Stock Trades by Senator Perdue Said to Have Prompted Justice Dept. Inquiry

Mr. Grimes wrote again the subsequent morning to apologize.

“David, Sorry. That email was not meant for you. Wrong David!” he wrote.

Mr. Perdue then contacted his wealth supervisor at Goldman Sachs, Robert Hutchinson, and instructed him to promote slightly greater than $1 million value of Cardlytics shares, or about 20 % of his place, three of the folks mentioned. One particular person acquainted with the inquiry into Mr. Perdue’s trades mentioned that the dialog was memorialized in an inner Goldman Sachs file later obtained by the F.B.I.

Financial disclosure varieties Mr. Perdue is required to file with the Senate present a Jan. 23 sale of $1 million to $5 million in Cardlytics inventory.

Investigators in Washington started scrutinizing Mr. Perdue within the spring; by June, the U.S. lawyer’s workplace in Atlanta was dealing with the case together with prosecutors within the division’s felony division in Washington.

Mr. Hutchinson instructed the F.B.I. that Mr. Perdue and his spouse weighed in solely on broader investing points, just like the proportion of shares and bonds to maintain of their portfolio, in accordance to an individual with information of his interview. But an individual acquainted with the senator’s money-management preparations with Goldman Sachs mentioned that Mr. Perdue retained a point of discretion over which trades had been made and when.

In this case, Mr. Perdue’s authorized workforce instructed investigators that Mr. Hutchinson had suggested their shopper in October 2019 that he wanted to promote Cardlytics shares to stability his holdings. The shares had elevated in worth and the advisers argued that Mr. Perdue ought to take the earnings from the gross sales and reinvest them elsewhere to restrict his publicity to the fluctuation of a single inventory. Mr. Perdue elected to go ahead with these modifications in January, his attorneys mentioned.

Mr. Hutchinson declined to remark.

After conducting interviews, together with with Mr. Perdue and Mr. Grimes, investigators reached their conclusion that the senator had no nonpublic details about the corporate’s efficiency when he made the Cardlytics commerce. The investigation was closed later in the summertime, in accordance to the folks acquainted with the case.

If the e-mail from Mr. Grimes was unintentional, mentioned Tai Park, a former federal prosecutor and white-collar crime accomplice on the regulation agency White & Case, Mr. Perdue “may be on firmer ground, because that’s objective evidence that the C.E.O. was not trying to tip him. In any event, trading on the basis of information learned from a C.E.O. of a company is exceedingly risky under any scenario and could draw attention from investigators.”