{
  "version": "1.0.0",
  "generatedAt": "2026-10-19T05:56:13.499Z",
  "findingType": "finding",
  "findingId": 4125,
  "contentHash": "ee6c55424416b19738d524613a00b77963c44d27777458bad94e49ec9f9d51b3",
  "title": "Stephen Miller Held $100K-$250K of Palantir Stock in Minor Child's Brokerage Account While Architect of Trump Immigration Policy; Divested Only After POGO Exposure in August 2025",
  "summary": "Stephen Miller serves as White House Deputy Chief of Staff for Policy and Homeland Security Advisor, with primary responsibility for the Trump administration's immigration enforcement strategy. According to Office of Government Ethics Form 278e financial disclosures obtained and analyzed by Project On Government Oversight (POGO), Miller disclosed Palantir Technologies stock holdings between $100,001 and $250,000 — registered in a brokerage account belonging to one of his three young children, all under the age of six. The Office of Government Ethics applies the imputed-disclosure rule under 18 U.S.C. § 208 (the federal criminal conflict-of-interest law), which treats assets owned by a spouse or minor child as if the employee owns them directly. Palantir holds a $30 million no-bid ImmigrationOS contract with ICE awarded April 2025 plus additional contracts servicing the deportation pipeline Miller architects. POGO published its investigation on June 24, 2025. Miller divested the Palantir holdings in August 2025, only after POGO's public exposure made the conflict actionable. White House spokesperson Abigail Jackson stated that Miller \"fully divested from stock holdings early in the administration in coordination with the Office of Government Ethics\" — a statement contradicted by the disclosed mid-March 2025 financial form showing the holdings still in place months later. A separate White House official told POGO that Miller \"has confirmed to White House ethics officials that he has and will continue to recuse from participating in official matters that could affect those stocks\" — a recusal that, if applied to its logical scope, would require Miller to withdraw from substantively all immigration enforcement policy.",
  "methodology": "This finding was identified through systematic investigation of 5 entities. Evidence was classified as \"critical\" severity based on source verification tier (investigative_journalism, government_document, news_reporting, ethics_filing). 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://www.whitehouse.gov/wp-content/uploads/2025/06/Miller-Stephen.pdf",
      "label": "Office of Government Ethics: Stephen Miller Form 278e disclosure",
      "type": "primary"
    },
    {
      "url": "https://newrepublic.com/post/197149/stephen-miller-palantir-stocks-immigration-report",
      "label": "The New Republic: Damning Report Exposes Stephen Miller's Shady Ties to Palantir",
      "type": "primary"
    },
    {
      "url": "https://www.rollingstone.com/politics/politics-news/stephen-miller-financial-stake-palantir-ice-contractor-1235371343/",
      "label": "Rolling Stone: Stephen Miller Has Financial Stake in Company Helping ICE With Deportations",
      "type": "primary"
    },
    {
      "url": "https://truthout.org/articles/stephen-miller-owns-up-to-250000-in-palantir-stock-report-finds/",
      "label": "Truthout: Stephen Miller Owns Up to $250,000 in Palantir Stock, Report Finds",
      "type": "primary"
    },
    {
      "url": "https://presidentmiller.com/money",
      "label": "$250K in Stock While Running Deportations — President Miller",
      "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": 4125
      }
    },
    {
      "description": "Involved entity resolution",
      "table": "entities",
      "parameters": {
        "names": [
          "Stephen Miller",
          "Palantir Technologies",
          "Immigration and Customs Enforcement (ICE)",
          "Project On Government Oversight (POGO)",
          "Office of Government Ethics"
        ]
      }
    }
  ],
  "dataSnapshot": {
    "id": 4125,
    "title": "Stephen Miller Held $100K-$250K of Palantir Stock in Minor Child's Brokerage Account While Architect of Trump Immigration Policy; Divested Only After POGO Exposure in August 2025",
    "findingType": "conflict_of_interest",
    "description": "Stephen Miller serves as White House Deputy Chief of Staff for Policy and Homeland Security Advisor, with primary responsibility for the Trump administration's immigration enforcement strategy. According to Office of Government Ethics Form 278e financial disclosures obtained and analyzed by Project On Government Oversight (POGO), Miller disclosed Palantir Technologies stock holdings between $100,001 and $250,000 — registered in a brokerage account belonging to one of his three young children, all under the age of six. The Office of Government Ethics applies the imputed-disclosure rule under 18 U.S.C. § 208 (the federal criminal conflict-of-interest law), which treats assets owned by a spouse or minor child as if the employee owns them directly. Palantir holds a $30 million no-bid ImmigrationOS contract with ICE awarded April 2025 plus additional contracts servicing the deportation pipeline Miller architects. POGO published its investigation on June 24, 2025. Miller divested the Palantir holdings in August 2025, only after POGO's public exposure made the conflict actionable. White House spokesperson Abigail Jackson stated that Miller \"fully divested from stock holdings early in the administration in coordination with the Office of Government Ethics\" — a statement contradicted by the disclosed mid-March 2025 financial form showing the holdings still in place months later. A separate White House official told POGO that Miller \"has confirmed to White House ethics officials that he has and will continue to recuse from participating in official matters that could affect those stocks\" — a recusal that, if applied to its logical scope, would require Miller to withdraw from substantively all immigration enforcement policy.",
    "severity": "critical",
    "evidenceSummary": "Miller's Palantir holdings disclosure ($100K-$250K range, minor child's brokerage account): OGE Form 278e (mid-March 2025), as obtained and analyzed by POGO (June 24, 2025). Imputed-disclosure rule under 18 U.S.C. § 208: OGE's own published guidance. August 2025 divestment timing: multiple outlets confirm post-POGO disclosure date. White House statements: \"fully divested\" (Abigail Jackson) and \"will recuse\" (separate official to POGO) — contradictory framings confirmed in reporting. Palantir $30M ImmigrationOS contract: previously documented in finding #4117.",
    "publicInterest": "The U.S. criminal conflict-of-interest statute, 18 U.S.C. § 208, was written precisely to prevent the structure documented here: an executive branch official making policy that directly enriches their own financial position through a holding nominally owned by a family member. The minor-child-brokerage-account structure obscures the conflict from casual review while not, as the OGE explicitly confirms, changing its legal character. The eight-month delay between OGE disclosure and actual divestment — and the divestment occurring only after public exposure — represents the precise failure of the ethics-enforcement regime that the disclosure system was designed to prevent. The White House's two contradictory statements (full early divestment vs. ongoing recusal commitment) cannot both be true; that they were both made to the same investigative organization within a single news cycle is itself a documented contradiction.",
    "sourceTypes": [
      "investigative_journalism",
      "government_document",
      "news_reporting",
      "ethics_filing"
    ],
    "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://www.whitehouse.gov/wp-content/uploads/2025/06/Miller-Stephen.pdf",
        "label": "Office of Government Ethics: Stephen Miller Form 278e disclosure"
      },
      {
        "url": "https://newrepublic.com/post/197149/stephen-miller-palantir-stocks-immigration-report",
        "label": "The New Republic: Damning Report Exposes Stephen Miller's Shady Ties to Palantir"
      },
      {
        "url": "https://www.rollingstone.com/politics/politics-news/stephen-miller-financial-stake-palantir-ice-contractor-1235371343/",
        "label": "Rolling Stone: Stephen Miller Has Financial Stake in Company Helping ICE With Deportations"
      },
      {
        "url": "https://truthout.org/articles/stephen-miller-owns-up-to-250000-in-palantir-stock-report-finds/",
        "label": "Truthout: Stephen Miller Owns Up to $250,000 in Palantir Stock, Report Finds"
      },
      {
        "url": "https://presidentmiller.com/money",
        "label": "$250K in Stock While Running Deportations — President Miller"
      },
      {
        "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": 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 #4125 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://www.whitehouse.gov/wp-content/uploads/2025/06/Miller-Stephen.pdf — confirm the claim described in the evidence summary.",
    "Visit source: https://newrepublic.com/post/197149/stephen-miller-palantir-stocks-immigration-report — confirm the claim described in the evidence summary.",
    "Visit source: https://www.rollingstone.com/politics/politics-news/stephen-miller-financial-stake-palantir-ice-contractor-1235371343/ — confirm the claim described in the evidence summary.",
    "Visit source: https://truthout.org/articles/stephen-miller-owns-up-to-250000-in-palantir-stock-report-finds/ — confirm the claim described in the evidence summary.",
    "Visit source: https://presidentmiller.com/money — 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 (Stephen Miller, Palantir Technologies, Immigration and Customs Enforcement (ICE), Project On Government Oversight (POGO), Office of Government Ethics) in the entities table.",
    "Verify the SHA-256 content hash by re-generating the JSON bundle and hashing it."
  ]
}