitting in the record: a form that says which clients paid him, a pledge that says he would stay away from them, a career official who said so in writing and was fired, and a federal judge who said the department he ran had gamed her courtroom for his old client.

I spent twenty years around lawyers who crossed over into government, and the honest ones treated the client list like a burn list: places you do not go for a year, no exceptions, no clever readings. Blanche's team read the pledge the way a defense lawyer reads a statute, looking for the gap. That is not a character flaw. It is the job he never stopped doing.

Here is the psychology. A man who spent two years telling juries his client was persecuted does not stop believing it when he changes offices. Recusal, to him, is not integrity; it is abandonment. So the rule that everyone else at DOJ lives under became, for him, a "hypothetical."

The ordinary-person version of this is simple. If you had a $1.776 billion claim against the government and your own lawyer got hired to run the agency deciding it, you would be told to find new counsel, and the lawyer would be told to leave the room. That rule held for every Attorney General you have ever heard of. It broke on August 8, 50 to 49.

Forward this to one person who thinks conflict-of-interest rules are paperwork, and ask them what the form was for.

Burn Notice: The disclosure form worked exactly as designed; it was the people reading it who decided the answer did not matter.

— Michael

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