Anita Dunn, a White House senior advisor, is being forced to divest an investment portfolio worth an estimated $16.8 million to $48.2 million that ethics attorneys say poses significant conflicts of interest in her new role. Dunn will also have to recuse herself from myriad domestic and international issues that affect her former clients.

The political and communications strategist’s newly released 93 pages long financial disclosures show extensive stock, options, bond, and private equity holdings — a fortune she and her husband Bob Bauer, who is a veteran attorney, have amassed over the years. Her husband is a high-powered lawyer who served in the White House under the Obama administration, while Dunn is a founding member of the consulting firm SKDK where she was paid, according to the White House, $738,715 over the last roughly 2 and a half years.

Also, the disclosure provides insight into her extensive client list at SKDK. Dunn will need to divest her holdings and is recused from all matters involving SKDK and her past clients, Chris Meagher, a White House spokesman told CNBC in an email. He also said that she also won’t be able to attend any meetings involving them for two years, pursuant to the Biden-Harris ethics pledge. Meagher added that the form discloses transactions over the two calendar years preceding her May 9 appointment.

Vice president and general counsel of the watchdog Campaign Legal Center, Kedric Payne said after reviewing her disclosure: “The ethics rules require White House officials to recuse from matters that conflict with their financial interests. When officials have a large scope of duties and an even larger stock portfolio, sunlight is the best disinfectant.”

From January 2021 to August 2021, Dunn worked for the president as one of his senior advisors, before returning for a brief stint this March. For both posts, she was considered a special government employee, who was exempt from disclosing her assets publicly. Until her most recent appointment in May, She wasn’t required to file a public disclosure form, reported CNBC.

As President Joe Biden’s public poll numbers were in flux and the administration was struggling with a panoply of vexing global and domestic crises, including Russia’s invasion of Ukraine, the computer chip shortage, rising gas prices and sky-rocketing inflation, she returned and in late February, Biden also announced he was nominating Judge Ketanji Brown Jackson to the Supreme Court.

Dozens of stock holdings acquired by Dunn and her husband are also shown in the disclosure, including call and put options tied to the S&P 500, corporate and municipal bonds, and a plethora of individual stocks held in numerous brokerage accounts. Investments in corporate giants such as Amazon, Alphabet, Boeing, Bank of America, Chevron, Dow, KKR and Morgan Stanley could be seen on those brokerage accounts.

It is estimated her and her husband’s holdings to be worth between $16.8 million and $48.2 million, based on her disclosure form, H. Jude Boudreaux, a senior financial planner at The Planning Center. A certified financial planner at Apex Financial Services, Lee Baker, estimated Dunn and her spouse to have a net worth between $18 million and $38 million in assets.

Their properties aren’t included in calculating their net worth or listed on the form. “Options are not exempt from the conflict of interest statute under any circumstance. That means that she came into government with a conflict of interest with every company whose stock she wrote an option for and with every company in the referenced indexes,” Walter Shaub, who used to run the Office of Government Ethics in the Obama administration and briefly served in the Trump administration, said after reviewing Dunn’s financial disclosure. She needs to divest all of the options or recuse herself for every issue “affecting any company in the S&P 500 and any other company whose stock is the subject of an option she held,” Shaub added.

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