Government Equity Stakes and Chip Export Deals
Summary
In his second term Trump has taken federal ownership shares, called equity, or special control rights in private companies. He has made some chip export licenses depend on payments to the government. He has also changed export rules in trade talks with China. By late October 2026 a Council on Foreign Relations (CFR) tracker counted 48 equity deals worth $30.3 billion. They include Intel, MP Materials, Trilogy Metals, L3Harris’s missile business and a Venezuelan oil venture. The government also holds a “golden share” in U.S. Steel, which gives it veto rights.47,1,2,3,4,48 Nvidia and AMD agreed to pay the government a share of their China chip sales in return for export licenses.5 Nvidia’s FY2026 10-K, its annual report to investors, shows about $60 million of licensed H20 sales and no H200 revenue.6 TikTok’s U.S. business went to a group of investors led by Oracle, Silver Lake and the Abu Dhabi-backed investor MGX.7 The group paid the Treasury a first $2.5 billion of a reported ~$10 billion fee.8 As of Nov 8, 2026 the record has no court ruling on any of them. It also has no decision by the Government Accountability Office (GAO), Congress’s auditing arm, and no new law.
Background
Article I, § 8, cl. 1 of the Constitution gives Congress the power to tax and spend.32 The Appropriations Clause (Art. I, § 9, cl. 7) says money may leave the Treasury only when a law passed by Congress approves it.33 The Export Clause (Art. I, § 9, cl. 5) bars taxes on exports. It says “No Tax or Duty shall be laid on Articles exported from any State.”5,34 The Export Control Reform Act of 2018 (ECRA, 50 U.S.C. § 4801 et seq.)35 lets the Commerce Department require licenses to export sensitive technology. It may do so for national-security and foreign-policy reasons. The record shows nothing in that law that allows license fees or revenue shares.5 The CHIPS and Science Act36 allowed grants to chipmakers. The record shows nothing in it that allows the government to take ownership shares.3 The Protecting Americans from Foreign Adversary Controlled Applications Act (PAFACA)37 gave TikTok two choices. Its Chinese parent, ByteDance, could sell it in a “qualified divestiture” that ended any “operational relationship,” or TikTok would be banned.10,11 The Supreme Court upheld the law unanimously in TikTok Inc. v. Garland, and it took effect Jan 19, 2025.11,10,38 The Take Care Clause (Art. II, § 3) requires the President to “take Care that the Laws be faithfully executed.”39
Several of the companies gave to the $239 million fund for Trump’s inauguration. CNBC lists Nvidia’s gift at $1 million or more, while NBC puts it at six figures.12 In August 2025 the administration confirmed it keeps a scorecard grading 553 companies on their “support of present and future administration initiatives.”13
What happened
Sovereign wealth fund and the 2025 stakes
On Feb 3, 2025 an executive order, a written order from the President to federal agencies, called for a U.S. “sovereign wealth fund,” a government-owned investment fund. Trump said it could buy TikTok.9 The order asked for “an evaluation of the legal considerations for establishing and managing such a fund, including any need for legislation.”9 The fund has not been created. Treasury Secretary Scott Bessent said on May 23, 2025 that Trump had put it “on pause,” and each stake is held by the agency that took it.15
On Jul 10, 2025, the Pentagon became MP Materials’ largest shareholder. It bought $400 million of preferred stock, about 15% of the company. It also set a 10-year minimum price for the company’s rare-earth output.2 On Aug 22, the government took a roughly 10% stake in Intel. It got 433.3 million shares at $20.47 each. It paid by turning grants into stock: $5.7 billion in CHIPS Act grants that had been awarded but not paid, and $3.2 billion in Secure Enclave funds.3 On Aug 7 Trump had publicly said CEO Lip-Bu Tan should resign over his China ties.18 Tan then met Trump and Commerce Secretary Howard Lutnick and, as Reuters put it, “charmed” him.19 The stake is passive, with no seat on Intel’s board.3
Later 2025 deals included three more. Lithium Americas gave warrants, which are rights to buy shares later, for 5% of the company and 5% of its GM joint venture at Thacker Pass. The warrants came with a restructured $2.26 billion Energy Department loan (Sept 30). Commerce took a participation interest, a right to share in future returns, in Westinghouse. The Pentagon gave a package to Vulcan Elements, a company that 1789 Capital invests in. CFR puts that package at $720 million, including a $620 million loan and a $50 million Commerce equity stake. The company’s release lists these separately from its CHIPS incentives (Nov 2; see Pentagon awards to companies tied to Trump’s sons below).17,30,53,75,76 On Oct 6, 2025, the government agreed to buy 10% of Trilogy Metals for $35.6 million, plus warrants for 7.5% more. The same day, Trump approved the 211-mile Ambler Road. The road serves the company’s project in the Ambler mining district.4 On Oct 23 the Interior Department reissued the road’s rights-of-way, the permits to cross public land, even though dozens of tribes opposed it. About 20 miles of the road crosses Gates of the Arctic National Park and Preserve.4,60 The government is both a Trilogy shareholder and the agency that permits the road.4,60 The stock tripled. At a Mar 25, 2026 House Natural Resources subcommittee hearing, Rep. Jared Huffman put Trump fundraiser John Paulson’s gain at about $70 million.21,61
CHIPS and Pentagon equity deals from December 2025
Equity deals multiplied from December 2025. That month Commerce signed a CHIPS research letter of intent, a first-step agreement, that included equity. It offered up to $150 million for an equal amount of equity in the lithography startup xLight (Dec 1).45 On Dec 15 the Pentagon and Commerce agreed to invest together in Korea Zinc’s planned smelter in Clarksville, Tennessee. Deputy Defense Secretary Steve Feinberg described a “conditional investment of $1.4 billion,” and Commerce is to provide $210 million in CHIPS funds. The company’s release gives no ownership percentages.86
By Jul 29, 2026 the Pentagon and Commerce had taken stakes in 19 more companies. They included $150 million of preferred equity in Atlantic Alumina (Jan 12). They also included $1 billion, committed in January, for a convertible preferred security in L3Harris’s Missile Solutions spinoff. That security turns into common stock at the company’s initial public offering (IPO), its first sale of shares to the public. The deal closed Apr 23. The IPO is planned for the second half of 2026.46,62,63 Commerce signed more CHIPS letters of intent, each conditioned on “a minority, non-controlling equity stake,” meaning a small share without control. One was for $2.013 billion with nine quantum-computing companies, led by IBM at $1 billion (May 21). Another was for $874 million with seven chip-materials and computing firms (Jul 29).46,64,65 Commerce’s releases say it also made a $500 million CHIPS Act award to SandboxAQ (Jun 17). It also signed a $250 million CHIPS Act final agreement with I-Pulse (Jun 25). Each was in exchange for a minority, non-controlling equity stake.82,83
The Office of Strategic Capital (OSC) is a Pentagon office that finances companies. It offered a conditional loan of up to $820 million to Performance Drone Works (Jul 31).47,66 The Pentagon also took equity in Strategic Bauxite ($85.5 million, Aug 7) and in Alcoa’s Wagerup gallium project in Western Australia (an estimated $174 million, Aug 31). It took equity in tungsten producer The Elmet Group (up to $450 million in redeemable preferred stock plus warrants, Sept 14). It also took equity in high-purity iron maker Hertha Metals ($65 million, Sept 29).47,67,68,69,70 OSC also made a conditional commitment of up to $1.5 billion in financing, with warrants, to Wolfspeed (Oct 7). Wolfspeed’s filing says the deal “is subject to substantial conditions.”47,71 On Oct 14 Commerce let GlobalFoundries redirect up to $955 million of its existing CHIPS award. In exchange, the government gets about 4% of the company, on top of about 1% under a July 29 letter of intent. Neither release gives the number of shares, the price or the voting terms.47,72 On Oct 22 Commerce signed $389 million in letters with Helion, Commonwealth Fusion Systems, Vertical Semiconductor and Sibelco for “non-voting” stakes.47,73 CFR’s tracker then counted 48 deals: 29 by Commerce, 13 by Defense, 6 by the Development Finance Corporation (DFC) and 2 by Energy.47 Fortune reported on stakes in private companies such as Vulcan and xLight. It said “no public securities filings with the SEC exist at all.”47
On Aug 28–Sept 5, 2026 OSC took a 35% stake, “at no cost to U.S. taxpayers,” in North American Blue Energy Partners (NABEP). NABEP is a Barbados company led by Alejandro Betancourt. Venezuela’s interim government had granted it 100-year concessions, or rights to drill, for 17 oilfields.48 The government can veto board appointments, and the State Department may buy 20% of output at production cost.48 On Aug 28 Pentagon spokesman Sean Parnell had said “OSC’s role is strictly limited to providing capital assistance.”48 CNBC reported that Betancourt “has faced money laundering and corruption allegations” and “has not been charged with a crime.”48
U.S. Steel golden share
On June 13, 2025, Trump approved Nippon Steel’s $14.9 billion takeover of U.S. Steel. He had campaigned against the deal.1 The takeover closed on June 18.85 A national-security agreement came with the deal. Under it, the government holds a “golden share.” That share gives it a veto over moving the headquarters, closing plants, redirecting the $11 billion investment pledge or moving jobs overseas.1 AP reported that the power belongs to Trump personally while he is in office and passes to Commerce and Treasury under later presidents.1 On Sept 19, 2025, U.S. Steel dropped its plan to idle its Granite City, Illinois, plant. It did so after Lutnick told the company the administration would not allow it. That was the first use of the rights.16,74
Chip export licenses and revenue shares
On May 13, 2025, Commerce cancelled the Biden administration’s AI Diffusion Rule. It was the first day of the Gulf trip on which UAE and Saudi AI-chip deals were announced. The rule would have capped advanced-chip exports by groups of countries from May 15. Before the rule was formally cancelled, Under Secretary Jeffrey Kessler had told staff not to enforce it. Those staff work at the Bureau of Industry and Security (BIS), the Commerce office that enforces export controls.50 On May 16 Commerce announced a 5-gigawatt AI data-center campus in Abu Dhabi, to be built with Nvidia hardware by G42.81
On Aug 11, 2025, Nvidia and AMD agreed to pay the government 15% of revenue from China sales of their H20 and MI308 chips. In return they got export licenses.5 The administration had restricted the chips in April for national-security reasons. Trump said he had first asked for 20%.5 Nvidia’s FY2026 10-K later said U.S. officials “expressed an expectation” of the 15%. But it said they “did not publish a regulation codifying such requirement,” and licensed H20 sales came to only about $60 million.6
At the Oct 30, 2025 Busan summit, the U.S. put off a Commerce rule known as the “Affiliates Rule,” which extended Entity List limits to companies at least 50% owned by listed Chinese firms.44 The Entity List is Commerce’s list of foreign companies that need a special license to receive U.S. goods. In return, China paused its controls on rare-earth exports for a year.22 A BIS rule suspended the Affiliates Rule from Nov 10, 2025 to Nov 9, 2026, a pause of one year. A further rule dated Nov 9, 2026 extends the suspension through Jan 10, 2027.52,77
On Dec 8 Trump approved sales of Nvidia’s H200 chip to China with 25% of revenue going to the government.23 A BIS final rule published Jan 15, 2026 changed how license requests for the H200, AMD’s MI325X and similar chips are handled. Before, they were presumed to be denied. Now each is reviewed case by case. Exporters must certify certain things, including that total shipments to China and Macau will be no more than 50% of the product shipped to U.S. customers. The chips must also be tested independently in the United States.51,78 Proclamation 11002 (Jan 14, 2026), a formal presidential announcement, put a 25% import duty on the listed chips under Section 232. That trade law covers imports that threaten national security. Chips for U.S. data centers and other uses at home are exempt. According to the Peterson Institute (PIIE), the two measures collect the 25% through an import tariff rather than a charge on exports.51,6,79 Beijing at first blocked the shipments.23 Trump visited Beijing on May 13–15, 2026, and Nvidia CEO Jensen Huang flew with him on Air Force One. During the visit, Commerce cleared 10 Chinese firms to buy the H200.24 Trump’s own accounts bought $500,001 to $1 million of Nvidia stock on Jan 6, 2026, a purchase labeled “UNSOLICITED” in his transaction report to the Office of Government Ethics (OGE). His trading is covered in Cabinet Financial Disclosures and Ethics Complaints#The President’s own trading.84
UAE chips and MGX
On Jan 21, 2025 Trump announced Stargate, a $500 billion artificial-intelligence (AI) venture. It includes MGX, an investment firm backed by the sovereign wealth fund of Abu Dhabi in the United Arab Emirates (UAE).14 On Sept 15, 2025, the New York Times reported a connection between two things. One was the decision to let the UAE import hundreds of thousands of Nvidia chips. The other was a $2 billion MGX investment routed through the Trump family’s USD1 stablecoin, a crypto token.20 On Jul 10, 2026 a BIS rule moved the UAE into its most favorable export-control group. It approved the UAE government and certain companies to receive advanced computing items “in the UAE license-free.” Sheikh Tahnoon bin Zayed is the UAE national-security adviser who controls G42 and MGX. On Jan 16, 2025, four days before the inauguration, he had bought 49% of World Liberty Financial through an investment company.49,80
TikTok
On Jan 20, 2025, his first day, Trump ordered the Attorney General not to enforce PAFACA for 75 days.10 He extended the order three more times (Apr 4 for 75 days, and Jun 19 and Sept 16 for 90 days each). The Justice Department (DOJ) told tech companies they could keep serving TikTok “without incurring any legal liability.” It said it was “irrevocably relinquishing any claims” against them.10 On Sept 25 an executive order approved a plan for selling TikTok’s U.S. business.11 The deal closed Jan 22, 2026 as “TikTok USDS.” Oracle, Silver Lake and MGX hold 15% each, and ByteDance keeps 19.9%.7 The Wall Street Journal and Reuters later reported that the administration was set to get a ~$10 billion “fee” for arranging the deal.8 The investors paid the first $2.5 billion to the Treasury when the deal closed on Jan 22. The rest is due in installments.8
Pentagon awards to companies tied to Trump’s sons
ProPublica reported that White House adviser Peter Navarro asked for the Vulcan loan. It also reported that 1789 Capital took a stake in Vulcan about three months before the deal was announced.30 Eric Trump is an investor in and chief strategy adviser to Foundation Future Industries, a startup that makes human-shaped robots. On Fox Business (Apr 23, 2026) he promoted its announced $24 million Pentagon contract to test robots. The report names no Pentagon office that awarded it.56 On Aug 5, 2026, Rep. Robert Garcia and Sens. Elizabeth Warren, Richard Blumenthal and Tammy Duckworth wrote to the Defense Department’s inspector general, an independent watchdog inside the agency. They asked for an investigation of $3.2 billion in federal awards, plus $3.1 billion in contract options. The awards went to companies tied to Donald Trump Jr.’s 1789 Capital and Eric Trump’s American Ventures. They were made after the Trump-tied firms became involved.57 The Washington Post reported that the administration and the Pentagon deny doing anything improper.57 On Nov 9, 2026, ProPublica reported that the CDC and the State Department gave nearly $40 million in disease-screening contracts to XpresTest. Months earlier, American Ventures, a fund launched by Dominari Holdings, had invested about $30 million in XpresTest’s parent company, XWELL. The Trump sons hold more than 10% of Dominari. A spokesperson for the sons said they are “merely passive, minority investors” and had no role in the contracts.87
Key dates
- 2025-01-20 — TikTok non-enforcement order — → ledger
- 2025-02-03 — Sovereign wealth fund EO — → ledger
- 2025-06-13 — Trump approves Nippon Steel’s U.S. Steel takeover with a golden share — → ledger
- 2025-08-11 — Nvidia/AMD 15% China revenue deal — → ledger
- 2025-08-22 — Government takes ~10% of Intel — → ledger
- 2025-10-30 — Busan summit, Affiliates Rule postponed — → ledger
- 2025-12-08 — H200 approval with 25% cut; Jan 2026 rule and Proclamation 11002 — → ledger
- 2026-01-22 — TikTok USDS closes — → ledger
- 2026-05-13 — Beijing state visit, H200 licenses for 10 firms — → ledger
- 2026-07-26 to 10-28 — CFR count reaches 48 deals worth $30.3B — → ledger
- 2026-08-05 — Lawmakers ask Pentagon IG to review $3.2B in awards to Trump-son-backed firms — → ledger
- 2026-08-28 to 09-05 — OSC 35% stake in Venezuelan oil venture NABEP — → ledger
- 2026-10-22 — Greenberg v. Trump emoluments suit — → ledger
Why it matters
Export Clause (Art. I, § 9, cl. 5) and ECRA (50 U.S.C. § 4801 et seq.). The first legal question is about payments tied to export licenses. Is such a payment a “Tax or Duty… on Articles exported,” which the Export Clause bars? The second question is about ECRA, which ties licensing to national security and foreign policy. Does it allow licenses to depend on revenue payments, or to be traded away in tariff talks, as at Busan?5,22 The administration’s position in the record is this. Officials “expressed an expectation” of the 15% but never published a regulation. The H200 deal was carried out as a 25% Section 232 import duty, not a payment on exports.6,51 Under ECRA, Commerce places countries into groups by rule, such as the UAE’s July 2026 move, without approval from Congress.49 The record shows no action by a court, the GAO or Congress on these deals.
Spending power (Art. I, § 8, cl. 1), the CHIPS Act, the Government Corporation Control Act (31 U.S.C. § 9102) and 10 U.S.C. § 149. The Intel stake turned CHIPS Act grants that Congress had funded into stock. Since then, Commerce has required small ownership stakes as a condition of CHIPS awards to more than 20 companies.3,45,46,47 This raises three questions about the laws. First, the CHIPS incentives law allows “financial assistance,” and Congress approved the money as grants. Does that law let Commerce demand stock in return?36 Second, under the Government Corporation Control Act, an agency may acquire a corporation only under a law “specifically authorizing the action.” Do the stakes meet that rule?54 Third, the law behind the Office of Strategic Capital defines “capital assistance” as “a loan, loan guarantee, or technical assistance,” in those words. May the office take warrants and equity, such as the Wolfspeed warrants and the NABEP stake?55,47,48 The record shows little of the administration’s legal reasoning. Commerce’s May 2026 release cited only “the CHIPS and Science Act,” as its basis. After the NABEP deal, a U.S. official said the stake “is structured consistent with the statutory authority granted to the Office of Strategic Capital.” Former National Security Council official Peter Harrell said the administration “does not appear to have laid out any legal rationale.”46,48 The record gives no stated legal basis for the MP Materials, Lithium Americas, Westinghouse or Trilogy stakes. It shows no court or GAO decision on any stake.15,2,30,4
Merger national-security agreement (U.S. Steel golden share). The veto rights come from the national-security agreement that came with the merger approval. The record names no law that creates them. AP reported that Trump uses them personally during his term.1 The record shows no challenge to the arrangement.16
Take Care Clause (Art. II, § 3) and PAFACA. After the Supreme Court upheld PAFACA, the President issued four orders not to enforce it.10 The first question is whether the Take Care Clause lets a President refuse to enforce a law the Supreme Court has upheld. The second is about the deal’s structure, in which ByteDance keeps 19.9% and licenses its algorithm. The question is whether that meets PAFACA’s “qualified divestiture” requirement of ending any “operational relationship.”10,11,7 The administration’s position is the finding in the Sept 25, 2025 order that the plan satisfies the law.11 No court has ruled on either question. The record names no law that allows the reported ~$10 billion fee. It does not include the administration’s stated legal basis for the fee.8
Conflict-of-interest law (18 U.S.C. §§ 202(c), 208; 48 C.F.R. § 3.101-1; 5 C.F.R. § 2635.502). Section 208 is a criminal law. It bars executive officials such as Lutnick from taking part in matters that affect their household’s money interests.25,40 Under 18 U.S.C. § 202(c), § 208 does not apply to the President.41 Trump’s sons are not federal employees, so § 208 does not reach them either. The Aug 5, 2026 request points to two other rules. A federal contracting rule tells officials to avoid “even the appearance of a conflict of interest.” An ethics rule on impartiality covers employees’ personal and business relationships. The request asks whether Defense contracting officials applied these rules to awards that benefit the President’s family.57,58,59 On Feb 25, 2026 Sens. Warren, Van Hollen and Wyden questioned Lutnick about his family firm, Cantor Fitzgerald. Cantor was paid to help place shares in a $1.6 billion USA Rare Earth deal that Commerce backed. Commerce gave no public response.25 Trump’s disclosures show trades in Nvidia and Oracle shares in early 2026 through a trust run by his children (May 14, 2026).26
Foreign Emoluments Clause (Art. I, § 9, cl. 8). MGX, chaired by UAE national-security adviser Sheikh Tahnoon, is a party to Stargate, TikTok USDS and the USD1 transaction.27,14,7 The clause bars officeholders from accepting emoluments, meaning payments or other benefits, from a foreign state unless Congress consents.42 On Oct 22, 2026 a Circle shareholder filed Greenberg v. Trump in the federal court in Washington, D.C. (D.D.C.).43 The suit claims that two deals were “unconstitutional emoluments.” One was MGX’s use of USD1. The other was a Tahnoon-backed purchase of 49% of World Liberty Financial.80 The suit also cites a 2025 Commerce Department approval of advanced Nvidia AI chip sales to an Abu Dhabi AI company chaired by Tahnoon. The White House called the suit frivolous.31 See Cabinet Financial Disclosures and Ethics Complaints, Crypto and World Liberty Financial, Gulf States, Israel and Gaza, China and North Korea and Tariffs and Trade Policy.
Outcome
Where things stand
As of Nov 8, 2026, no completed deal has been undone. The record has no court ruling, GAO decision or new law on any of them. CFR counts 48 equity deals worth $30.3 billion, each held by the agency that made it. Several CHIPS stakes are letters of intent, not final agreements. There is no sovereign wealth fund and no single public accounting of the stakes.47,46,15 Fortune reported that “There is no consolidated ledger of the government’s holdings.”47 The 15% H20 payment was never put into a regulation. Licensed H20 sales were about $60 million, so at most about $9 million could have been owed. Nvidia’s 10-K does not say whether anything was paid. Nvidia had no H200 revenue as of that filing. Any H200 money would arrive as tariff revenue.6 In September 2025 China’s Cyberspace Administration told companies including ByteDance and Alibaba not to buy Nvidia’s RTX Pro 6000D.28 H200 licenses for Chinese buyers were issued in May 2026.24
Gaps: the record lacks the current value of the stakes. It lacks share counts, prices and voting terms for most 2026 stakes. It does not show whether any H20 money was actually paid, or whether TikTok fee installments beyond the first $2.5 billion have been paid.
Status
| Item | Status | Latest development (date) | What would change it |
|---|---|---|---|
| Federal equity stakes (48 deals, $30.3 billion) | In force | CFR count (Oct 2026)47 | — |
| CHIPS equity letters of intent | Pending (Commerce) | Letters with fusion companies (Oct 22, 2026); several not final47,46,73 | Final award agreements46 |
| L3Harris Missile Solutions convertible security | Pending (IPO) | Deal closed (Apr 23, 2026); no IPO reported46,63 | The IPO planned for the second half of 202646 |
| Sovereign wealth fund | Unresolved | “On pause” (May 23, 2025); not created15 | — |
| OSC stake in NABEP (35%) | In force | Taken (Aug 28–Sept 5, 2026)48 | — |
| U.S. Steel golden share | In force | Used to stop the Granite City idling (Sept 19, 2025)16,74 | — |
| H20 15% revenue share | Unresolved | Never put into a regulation; 10-K does not say whether anything was paid6 | — |
| H200 sales with 25% via Section 232 import duty | In force | Licenses for 10 Chinese firms (May 2026); no H200 revenue as of the 10-K24,6,78,79 | — |
| Affiliates Rule suspension | In force | Extended through Jan 10, 2027 (Nov 9, 2026 rule)52,22,77 | The Jan 10, 2027 end date52 |
| UAE most-favorable export-control tier | In force | Since Jul 10, 202649,29 | — |
| TikTok USDS and ~$10 billion fee | In force | Operating since Jan 22, 2026; first $2.5 billion paid8 | — |
| Greenberg v. Trump (emoluments) | Pending (D.D.C.) | Filed (Oct 22, 2026)31,43 | A ruling on the complaint31 |
| Inspector-general request on awards to sons’ companies | Pending (Defense Department inspector general) | Sent (Aug 5, 2026); no response reported57 | A decision by the inspector general to investigate57 |
| Senators’ USA Rare Earth letter to Lutnick | Unresolved | Sent (Feb 25, 2026); no public response25 | — |
Who is affected
These deals affect companies that took federal money or needed federal approval. They affect the agencies that now hold stakes or collect payments. They also affect buyers of chips sold under export licenses.47,5 Agencies turned grants, loans and investments into equity in at least 48 companies. They also made small ownership stakes a condition of CHIPS Act awards.47,46 Nvidia and AMD agreed to share China chip revenue in return for licenses. Chinese buyers and the United Arab Emirates (UAE) gained access to advanced chips.5,24,49 TikTok’s U.S. business passed to a group of investors who pay the Treasury a fee.7,8 Lawmakers asked the Pentagon’s inspector general to review awards to companies tied to Trump’s sons.57
- Federal portfolio (48 equity deals, In force) — The Council on Foreign Relations (CFR) counted 48 deals worth $30.3 billion by late October 2026: 29 by Commerce, 13 by Defense, 6 by the Development Finance Corporation and 2 by Energy. Fortune reported that “There is no consolidated ledger of the government’s holdings.”47
- Intel (about 10% stake taken Aug 22, 2025, In force) — The government received 433.3 million shares at $20.47. It paid by converting $5.7 billion in awarded but unpaid CHIPS Act grants and $3.2 billion in Secure Enclave funds. The stake is passive, with no board seat.3
- MP Materials (Pentagon preferred-stock purchase Jul 10, 2025, In force) — $400 million bought about 15%, making the Pentagon the largest shareholder. The deal also set a 10-year minimum price for the company’s rare-earth output.2
- Trilogy Metals and Gates of the Arctic National Park (10% stake and Ambler Road approval Oct 6, 2025, In force) — The government agreed to pay $35.6 million for the stake, plus warrants for 7.5% more, the same day Trump approved the road. Interior reissued the rights-of-way Oct 23, and about 20 miles of the road crosses the park and preserve. The stock tripled. On Mar 25, 2026 Rep. Jared Huffman put Trump fundraiser John Paulson’s gain at about $70 million.4,60,21,61
- Borrowers that gave warrants or equity (federal stakes, In force) — Lithium Americas gave warrants for 5% of the company and 5% of its GM joint venture with a restructured $2.26 billion Energy Department loan (Sept 30, 2025). Vulcan Elements received a $620 million loan and a $50 million Commerce equity stake (Nov 2, 2025). Wolfspeed received a conditional commitment of up to $1.5 billion in Office of Strategic Capital (OSC) financing, with warrants (Oct 7, 2026).17,30,53,47,75,76,71
- CHIPS award recipients (equity letters of intent, Pending; several not final) — Commerce conditioned letters on “a minority, non-controlling equity stake.” These included $2.013 billion with nine quantum-computing companies (May 21, 2026), $874 million with seven chip-materials and computing firms (Jul 29) and $389 million with Helion, Commonwealth Fusion Systems and two other firms (Oct 22). SandboxAQ ($500 million award, Jun 17) and I-Pulse ($250 million definitive agreement, Jun 25) gave minority stakes. GlobalFoundries gave about 4% for redirecting up to $955 million of its existing award (Oct 14).46,47,64,65,73,72,82,83
- U.S. Steel’s Granite City plant (golden share, In force) — On Sept 19, 2025 U.S. Steel dropped its plan to idle the Granite City, Illinois, plant after Commerce Secretary Howard Lutnick told the company the administration would not allow it. The share also carries a veto over redirecting the $11 billion investment pledge.16,74,1
- Nvidia and AMD (15% H20 and MI308 revenue share, Unresolved) — Nvidia’s FY2026 10-K reports about $60 million of licensed H20 sales. At most about $9 million could have been owed on those sales. The report does not say whether anything was paid.6
- Chinese chip buyers (H200 sales with 25% via Section 232 import duty, In force) — Commerce cleared 10 Chinese firms to buy the H200 in May 2026 after Beijing at first blocked shipments. Nvidia reported no H200 revenue as of its 10-K.24,23,6
- Subsidiaries of listed Chinese firms (Affiliates Rule suspension, In force) — Bureau of Industry and Security (BIS) rules suspend Entity List limits on companies at least 50% owned by listed Chinese firms. The suspension runs from Nov 10, 2025 through Jan 10, 2027.44,52,77
- UAE government and approved companies (most-favorable export-control tier from Jul 10, 2026, In force) — A BIS rule approved them to receive advanced computing items “in the UAE license-free.” On Sept 15, 2025 the New York Times had reported a connection between letting the UAE import hundreds of thousands of Nvidia chips and a $2 billion MGX investment. That investment was routed through the Trump family’s USD1 stablecoin.49,20
- TikTok USDS investors and ByteDance (divestiture closed Jan 22, 2026, In force) — Oracle, Silver Lake and MGX hold 15% each, and ByteDance keeps 19.9%. The investors paid the Treasury $2.5 billion of a fee that the Wall Street Journal and Reuters reported at about $10 billion.7,8
- Venezuelan oil concessions (OSC 35% stake in North American Blue Energy Partners, In force) — OSC took the stake Aug 28–Sept 5, 2026 “at no cost to U.S. taxpayers.” The company holds 100-year concessions for 17 oilfields. The government can veto board appointments, and the State Department may buy 20% of output at production cost.48
- Companies tied to Trump’s sons (inspector-general request Aug 5, 2026, Pending) — Rep. Robert Garcia and three senators asked for a review of $3.2 billion in federal awards plus $3.1 billion in contract options. The awards went to companies tied to 1789 Capital and American Ventures after the Trump-tied firms became involved. The Washington Post reported that the administration and the Pentagon deny doing anything improper.57
Key players
- Donald Trump — President (from 2025) — announced the stakes, holds the U.S. Steel veto during his term, announced the chip revenue shares.1,5,23
- Howard Lutnick — Commerce Secretary (from 2025) — negotiated the Intel stake; oversees export licensing; told U.S. Steel the Granite City idling would not be allowed.3,16,74
- Jensen Huang — Nvidia CEO — agreed to the H20 and H200 revenue arrangements.5,23
- Lip-Bu Tan — Intel CEO — Trump said he should resign; Intel then agreed to the stake.18,19
- Sheikh Tahnoon bin Zayed — UAE national-security adviser, MGX chair — MGX is a partner in Stargate and TikTok USDS.27,14,7
- Jeffrey Kessler — Commerce Under Secretary for BIS (from 2025) — ordered non-enforcement of the AI Diffusion Rule; said H200 sales “under controlled conditions” would “strengthen the American technology ecosystem.”50,51
- Steve Feinberg — Deputy Defense Secretary (from 2025) — described the Pentagon’s $1.4 billion conditional Korea Zinc investment.86
- Alejandro Betancourt — head of NABEP, in which OSC holds 35% — CNBC reports he has faced money-laundering and corruption allegations and has not been charged.48
- John Paulson — Trump fundraiser — Rep. Huffman put his Trilogy gain at ~$70 million.21
Chronology
- 2025-01-16 — Tahnoon-linked vehicle buys 49% of World Liberty Financial — → ledger
- 2025-01-20 — Record $239M inauguration donors — → ledger
- 2025-01-20 — TikTok non-enforcement order — → ledger
- 2025-01-21 — Stargate with UAE’s MGX — → ledger
- 2025-02-03 — Sovereign wealth fund EO — → ledger
- 2025-02-18 — Lutnick, Cantor and USA Rare Earth — → ledger
- 2025-05-13 — AI Diffusion Rule rescinded — → ledger
- 2025-05-16 — U.S.–UAE AI campus deal with G42 — → ledger
- 2025-06-13 — Trump approves Nippon Steel’s U.S. Steel takeover with a golden share — → ledger
- 2025-06-18 — Nippon Steel’s U.S. Steel takeover closes — → ledger
- 2025-07-10 — Pentagon stake in MP Materials — → ledger
- 2025-08-11 — Nvidia/AMD 15% China revenue deal — → ledger
- 2025-08-15 — White House corporate scorecard — → ledger
- 2025-08-22 — Government takes ~10% of Intel — → ledger
- 2025-09-15 — UAE chips deal and MGX/USD1 — → ledger
- 2025-09-19 — U.S. Steel reverses Granite City idling after Lutnick warning — → ledger
- 2025-09-25 — TikTok divestiture EO — → ledger
- 2025-09-30 — Lithium Americas warrants with restructured Energy loan — → ledger
- 2025-10-06 — Trilogy Metals stake and Ambler Road approval — → ledger
- 2025-10-23 — Interior reissues Ambler Road rights-of-way — → ledger
- 2025-10-30 — Busan summit, Affiliates Rule postponed — → ledger
- 2025-11-02 — Vulcan Elements loan and Commerce equity — → ledger
- 2025-11-12 — BIS suspends Affiliates Rule for one year — → ledger
- 2025-12-01 — Commerce CHIPS letter of intent for xLight equity — → ledger
- 2025-12-08 — H200 approval with 25% cut; Jan 2026 rule and Proclamation 11002 — → ledger
- 2025-12-15 — Pentagon and Commerce co-invest in Korea Zinc smelter — → ledger
- 2026-01-12 — Pentagon preferred equity in Atlantic Alumina — → ledger
- 2026-01-13 — Pentagon commits $1B to L3Harris missile spinoff — → ledger
- 2026-01-14 — Proclamation 11002: 25% Section 232 duty on advanced chips — → ledger
- 2026-01-15 — BIS rule moves H200 licenses to case-by-case review — → ledger
- 2026-01-22 — TikTok USDS closes — → ledger
- 2026-02-01 — Tahnoon’s WLF stake, G42 chips — → ledger
- 2026-03-25 — Huffman puts Paulson’s Trilogy gain at ~$70M — → ledger
- 2026-04-23 — L3Harris closes $1B Pentagon investment — → ledger
- 2026-04-23 — Eric Trump-backed robot startup announces $24M Pentagon contract — → ledger
- 2026-05-13 — Beijing state visit, H200 licenses for 10 firms — → ledger
- 2026-05-14 — Trump’s Q1 2026 stock trades, including a Jan 6 Nvidia purchase labeled “UNSOLICITED” — → ledger
- 2026-05-21 — $2.013B CHIPS letters with nine quantum firms — → ledger
- 2026-06-17 — $500M CHIPS award to SandboxAQ for minority equity — → ledger
- 2026-06-25 — $250M CHIPS agreement with I-Pulse for minority equity — → ledger
- 2026-07-10 — UAE moved to most favorable export-control tier — → ledger
- 2026-07-26 to 10-28 — CFR count reaches 48 deals worth $30.3B — → ledger
- 2026-07-29 — $874M CHIPS letters with seven firms — → ledger
- 2026-07-31 — OSC conditional loan of up to $820M to Performance Drone Works — → ledger
- 2026-08-05 — Lawmakers ask Pentagon IG to review $3.2B in awards to Trump-son-backed firms — → ledger
- 2026-08-07 — Pentagon equity in Strategic Bauxite — → ledger
- 2026-08-14 — WLF trust bank; UAE export controls loosened — → ledger
- 2026-08-28 to 09-05 — OSC 35% stake in Venezuelan oil venture NABEP — → ledger
- 2026-08-31 — Pentagon equity in Alcoa’s Wagerup gallium project — → ledger
- 2026-09-14 — Pentagon preferred stock and warrants in Elmet Group — → ledger
- 2026-09-29 — Pentagon equity in Hertha Metals — → ledger
- 2026-10-07 — OSC conditional $1.5B commitment with warrants to Wolfspeed — → ledger
- 2026-10-14 — GlobalFoundries gives ~4% equity for CHIPS redirect — → ledger
- 2026-10-22 — $389M CHIPS letters with Helion, Commonwealth Fusion and two others — → ledger
- 2026-10-22 — Greenberg v. Trump emoluments suit — → ledger
- 2026-11-09 — ProPublica: nearly $40M in federal screening contracts to XpresTest after a sons-linked fund invested in its parent — → ledger
Sources
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AP: Trump gets “golden share” power in US Steel buyout · Timeline 2025-06-13 → ledger ↩↩↩↩↩↩↩
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CNBC: Pentagon to become largest shareholder in MP Materials · Reuters: MP Materials partners with DoD · Timeline 2025-07-10 → ledger ↩↩↩↩
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Intel press release: Intel and Trump administration reach historic agreement · NBC News: U.S. takes 10% stake in Intel · Timeline 2025-08-22 → ledger ↩↩↩↩↩↩↩
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CBS News: federal government to take ownership stake in Trilogy Metals · Alaska Public Media: administration re-approves Ambler Road corridor · Timeline 2025-10-06 → ledger ↩↩↩↩↩↩
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BBC: Nvidia and AMD to pay 15% of China chip sales to US government · FT: Nvidia and AMD to pay 15% · Timeline 2025-08-11 → ledger ↩↩↩↩↩↩↩↩↩↩
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Nvidia Form 10-K FY2026 (SEC) · Timeline 2025-08-11 → ledger ↩↩↩↩↩↩↩↩↩
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NYT: TikTok deal with new U.S. entity · Timeline 2026-01-22 → ledger ↩↩↩↩↩↩↩
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Reuters: administration set to receive $10B fee for brokering TikTok deal · Timeline 2026-01-22 → ledger ↩↩↩↩↩↩↩
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White House: EO “A Plan for Establishing a United States Sovereign Wealth Fund” · CBS News: Trump orders creation of a U.S. sovereign wealth fund · Timeline 2025-02-03 → ledger ↩↩
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Reason/Volokh: order promises no enforcement of TikTok ban for 75 days · Washington Post: TikTok deal finalized · Timeline 2025-01-20 → ledger ↩↩↩↩↩↩
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White House: EO “Saving TikTok While Protecting National Security” · Timeline 2025-09-25 → ledger ↩↩↩↩↩
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OpenSecrets: 2025 inauguration donors · NBC News: megadonors gave $239 million to fund inauguration · Timeline 2025-01-20 → ledger ↩
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Forbes: White House creates loyalty rating system for 553 companies · Timeline 2025-08-15 → ledger ↩
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Just Security: Trump’s announcement of the Stargate AI project · Chatham House: Stargate and DeepSeek · Timeline 2025-01-21 → ledger ↩↩↩
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Bloomberg Law: Bessent says Trump paused sovereign wealth fund · Timeline 2025-02-03 → ledger ↩↩↩↩
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CNBC: Trump wields ‘golden share’ to halt U.S. Steel plant shutdown · Timeline 2025-06-13 → ledger ↩↩↩↩↩
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FT: 1789-backed companies’ contracts · Timeline 2025-07-10 → ledger ↩↩
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AP: Intel stock tumbles after Trump says CEO must resign · Timeline 2025-08-22 → ledger ↩↩
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Reuters: how a Silicon Valley dealmaker charmed Trump and gave Intel a lifeline · Timeline 2025-08-22 → ledger ↩↩
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NYT: Trump, UAE chips, Witkoff and World Liberty · Timeline 2025-09-15 → ledger ↩↩
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Alaska Public Media: House Democrat derides investment in Alaska mine project · Timeline 2025-10-06 → ledger ↩↩↩
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White House fact sheet: deal on economic and trade relations with China · CNBC: what Trump and Xi agreed to in the trade truce · Timeline 2025-10-30 → ledger ↩↩↩
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Guardian: China blocks H200 chips US cleared for export · Timeline 2025-12-08 → ledger ↩↩↩↩↩
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Reuters: US clears H200 chip sales to 10 China firms · Timeline 2026-05-13 → ledger ↩↩↩↩↩
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CNBC: Democratic senators press Lutnick on USA Rare Earth deal · Timeline 2025-02-18 → ledger ↩↩↩
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NBC News: Trump ethics filing reveals thousands of trades · Timeline 2026-05-14 → ledger ↩
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WSJ: “Spy Sheikh” secret stake in Trump crypto firm · NYT: UAE chips and World Liberty · Timeline 2026-02-01 → ledger ↩↩
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CNBC: Huang “disappointed” after report China banned Nvidia chips · Timeline 2025-08-11 → ledger ↩
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WSJ: Trump family’s new crypto bank is backed by Abu Dhabi sheikh · Timeline 2026-08-14 → ledger ↩
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CNBC: Trump administration equity portfolio grows. These are investments so far · ProPublica: The White House intervened to get a $620 million deal for a company tied to Donald Trump Jr. · Timeline 2025-07-10 → ledger ↩↩↩↩
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CNBC: Lawsuit accuses Trump of illegally profiting off foreign crypto deals · Timeline 2026-10-22 → ledger ↩↩↩
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Cornell LII: U.S. Constitution, Article I (§ 8, cl. 1, taxing and spending) legal authority ↩
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Cornell LII: U.S. Constitution, Article I (§ 9, cl. 7, Appropriations Clause) legal authority ↩
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Cornell LII: U.S. Constitution, Article I (§ 9, cl. 5, Export Clause) legal authority ↩
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Cornell LII: 50 U.S.C. § 4801 — Definitions (Export Control Reform Act of 2018, Pub. L. 115-232, div. A, title XVII, subtitle B) legal authority ↩
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Cornell LII: 15 U.S.C. § 4652 — Semiconductor incentives (CHIPS program, as amended by Pub. L. 117-167, the CHIPS and Science Act) legal authority ↩↩
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GovInfo: Public Law 118-50, Division H — Protecting Americans from Foreign Adversary Controlled Applications Act legal authority ↩
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Supreme Court: TikTok Inc. v. Garland, Nos. 24-656 and 24-657 (Jan 17, 2025) (per curiam) legal authority ↩
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Cornell LII: U.S. Constitution, Article II (§ 3, Take Care Clause) legal authority ↩
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Cornell LII: 18 U.S.C. § 208 — Acts affecting a personal financial interest legal authority ↩
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Cornell LII: 18 U.S.C. § 202 — Definitions (subsec. (c) excludes the President) legal authority ↩
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Cornell LII: U.S. Constitution, Article I (§ 9, cl. 8, Foreign Emoluments Clause) legal authority ↩
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CNBC (court filing): Greenberg v. Trump, No. 1:26-cv-03686 (D.D.C.), verified complaint filed Oct 22, 2026 (PDF) legal authority ↩↩
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Federal Register: BIS, “Expansion of End-User Controls To Cover Affiliates of Certain Listed Entities” (2025-19001, Sept 30, 2025) · Federal Register: “One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities” (2025-19846, Nov 12, 2025) legal authority ↩↩
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NIST: CHIPS R&D letter of intent with xLight · CFR: Equity Stakes Tracker · Timeline 2025-12-01 → ledger ↩↩
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L3Harris: closes $1B investment from Department of War · CFR Equity Stakes Tracker · NIST: letters of intent with 9 companies · NIST: letters of intent with 7 companies · Timeline 2026-01-12 → ledger ↩↩↩↩↩↩↩↩↩↩↩
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CFR: Washington’s growing portfolio · Fortune: The U.S. government invested $27 billion in corporate stakes · NIST: agreement with GlobalFoundries · GlobalFoundries press release (SEC) · NIST: letters of intent with 4 companies · Timeline 2026-07-26 to 10-28 → ledger ↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩↩
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CNBC: Trump’s state capitalism comes to the oil industry · CFR Equity Stakes Tracker · Timeline 2026-08-28 to 09-05 → ledger ↩↩↩↩↩↩↩↩↩↩
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BIS: Commerce eases export controls for UAE · Federal Register: Enhanced Favorable Treatment for the United Arab Emirates Under the Export Administration Regulations · Timeline 2026-07-10 → ledger ↩↩↩↩↩
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BIS: Rescission of AI Diffusion Rule · Timeline 2025-05-13 → ledger ↩↩
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BIS: Commerce revises license review policy for semiconductors exported to China · Federal Register: Revision to License Review Policy for Advanced Computing Commodities · Federal Register: Proclamation 11002 · PIIE: Trump’s trade war timeline 2.0 (Jan 14, 2026 entry) · Timeline 2025-12-08 → ledger ↩↩↩↩
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Federal Register: One Year Suspension of Expansion of End-User Controls for Affiliates (FR 2025-19846) · Federal Register: Extension of the Suspension (FR 2026-22793, Nov 9, 2026) · Timeline 2025-10-30 → ledger ↩↩↩↩
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CFR: Equity Stakes Tracker · Timeline 2025-07-10 → ledger ↩↩
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Cornell LII: 31 U.S.C. § 9102 — Establishing and acquiring corporations (Government Corporation Control Act) legal authority ↩
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Cornell LII: 10 U.S.C. § 149 — Office of Strategic Capital (“capital assistance” defined at subsec. (h)) legal authority ↩
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Fox Business: Eric Trump-backed robot startup lands $24M Pentagon deal · Timeline 2026-04-23 → ledger ↩
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House Oversight Democrats: Garcia, Warren, Blumenthal, Duckworth urge DoD watchdog to investigate $3.2 billion in government awards to companies tied to Trump sons · Washington Post: Lawmakers call for Pentagon probe of Trump family-backed companies · Timeline 2026-08-05 → ledger ↩↩↩↩↩↩↩
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Cornell LII: 48 C.F.R. § 3.101-1 — General (Standards of conduct, Federal Acquisition Regulation) legal authority ↩
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Cornell LII: 5 C.F.R. § 2635.502 — Personal and business relationships legal authority ↩
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Alaska Public Media (NPR): Administration re-approves Ambler Road corridor · Timeline 2025-10-23 → ledger ↩↩↩
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Alaska Public Media: House Democrat derides investment in Alaska mine project · Timeline 2026-03-25 → ledger ↩↩
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CFR Equity Stakes Tracker · Timeline 2026-01-13 → ledger ↩
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L3Harris: closes $1B investment from Department of War · Timeline 2026-04-23 → ledger ↩↩
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NIST: letters of intent with 9 companies · Timeline 2026-05-21 → ledger ↩↩
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NIST: letters of intent with 7 companies · Timeline 2026-07-29 → ledger ↩↩
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CFR: Washington’s growing portfolio · Timeline 2026-07-31 → ledger ↩
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CFR: Washington’s growing portfolio · Timeline 2026-08-07 → ledger ↩
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CFR: Washington’s growing portfolio · Timeline 2026-08-31 → ledger ↩
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CFR: Washington’s growing portfolio · Timeline 2026-09-14 → ledger ↩
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CFR: Washington’s growing portfolio · Timeline 2026-09-29 → ledger ↩
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CFR: Washington’s growing portfolio · Timeline 2026-10-07 → ledger ↩↩
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NIST: agreement with GlobalFoundries · GlobalFoundries press release (SEC) · Timeline 2026-10-14 → ledger ↩↩
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NIST: letters of intent with 4 companies · Timeline 2026-10-22 → ledger ↩↩↩
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CNBC: Trump wields ‘golden share’ to halt U.S. Steel plant shutdown · Timeline 2025-09-19 → ledger ↩↩↩↩
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CFR: Equity Stakes Tracker · Timeline 2025-09-30 → ledger ↩↩
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CFR: Equity Stakes Tracker · ProPublica: The White House intervened to get a $620 million deal for a company tied to Donald Trump Jr. · Timeline 2025-11-02 → ledger ↩↩
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Federal Register: One Year Suspension of Expansion of End-User Controls for Affiliates (FR 2025-19846) · Timeline 2025-11-12 → ledger ↩↩↩
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Federal Register: Revision to License Review Policy for Advanced Computing Commodities · BIS: Commerce revises license review policy for semiconductors exported to China · Timeline 2026-01-15 → ledger ↩↩
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Federal Register: P11002 · Timeline 2026-01-14 → ledger ↩↩
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WSJ: spy sheikh’s secret stake in Trump crypto · Telegraph: Trump sold “spy sheikh” $500M stake · Timeline 2025-01-16 → ledger ↩↩
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CNBC: Trump Middle East trip and OpenAI/UAE Stargate · Timeline 2025-05-16 → ledger ↩
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CFR Equity Stakes Tracker · Timeline 2026-06-17 → ledger ↩↩
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CFR Equity Stakes Tracker · Timeline 2026-06-25 → ledger ↩↩
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OGE: Trump periodic transaction report, May 8, 2026 (PDF) · NBC: Trump ethics filing reveals thousands of trades · Timeline 2026-05-14 → ledger ↩
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AP: Trump gets “golden share” power in US Steel buyout · Timeline 2025-06-18 → ledger ↩
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Korea Zinc: partnership release · CFR: Equity Stakes Tracker · Timeline 2025-12-15 → ledger ↩↩
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ProPublica: Firm Linked to Trump’s Sons Got Nearly $40 Million in Federal Contracts to Screen for Ebola and Other Diseases · Timeline 2026-11-09 → ledger ↩