The recurring problem for all of us watching the Donald Trump campaign, election and subsequent transition is that it is hard to identify which parts of Trump’s rhetoric will actually become policy and which was used to drum up votes. It’s difficult to figure out what facts the president-elect believes: He has a long track record of statements that under even the most generous characterization are highly misleading. His actions over the course of his life seldom matched the rhetoric of his campaign.

The question now is whether this approach continues into his transition and his presidency, and, essentially, whether we can believe a word he says about his plans, his policy goals, the ethics rules he’ll set and appointments he’ll make — or whether we just have to wait and see what he actually does, at which point he’ll tell us that he told us he’d do this all along.

One of his most sweeping promises, and one of the claims most relevant to us at Sunlight, is that he’ll “drain the swamp” in Washington. This implies to us, in an artfully nonspecific but still powerful way, a lot of possibilities: getting rid of corruption and conflicts of interest, lessening the grip of money in politics and lobbyists, and a change in the establishment. But does Trump look at the swamp in the same way?

Looking at the evidence we have so far (such as key transition team members and likely appointees for cabinet roles), that evidence does not point to a swamp-draining. (Check out Every Voice’s “Trump’s Swamp” tumblr for a look at all the many examples.)

Let’s start with lobbyists. At first, Trump’s transition team was slated to be packed with lobbyists representing a huge variety of organizations and corporations, from tobacco and pharmaceuticals to the American Beverage Association. Isaac Arnsdorf at Politico uncovered the full list, including several names of individuals who aren’t registered lobbyists but still work at lobbying firms or advocacy groups (that is, individuals who may be shadow lobbyists). Things have changed slightly: The Wall Street Journal reports that with the change of guard in the transition team from Gov. Chris Christie to Vice President-elect Mike Pence, Pence has ordered the removal of lobbyists. We’ll wait to see what actually happens.

Thursday morning, the president-elect’s transition team has announced it would require certain executive staff to sign ethics pledges saying that they would not lobby for five years after leaving the White House, and, furthermore, would not lobby for foreign nations ever after they left the White House. While his intentions may seem good, this is not a practical way of addressing this. All this means is that people who want to serve will deactivate their registrations and we won’t know who they are or who they represent. After they leave the White House, they simply won’t register at all and the public will have no idea of their activities. We call those people “shadow lobbyists,” and have written extensively about why this is a problem. Finally, there’s no way to enforce this.

There is the potential for conflicts of interest throughout the Trump transition, all the way up to Trump himself. Rudy Giuliani, a top contender for secretary of state, has a lengthy history and established record of being a “political insider.” Known for his time as mayor of New York City and his own failed presidential run, Giuliani also built a business based on consulting and receiving money from paid speeches — some bringing in fees of as much as $200,000. He was reportedly paid $4 million to advise the government of Mexico City on crime. Arnsdorf reported Giuliani has previously been paid as a consultant by the Iranian political party MEK, which was designated a terrorist organization by the State Department until a successful lobbying campaign to get the group removed by many high-profile American political and military figures. The Qatari state-run oil company also paid Giuliani’s firm. As Arnsdorf noted, this could make the ethical issues surrounding foreign government donations to the Clinton Foundation “seem trifling,” seeing as “unlike Giuliani, [Clinton] never personally profited from the foreign contributions to her charity.”

Then there’s Trump himself, and his plan to put his assets in a “blind trust” that’s run by his own children, which would not be a blind trust). There’s also his known debts to banks in Germany and China, as well as his investments in foreign companies — including in “countries where the U.S. has sensitive diplomatic or financial relationships, such as Saudi Arabia, the United Arab Emirates and China.”

In an interview with 60 Minutes, Trump also referred to something that we’ve been advocating on for a long time: foreign money. The reference was passing and vague: “Right now, we’re going to clean it up. We’re having restrictions on foreign money coming in,” he said. It’s not clear to what, exactly, he was referring: whether he meant foreign governments and companies paying lobbyists in D.C. (like those that paid Giuliani), or the potential for foreign money to influence U.S. elections through undisclosed donations to 501(c)(4) groups. (Meanwhile, his daughter’s company sent out a press release publicizing a $10,000 bracelet she wore during the interview.)

Trump has been especially outspoken on the issue of money in presidential campaigns. However, many of the things he has proposed are strongly opposed by Senate Majority Leader Mitch McConnell, who opposes restrictions on campaign financing. What will happen under a Republican Congress will likely be in direct contrast with what we would consider “draining of the swamp.”

We’ve put a lot of thought into what we’d like to see done to reform the corrupting influence of money in politics. Here are some of the things we believe President-elect Trump could do:

• Oppose or promise to veto the Republican bill that would end the requirement that 501(c)(4)s disclose their donors to the IRS, a rule that allows the IRS to enforce the ban on foreign money.
• Request that the FEC open rulemaking on foreign money, as well as call on the FEC to enforce the law barring foreign contributions against a super PAC that supported him during the election, a representative of which was recorded soliciting foreign donations.
• Encourage the disclosure of beneficial owners of LLCs.
• Require companies to report to the SEC the money they are spending on campaigns.
• Require real-time disclosure of campaign contributions.
• Require real-time disclosure of lobbying activity.

We’d love to see more done to curtail the corrupting influence of money in politics. So far, what has been proposed in this administration does not seem like a substantive action planned out with people who understand the intricacies of influence in Washington.