WASHINGTON (AP) — President Donald Trump is expected to pardon his former chief strategist, Steve Bannon, as part of a flurry of clemency action that appeared to be still in flux in the final hours of his presidency, according to a person familiar with his thinking.

The person, who spoke on condition of anonymity to discuss private deliberations, stressed that Trump has flip-flopped repeatedly as he mulls his final actions, and warned the decision could be reversed until it's formally unveiled.

The last-minute clemency would follow separate waves of pardons over the last month for Trump allies, including associates convicted in the FBI’s Russia investigation as well as the father of his son-in-law. It would underscores the president’s willingness, all the way through his four years in the White House, to flex his constitutional powers in ways that defy convention and explicitly aid his friends and supporters.

Whereas pardon recipients are generally thought of as defendants who have faced justice, often by having served at least some prison time, a pardon for Bannon would nullify a prosecution that was still in its early stages and likely months away from trial in Manhattan, effectively eliminating any prospect for punishment.

Though other presidents have issued controversial pardons at the ends of their administration, perhaps no commander in chief has so enjoyed using the clemency authority to benefit not only friends and acquaintances but also celebrity defendants and those championed by allies. Critics say such decisions result in far more deserving applicants being passed over.

“Steve Bannon is getting a pardon from Trump after defrauding Trump’s own supporters into paying for a wall that Trump promised Mexico would pay for,” Democratic Rep. Adam Schiff said on Twitter. “And if that all sounds crazy, that’s because it is. Thank God we have only 12 more hours of this den of thieves.”

Trump is expected to offer pardons and commutations to as many as 100 people in the hours before he leaves office at noon Wednesday, according to two people briefed on the plans. The list is expected to include names unfamiliar to the American public — regular people who have spent years languishing in prison — as well as politically connected friends and allies.

Bannon has been charged with duping thousands of investors who believed their money would be used to fulfill Trump’s chief campaign promise to build a wall along the southern border. Instead, he allegedly diverted over a million dollars, paying a salary to one campaign official and personal expenses for himself.

Bannon did not respond to questions Tuesday.

Trump has already pardoned a slew of longtime associates and supporters, including his former campaign chairman, Paul Manafort; Charles Kushner, the father of his son-in-law; his longtime friend and adviser Roger Stone; and his former national security adviser Michael Flynn.

A voice of nationalist, outsider conservatism, Bannon — who served in the Navy and worked at Goldman Sachs and as a Hollywood producer before turning to politics — led the conservative Breitbart News before being tapped to serve as chief executive officer of Trump’s 2016 campaign in its critical final months.

He later served as chief strategist to the president during the turbulent early days of Trump’s administration and was at the forefront of many of its most contentious policies, including its travel ban on several majority-Muslim countries.

But Bannon, who clashed with other top advisers, was pushed out after less than a year. And his split with Trump deepened after he was quoted in a 2018 book making critical remarks about some of Trump’s adult children. Bannon apologized and soon stepped down as chairman of Breitbart. He and Trump have recently reconciled.

In August, he was pulled from a luxury yacht off the coast of Connecticut and brought before a judge in Manhattan, where he pleaded not guilty. When he emerged from the courthouse, Bannon tore off his mask, smiled and waved to news cameras. As he went to a waiting vehicle, he shouted, “This entire fiasco is to stop people who want to build the wall.”

The organizers of the “We Build The Wall” group portrayed themselves as eager to help the president build a “big beautiful” barrier along the U.S.-Mexico border, as he promised during the 2016 campaign. They raised more than $25 million from thousands of donors and pledged that 100% of the money would be used for the project.

But according to the criminal charges, much of the money never made it to the wall. Instead, it was used to line the pockets of group members, including Bannon.

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Associated Press writer Zeke Miller contributed to this report.