the pardon market

Trevor Milton and his wife donated approximately $1.8 million to Trump re-election entities in October and November 2024, weeks before the presidential election. On March 28, 2025, Trump granted Milton a full and unconditional pardon for his federal convictions of securities fraud and wire fraud. The pardon remitted "any and all restitution ordered by the court," wiping approximately $675 million in restitution owed to Nikola shareholders. Milton also avoided serving a 4-year federal prison sentence. The ratio of restitution wiped to donation made is approximately 375 to 1.

Sources: FEC donation records (Federal Election Commission); DOJ Office of the Pardon Attorney grant listing; CNN, CNBC, Fortune, Washington Post coverage of the pardon and restitution impact.

A convicted tax cheat's mother attended a $1 million-per-head fundraiser at Mar-a-Lago. Three weeks later, her son received a presidential pardon. The pardon wiped $4.4 million in restitution ordered by the court. The 3-week gap between the million-dollar political event and the pardon grant is the shortest documented interval in the cases analyzed.

Sources: ABC News reporting; NBC News coverage of Trump pardon pattern; California Governor Newsom's "Trump Criminals" tracker (March 2026).

Julio Herrera Velutini, a foreign billionaire charged with bribing Puerto Rico's governor, had his charges dropped in January 2026. His daughter, whose prior political giving history shows a single $20 donation to Pete Buttigieg's presidential campaign, donated $3.5 million to a Trump super PAC before the charges were dropped. The Campaign Legal Center documented this contribution as part of a broader "seeking pardon" analysis of foreign-connected clemency petitioners. The $3.5M contribution is the largest single donation in the documented cases analyzed here.

Sources: Campaign Legal Center analysis, "Seeking Pardon, Foreign Billionaire Allegedly Funneled Millions to Trump Super PAC" (2026); FEC filings.

The Lobbying Disclosure Act database contains zero registrations specifically mentioning clemency or pardons in the first year of any US president since modern registration requirements began, covering Obama (2009), Trump first term (2017), and Biden (2021). In Trump's second-term year one, 10 different lobbyists registered for pardon-specific work on behalf of 9 different clients. The Marshall Project reviewed these registrations and confirmed the historical anomaly. The existence of a commercial pardon-lobbying industry is new. Its emergence precisely when documented financial connections to the pardon process became visible is consistent with market formation in response to perceived access.

Sources: Lobbying Disclosure Act database (lda.senate.gov); The Marshall Project, "How Trump Is Flouting Government Rules on Pardons to Help Allies" (July 2025).

David Gentile, founder of GPB Capital Holdings, was convicted on securities and wire fraud charges for operating what prosecutors and the SEC described as a Ponzi-like scheme that raised over $1.7 billion from more than 10,000 investors, including veterans, teachers, farmers, and nurses. He was sentenced to 7 years in federal prison. He reported to prison on November 14, 2025. President Trump commuted his sentence on December 1, 2025: 12 days after Gentile arrived at the facility. The commutation was issued before Gentile had served more than 0.5% of his sentence.

Sources: CNN Politics (December 1, 2025); Bloomberg; NBC News; Fortune; The Daily Beast.

The Boeing 737 MAX criminal case was the only federal criminal prosecution of a US aircraft manufacturer for fraud connected to a mass-casualty crash in aviation history. 346 people died in two crashes caused by the MCAS system, which Boeing had concealed design flaws in from the FAA and from pilots. The Trump DOJ dropped all criminal charges in May 2025 via a non-prosecution agreement. The judge, who could not legally refuse the DOJ's dismissal motion, wrote that he found the agreement was not in the public interest. Victims' families filed a Fifth Circuit mandamus petition challenging the process. Boeing's $100B+ in active Department of Defense contracts were unaffected by the NPA.

Sources: CNBC; CNN Business; Al Jazeera; NPR; DOJ Criminal Division case page (US v. The Boeing Company); Fox Business.

Boeing Chief Legal Officer Brett Gerry oversaw the legal defense that resulted in the DOJ's May 2025 non-prosecution agreement and the dismissal of all criminal charges. Boeing's DEF 14A proxy statement filed with the SEC shows that Gerry's total compensation for FY2025 increased 58%, the largest percentage pay increase among Boeing's named executive officers for that year. The compensation increase was structured and approved by Boeing's board in the same fiscal year that the criminal case was resolved. This is not illegal. It is documented in a public filing.

Sources: Boeing DEF 14A proxy statement (SEC EDGAR); Law.com Corp Counsel, "Boeing CLO's Pay Soared 58% in 2025 as DOJ Dropped 737 Max Criminal Case" (March 9, 2026).

Changpeng "CZ" Zhao, founder of Binance, the world's largest cryptocurrency exchange by volume, pleaded guilty in 2023 to failing to maintain an effective anti-money laundering regime, paid a $4.3 billion company settlement, and served 4 months in prison. Trump pardoned him on October 21, 2025. At the time of the pardon, the Trump family's World Liberty Financial crypto venture had active business ties with Binance. Critics including former DOJ Pardon Attorney Liz Oyer called the pardon "corruption." The White House stated Zhao had been the victim of "Biden's war on cryptocurrency." No financial connection between Zhao personally and Trump political entities was confirmed in FEC records, but the business relationship between WLF and Binance was publicly disclosed.

Sources: NBC News; CNBC; Al Jazeera; FactCheck.org; Newsweek; Slate.

Justin Sun, the Tron Foundation founder, invested $75 million in World Liberty Financial, the Trump family's cryptocurrency venture, before Trump took office. Sun faces an active SEC enforcement action for alleged securities law violations and market manipulation. Under SEC Chair Paul Atkins, Reuters reported in March 2026 that the Sun case was among those that outgoing Enforcement Director Margaret Ryan had clashed with Atkins's team over, reportedly because it involved a Trump-connected figure. No formal withdrawal of the Sun enforcement action has been announced, but the case had not progressed materially as of the reporting date.

Sources: Reuters (March 23, 2026); CNBC (SEC enforcement director resignation); Al Jazeera (Zhao pardon conflict of interest analysis).

Paul Atkins was confirmed as SEC chair in April 2025. His financial disclosures, reviewed at confirmation, showed more than $327 million in crypto-related assets and business interests, including holdings in crypto advisory firms, token interests, and consulting relationships with major crypto industry participants through his firm Patomak Global Partners. Atkins recused himself from certain individual cases but not from the broader policy direction of crypto enforcement. The SEC's Division of Enforcement issued a new enforcement manual in February 2025 that explicitly deprioritized crypto industry market structure cases. As of March 2026, the number of new SEC crypto enforcement actions had fallen materially from 2024 levels.

Sources: SEC Chair Atkins financial disclosures; existing SEC revolving door investigation (transparency-lab.com/case/sec-revolving-door/).

The Trump administration's DOJ negotiated a Boeing NPA that included $944.5 million in total victim compensation ($500M from the 2021 DPA + $444.5M additional). In the same period, the administration's pardon decisions wiped out an estimated $1.3 to $2 billion in victim restitution from financial fraud cases. The total restitution erased through pardons is approximately two times the total Boeing victim compensation paid. The administration simultaneously negotiated a record-setting payment to aviation victims and wiped a larger sum from financial fraud victims. The net outcome depends on which metric is used.

Sources: DOJ NPA filing; House Judiciary Democrats memo (June 17, 2025); California Governor's office analysis (March 5, 2026).

The Oglala Sioux Tribe, a federally recognized Native American sovereign nation, was defrauded of approximately $60 million by Jason Galanis through a bond issuance scheme that exploited the tribe's limited market access. Federal courts ordered Galanis to pay $84.8 million in restitution across two judgments. Trump commuted Galanis's sentence in March 2025, with the commutation remitting the restitution obligation. The Oglala Sioux Nation received zero recovery. The tribe had cooperated with federal prosecutors throughout the case in the expectation of restitution.

Sources: Federal court restitution orders (US v. Galanis, SDNY); House Judiciary Democrats memo (June 2025); general news coverage of Galanis commutation.

Boeing's 2021 Deferred Prosecution Agreement required the company to implement specified compliance reforms and maintain a compliance monitor. Following the January 2024 Alaska Airlines door plug blowout, a third major 737 MAX safety failure, the DOJ investigated and determined that Boeing had breached the terms of the 2021 DPA by failing to implement required reforms. The normal consequence of a DPA breach is that prosecution resumes. Instead, the Trump DOJ in May 2025 filed a new NPA that dropped the criminal charges entirely. A company found to be in breach of a deferred prosecution agreement received a non-prosecution agreement as the resolution, an outcome with no close precedent in corporate criminal enforcement.

Sources: DOJ Criminal Division case records; NPR; Yahoo Finance; CNN Business reporting on NPA timeline.

On March 23, 2026, Reuters reported that Margaret Ryan, the SEC's Division of Enforcement director, had resigned after clashing with SEC Chair Paul Atkins and his team over the direction of high-profile enforcement cases. Sources told Reuters that the disagreements included cases involving individuals connected to Trump and his allies. Those named included Justin Sun (Trump's WLF investor) and the question of whether to pursue investigations touching the president's circle. Ryan's departure is consistent with the documented pattern of SEC enforcement retreat in crypto cases and the concurrent rollback of enforcement manual standards. It represents the most direct evidence that prosecutorial decisions at the SEC are being made with awareness of political relationships.

Sources: Reuters (March 23, 2026), "SEC's ex-enforcement chief clashed with bosses before leaving"; CNBC coverage of the resignation and internal rifts.