For a man nominated to lead an agency with over 70,000 employees and a budget surpassing $20 billion, Ryan Zinke’s management resume includes some pretty questionable ethical practices that raise significant questions about his ability to manage conflicts of interest at the Department of Interior. Can the American people expect more of the same, or will Zinke have a plan to hold himself, and Interior, to account?

In 2012 Ryan Zinke was just a state legislator with political ambitions. In an apparent move to elevate his political stature, he started a federal Super PAC and began collecting political donations. Special Operations for America PAC, or SOFA PAC, was initially intended to support Mitt Romney’s Presidential bid – but it quickly turned in to a way to support his own candidacy for Congress and enrich his company and line his family’s pockets with obscure “consulting” fees.

Things moved rather quickly after he formed SOFA PAC. By 2013 it had shifted to congressional campaigns and by October of that year it had already started spending money supporting Zinke’s own congressional campaign. He had resigned from the PAC just one month earlier in order to become a candidate for Congress.

PACs are strictly forbidden from coordinating with the candidates they support. Otherwise, it would be an easy way to evade campaign contribution limits and skirt the law.

During the 2013 – 2014 election cycle, Zinke’s congressional campaign and SOFA PAC used 6 of the same campaign vendors and on multiple occasions paid them at the exact same time. Sure, this could be a coincidence, but it could also point to illegal campaign coordination.

Zinke falsely claimed on national television that he didn’t personally make money from SOFA PAC, but FEC filings tell a different story. SOFA paid Zinke’s company Continental Divide International and his family at least $35,000.

After the campaign, Zinke even hired SOFA PAC’s treasurer as his Congressional Chief of Staff.

While these indiscretions may not prove illegal coordination, they paint a picture of someone who carelessly flouts the spirit of the law. It leads us to one final question:

How will Zinke avoid similar missteps, mistakes and conflicts of interest when in charge of the Department of Interior?