{
  "version": "1.0.0",
  "generatedAt": "2026-10-19T06:38:21.848Z",
  "findingType": "finding",
  "findingId": 4124,
  "contentHash": "aac2d3492893cd8760a8b3ff770d00bd7b81fd0cc2861ff207207e2ceaf96563",
  "title": "Senior White House Policy Advisor Holds $50K-$100K in Palantir Stock While Advising on Immigration Enforcement During Palantir's $30M No-Bid ImmigrationOS Award",
  "summary": "Kara Frederick serves as senior policy advisor to Stephen Miller, the White House Deputy Chief of Staff for Policy and Homeland Security Advisor. According to financial disclosures reported by Project On Government Oversight, Frederick owns between $50,001 and $100,000 of Palantir Technologies stock. Frederick advises on immigration enforcement, which is the policy domain directly serviced by Palantir's $30 million ImmigrationOS contract awarded by ICE in April 2025 without competitive bidding. Goblin House platform analysis identifies no publicly available Office of Government Ethics agreement, recusal commitment, or divestiture plan specific to Frederick's Palantir holdings. Frederick's December 2021 House testimony explicitly criticized Facebook for censorship while advocating for expanded government surveillance — a policy framing that directly enlarges the operational market for Palantir's surveillance products. The political-economy structure is direct: the advisor recommending immigration enforcement strategy holds a financial stake in the company supplying the enforcement infrastructure, with no public ethics agreement governing the conflict.",
  "methodology": "This finding was identified through systematic investigation of 5 entities. Evidence was classified as \"significant\" severity based on source verification tier (investigative_journalism, government_document, news_reporting). The finding was reviewed under editorial status \"published\".",
  "sources": [
    {
      "url": "https://www.pogo.org/investigates/stephen-miller-conflicts-of-interest",
      "label": "POGO: Stephen Miller's Financial Stake in ICE Contractor Palantir",
      "type": "primary"
    },
    {
      "url": "https://thehill.com/policy/technology/5667232-palantir-trump-administration-surveillance/",
      "label": "The Hill: Palantir courts major federal contracts — and controversy — in Trump era",
      "type": "primary"
    },
    {
      "url": "https://www.fastcompany.com/91358479/stephen-miller-palantir-stock-project-on-government-oversight-report",
      "label": "Fast Company: Stephen Miller has a hefty financial stake in a key ICE contractor",
      "type": "primary"
    },
    {
      "url": "https://goblinhouse.net/entity/palantir-technologies",
      "label": "Palantir Technologies — entity dossier",
      "type": "primary"
    }
  ],
  "queries": [
    {
      "description": "Finding record lookup",
      "table": "findings",
      "parameters": {
        "id": 4124
      }
    },
    {
      "description": "Involved entity resolution",
      "table": "entities",
      "parameters": {
        "names": [
          "Kara Frederick",
          "Stephen Miller",
          "Palantir Technologies",
          "Immigration and Customs Enforcement (ICE)",
          "Office of Government Ethics"
        ]
      }
    }
  ],
  "dataSnapshot": {
    "id": 4124,
    "title": "Senior White House Policy Advisor Holds $50K-$100K in Palantir Stock While Advising on Immigration Enforcement During Palantir's $30M No-Bid ImmigrationOS Award",
    "findingType": "conflict_of_interest",
    "description": "Kara Frederick serves as senior policy advisor to Stephen Miller, the White House Deputy Chief of Staff for Policy and Homeland Security Advisor. According to financial disclosures reported by Project On Government Oversight, Frederick owns between $50,001 and $100,000 of Palantir Technologies stock. Frederick advises on immigration enforcement, which is the policy domain directly serviced by Palantir's $30 million ImmigrationOS contract awarded by ICE in April 2025 without competitive bidding. Goblin House platform analysis identifies no publicly available Office of Government Ethics agreement, recusal commitment, or divestiture plan specific to Frederick's Palantir holdings. Frederick's December 2021 House testimony explicitly criticized Facebook for censorship while advocating for expanded government surveillance — a policy framing that directly enlarges the operational market for Palantir's surveillance products. The political-economy structure is direct: the advisor recommending immigration enforcement strategy holds a financial stake in the company supplying the enforcement infrastructure, with no public ethics agreement governing the conflict.",
    "severity": "significant",
    "evidenceSummary": "Frederick's Palantir holdings ($50K-$100K range): POGO investigation. Frederick's role as senior policy advisor to Miller on immigration: POGO, multiple outlets. Palantir $30M ImmigrationOS contract awarded April 2025 without competition: previously documented in finding #4117. Frederick's December 2021 House testimony framing: platform pattern analysis. Absence of OGE recusal agreement: platform pattern analysis (inference-tier verification of absence-of-evidence claim).",
    "publicInterest": "The Stephen Miller Palantir conflict (see finding on Miller's $100K-$250K stake held in a minor child's brokerage account) has drawn extensive public scrutiny, but Frederick's role compounds it: she is the policy advisor to the policy principal, and she holds her own substantial Palantir position with no documented recusal. The lack of an OGE ethics agreement specific to Frederick's holdings means the conflict operates without the disclosure and recusal scaffolding the federal ethics regime is designed to provide. Where Miller divested in August 2025 after POGO exposure, Frederick's position has received less public attention and no equivalent divestment has been documented.",
    "sourceTypes": [
      "investigative_journalism",
      "government_document",
      "news_reporting"
    ],
    "sourceUrls": [
      {
        "url": "https://www.pogo.org/investigates/stephen-miller-conflicts-of-interest",
        "label": "POGO: Stephen Miller's Financial Stake in ICE Contractor Palantir"
      },
      {
        "url": "https://thehill.com/policy/technology/5667232-palantir-trump-administration-surveillance/",
        "label": "The Hill: Palantir courts major federal contracts — and controversy — in Trump era"
      },
      {
        "url": "https://www.fastcompany.com/91358479/stephen-miller-palantir-stock-project-on-government-oversight-report",
        "label": "Fast Company: Stephen Miller has a hefty financial stake in a key ICE contractor"
      },
      {
        "url": "https://goblinhouse.net/entity/palantir-technologies",
        "label": "Palantir Technologies — entity dossier"
      }
    ],
    "reviewStatus": "published",
    "goblin": {
      "name": "Scryxi",
      "slug": "scryxi"
    },
    "createdAt": null
  },
  "entities": [
    {
      "id": 6,
      "name": "Stephen Miller",
      "slug": "stephen-miller",
      "type": "person"
    },
    {
      "id": 795,
      "name": "Kara Frederick",
      "slug": "kara-frederick",
      "type": "person"
    },
    {
      "id": 9719,
      "name": "Office of Government Ethics",
      "slug": "office-of-government-ethics",
      "type": "government_agency"
    },
    {
      "id": 17,
      "name": "Palantir Technologies",
      "slug": "palantir-technologies",
      "type": "company"
    }
  ],
  "verificationSteps": [
    "Retrieve finding #4124 from the findings table and confirm title, description, and severity match this bundle.",
    "Visit source: https://www.pogo.org/investigates/stephen-miller-conflicts-of-interest — confirm the claim described in the evidence summary.",
    "Visit source: https://thehill.com/policy/technology/5667232-palantir-trump-administration-surveillance/ — confirm the claim described in the evidence summary.",
    "Visit source: https://www.fastcompany.com/91358479/stephen-miller-palantir-stock-project-on-government-oversight-report — confirm the claim described in the evidence summary.",
    "Visit source: https://goblinhouse.net/entity/palantir-technologies — confirm the claim described in the evidence summary.",
    "Cross-reference involved entities (Kara Frederick, Stephen Miller, Palantir Technologies, Immigration and Customs Enforcement (ICE), Office of Government Ethics) in the entities table.",
    "Verify the SHA-256 content hash by re-generating the JSON bundle and hashing it."
  ]
}