FBI Director's Late MicroStrategy Filing Now Down 48%—Even the 45-Day Rule Couldn't Outrun BTC 📉

FBI Director Kash Patel reported a purchase of between $100,001 and $250,000 in MicroStrategy stock roughly six months after the trade, breaching the 45-day window required under the Stop Trading on Congressional Knowledge (STOCK) Act. According to NOTUS, Patel bought the shares on November 21, 2025, at a price near $181, but only reported the transaction to federal regulators on May 26, 2026, stating the position had been "inadvertently omitted" from an earlier filing and that "no current conflict exists" with the investment. First-time violators face a $200 fine under the statute, a penalty the Justice Department has not imposed on Patel, per NOTUS.

The timing has compounded the financial damage. MicroStrategy, rebranded as Strategy and ticker MSTR, has fallen nearly 48% since Patel's purchase date, dropping below $100 in late June for the first time since March 2024 before the company announced a financial overhaul plan. At writing, MSTR traded at $100.55. Assuming he has not sold, the unrealized loss on Patel's disclosed position sits between $44,000 and $110,000. Bitcoin ($BTC) itself has slid over 41% in the last year, from above $106,000 to $61,933, and TD Cowen this week cut its MSTR price target 35%—from $400 to $260—citing Bitcoin's "observed ongoing weakness."

The overlap between the trade and Patel's role is central to the scrutiny. Strategy is the largest corporate holder of Bitcoin, with more than 847,000 BTC on its balance sheet, a stack worth over $52 billion at current prices. It is also a registered US government contractor that has done millions of dollars of business with the Justice Department, which oversees the FBI, while the bureau itself investigates cryptocurrency fraud. Patel has publicly promoted the agency's enforcement record, including a $15 billion Bitcoin seizure announced in October 2025.

Ethics officials and government watchdogs drew different conclusions. Deputy Assistant Attorney General William Taylor, who reviewed the amended filing, wrote in a May 28 letter that Patel attributed the delay to a "miscommunication" and that he "continue[s] to believe that Director Patel is in compliance with applicable laws and regulations governing conflicts of interest." Dylan Hedtler-Gaudette of the Project on Government Oversight disagreed, telling NOTUS the disclosure was "absolutely" late under the statute. "That's violating the law — no other way to put it," he said. According to NOTUS, more than 30 members of Congress submitted overdue disclosures over the past year, and Capitol Trades records show Representative Shri Thanedar waited until August 2025 to report a $15,001 to $50,000 Strategy investment made in June 2024.

The STOCK Act, signed by former President Barack Obama in April 2012, requires covered federal officials to disclose securities trades worth at least $1,000 within 45 days, with subsequent violations subject to larger fines. Patel's amended filing remains the only public record of the Strategy purchase.