Kevin Chmielewski, the former Trump campaign “body man” who worked at both the Department of Homeland Security and the Environmental Protection Agency before running afoul of EPA Administrator Scott Pruitt and being fired on March 18, has another problem on his hands: He never filed required financial disclosure forms during his year in the Trump administration — a rare and potentially serious offense that in other cases has resulted in a criminal charge by the Justice Department.

Chmielewski, 38, served with the U.S. Coast Guard and Merchant Marines before working on several Republican presidential campaigns, including those of former Texas Gov. Rick Perry (now the secretary of energy) and former Massachusetts Gov. Mitt Romney. As a personal assistant, or body man, to Donald Trump on the campaign trail in 2016, he became a favorite of the candidate. During a campaign rally in Chmielewski’s hometown of Berlin, Maryland, Trump called him a “star” and a “gem.”

After Trump’s inauguration, Chmielewski worked temporarily with Homeland Security in a security and operational role. In May 2017, he became the EPA’s director of scheduling and advance and later its deputy chief of staff of operations, with a senior executive salary of $140,000. He often accompanied Pruitt or Vice President Mike Pence on official trips.

He was fired after raising concerns about excessive travel and office spending by Pruitt, according to The New York Times. A political fight has broken out as whistleblower accusations emerge in news reports and the agency has criticized the accounts. Chmielewski spoke this week with Democratic congressional staff about Pruitt’s spending and other controversies. EPA officials blamed Chmielewski’s “unresponsiveness” while on trips as the primary reason for his dismissal, according to The New York Times.

The Ethics in Government Act requires that all political appointees file financial disclosures with the agency they work at within 30 days of their start date. The disclosures serve two purposes: transparency and identifying potential liabilities tied to financial conflicts of interest. They include staffers’ assets, debts, and stock and other financial holdings. Staffers can get 90-day extensions from agencies.

EPA officials say Chmielewski has not been granted any extensions, and he’s still obligated to provide a financial disclosure even though he has left the agency. “He has not been absolved of this obligation,” said Justina Fugh, the EPA’s senior counsel for ethics. OGE officials say any referrals for prosecution or civil fines would be handled by the EPA.

Chmielewski did not respond to ProPublica’s requests for comment.

Political appointees have been charged with crimes and paid civil penalties for comparable violations involving financial disclosures. In July 2013, for example, a Defense Department appointee left the agency but did not file a required financial disclosure “termination” form. She was charged with violating the Ethics in Government Act but prosecutors dismissed the case after she agreed to pay a $1,000 fine and file the required documents.

A Homeland Security appointee who left in March 2012 was also charged for the same offense and the government settled the case a year later after she paid a $4,000 fine and filed the form.

Both of those cases involved government political appointees who had filed so-called new entrant reports when they started government work but failed to file reports when they left.

The key difference: Chmielewski, for whatever reason, never filed his initial financial disclosure form. Whether or not he filed the paperwork, experts say, Chmielewski was still subject to criminal penalties if he violated conflict of interest laws.

“The fact that someone hasn’t filed a financial disclosure report would not absolve them of any civil or potentially criminal liability for violating the conflicts of interest statute,” according to Don Fox, the acting director of the Office of Government Ethics during the Obama administration.

Other Trump political appointees have been late in filing required paperwork, and have avoided ethics attorneys’ questions or failed to fill out an ethics pledge. At the EPA, three Trump appointees who have since left received complaints from ethics officials for either not responding to outstanding questions about their disclosures or filing late “despite many reminders.”

Still, former government ethics attorneys say Chmielewski’s case is unprecedented. When the facts were initially described to him, Fox responded: “Oh good Lord, he didn’t file within a year? ... I certainly have no good explanation as to why someone would be there a year and not file. He could’ve been a liability criminally [to the EPA].”

Marilyn Glynn, former general counsel and acting director of the Office of Government Ethics in the George W. Bush administration, said Chmielewski’s failure to file the government paperwork is “highly unusual.”

“Never filing anything seems unusual to me,” she said. “He was still under the obligation to recuse himself [in the event of a conflict of interest], so presumably the ethics office would’ve told him that he’s liable for criminal prosecution should he step over that line.”

It’s unclear if Chmielewski simply forgot to file the required paperwork or chose to dodge the requirement. In an interview with his hometown paper, The Dispatch, in April 2016, he described himself as having once been “on welfare.” Maryland state records show Chmielewski settled a $7,667 state tax lien from 2015 soon after joining Homeland Security in February 2017.

“I never went to college,” Chmielewski said in the Dispatch interview, “and I should have been one of those kids that ends up in jail or doing dishes somewhere.”