The Trump campaign says it will dispatch high-level government appointees to stump in Iowa ahead of the state’s Monday caucuses, setting up potential pitfalls for Cabinet secretaries and other officials bound by ethics restrictions on their politicking.

“This goes above and beyond anything I’ve ever seen when it comes to the White House deploying its resources on the campaign trail,” said Democratic consultant Jim Manley, once an aide to then-Senate Majority Leader Harry Reid, D-Nev.

“On the one hand, it’s not surprising because this White House really hasn’t been following the ethics rules,” he added, “but it’s so brazen and outrageous that there’s got to be some accountability.”

Though Trump administration officials previously have flouted ethics requirements and the Hatch Act, which puts limits on the campaign activities of nearly all federal employees, the Trump campaign’s announcement of the upcoming political tour avoided a common mistake, ethics experts said.

The campaign did not use the official titles of Cabinet secretaries Wilbur Ross, who leads the Commerce Department; Health and Human Services’ Alex Azar; Ben Carson of Housing and Urban Development; Betsy DeVos of the Education Department; Interior’s David Bernhardt; and Robert Wilkie of Veterans Affairs. Instead, the campaign simply used the word “honorable” in front of each name.

“Look, I can’t say anything about the events, but they have managed to avoid the most obvious violation that they could have by not including these folks’ official titles in the announcement,” said Donald Sherman, deputy director of Citizens for Responsibility and Ethics in Washington. “Separate and apart from that, it is clear that this administration has routinely failed to enforce the Hatch Act.”

[In bashing Biden, did Kellyanne Conway break the law again?]

Because of that, Sherman said it is “reasonable” to monitor how the Trump campaign deploys Trump administration officials in 2020 electioneering events.

The Hatch Act prohibits the use of federal resources to promote partisan politics. The Cabinet secretaries, for example, would need to pay for their own travel to Iowa, or the Trump campaign or the Republican National Committee could foot the bill, ethics and campaign finance lawyers said.

Acting White House Chief of Staff Mick Mulvaney, and Jovita Carranza, who runs the Small Business Administration, also will head to Iowa, the Trump campaign said. Ditto for numerous members of Congress including House Minority Leader Kevin McCarthy of California and GOP Reps. Elise Stefanik of New York, Rodney Davis of Illinois and numerous federal and state Iowa lawmakers.

“Our Caucus Day operation is just a preview of what is to come,” Brad Parscale, Trump 2020 campaign manager, said in a news release Monday. “This will be the strongest, best funded, and most organized presidential campaign in history. We are putting the Democrats on notice — good luck trying to keep up with this formidable re-election machine.”

President Donald Trump faces no serious competition for his party’s nomination, indicating that his campaign’s high-profile effort for the Iowa caucuses is more about not ceding all the attention to Democrats, as their party begins the official process of picking a nominee to face the president.

Members of Congress are not subject to the Hatch Act, but need to pay for their campaign efforts from campaign funds, not taxpayer money, said Republican campaign finance attorney Cleta Mitchell, a partner at Foley & Lardner.

She also noted that when Trump travels to his political rallies, his campaign or the party committee must reimburse for expenses of flying on Air Force One.

“They have to draw a line and can’t blur those lines,” Mitchell said.

Cabinet secretaries and other top federal officials will need to make clear distinctions between any of their official duties and their campaign activities if they are to avoid potential problems.

Azar’s travel is being paid directly by Trump’s campaign, according to a Health and Human Services spokesperson.

Perhaps the best-known recent concerns about the Hatch Act are from Kellyanne Conway, counselor to the President, whom the U.S. Office of Special Counsel has determined violated it on multiple occasions.

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Sherman’s group CREW has filed complaints against Conway in the past and sued the federal government in December in an effort to take action against her over the violations.

Sherman said Conway offers a “textbook case” of what federal officials should not do, such as standing in front of the White House and promoting, or disparaging, political candidates.

Members of both parties have raised electioneering problems over the years. Kathleen Sebelius, Secretary of Health and Human Services in the Obama administration, violated the Hatch Act during an event in North Carolina in 2012, according to the Office of Special Counsel, requiring her agency to seek reimbursement for her travel costs.