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In his first weeks in office, President Donald Trump’s approach to energy and environmental policy has favored the symbolic over the substantive and the transactional over the visionary. Whereas Presidents Ronald Reagan, George H.W. Bush and George W. Bush each outlined broad energy plans in their first days in office, Trump put forward no energy policy ideas in his first address to a joint session of Congress.

President Trump’s early actions on energy and environmental policy have instead been crude giveaways to loyal supporters and well-connected oil, gas, coal, and utility executives: the elimination of an anti-bribery rule to help Exxon Mobil; a green light to a pipeline company in which Trump was financially invested as recently as last year; and executive orders signaling his intention to eliminate or weaken clean air and clean water rules at the request of corporate polluters.

Although President Trump has still not attempted to fill most high-level positions in his administration, his early actions provide clues about who is guiding his energy and environmental decisions, from both inside and outside government. Whereas President George W. Bush deputized Vice President Dick Cheney to lead his energy policy task force and President George H.W. Bush asked his secretary of state, James Baker III, to position the United States as a leader in the global fight against climate change, Trump’s network of advisers on energy and environment matters appears to be more secretive and less formally organized than his predecessors’. Trump’s energy and environmental team most closely resembles a cartel, insofar as it is dominated by corporate interests that are operating both inside and outside government to deliver financial benefits to themselves and their allies.

The Center for American Progress’ review of the Trump administration’s early anti-environmental actions, statements, and disclosures indicates that there are at least five key players in this emerging cartel:

• Mike Catanzaro, special assistant to the president for domestic energy and environmental policy. Catanzaro came to the White House from the Washington, D.C.-based lobbying firm CGCN Group, where last year he represented a long list of fossil fuel interests, including Koch Industries, Devon Energy, Hess Corp., America’s Natural Gas Alliance, and Halliburton. Trump’s weakening of lobbying restrictions implemented by the Obama administration allow Catanzaro to now work, from within the White House, on policies that will benefit the industries for whom he lobbied just months ago.

• Scott Pruitt, administrator of the U.S. Environmental Protection Agency, or EPA. Pruitt made a name for himself as Oklahoma’s attorney general by suing the agency he now leads 14 times, including to block the Clean Power Plan. He worked closely with the fossil fuel industry, using its talking points as his own when he wrote to the EPA to oppose environmental protections. He has received campaign contributions from Koch Industries and worked to attract fossil fuel companies to join the Republican Attorneys General Association, of which he was president at the time. Pruitt was recently court ordered to release thousands of emails that reveal the extent to which he worked directly on behalf of fossil fuel interests to challenge the EPA’s pollution limits.

• Exxon Mobil. With the confirmation of former Exxon Mobil CEO Rex Tillerson to serve as secretary of state and the confirmation of Exxon Mobil allies Pruitt, Jeff Sessions, Ryan Zinke, and Rick Perry to serve alongside him in the Cabinet, the oil and gas giant has secured unparalleled power in the U.S. government. Although Exxon Mobil has already tallied one major policy win in this administration through the repeal of a rule that prohibited bribery by oil companies operating in foreign countries, the company could reap up to $1 trillion in financial benefits through the actions of the company’s allies in the Trump administration.

• Robert Murray, CEO of Murray Energy Corp. In addition to serving as CEO of the largest privately owned mining company in the United States, Robert Murray is one of President Trump’s most loyal supporters and a longtime advocate against environmental protections. After endorsing Trump in May 2016, Murray Energy’s political action committee gave $100,000 to Trump’s fundraising committee just days before the company announced layoffs of 4,400 workers. Trump has been quick to reward Murray’s support. One of the Trump administration’s first actions was to sign a congressional resolution revoking an Obama administration rule that prevented coal companies from polluting nearby streams. The elimination of this stream protection rule was a “top priority” of Murray and the coal industry.

• Carl Icahn, special adviser to the president on regulatory reform. Icahn, a billionaire hedge fund investor with vast holdings in energy companies, has been formally named an adviser to President Trump on regulatory matters. Icahn is reportedly working for the administration in an “individual capacity” rather than as a federal government employee, a step that might be intended to try to limit his responsibilities under federal conflict of interest laws and to maintain his financial holdings. Icahn, whose holdings include a majority ownership stake in the Texas oil refiner CVR Energy Inc., has criticized EPA rules relating to renewable fuels and is reportedly advising Trump to accept a backroom deal to change EPA ethanol policies in a way that could benefit his company.

As President Trump expands his energy and environmental team over the coming weeks, the public, journalists, and oversight committees in Congress should review the backgrounds of the individuals and interests that are shaping his agenda, as well as the mechanism through which they are coordinating. The current cartel-like structure, through which senior members of the administration appear to be coordinating directly with corporate interests and executives outside government, raises grave risks of ethical violations, conflicts of interest, and the promulgation of policies that harm consumers, families, public health, and the environment.

Matt Lee-Ashley is a Senior Fellow and the Senior Director of Environmental Policy and Strategy at the Center for American Progress. Erin Auel is a Research Associate for the Energy Policy team at the Center. Claire Moser is the Senior Campaign Manager for Climate at the Center.