Stark differences between Biden and Trump administration officials’ financial disclosures highlight a need for reforms of ethics rules. A review of senior Biden administration officials’ financial disclosures for 2022 shows a high degree of compliance with divestiture obligations, and even includes examples of cabinet members going beyond required divestitures. In contrast, several notable examples from both the Trump White House and Cabinet illustrate how officials were permitted to retain holdings that presented significant concerns about conflicts of interest and appeared to allow them to profit off of their public positions. To prevent future abuses, Congress should adopt legislation that bans the president, vice president, cabinet members and all senior White House staff from owning and trading individual stocks and from retaining personal interests in family businesses that could make them susceptible to influence-peddling. 

For example, Jared Kushner and Ivanka Trump reported earning between $172 million and $640 million in outside income while working in the White House. One source of this income was from Ivanka Trump’s eponymous business holdings, which benefited from at least 28 foreign trademarks that were approved while she served in the White House. The timing of many of these approvals raised significant ethics questions. In addition to these conflicts of interest, Ivanka Trump worked on the implementation of the 2018 Opportunity Zones program while her husband owned a substantial financial stake in Cadre, a company which offered investment vehicles under the same program. Kushner’s stake in Cadre grew from between $5 million and $25 million when he entered the administration to between $25 million and $50 million by the end of his employment in the White House, despite his being told it was “reasonably necessary” for him to divest this interest in 2019.

Members of Trump’s cabinet were also plagued by conflicts of interest and compliance issues. For example, Wilbur Ross earned between $53 million and $127 million in outside income while serving as the Secretary of Commerce where his tenure was marked by repeated instances of him mixing personal business with his official duties and other compliance issues. He continued to hold stock in an investment firm after he previously certified that he divested those holdings as well all other conflicting assets he pledged to sell during his Senate confirmation process. Ross’s financial disclosures and compliance documents contained so many omissions and inaccuracies that the Office of Government Ethics (“OGE”) first denounced his conduct, and later refused to certify his 2018 financial disclosure report for non-compliance with his ethics agreement. 

Another cabinet member, Betsy DeVos, who earned at least $225 million in outside income while working as Secretary of Education, retained a significant financial stake in a “brain-performance” company which offers unproven, medication-free treatments for children and adults. DeVos failed to issue a recusal statement for matters related to Neurocore, despite reporting a stake in the company valued between $5 million and $25 million and the possibility that the company could partner with schools and benefit from programs under her influence. Like President Trump, his cabinet members and senior White House officials seemingly disregarded their ethical obligations, including the possible conflicts of interest that could arise from the business interests they retained. These are but a few examples of the ethical challenges that plagued the Trump Administration. In contrast, the vast majority of Biden’s cabinet members and senior White House staff did not report holding any publicly traded stock or divested the entirety of their stock holdings, while the remaining officials appear to be taking steps to resolve potential conflicts or have been permitted to retain some limited holdings that do not appear to pose a conflict.

Biden cabinet members complied with their ethics divestiture commitments

A review of Biden cabinet members’ public financial disclosure reports covering calendar year 2021 shows that Biden cabinet members have complied with their ethics divestiture commitments. When President Biden’s cabinet members took office they addressed potential conflicts of interest by agreeing to streamline their financial portfolios, limit their private investments, restrict their outside positions and deactivate their private consulting businesses.  In many cases, cabinet members had no individual stock holdings to begin with. In the few instances where individual stocks have been retained, they appear to be de minimis in value or tied to their spouse’s employment compensation.

President Biden’s cabinet members were required to file financial reports covering calendar year 2021 by May 16, 2022, unless they received an extension. By November 17, 2022, the Office of Government Ethics (“OGE”) had reviewed and certified the annual financial disclosure reports filed by Biden cabinet officers. Once the last report was released by OGE, Citizens for Responsibility and Ethics in Washington undertook its own review to confirm compliance with their divestiture commitments and to examine the nature of any new investments – mostly publicly-traded diversified mutual funds – and any gifts that had been accepted. Of the 21 cabinet reports reviewed by CREW, gifts from five donors were reported. As discussed below, the gifts raised few ethics concerns because they were either from another federal entity or appear to be based on a pre-existing, personal relationship. 

Individual stock holdings and other divestitures

Except for spousal and de minimis holdings noted below, Biden cabinet members divested their individual stock holdings and several additional assets. For example, in addition to his stock holdings, Defense Secretary Lloyd Austin also divested restricted stock units and deferred stock units issued to him as compensation for having served on the board of directors of various companies, which led to more than $3 million in cash payments. Commerce Secretary Gina Raimondo divested a number of healthcare and energy sector mutual funds, while Attorney General Merrick Garland sold his state and municipal bond holdings and Secretary of Homeland Security Alejandro Mayorkas cashed out his $2.9 million law firm partnership share.

Divestitures of private consulting businesses can be more complicated undertakings depending on the size of the interest. Secretary of State Antony Blinken sold his equity interest in his former consulting firm in exchange for a note receivable, which is valued between $1 million and $5 million and payable incrementally over two years. Small Business Administrator Isabel Guzman was able to cash out her interest in a consulting business with a single payout of $57,032.

In at least one case, cabinet members went beyond mandated divestitures. Even though it was not required, Transportation Secretary Pete Buttigieg divested several investment funds that he held in a defined contribution plan sponsored by a former employer, McKinsey & Co. His divestiture of these funds is not particularly surprising, however, since the registered investment adviser for McKinsey’s retirement plans apparently was a wholly-owned subsidiary of McKinsey, which had been assessed civil penalties by the Securities and Exchange Commission after being investigated for controversial fund management practices.

Proceeds from cabinet members’ individual stock sales and other divestitures appear to have been reinvested in publicly-traded diversified mutual funds, or other non-conflicting assets, such as bank accounts. None of the cabinet members held or reported new investments in hedge funds, venture capital funds, private equity funds, or other high-risk ventures.

Spousal and De Minimis holdings

In one case, a  cabinet member’s spouse retained investments tied to his employment compensation.  Commerce Secretary Raimondo’s spouse retained stock, stock options and unvested restricted stock in his employer, PathAI, which uses artificial intelligence-powered pathology to improve patient outcomes; he exercised at least $65,000 worth of PathAI stock options in December 2021. Because her spouse’s financial interests in PathAI are imputed to Secretary Raimondo under the criminal conflict of interest law, 18 U.S.C. § 208, she expressly committed in her ethics agreement to recuse from any particular matters that would directly and predictably affect PathAI’s financial interests.  

While Secretary Raimondo must recuse from those particular matters, she was able to speak at the Department of Commerce’s May 2022 launch of the National Artificial Intelligence Advisory Committee, and more recently to meet with her EU counterpart to discuss “coordination on U.S. and EU CHIPs legislation” and to “engage on technology policy issues,” including artificial intelligence, semiconductors, and information communication technology services.  These events likely were not viewed by agency ethics officials as “particular matters” that would have mandated recusal under 18 U.S.C. § 208(a). Of course, those recusal obligations could become operative if the artificial intelligence initiatives evolve into regulatory matters. 

Several cabinet secretaries and their spouses retained holdings that do not trigger recusal or divestment obligations because they are below the de minimis thresholds established by OGE. Secretary of Interior Debra Haaland’s report shows that her spouse divested stock in a gaming equipment company that was rooted in the Native American gaming industry, but retained de minimis holdings in two other gaming industry companies, Everi Holdings, Inc. and International Game Technology PLC. While these two holdings (each less than $15,000) would normally require Secretary Haaland to recuse from particular matters affecting the gaming industry, so long as her holdings remain below the de minimis thresholds, she will qualify for OGE’s regulatory exemptions at 5 C.F.R. § 2640.202, which permit her to participate in gaming industry matters. 

Secretary of Agriculture Tom Vilsack was permitted to retain de minimis holdings in U.S. Bancorp stock (less than $50,000), and received a financial interest waiver arising out of Department of Agriculture benefits he receives for his farm property pursuant to a USDA conservation protection program. Environmental Protection Agency Administrator Michael Regan retained de minimis holdings in Prudential Financial, while U.S. Ambassador to the United Nations Linda Thomas-Greenfield and/or her spouse retained de minimis holdings in American Airlines, Duke Energy, and mining and chemical manufacturer Tronox Holdings Plc.

Pursuant to her ethics agreement, Secretary of Energy Jennifer Granholm divested her vested stock options in electrical vehicle maker Proterra Inc., in May 2021, resulting in net capital gains of $1.6 million. Before she cashed them out, Secretary Granholm’s holdings had become a “flashpoint” for critics when President Biden made a virtual visit to a Proterra facility as part of an Administration push for electric vehicles. Although she later divested her Proterra stock and a few other individual stock holdings, Secretary Granholm and her spouse retained certain other equity investments. These holdings, which include Cedar Fair LP; Invesco Ltd; Redfin, Teledoc Health, Gilead, and Uber, appear to meet the regulatory de minimis thresholds based on their individual values, which range between $1,000 and $45,000.


While few gifts were reported by cabinet members, those that did report them most likely relied on the personal relationship exception to accept gifts that would otherwise be prohibited if they were from a prohibited source or offered because of their official position. U.S. Ambassador Thomas-Greenfield indicated as much when she explicitly reported that she accepted U.S. Open Tennis tickets worth $5,500 from her spouse’s “former co-worker and personal friend.” 

In other cases, the nature of the gifts (e.g. wedding and baby gifts) suggests a personal relationship with the donor.  In this regard, newly-married Secretary Haaland reported a $700 wedding gift of two silver-turquoise bracelets and a piece of pottery and Secretary Buttigieg reported a $596 baby gift card.  In some instances, the basis for the gift is less clear.  In this regard, Secretary Buttigieg reported $1,750 worth of theater tickets.  Although there is no explicit reference to a personal friendship between Secretary Buttigieg and the donor, agency ethics officials and OGE appear to have been satisfied that an appropriate gift exception applied by virtue of having certified that he was in compliance with applicable ethics laws. 

Other gifts raise no ethics concerns.  For example, Secretary Raimondo reported accepting three Kennedy Center Honors tickets worth $2,700. Since Secretary Raimondo and her guests  accepted the tickets from a member of the the Kennedy Center’s National Committee for the Performing Arts (and her spouse), the tickets were  likely viewed as permissible based on an OGE opinion that views the Kennedy Center and/or its Board of Trustees as an “entity of the Federal Government.” 

New cabinet member

The new Director of the Office of Science and Technology Policy, Arati Prabhakar, (“OSTP”) was confirmed in September 2022, after she was nominated to replace former OSTP Director Eric Lander who resigned under controversy in February 2022. Director Prabhakar committed in her ethics agreement to divest within 90 days of confirmation her AutoGrid Systems, Inari Medical, Airbnb, Inc., and two sector fund holdings. She also agreed to divest within 120 days of confirmation her venture capital fund investments in U.S. Venture Partners X, U.S. Venture Partners IX, and Inventus I. Some of Director Prabhakar’s divestitures appear to have been completed, including her sales of Inari Medical and Airbnb stock holdings, while others may still be pending. Given the proximity of her recent confirmation, a full assessment of Director Prabhakar’s ethics compliance is not yet possible, but should be once her 2023 annual report is submitted later this year. 

In sum, a review of Biden cabinet members’ annual financial disclosure reports covering calendar year 2021 shows full compliance with their divestiture obligations agreed to as part of the Senate confirmation process.  The review shows a largely conservative approach to ethics in general.  Most cabinet members limited their investments to publicly-traded diversified mutual funds and other non-conflicting assets, with some voluntarily divesting from several mutual funds.

Most Biden White House officials divested their individual stock holdings

Most senior Biden White House officials are free of potential conflicts of interest from individual stock holdings or have indicated their intentions to divest. According to a review of the financial disclosures filed by the 56 assistants and deputy assistants to the president for 2022, 48 did not report holding any publicly traded stock or had already divested the entirety of their stock holdings. For three officials, individual stocks tied to spousal employment or family partnerships were retained, and two others have been permitted to retain certain limited holdings and presumably recuse from any matters that would affect those interests. 

While there has been a high degree of compliance overall, four reports are unclear as to whether each filer has fully divested their conflicting assets. For example, Director of Speechwriting Vinay Reddy reported owning between $15,001 and $50,000 in IBM stock upon entering the White House in January 2021. In April of 2021, Reddy received a certificate of divestiture (“CD”) from the Office of Government Ethics (“OGE”) for this stock. In an annual report filed in May 2022, he reported still owning the IBM stock but indicated that he had agreed to divest the asset. When Ashish Jha replaced Jeffrey Zients as Coordinator of the COVID-19 Response in April 2022, he reported owning less than $15,000 in Amino Health, a privately held stock, but noted that he is divesting as soon as possible. 

Domestic Policy Advisor Susan Rice’s annual report shows that while she has resolved most conflicts of interest from her stock portfolio, it is not clear if all of her divestiture commitments have been completed. In her New Entrant report filed in 2021, Rice stated that she would dispose of her Netflix stock options, and she reported in her 2022 annual report both $660,417 in ordinary income in connection with exercising these stock options and multiple sales transactions during 2021. However, the new report still includes an entry for Netflix stock options seemingly representing assets valued between $500,001 and $1 million. While Rice likely fully divested from Netflix, that is uncertain while the entry does not state a value of “none.” Rice also indicated in her 2021 New Entrant report that she would forfeit or transfer her carried interest in Amplo Partners LLC, a venture capital firm where Rice was a board partner from 2018 to 2021. Her 2022 annual report, however, includes entries for Amplo Partners I and II “carried interest,” suggesting those interests may have yet to be forfeited.

Some officials, newly promoted or appointed in 2022, divested their stock holdings rather quickly. This includes Director of Presidential Personnel Gautam Raghavan, who reported Kanarys Inc. stock in his 2022 annual report that was divested after filing. Other officials indicated their intention to divest their individual stock holdings by obtaining a CD. This was the case for Anita Dunn, who previously completed two stints in the Biden White House from January to August 2021 and in March 2022. Dunn returned to the White House as an Assistant and Senior Advisor to the President in May 2022. The financial disclosure she filed upon reentering the White House in May shows significant investments. In November, OGE issued Dunn a CD that included many, but not all, of her individual stock holdings. OGE will only issue a CD if the employee agrees to divest all of the property that presents a conflict of interest, as well as other similar or related property, and when divestiture could have tax consequences (i.e., OGE will not issue CDs for assets held in tax-deferred accounts). Because a CD is effective only if obtained prior to divestiture of an asset, her divestiture process began in November 2022 after her CD was issued. Her recently-released January 31, 2023 transaction report reflects 669 sale transactions, many of which were for individual stocks listed in the CD, while several additional holdings were divested voluntarily. It appears that she has divested most of the individual stock holdings, and future reports should make clear whether she retained any assets that might raise potential conflicts of interest.  

A few White House officials reported that stock tied to their spouse’s employment or family partnerships was retained. For example, Gender Policy Co-Chair Jennifer Klein, who has taken significant steps to divest from her other stock holdings, reported between $250,001 and $500,000 in Jupiter Intelligence Inc. vested stock options retained by her spouse. Additionally, Klein reported nearly $750,000 in partnership income related to her spouse’s investments in the Chicago Bulls. Her report also shows individual stock holdings in two trusts belonging to one of her dependent children. The report notes that these assets are not imputed to Klein under 18 U.S.C. § 208, however, because this child is not a minor. Two other officials who reported stock holdings tied to their spouse’s employment have since left the White House.

According to this review, two Biden White House officials have retained limited holdings. Director of Scheduling and Advance Ryan Montoya, whose investments in cryptocurrencies were mentioned in CREW’s last review of White House officials’ holdings, disclosed cryptocurrency investments totaling between $471,000 and $1,140,000. Like other investment assets, cryptocurrency can create a conflict of interest for federal employees. As a result, Montoya will have to recuse from participating in any particular matters that would directly and predictably affect his financial interests in cryptocurrency. According to Montoya’s annual report, he is also a manager of two corporations. One of these corporations, Three Dot One Four LLC, reportedly had a $111,369 loan forgiven by the federal government as part of the Paycheck Protection Program in April 2020.

Susan Rice’s annual report also shows that she retained significant investments in Canadian companies. Since White House officials and the OGE previously certified her public financial disclosure report, conflicts of interest for these assets were most likely addressed through recusal commitments. Rice’s annual report also showed more than $4,000 in timber sales from her share in Kelvin Creek Timber, which was also likely the subject of recusal commitments.

Almost none of the Biden White House officials reviewed reported accepting gifts. Deputy National Climate Advisor Ali Zaidi reported receiving funding for travel and lodging from the American Lands Project associated with a visit to the Tongass National Forest in August 2021. Cedric Richmond, Director of the Office of Public Engagement until his departure from the administration in May 2022, reported receiving $1,500 from the Broward County Democratic Party for a political event. 

The extent to which a public official could personally profit off of their public service should not be left up to their administration’s level of commitment to ethics. While Biden administration officials’ financial disclosures show that it is possible to minimize conflicts of interest under the current ethics regime, if officials and the administration are committed to meeting a high ethical standard, the examples from the Trump administration make clear the potential for abuse. To prevent future abuses, Congress should adopt legislation that bans the president, vice president, cabinet members and all senior White House staff from owning and trading individual stocks and from retaining personal interests in family businesses that make them susceptible to influence peddling. 

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