Right-wing podcaster Dan Bongino will enter the FBI on Monday as its deputy director with a ton of baggage and potential conflicts of interest — a direct result of his hugely successful business enterprises that threaten to complicate his new job.
As of late December, Securities and Exchange Commission filings show, Bongino was among the top shareholders in the video platform company Rumble, with a stake worth roughly $130 million as of this week. Recent filings don’t indicate that he’s sold his shares, which account for a whopping 5.7% of the firm’s Class A common stock.
He also has senior positions with seven corporations in Florida, all of which continue to list him as manager, president or similar ownership roles.
And he’s spent years plugging advertisers by name during episodes of “The Dan Bongino Show,” with many of those advertisers operating in business sectors that have attracted government scrutiny.
It’s a profile unlike any the FBI has ever seen for someone taking its No. 2 role. And that is exactly why the spot has traditionally gone to a career “G-man” who has had limited run-ins with the business world and little by way of a public life outside the insular FBI.
“He’ll run into conflicts of interest and he’ll have to decide if integrity will rule the day,” said James S. Davidson, a former agent who now runs the FBI Integrity Project to provide current employees a channel for addressing ethical quandaries.
The issues already appear to be on Bongino’s radar. The commentator, who has continued his podcast since President Donald Trump announced his selection on Feb. 23, has said he has to “take a couple of days off” to deal with the transition.
“I have to travel up to D.C. and get some stuff done. There is a pretty extensive paperwork requirement you have to go through for backgrounds and things like that. I’m sure you guys can imagine. Many of you out there have been government employees. It’s some of the same paperwork,” Bongino said on his Feb. 26 show.
Bongino has also gone on the defensive, lambasting journalists on his Feb. 28 show.
“The Dan Bongino deputy director appointment meltdown in the media continues, which is like nothing I’ve seen in a while,” he said. “I have a job. The job has to wind down. This isn’t anything. Would you prefer I just take the spot while I have contractual obligations elsewhere? Because I’m pretty sure that’s a violation of government ethics rules.”
Bongino did not respond to NOTUS’ inquiries sent to his show producer, nor phone calls, texts and email.
While Democrats said they were deeply disturbed by Kash Patel’s nomination to run the FBI — particularly after he made threats to exact vengeance on Trump’s political enemies — they were at least able to vote on his nomination. The second-in-command role does not require Senate confirmation, despite the fact it is an operations role that comes into daily contact with the agency’s active law enforcement investigations.
“The director is really more of a figurehead. He’s not actually the one running it day to day, unless it’s something like Waco — a big operation that’s high profile. The guy actually running the day-to-day operations is going to be Bongino,” said I. Chuck McCullough, who spent years as a member of the bureau’s SWAT team and later served as the intelligence community’s inspector general.
Like other executive branch personnel, Bongino has to fill out an Office of Government Ethics Form 278 that publicly lists his assets and liabilities. However, as an FBI employee who will require a top secret clearance and daily access to national security information, Bongino also has to supply an annual Security Financial Disclosure Form that’s much more stringent and requires listing all kinds of credit lines, safety deposit boxes and even instances where a friend lends as little as $500 that isn’t paid off by year’s end.
While the ethics form seeks to identify potential work conflicts, the security form is meant to screen for counterintelligence concerns and ensure that senior government officials can’t fall prey to foreign spies through blackmail or influence operations. That’s where being a successful podcaster receiving money from dozens of businesses could cause headaches, former FBI employees told NOTUS.
But it’s what these forms don’t capture that could cause issues for senior FBI leadership who will have to meet regularly with Bongino to discuss covert operations and ongoing investigations. His many business dealings could overlap with work at the nation’s top law enforcement agency.
Bongino plugged longtime advertiser ExpressVPN on his show just as one of the company’s top executives, Daniel Gericke, was fined by the Department of Justice for previously helping the United Arab Emirates hack and spy on human rights activists it considered state enemies — accountability that stemmed from an FBI investigation.
His advertised link to AllFamilyPharmacy.com/Bongino — where the code “Bongino10” grants customers 10% off — immediately directs to a page for “Ivermectin and other essential medications.” The Boca Raton business, an hour drive south from Bongino’s South Florida home, is run by a man who was accused in a 2020 whistleblower lawsuit of running a marketing company that “is engaged in the scam of promoting unnecessary medications to patients based upon internet ads.” (The lawsuit was dismissed after the local federal attorney in 2023 declined to prosecute, stating it did not “warrant the continued expenditure of government resources to monitor the claims based on currently available information.” Lawyers involved declined to discuss the matter.)
The FBI also routinely investigates traders of precious metals, especially as foreign adversaries and corrupt politicians use the industry to try to circumvent economic sanctions. Bongino has hawked gold products on his show for years.
On another episode, Bongino called the Texas virtual network operator Patriot Mobile “one of our biggest supporters over the years.” Apart from the fact that the FBI regularly approaches cell network providers for surveillance data, there’s also an unexpected political dimension to this — one that touches on the current Justice Department’s rejection of the Biden administration’s efforts to use the FBI to investigate the politically driven harassment of public officials by parents at school board meetings. Patriot Mobile is the driving force behind a political action committee that “took over” four Texas school boards in 2022. The company’s PAC gloats that its “hard work turned Tarrant County, Texas from purple back to SOLID RED.”
None of the advertisers responded to questions sent by NOTUS this week.
Then there are the many show sponsors Bongino doesn’t even mention by name, which interrupt his show with commercials dubbed by AI-generated voices and overlaid with stock images that sell supposed miracle treatments — for visual degeneration, wrinkles and body fat. One has referred to a “grandmother’s French beauty secret” that “works at the cellular level” but has been “erased by major media” and big corporations who “don’t want their premium antiaging line revenues to fall.”
One former FBI agent, who described himself as “politically down the middle,” told NOTUS that Bongino would have to be constantly on the lookout for FBI investigations that even tangentially cross any of his past business arrangements.
“I’m not sure those sorts of issues will come up in financial disclosures. But these relationships, if they’re a long-time advertiser, really do raise a question as to whether there’s an appearance of impropriety. Hopefully he’ll recuse,” the former agent said.
Paul Wiegartner Jr., a retired FBI attorney who routinely reviewed matters at the bureau’s massive New York field office, warned that Bongino’s prolific business activities would complicate his ability to avoid the appearance of impropriety while leading the agency.
“It seems like there would be a lot that might affect those businesses. I think it’d be exponentially more challenging to navigate that. As a field agent, you get assigned a narrow focus and investigation, but as a No. 2 person at the FBI, you have an extremely broad focus,” Wiegartner said.
These kinds of business entanglements are nothing new at the FBI. The law enforcement agency regularly hires accountants to bolster its review of financial evidence, and many candidates come from CPA firms and large consultancies where they made significant income and may have come across major investment opportunities. Wiegartner recalled one FBI agent who left the ill-fated investment bank Bear Stearns and managed to separate his past with his investigative duties just fine.
Then again, Wiegartner remembered running into issues of his own when he was offered a part-time job that would pale in comparison to Bongino’s entrepreneurial work.
“I was coaching wrestling on the side, and had to get outside approval. And I couldn’t get approval for that!” he said.
Anyone looking to suggest Bongino recuse himself from a case will also encounter a different power dynamic and chain-of-command. Normally, a field agent would seek approval from their supervisor and maybe even input from the field office’s attorneys. By contrast, Bongino will sit atop the pyramid and would only be hearing from the bureau’s general counsel, who technically has no authority over him.
Former FBI employees told NOTUS that the bureau’s top lawyer would likely present Bongino with conflicts as they arise — and Bongino would be wise to take those recommendations.
“Have the GC tell deputy director what to do? I think it’s going to be difficult,” said the former FBI agent. “This is a serious problem. What he should do is probably divest, put everything in a blind trust. It’s going to be messy with all of his business interests. It’s just going to raise a whole set of appearances of impropriety.”
Any allegations of misjudgments on Bongino’s part would have to be handled by Attorney General Pam Bondi, and if she declines, by DOJ Inspector General Michael E. Horowitz — who has managed to maintain his reputation as a hard-charging and nonpolitical referee.
“I don’t see Pam Bondi investigating Dan Bongino. That’s an issue,” said Davidson, a former FBI supervisory agent in Los Angeles.
In the past two weeks, Bongino has repeatedly stressed that his past work won’t affect his future position at the FBI. On Feb. 28, he tried to clear the air in the first minutes of the Friday episode.
“I am obviously not in the FBI yet. I do not start for another two weeks. Those are two completely distinct and different roles. They are separate,” he said. “It’s not a fine line, it’s a bold line. I am not there yet … I am still the humble host of ‘The Dan Bongino Show’ while we wind down the business. I did not want to leave you cold. They are two separate enterprises. You guys get where I’m going with this? I want to be clear on that. Those are two separate roles. All right?”
Eight seconds later, Bongino went back on script:
“Today’s show is sponsored by Lumen. You know, when your metabolism is working properly, you can feel the benefits in literally every aspect of your life. I found a valuable tool that helps me get insight into creating an improved metabolism for my body. You know I love life hacks. It’s called Lumen, L-U-M-E-N.”
Then it came time to speed read the disclaimer: “Thank you, Lumen, for sponsoring the show. Your statements and products have not been evaluated by the FDA, not intended to diagnose treat, cure or prevent any disease or condition.”
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Jose Pagliery is a reporter at NOTUS.