The Trump International Golf Course Scotland in Aberdeenshire is set to get a second 18-hole golf course, a new 450-room five-star hotel, a timeshare complex and a private housing estate.
Officials with the organization insist that the venture is not contrary to Trump's promise.
"Implementing future phasing of existing properties does not constitute a new transaction, so we intend to proceed," a Trump Organization spokeswoman told the Guardian.
During last year's presidential election in the US, Trump promised that he would divest himself from his business if he became president.
Last week, Trump's attorney Sheri Dillon told reporters at a news conference that the president-elect's sons, Eric Trump and Donald Trump Jr., would take over his properties before his inauguration, and that the mogul-turned-president would limit the information he receives about his assets to total profit and loss statements only.
Critics have said that having his children manage his assets does little to remove Trump from the operations of his businesses, and that doing so does not constitute the type of blind trust that his predecessors have traditionally used to avoid the potential for conflicts of interest.