A recent financial disclosure has raised questions about the trading activities of Adriana Kugler, a former governor of the Federal Reserve, who resigned from her position in August after a brief tenure beginning in 2023. The disclosure, filed with the U.S. Office of Government Ethics (OGE) in September, includes details of stock trades made by Kugler and her spouse, which have come under scrutiny for potentially violating the Fed’s ethics rules.
The issues surfaced after Kugler’s financial disclosures drew the attention of ethics officials at the Federal Reserve, who subsequently declined to certify the report. Sean Croston, the deputy associate general counsel and designated ethics official at the Federal Reserve Board, indicated that “matters related to this disclosure were referred earlier this year by the Board’s Ethics Office to the independent Office of Inspector General.”
The report highlights trades made in stocks of major companies such as Apple, Cava Group, Southwest Airlines, and Caterpillar. These trades had been identified by the Federal Reserve as restricted under newly implemented ethics rules, established in 2021 in the wake of previous trading scandals involving senior officials.
Typically, ethics reports for senior officials are approved by agency ethics officers, but Kugler’s situation has prompted further examination. In her latest disclosure, Kugler indicated that the trades in question were made without her knowledge by her husband, Ignacio Donoso, an immigration attorney. In her 2024 report, she stated that these trades were divested at the direction of ethics officials following concerns about compliance.
The allegations include that several trades made in 2024 might violate the Fed’s ethics policy, which prohibits officials from trading individual stocks and engaging in transactions during “blackout periods”—times when trading is restricted ahead of significant monetary policy decisions. These compliance issues became particularly relevant following ethics training sessions held in the fall, which highlighted potential discrepancies in Kugler’s reporting.
In July, discussions reportedly took place involving Kugler and other officials, including Fed Chair Jerome Powell, regarding the possibility of obtaining a waiver from the Fed’s pre-clearance and blackout-period trading restrictions to manage her investments more effectively. However, Kugler ultimately did not participate in this meeting, citing personal reasons, and soon after announced her resignation.
In her financial disclosure, Kugler also reported receiving nearly $50,000 worth of pro bono legal services from the law firm Arnold & Porter. Following her resignation, she returned to her academic role at Georgetown University, where she serves as a professor at the McCourt School of Public Policy and Economics.
