Andrew Horn, a former Department of Energy official from the first Trump administration, agreed to pay $59,000 in July 2025 to settle allegations that he violated federal conflict-of-interest rules, though the Justice Department made no determination of liability.
The settlement stemmed from accusations that Horn used his government position to generate business opportunities just before leaving office in January 2021. While the original agreement left many specifics unclear, newly obtained documents and emails now shed light on the companies and individuals involved.
Records show Horn drafted official letters of interest on government letterhead during his final weeks at the Energy Department. These letters expressed federal support for critical minerals projects, which the DoJ alleged occurred while Horn was simultaneously negotiating private-sector employment with one of the companies.
Horn has consistently denied any wrongdoing, stating that the settlement “put the issue to bed” and that he “never violated any sort of ethical constraints.”
The DoJ settlement referred to two unnamed companies. Documents identify the first as VUONG Holdings, founded by Pennsylvania entrepreneur Vinh Vuong, who had ties to former Trump Organization executives. The second company, Grimstone Mining LLC, specialized in extracting rare earth minerals from mining waste in West Virginia.
In one letter dated January 15, 2021—just five days before Trump’s term ended—Horn expressed official U.S. interest in purchasing 10 million tons of scrap material from a proposed partnership between the two companies at $100 per ton, a deal worth $1 billion.
Grimstone’s attorney told reporters there was never any partnership or direct contact between the companies. VUONG Holdings acknowledged a meeting occurred while Horn was still in government but said the investment never materialized.
Ten days after leaving office, Horn emailed former Trump Organization executives about forming a new firm focused on mineral projects, specifically mentioning Grimstone’s opportunity. He claimed he could secure a $500 million loan from financier Erik Bethel, who later denied any such arrangement or business relationship with Horn.
Horn continues to promote rare earth mining projects in Greenland through his company GreenMet, arguing these minerals are critical for national security and reducing dependence on Chinese supply chains.