Trump's $1M-$5M NVIDIA Purchase Preceded AI Export Rule Repeal

The Guardian, citing an analysis by the anti-corruption group DeKleptocracy, said NVIDIA's shares rose after the rescission was announced and after the purchase. Seoul Economic Daily relayed the report on Nov. 14 and said Democrats have begun procedures for a formal inquiry. The filing records trades and dates, not motive, and no wrongdoing has been established. Neither report carried a White House response.

The rule is the economic hinge. The Biden administration issued the AI Diffusion Rule on Jan. 15, 2025, with compliance due May 15, 2025. The Bureau of Industry and Security (BIS) said on May 13, 2025 that the requirements would have stifled American innovation and told enforcement officials not to enforce it. The Guardian noted that China accounted for about a quarter of NVIDIA's sales between 2010 and 2022. As Voltgrid reported on NVIDIA's H200 China shipments, that market is still where the export-control argument is fought.

What the filing lists

The purchases appear in Part 7 of Trump's annual OGE Form 278e for calendar 2025, which the Office of Government Ethics stamped as received on June 29, 2026. The May 6, 2025 NVIDIA entry sits in investment account No. 6. The same account lists purchases that day of Apple, Microsoft and Amazon in the same $1,000,001 to $5,000,000 range, plus several other large companies, so the NVIDIA line is one of a broad batch. It also lists a further NVIDIA purchase on May 15, 2025 of $500,001 to $1,000,000.

The second episode follows Trump's Dec. 8, 2025 announcement that NVIDIA could sell H200 chips to approved customers in China, with 25% of the revenue going to the US government, according to law firm ArentFox Schiff. The filing shows NVIDIA purchases of $250,001 to $500,000 on Dec. 9 in two separate accounts, $250,001 to $500,000 on Dec. 12, and $500,001 to $1,000,000 on Dec. 17. The Guardian counted at least three purchases of $250,001 to $500,000 in the days after the announcement.

The export rule change and its cost

BIS published a final rule on Jan. 15, 2026, per ArentFox Schiff, moving licence review for H200-class chips bound for China and Macau from a presumption of denial to case-by-case review. The rule applies to exports from the US only, and applicants must certify US supply is sufficient. For NVIDIA, the economic effect is access to a market the Biden rule would have narrowed. Because chips made abroad must first be imported into the US and pay a 25% duty before export under a licence, ArentFox Schiff says, the US collects its share at the border.

What is not confirmed yet

The filing does not say who directed each trade. Neither the Guardian nor Seoul Economic Daily reports a regulator finding. BIS said in May 2025 that it would publish a regulation formalising the rescission; a Federal Register notice formalising it could not be confirmed. Earlier, Voltgrid reported that Commerce Secretary Howard Lutnick reportedly stalled a third crackdown on NVIDIA chip diversion, and no published scope or timetable for the Democratic inquiry has been found.