In the days before the U.S. carried out the first strikes of the Iran war, a high-ranking Treasury Department official leading the agency’s terrorist financing prevention efforts personally purchased tens of thousands of dollars worth of shares in oil and gas, nuclear energy and cybersecurity funds, according to a new financial disclosure.

The disclosure indicates that Assistant Secretary for Terrorist Financing Jonathan Burke purchased from $15,001 to $50,000 worth of shares in three different exchange-traded funds with narrow investment strategies: the U.S. Oil & Gas Exploration & Production ETF, VanEck Uranium and Nuclear Energy ETF and First Trust NASDAQ Cybersecurity ETF.

Burke made the purchases on Feb. 20 — eight days before President Donald Trump ordered attacks on Iran.

The purchases appear to be part of a process wherein the government requires officials such as Burke to unload existing investments that may pose a conflict of interest to their duties — in this case, stock in Citigroup — but allows them to avoid capital gains taxes on the mandated sale so long as they reinvest in financial funds or bonds that do not run a foul of ethics rules, according to a certificate of divestiture issued by the Office of Government Ethics in January.

“All senior Treasury officials undergo a rigorous ethics review led by career officials to ensure compliance with applicable laws, regulations, and policies,” a Treasury spokesperson told NOTUS in a statement. “As part of this process, officials may enter into ethics agreements requiring the divestment of certain holdings.”

Although approved by ethics officials, the purchases represent yet another instance of Trump administration officials owning a financial stake in fields impacted by their departments’ work. Per the terms of his signed ethics agreement, Burke only needs to recuse himself from matters related to his investments if the value of his investment in any one sector is greater than $50,000, unless he receives a written waiver.

Burke had 90 days from the Feb. 4 sale of his existing Citigroup Inc. holdings, worth between $250,000 and $500,000, to choose and execute his reinvestments.

Within about two weeks, he had landed on seven exchange-traded funds, cumulatively worth between $210,000 and $500,000 — among them, the oil and gas, nuclear energy and cybersecurity funds.

“These transactions were reviewed and approved by career ethics officials,” the Treasury spokesperson said. “Assistant Secretary Burke followed all steps from the August 2025 ethics agreement, in close coordination with Treasury’s ethics team.”

In his role, Burke “is responsible for formulating and coordinating the counter terrorist financing and anti-money laundering efforts of the Department of the Treasury.” Last year, he told the Senate Banking Committee he would work to “develop and implement sanctions that are appropriately targeted, meaningful, and effective in supporting U.S. policy objectives.” NOTUS’ request for the Treasury Department to clarify Burke’s responsibilities and the extent to which he works on sanctions went unanswered.

The Office of Terrorist Financing and Financial Crimes, which Burke leads, operates under the Office of Terrorism and Financial Intelligence, as does the Office of Foreign Assets Control, which directly administers sanctions.

The day before the trades, President Donald Trump had given his strongest signal to date that strikes on Iran could be imminent. A number of American warships, aircraft carriers and other military firepower had already been deployed in the Middle East.

The war and subsequent chaos in the global oil market have prompted the Treasury to use the levers at its disposal to stabilize supply and take further action against the sale of petroleum as a means of funding for Iran and its terrorist proxies. The Iranian blockade of the Strait of Hormuz spiked the price of oil in the weeks after the war began.

The oil and gas ETF Burke purchased immediately became several percentage points more valuable after the United States began combat operations, and in little more than a month, it had ticked up 20 percent, a high from which it has retreated somewhat in recent days.

Less than two weeks after Burke invested in the oil and gas fund, the Treasury Department issued a 30-day waiver allowing refiners in India access to sanctioned Russian oil to help stabilize the global oil market and with the expectation that “New Delhi will ramp up purchases of U.S. oil.”

That sanctions action precipitated others the Treasury Department explored in order to boost supply in the oil and gas market.

“There are hundreds of millions of sanctioned, barrels of sanctioned crude on the water, and in essence, by unsanctioning them, Treasury can create supply,” Treasury Secretary Scott Bessent said in a March 6 interview. “We’re going to keep a cadence of announcing measures to bring relief to the market during this conflict.”

Bessent went so far as to give investment advice in his interview.

“Larry I’m sure you agree with me,” Bessent told Fox News host Larry Kudlow, “that in our investment careers, the best investments you made was looking to the other side. And the other side here is that, once this is over, then oil prices are going to be sustainably lower and in a safer position for years, if not decades to come. So I would encourage people to look to the other side of this.”