President-elect Trump is stacking his cabinet with billionaires and centi-millionaires, whose financial entanglements pose conflict of interest challenges.

A month after securing the White House with populist promises to working class voters, President-elect Donald Trump has chosen at least half a dozen billionaires and several other ultra-wealthy business leaders to serve in top administration roles.

Trump’s Cabinet is on track to be one of the richest in modern history, on par only with the team of millionaires and billionaires he assembled during his first term. He’s picked billionaires to serve as commerce secretary and education secretary, and he has tapped other ultra-wealthy leaders for treasury and interior. He’s also offered noncabinet positions, including NASA director and deputy defense secretary, to billionaires.

Throughout the transition, Elon Musk, the world’s richest man, has been by Trump’s side, serving as “first buddy” and establishing the nongovernmental “Department of Government Efficiency.” On Thursday night, Trump tapped tech investor David Sacks — who made his fortune in part through the $1.2 billion sale of the software company Yammer to Microsoft — to serve as his artificial intelligence and cryptocurrency czar.

Trump’s team of rivals stands in stark contrast to Biden’s Cabinet, which had a combined net worth of $118 million in the first year of his presidency, according to Forbes. Trump’s picks have not yet released their financial disclosures, but his 2025 Cabinet is likely to be even richer than the first Trump Cabinet, which had a combined net worth of $6.2 billion.

Linda McMahon, whom Trump says he will nominate for education secretary, shares a net worth of $3 billion with her husband Vincent McMahon, according to Forbes. Howard Lutnick, Trump’s pick for commerce secretary, has a net worth of at least $2.2 billion, according to the Bloomberg Billionaires Index. Trump’s treasury choice, Scott Bessent, managed billion-dollar hedge funds, but his exact net worth has not yet been reported. Doug Burgum, Trump’s pick for interior, is worth at least $100 million, Forbes said.

The median net worth of an American family is $192,900, according to a 2023 Federal Reserve report.

Wealthy Americans who have had successful careers in business have long served in government, but watchdog groups say the high concentration of ultra-wealthy picks for roles in Trump’s Cabinet presents distinct conflict of interest risks and could work against promises Trump — a billionaire himself — made on the campaign trail. As he crisscrossed the country to host rallies, Trump repeatedly promised to fight for the rights of working and middle class Americans by bringing back manufacturing jobs and limiting inflation.

Trump’s selections may be more inclined to look out for the interests of their own businesses and their fellow billionaires than for working-class voters, said Noah Bookbinder, president of Citizens for Responsibility and Ethics in Washington.

“It is hard to see how a Cabinet made up largely of the very, very wealthiest of Americans is going to have an understanding of what the needs of regular Americans are,” he said.

Trump, who has an estimated net worth of $5.5 billion, has long aligned himself with other wealthy business leaders, delighting in attention and praise from those he regards as successful executives.

Trump-Vance Transition spokeswoman Taylor Rogers said in a statement that Trump has made “brilliant decisions” on picks for his second administration and cabinet.

“Many of these individuals have experienced the American Dream and want to keep that dream alive for future generations,” she said.

But the Cabinet selections are an early test of Trump’s ability to unite a transformed Republican Party, where the goals of populists who say they are focused on elevating the working class can clash with those of the business leaders and wealthy donors who have long shaped the party’s policies. Even some Republicans have expressed worries about the composition of Trump’s Cabinet.

Sen. Josh Hawley (R-Missouri) expressed concern about the business backgrounds of some of Trump’s picks in an interview with Politico on Tuesday.

“All these Treasury secretaries, my point is, always end up being sort of Wall Street guys. Do I think that’s a great trend? Not really,” Hawley said.

After making several industry-friendly picks, Trump made a nod to the growing populist wing of the Republican Party by picking the union-friendly Rep. Lori Chavez-DeRemer (R-Oregon) to lead the Labor Department.

Oren Cass, the founder and chief economist at the conservative think tank American Compass, said he is optimistic that the new Trump administration will be more oriented toward populist goals than the first. He said the best example is Trump’s selection of JD Vance for vice president, who stands in stark contrast to former vice president Mike Pence, who has warned rising populism undermines the “traditional conservative agenda.”

“Some of them offer a lot of cause for optimism,” Cass said. “It’s the sort of thing where [the] rubber meets road when the administration actually starts.”

Democrats have roundly criticized Trump’s choices. The Democratic Party on Tuesday put out a news release that said Trump was “stacking his Cabinet with out of touch billionaires.” Sen. Elizabeth Warren (D-Massachusetts) told The Washington Post that the choices suggest Trump’s presidency will “be one giveaway after another for the wealthy and well-connected.”

“He’s nominating his ‘rich-as-hell’ buddies to run every facet of our economy, corrupting our government at the expense of ordinary Americans,” she said.

Watchdog groups are concerned about the new conflicts of interests that Trump’s nominees could present. Trump’s first-term commerce secretary, Wilbur Ross, violated an ethics agreement by improperly reporting his stock holdings and faced scrutiny for his financial dealings while in office.

Many business leaders who enter government roles put their assets in blind trusts to preempt concerns that they could abuse their political power to benefit their personal portfolios. But watchdog groups are skeptical that even those vehicles provide an adequate shield against ethics risks.

“People who spend their entire lives getting rich do not automatically forget their economic stakes when they enter government,” said Jeff Hauser, the executive director of the Revolving Door Project.

Trump himself has not promised to divest from any of his businesses, which have now soared and include a cryptocurrency business and a stake in a social media company. And with Trump’s own party controlling both chambers of Congress and a Cabinet packed with his allies and loyalists, he can expect little oversight over his finances, Bookbinder said.

“People in government take a cue from the top,” he said. “This time around, Donald Trump, is not — at least as of now — even making a show of addressing his own conflicts of interest.”