CNN  — 

President Donald Trump’s expected batch of 100 pardons and commutations on the penultimate day of his presidency won’t be the highest of his recent predecessors. But his record of clemency could very well be the most controversial.

Unlike past presidents, Trump has shown little interest in using the Justice Department’s Pardon Attorney system for assessing requests for executive clemency. Instead, petitioners are approaching the White House directly, calling or emailing senior adviser Jared Kushner, chief of staff Mark Meadows or White House counsel Pat Cipollone – when they can’t get a hold of Trump himself.

Many of the people Trump has chosen to pardon so far fall along predictable lines: associates such as Roger Stone and Michael Flynn who remained loyal to him through their legal troubles; criminals with friendly or familial ties to the administration, such as Jared Kushner’s father Charles; celebrities or people connected to celebrities, such as Rod Blagojevich; and those whose cause was taken up by conservative media, such as Blackwater security guards who massacred Iraqi civilians.

He has pardoned or commuted the sentences of some people serving lengthy prison terms for low-level offenses, such as Alice Johnson, who spoke at the Republican National Convention.

But by and large, Trump’s pardon record has broken with historical norms. Many of the high-profile criminals he has pardoned have shown little contrition or remorse for their crimes and few have argued they were wrongfully convicted.

He is expected to adhere to that record on Tuesday when he issues around 100 pardons or commutations. The final batch of clemency actions is expected to include a mix of criminal justice reform-minded pardons and more controversial ones secured or doled out to political allies. White collar criminals, high-profile rappers and a prominent eye doctor from Palm Beach, Florida, who is in prison after being convicted on dozens of counts of health care fraud, are expected to be on the list.

There has been a crush of pardon requests during Trump’s final days in office from allies, lobbyists and others hoping to cash in on their loyalty to Trump. The New York Times reported Sunday some of those people were getting paid tens of thousands of dollars to lobby on behalf of felons hoping for pardons.

“Everyone assumed there’s no formal process and they should reach out to the administration directly,” a person familiar with the matter has told CNN. “Everyone hopes they have a friend of a friend of a friend of a cousin who they hope will get them to read their email.”

The 11th-hour batch of clemency is in keeping with presidential tradition.

President Barack Obama pardoned or commuted the sentences of 330 individuals on the day before he left office, a record number that went mainly to low level drug offenders serving mandatory sentences. 

President George W. Bush was more sparing with his use of pardons and commutations. He commuted the sentences of two border agents as he departed office (Trump later pardoned them). But he wrote in his memoir how a rush of requests came to him as he closed out his tenure.

“One of the biggest surprises of my presidency was the flood of pardon requests at the end. I could not believe the number of people who pulled me aside to suggest that a friend or former colleague deserved a pardon. At first I was frustrated. Then I was disgusted,” he wrote in “Decision Points.”

“I came to see massive injustice in the system,” he added. “If you had connections to the president, you could insert your case into the last-minute frenzy. Otherwise, you had to wait for the Justice Department to conduct a review and make recommendation. In my final weeks in office, I resolved that I would not pardon anyone who went outside the formal channels.”

Bush said he told Obama in their shared limo ride to the US Capitol for Obama’s inauguration to develop a pardon policy early on and stick to it.

President Bill Clinton drew scrutiny for his pardons and commutations of 140 people on Inauguration Day in 2000, which included high profile donors and political supporters such as Marc Rich, his half-brother Roger and Patty Hearst. Some of them came after middlemen, paid high sums, intervened with Clinton to argue their case. But the majority of the people on his list still went through the Justice Department process.

President George H.W. Bush pardoned a dozen people a day before leaving office. President Ronald Reagan pardoned around 25 people during his final week as president. And President Jimmy Carter, as he departed office, pardoned Pete Yarrow, of the group Peter, Paul and Mary, for an “indecent liberties” offense with a 14-year-old girl.