Five days before the 2020 presidential election, acting Homeland Security chief Chad Wolf flew to Texas to celebrate the construction of the 400th mile of the wall on the U.S.-Mexico border. The milestone hadn’t actually been reached yet; it would take another week for the structure to span that distance. The timing of the visit also raised eyebrows. To critics, its purpose seemed clear: Polls showed then-President Donald Trump trailing Joe Biden, and Wolf was there to run through the Trump campaign’s talking points.
Although he did not mention Biden by name, Wolf said that Biden’s immigration platform would pose a threat to national security. “Each of those policies would endanger the lives of the border patrol and Americans across the country,” Wolf said in a speech flanked by federal and local law enforcement officers. Standing next to him, Mark Morgan, the acting commissioner of U.S. Customs and Border Protection, said Biden’s policies would prompt a migrant “invasion.”
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The spectacle was part of an unusually blatant campaign blitz before the 2020 election by Trump’s cabinet heads, who crossed the country in government planes to tout his policies. No agency was more involved than the Department of Homeland Security. Wolf and other senior officials traveled to battleground states to publicize routine arrests, warned of dire national security risks if Trump wasn’t re-elected, and erected billboards in key states showcasing “immigration violators.”
Ethics experts and government watchdogs say the effort violated ethics laws, effectively transforming the nation’s third-largest federal department into an arm of the president’s campaign under the guise of official business. And American taxpayers footed the bill, according to records obtained by the watchdog group American Oversight and shared with TIME. Four trips taken by Wolf to the battleground states of Florida, Pennsylvania, Wisconsin, Michigan, Arizona and Texas cost $223,652, roughly $221,300 of which was spent on government planes, according to the documents, which were obtained through the Freedom of Information Act.
In that time, DHS held an unusual number of press conferences and speeches, amplified through official government channels, all of which broadcast Trump’s political platform. The day he visited the wall, Wolf and DHS social media accounts posted an almost 2-minute video that was indistinguishable from a campaign ad. “They said it couldn’t be done…They were wrong. 400 times and counting,” Wolf tweeted.
Wolf’s trips were just the tip of the iceberg. While high-level members of previous administrations have also highlighted their accomplishments around election season, the Trump Administration’s actions were unprecedented, says Noah Bookbinder, president of the government ethics watchdog Citizens for Responsibility and Ethics (CREW). Education Secretary Betsy DeVos hosted a “Moms for Trump” event in Michigan. Agriculture Secretary Sonny Perdue praised Trump in a North Carolina speech led the crowd to chant “four more years.” Secretary of State Mike Pompeo delivered a video-taped speech from Israel to the Republican National Convention while on a diplomatic trip. “It was a very systematic and conscious decision to send people out to swing states to advocate for the reelection of the president,” Bookbinder says, “using the resources of the government to keep [him] in power.”
Wolf did not respond to TIME’s request for comment. The revelations about the cost of his trips come amid renewed scrutiny of the Trump Administration’s various ethics violations in its final months, and recent efforts in Congress to strengthen ethics laws which have proved to be largely toothless. Trump reportedly violated the Presidential Records Act by not turning over 15 boxes of documents until last month. (The violation currently carries no penalty.) The battery of Trump officials, including Wolf, who were found by the Office of Special Counsel (OSC) last fall to have violated the Hatch Act have not faced any consequences. The Hatch Act prohibits government officials, except for the president and vice-president, from “holding purportedly official events for the purpose of promoting a candidate for partisan political office.”
A week before his trip to Texas, Wolf flew to Phoenix to give a speech to the Arizona Sheriff’s Association. He warned of the “unimaginable public health crisis” that would come with a surge in migration if Trump were to lose the election and the next administration overturned his hardline policies. “The only reason today’s crossings have not reached a crisis level is because of the policies and procedures the department has put in place over the past four years,” Wolf said in his speech Oct. 22.
This language echoed yet another speech Wolf gave on Oct. 16 in Philadelphia, where he and Acting ICE Director Tony Pham touted the arrests of 170 immigrants in sanctuary cities across the country. ICE also paid for billboards that October to be erected in six locations in Pennsylvania, with pictures of immigrants who had been previously arrested or convicted of crimes.
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“Top DHS officials are acting more like campaign surrogates than public servants, and they need to be held accountable,” Austin Evers, the executive director of American Oversight, which filed the FOIA for Wolf’s records, told TIME that month.
The campaign’s focus on immigration was no surprise. But DHS “went off the tracks” with its “electioneering,” says Dave Lapan, a retired Marine Corps colonel who served as DHS spokesman during the Trump Administration under then-Secretary John Kelly. “Going specifically to battleground states, spending government money on billboards that were very clearly political,” Lapan says. “They felt there were no guardrails and they could do these things with impunity.”
Democrats and ethics watchdogs argue the scale and cost of these official trips—only a fraction of which are public—underscore why federal ethics laws need to be strengthened. They sometimes blended electioneering and official business. For example, Wolf’s stop in Louisiana, where he met with FEMA in an area damaged by Hurricane Laura, came after a visit to Florida where he touted Trump’s law-and-order campaign message.
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“In the past we all just trusted that our democratically elected presidents would follow along with the rules and norms, and now we’ve learned that they won’t necessarily, that maybe there needs to be some stronger penalties,” says Melanie Sloan, a senior adviser at American Oversight. Sloan emphasized the importance of documenting the details that continue to come out through public records requests. “If we don’t put this out, when Chad Wolf wants his next Senate-confirmed job, no one will even know to ask him about it.”
Wolf defended his actions at the time, saying that it was part of his job to highlight policies he said were affecting public safety. “It’s not about Republicans, it’s not about Democrats, it’s not about elections,” he said Oct. 7. “It’s about dangerous policies that are dangerous for that community.”
During this period, Wolf was serving in his post illegally, according to rulings by several federal judges as well as the Government Accountability Office (GAO), which said Trump circumvented the Senate confirmation process and violated a federal law that specifies the order of succession.
Wolf and 12 other senior Trump administration officials were found to have violated the Hatch Act in previous activities around the Republican National Convention, according to a report released by the Office of the Special Counsel in November 2021. They misused government resources “for what appeared to be a taxpayer-funded campaign apparatus within the upper echelons of the executive branch,” the report says, including a naturalization ceremony led by Wolf that was aired at the RNC. But it also noted that discipline was no longer possible since these officials were leaving government office, saying it was “issuing this report to fully document the violations.”
Several bills in Congress have sought to strengthen federal ethics laws and eliminate these gray zones. The Protecting Our Democracy Act, which passed the House of Representatives last year, would empower the OSC to fine political appointees for violations and raise the maximum penalty to $50,000. Earlier this month, Democratic Sens. Elizabeth Warren and Ed Markey of Massachusetts and Jeff Merkley of Oregon introduced the Political CRIMES Act, which includes a series of measures to bolster the Hatch Act, including the establishment of an independent counsel to probe all violations.
“I think there’s a good argument to be made that the things that happened post-election wouldn’t have happened without the kinds of abuses that went on before the election, and often went on without consequences,” says Bookbinder of CREW. “It was hundreds of thousands of dollars being spent, violation after violation, and this wasn’t happening by accident but came from the top.”