Kash Patel’s Late Stock Disclosure Raises STOCK Act Questions

FBI Director Kash Patel failed to properly disclose a six-figure purchase of stock in a bitcoin-fueled business intelligence and mobile software company that has contracted with the Department of Justice, according to federal financial records reviewed by NOTUS.
Patel, who has regularly traded individual stocks since becoming FBI director, purchased between $100,001 and $250,000 worth of stock in MicroStrategy on Nov. 21. But Patel did not disclose the trade with federal regulators until May 26 because he “inadvertently omitted” it from a previously filed stock disclosure document, he told Office of Government Ethics officials in a letter that day.
The Stop Trading on Congressional Knowledge Act requires high-ranking executive branch officials to publicly disclose individual stock trades of more than $1,000 no later than 45 days after executing a trade. First-time violators are subject to a $200 fine.
MicroStrategy, commonly known as Strategy, is a government contractor that has done millions of dollars in business over the years with the Justice Department, of which the FBI is a part.
MicroStrategy bills itself as a “Bitcoin Treasury Company” that aims to “strategically accumulate Bitcoin and advocate for its role as digital capital.” The FBI investigates certain cryptocurrency matters, particularly cryptocurrency investment fraud, and Patel has praised his bureau’s crypto efforts.
“Crypto Fraudsters have been scamming and taking advantage of the America people for too long. No more! This FBI will find you, and we will bring you to justice!” Patel wrote in a June 19 post on X.“$15 BILLION in bitcoin seized. One of the biggest financial fraud takedowns ever — a global criminal network built on forced labor, money laundering & deception. This FBI took down their empire,” Patel wrote on X in October, the month before making his MicroStrategy purchase.
In a May 28 letter to the Office of Government Ethics, Deputy Assistant Attorney General William Taylor said Patel’s personal purchase of MicroStrategy stock does not represent a conflict of interest with his responsibilities overseeing the FBI.
“I continue to believe that Director Patel is in compliance with applicable laws and regulations governing conflicts of interest,” Taylor said, adding that Patel’s late disclosure was caused by an unspecified “miscommunication.”
An FBI official familiar with the matter said Patel’s late reporting “was not realized and unintentional.” The official added that the Department of Justice, which would be responsible for issuing or waiving any STOCK Act violation fine, has not at present fined him.
In a statement to NOTUS, the FBI reiterated points Taylor made in his letter and said that “once the mistake was discovered,” Patel amended his disclosure from last year and “correct paperwork” was filed and subsequently approved by a DOJ ethics official.
Dylan Hedtler-Gaudette, acting vice president of policy and government affairs for nonpartisan watchdog organization Project on Government Oversight, said Patel’s stock purchase disclosure is “absolutely” late under the letter of the STOCK Act.
“That’s violating the law — no other way to put it,” said Hedtler-Gaudette, who like many government watchdog groups and some members of Congress have advocated for a ban on federal officials trading individual stocks to defend against potential conflicts of interest and the specter of insider trading.
NOTUS has identified more than 30 members of Congress who have submitted tardy STOCK Act disclosures during the past year.
Office of Government Ethics spokesperson Patrick Shepherd declined to comment on Patel, saying the independent agency “does not respond to questions about specific individuals.”
MicroStrategy stock has lost about half its value since Patel bought his tranche last year, although some financial analysts are bullish on the stock because of the company’s recently announced financial overhaul plan.
Patel’s personal stock trading has previously earned attention: In May 2025, he purchased up to $50,000 worth of stock in doughnut chain Krispy Kreme, which found itself the target of shareholder lawsuits related to a 2024 data breach that exposed the personal data of more than 160,000 people.
The FBI became involved when it issued an advisory in June 2025 indicating that it was investigating Play — a ransomware group that took credit for the Krispy Kreme data breach — for suspected criminality.