— Former Federal Reserve governor Adriana D. Kugler, who resigned in August, repeatedly made or was linked to stock trades in 2024 that violated the Fed’s ethics and trading restrictions, according to a report from the U.S. Office of Government Ethics released on Nov. 15. The disclosures list purchases and sales in individual companies including Apple, Southwest Airlines and Cava, many executed during the blackout period before policy meetings. The transactions, ranging from about $1,000 to $250,000, were flagged to the Fed’s internal watchdog in early 2025 and help explain Ms. Kugler’s abrupt departure months before her term was due to end.
Key Takeaways
- OGE report (Nov. 15, 2025) finds multiple trades by or attributed to Adriana D. Kugler during Fed blackout windows ahead of policy meetings.
- Reported transactions in 2024 included shares in Apple, Southwest Airlines and Cava; individual trade sizes cited range from $1,000 to $250,000.
- Ms. Kugler’s disclosure forms state many trades were executed by her husband and that he “did not intend to violate any rules or policies.”
- The Fed’s tightened trading rules from 2022 bar trades in individual companies and restrict transactions during the roughly two-week pre-meeting blackout period.
- Some improper trades were brought to the Fed’s internal watchdog in early 2025 after compliance discussions in fall 2024 and an unsuccessful waiver request before the July 29–30 meeting.
- Ms. Kugler announced her resignation on Aug. 1, 2025; she had joined the Board in September 2023 after a Biden nomination.
- The episode follows earlier Fed ethics controversies: three officials resigned in 2021–22, prompting the 2022 rule tightening that also banned crypto, FX and commodity trades by senior officials.
Background
Federal Reserve governors and other senior officials are subject to strict trading restrictions intended to prevent conflicts between personal financial activity and monetary policymaking. After several ethics breaches in 2021 and 2022 — which led to three resignations — the Fed tightened rules in 2022, prohibiting trades in individual securities and banning certain asset classes including cryptocurrencies, foreign exchange and commodities. The updated policy also enforces a blackout period of roughly two weeks before rate-setting meetings during which trades are not permitted.
Those restrictions extend to spouses and minor children, and require timely disclosure of financial transactions. The 2024 calendar-year disclosures were due in May (per the reporting timeline cited), and while most policymakers met that deadline, Ms. Kugler obtained an extension. The Office of Government Ethics (OGE) conducts independent reviews of executive-branch conflicts and recently released a report detailing the transactions that prompted internal probes at the Fed.
Main Event
The newly released OGE disclosures show repeated purchases and sales of individual stocks in 2024, many executed within blackout windows before policy meetings, including transactions involving Apple, Southwest Airlines and Cava. According to the filings, Ms. Kugler indicated that several trades were carried out by her husband without her knowledge; the forms quote him as saying he did not intend to break rules. Trade sizes reported in the filings span from roughly $1,000 to $250,000.
Compliance staff at the Fed met with Ms. Kugler in fall 2024 to review the bank’s trading rules and the disclosure process, the report says. Days before the July 29–30, 2024 policy meeting, Ms. Kugler requested a temporary waiver from Chair Jerome H. Powell to dispose of impermissible holdings; the request was denied. Although she participated in pre-meeting briefings, she did not attend the July meeting itself; the Fed announced her absence the morning the meeting began, calling it a “personal matter.” On Aug. 1, 2025, she announced her resignation.
Some flagged transactions were referred to the Fed’s internal watchdog in early 2025, which in turn informed the Office of Government Ethics. The OGE report released Nov. 15 documents the trades and the explanations Ms. Kugler provided on disclosure forms filed after the events. She has not provided a public, detailed accounting beyond the disclosures, and did not immediately respond to requests for comment tied to the OGE release.
Analysis & Implications
The findings underscore the continued challenge of insulating monetary policymakers from personal financial interests. The 2022 rule changes were meant to close loopholes after earlier scandals, yet the OGE disclosures show enforcement and compliance remain complex when trades are routed through family members. If a spouse executes trades without the official’s knowledge, regulators face an evidentiary hurdle in proving intent or culpability, complicating sanctions and public accountability.
Politically, the episode arrives at a sensitive moment for the Fed. The departures and probes give critics leverage to question the board’s governance and ethics safeguards. In turn, any perception of weak enforcement can erode public trust in rate-setting institutions, raising pressure on both Congress and the Fed to demand clearer rules, swifter investigations and stiffer penalties for breaches.
Operationally, the disclosures may prompt the Fed to tighten internal compliance processes: more proactive monitoring of family-held accounts, accelerated reviews of extensions and clearer guidance about waiver requests. For markets, the concern is reputational rather than transactional — there is no evidence presented that policy votes were swayed by these holdings — but reputational damage can affect the Fed’s broader ability to communicate and implement policy effectively.
Comparison & Data
| Year | Notable Fed Ethics Incidents | Outcome |
|---|---|---|
| 2021–2022 | Multiple officials found to have traded while on the Board | Three resignations; rules tightened in 2022 |
| 2024 | Transactions by or attributed to family members of a governor flagged | Internal compliance meetings; waiver request denied |
| 2025 | OGE report on Adriana D. Kugler’s 2024 trades released | Public disclosures; renewed scrutiny |
The table above places the OGE disclosures in context alongside the 2021–22 resignations that precipitated the 2022 policy changes. While the earlier cases led directly to resignations, the 2024–25 inquiries resulted in internal referrals, an OGE report and public reporting that contributed to Ms. Kugler’s early exit in 2025.
Reactions & Quotes
Fed officials have largely pointed to existing processes and said they will follow up on the OGE findings. The public response has mixed tones: ethics advocates call for stricter enforcement, while some policymakers emphasize procedural fairness when spouses are involved.
“The Board takes its ethics obligations seriously and will review the OGE’s findings and recommendations,”
Federal Reserve spokesman (official statement)
Legal and ethics experts noted the difficulty of demonstrating willful misconduct when trades originate with family members, underscoring a frequent fault line in enforcement.
“Attribution of trades to a spouse raises tricky questions about intent and notice — enforcement needs both clear rules and robust investigatory tools,”
Ethics scholar, university law center
Public advocacy groups urged clearer preventive measures, arguing that the reputational costs to the institution justify more proactive safeguards.
“Independent bodies should have prompt access to trading records to ensure transparency and deter violations,”
Government ethics advocacy group
Unconfirmed
- Whether any of Ms. Kugler’s trades directly influenced her public views or votes on policy remains unproven in the public record.
- No public evidence has been released establishing that Ms. Kugler personally directed the trades attributed to her spouse; the spouse’s intent is stated in filings but not independently verified.
- It is not publicly confirmed whether the OGE will recommend sanctions to the President or pursue further administrative penalties beyond disclosure.
Bottom Line
The OGE disclosures make clear that enforcement gaps persist even after the Fed’s 2022 tightening of ethics rules. Trades tied to or carried out by family members can evade immediate scrutiny, creating situations that breed public doubt about the independence of monetary policymakers. While the records do not allege policy decisions were bought or sold, the optics are damaging and likely to catalyze calls for stronger preventive measures.
For policymakers, the case amplifies pressure to improve compliance systems — including faster audits of extensions, clearer guidance on family account oversight, and firmer rules on waiver requests. For the public and markets, the episode is a reminder that institutional integrity depends not only on rules but on transparent, enforceable processes that limit real and perceived conflicts of interest.
Sources
- The New York Times — news report summarizing OGE disclosures and Fed response (media)
- U.S. Office of Government Ethics (OGE) — federal ethics oversight body (official)
- Board of Governors of the Federal Reserve System — institutional rules and public statements (official)