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  Horowitz Report Chapter 1: Introduction

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CHAPTER ONE

INTRODUCTION

I. Background and Overview

The Department of Justice( Department) Office of the Inspector General( OIG) undertook this review to examine certain actions by the Federal Bureau of Investigation( FBI) and the Department during an FBI investigation into whether individuals associated with the Donald J. Trump for President Campaign were coordinating, wittingly or unwittingly, with the Russian government. The FBI 's counterintelligence investigation, known as" Crossfire Hurricane,'' was opened on July 31, 2016, weeks after the Republican National Convention( RNC) formally nominated Trump as its candidate for President, and several months before the November 8, 2016 elections, through which Trump was elected President of the United States. On May 17, 2017, the Crossfire Hurricane investigation was transferred from the FBI to the Office of Special Counsel upon the appointment of Special Counsel Robert S. Mueller III to investigate Russian interference with the 2016 presidential election and related matters.

The FBI opened Crossfire Hurricane in July 2016 following the receipt of certain information from a Friendly Foreign Government( FFG). According to the information provided by the FFG, in May 2016, a Trump campaign foreign policy advisor, George Papadopoulos," suggested'' to an FFG official that the Trump campaign had received" some kind of suggestion'' from Russia that it could assist with the anonymous release of information that would be damaging to Hillary Clinton( Trump 's opponent in the presidential election) and President Barack Obama. At the time the FBI received the FFG information, the U.S. Intelligence Community( USIC), which includes the FBI, was aware of Russian efforts to interfere with the 2016 U.S. elections, including efforts to infiltrate servers and steal emails belonging to the Democratic National Committee( DNC) and the Democratic Congressional Campaign Committee. The FFG shared this information with the State Department on July 26, 2016, after the internet site Wikileaks began releasing emails hacked from computers belonging to the DNC and Clinton 's campaign manager. The State Department advised the FBI of the information the next day.

Crossfire Hurricane was opened several weeks after the FBI 's July 5, 2016 conclusion of its" Midyear Exam'' investigation into Clinton 's handling of government emails during her tenure as Secretary of State. Some of the same FBI officials, supervisors, and attorneys responsible for the Midyear investigation were assigned to the newly opened Crossfire Hurricane investigation, but there was almost no overlap between the FBI agents and analysts assigned to the Midyear and Crossfire Hurricane investigations. The FBI opened Crossfire Hurricane as an umbrella counterintelligence investigation, without identifying any specific subjects or targets. FBI officials told us that they did not immediately identify subjects or targets because it was unclear from the FFG information who within the Trump campaign may have received the reported offer of assistance and might be coordinating, wittingly or unwittingly, with the Russian government. By August 10, 2016, the FBI had assembled an investigative team of special agents, analysts, and supervisory special agents( the Crossfire Hurricane team) and conducted an initial analysis of links between Trump campaign members and Russia. Based upon this analysis, the FBI opened individual cases under the Crossfire Hurricane umbrella on three U.S. persons- Papadopoulos, Carter Page, and Paul Manafort- all of whom were affiliated with the Trump campaign at the time the cases were opened. On August 16, 2016, the FBI opened a fourth individual case under Crossfire Hurricane on Michael Flynn, who was serving at the time as the Trump campaign 's National Security Advisor.

Two of the four Crossfire Hurricane subjects were already the subjects of other existing federal investigations. Carter Page was the subject of an ongoing counterintelligence investigation opened by the FBI 's New York Field Office( NYFO) on April 4, 2016, relating to his contacts with suspected Russian intelligence officers. Manafort was the subject of an ongoing criminal investigation, supervised by the Money Laundering and Asset Recovery Section( MLARS) in the Department 's Criminal Division, concerning millions of dollars Manafort allegedly received from the government of Ukraine.

Some of the early investigative steps taken by the Crossfire Hurricane team immediately after opening the investigation were to develop profiles on each subject; send names of, among others, individuals associated with the Trump campaign to other U.S. government intelligence agencies for any further information; and review FBI files for potential FBI Confidential Human Sources( CHSs) who might be able to assist the investigation. FBI witnesses we interviewed told us they believed that using CHSs in covert operations would be an efficient way to develop a better understanding of the information received from the FFG. We determined that the Crossfire Hurricane team tasked several CHSs and Undercover Employees( UCEs) during the 2016 presidential campaign, which resulted in interactions with Carter Page, Papadopoulos, and a high-level Trump campaign official who was not a subject of the investigation. All of these interactions were consensually monitored and recorded by the FBI. The interactions between CHSs and Page and Papadopoulos occurred both during the time Page and Papadopoulos were advisors to the Trump campaign, and after Page and Papadopoulos were no longer affiliated with the Trump campaign. We also learned that in August 2016, a supervisor of the Crossfire Hurricane investigation participated on behalf of the FBI in a strategic intelligence briefing given by the Office of the Director of National Intelligence( ODNI) to candidate Trump and his national security advisors, including investigative subject Flynn, and also participated in a separate strategic intelligence briefing given to candidate Clinton and her national security advisors. The FBI viewed the briefing of candidate Trump and his advisors as a possible opportunity to collect information potentially relevant to the Crossfire Hurricane and Flynn investigations. The supervisor memorialized the results of the briefing in an official FBI document, including instances where he was engaged by Trump and Flynn, as well as anything he considered related to the FBI or pertinent to the Crossfire Hurricane investigation. The supervisor did not memorialize the results of the briefing of candidate Clinton and her advisors.

An early investigative step considered but not initially taken by the Crossfire Hurricane team was to seek court orders under the Foreign Intelligence Surveillance Act( FISA) authorizing surveillance of Page and Papadopoulos. The U.S. Foreign Intelligence Surveillance Court( FISC) may approve FISA surveillance of an American citizen for a period of up to 90 days, subject to renewal, if the government 's FISA application establishes probable cause to believe that the targeted individual is an agent of a foreign power by knowingly engaging in at least one of the five activities enumerated in the FISA statute. The Crossfire Hurricane team initially considered seeking FISA surveillance of Papadopoulos as a result of his statement to the FFG and of Page based upon information the FBI had collected about his prior and more recent contacts with known and suspected Russian intelligence officers, as well as Page 's financial, political, and business ties to the Russian government. Officials determined there was an insufficient basis to proceed with a FISA application concerning Papadopoulos, and the Crossfire Hurricane team never submitted a FISA application for Papadopoulos. With regard to Page, on August 15, 2016, the Crossfire Hurricane team requested assistance from the FBI 's Office of the General Counsel( OGC) to prepare a FISA application for submission to the FISC. However, after consultation between FBI OGC and attorneys in the Office of Intelligence( OI) in the Department 's National Security Division( NSD), which is responsible for preparing FISA applications and appearing before the FISC, the Crossfire Hurricane team was told in late August 2016 that more information was needed to establish probable cause for a FISA on Page.

A few weeks later, on September 19, 2016, the Crossfire Hurricane team received a set of six reports prepared by Christopher Steele concerning Russian interference in the 2016 U.S. election and alleged connections between this Russian effort and individuals associated with the Trump campaign. Steele is a former intelligence officer who, following his retirement, opened a consulting firm and furnished information to the FBI beginning in 2010, primarily on matters concerning organized crime and corruption in Russia and Eastern Europe. In 2013, the FBI prepared paperwork to enable it to open Steele as an FBI CHS. In providing the first two election reports to his FBI handling agent in July 2016, Steele told the handling agent that he had been hired by an investigative firm, Fusion GPS, to collect information on the relationship between candidate Trump 's businesses and Russia. Steele further informed the FBI handling agent that Fusion GPS had been retained by a law firm to conduct this research. According to the handling agent, it was obvious to him that the request for the research was politically motivated. Two of the six Steele reports received by the Crossfire Hurricane team on September 19 referenced Carter Page by name. One stated that Page had held secret meetings with two high level Russian officials during Page 's July 2016 trip to Moscow. This report also indicated that one of the alleged meetings included a discussion about the Kremlin potentially releasing compromising information about Democratic candidate Hillary Clinton to Trump 's campaign team. Another report from Steele described" a well-developed conspiracy of co-operation'' between the Russian government and Trump 's campaign to defeat Clinton, using Carter Page and others as intermediaries. On September 21, 2016, 2 days after the team received these reports, FBI OGC advised OI that the FBI believed it was ready to submit a request for FISA authority on Carter Page, and 01 and the FBI began drafting the first FISA application. Among the FBl 's purposes in seeking a FISA order for Page was to obtain information about Page 's trip to Russia in July 2016, when Page was still a member of the Trump campaign.

On September 23, 2016, Yahoo News published an article stating that U.S. intelligence officials had received reports regarding Carter Page 's private meetings in Moscow with senior Russian officials. The article cited a" well-placed Western intelligence source,'' and contained details about Carter Page 's activities in Russia that closely paralleled the information contained in the reporting that Steele had provided to the FBI. We found no evidence that anyone from the FBI asked Steele in September 2016 or at any other time, if he had spoken with the Yahoo News reporter. Steele had, in fact, spoken with the reporter prior to the article 's publication, which the FBI would learn from public records after the submission of the first FISA application.

On October 21, 2016, NSD submitted the Carter Page FISA application to the FISC, asserting that there was probable cause to believe that Page was an agent of the Russian government. The application relied on, among other things:

• The information provided by the FFG about its interaction with Papadopoulos;

• Information from the FBI 's previously opened counterintelligence investigation relating to Page arising from his contacts with Russian intelligence officers;

• Information from Steele 's reports that pertained specifically to Carter Page; and

• Information from a meeting between Page and an FBI CHS that was consensually monitored by Crossfire Hurricane investigators.

The application also stated in a footnote that the FBI" speculates that the[ person who hired Steele] was likely looking for information that could be used to discredit[ candidate Trump 's] campaign.'' Further, the application advised the court of information reported in the September 23, 2016 Yahoo News article and stated that( a) the FBI" does not believe that Source# 1 directly provided... to the press'' the information in the article,( b) according to the article and other news articles, individuals affiliated with the Trump campaign made statements distancing the campaign from Carter Page, and( c) Page himself denied the accusations in the Yahoo News article and reiterated that denial in a September 25, 2016 letter to the FBI Director and in a September 26, 2016 media interview.

However, the application, as well as the renewal applications, did not include significant relevant information, and contained inaccurate and incomplete information, that was known to the Crossfire Hurricane team at the time but that it did not share with NSD attorneys. For example, when asked by an NSD attorney who was involved in helping to draft the first FISA application whether Page had provided information to another U.S. government agency or was a source for that other agency, a Crossfire Hurricane agent incorrectly told the NSD attorney that Page 's contact with the other U.S. government agency was" dated'' and" outside scope.'' The Crossfire Hurricane agent made this statement despite the fact that the Crossfire Hurricane team had been told by the other agency in a written memorandum that Page had been approved as an operational contact for the other agency from 2008 to 2013 and that Page had provided information to the other agency that was relevant to the FISA application. The Crossfire Hurricane team also failed to inform NSD attorneys about information obtained by the FBI during CHS operations and interviews that was inconsistent with the allegations contained in the Steele reporting that was being relied upon in the FISA application.

The FISA application was reviewed by numerous FBI agents, FBI attorneys, and NSD attorneys, and, as required by law, was ultimately certified by then FBI Director James Comey and approved by then Deputy Attorney General Sally Yates. The FISC granted the first FISA application on October 21, 2016, authorizing the use of FISA authority on Carter Page.

On October 31, 2016, Mother Jones magazine published an online news article titled" A Veteran Spy has Given the FBI Information Alleging a Russian Operation to Cultivate Donald Trump.'' The October 31 article quoted a" well placed Western intelligence source,'' and described how that individual had provided reports to the FBI about connections between Trump and the Russian government.

According to the article, the source was continuing to provide information to the FBI, and was quoted as saying" it 's quite clear there was or is a pretty substantial inquiry going on.'' On November 1, 2016, Steele 's FBI handling agent questioned Steele, who admitted speaking to the reporter who wrote the October 31 article. The handling agent advised Steele at that time that his relationship with the FBI would likely be terminated for disclosing his relationship with the FBI to the press, and the FBI officially closed Steele for cause on November 17, 2016. Steele was never paid by the FBI for any of the reports or information that he provided concerning Carter Page or connections between the Russian government and the Trump campaign.

After Steele was closed as an FBI CHS, Crossfire Hurricane agents continued to receive information from him through a conduit, Department attorney Bruce Ohr, who at the time was an Associate Deputy Attorney General in the Office of the Deputy Attorney General( ODAG). Ohr had known Steele, through work, since at least 2007 and, starting in July 2016, Steele had contacted Ohr on multiple occasions to discuss information from Steele 's reports. At Steele 's suggestion, Ohr also met in August and December 2016 with Glenn Simpson, the owner of Fusion GPS, which Ohr 's wife had worked for as an independent contractor through September 2016. During those meetings, Simpson provided Ohr with several of Steele 's election reports. Ohr also communicated with a senior State Department official concerning, among other matters, the Steele reporting. Between the date of Steele 's closing as an FBI CHS in November 2016 and May 15, 2017, Ohr met with the FBI on 13 occasions. In his meetings with the FBI, Ohr provided the FBI with information that Steele had provided to him, the Steele election reports that Ohr had received from Simpson, as well as a thumb drive containing information Ohr had received from his wife that contained open source research she had compiled while working for Fusion GPS. Department leaders, including Ohr 's supervisors within ODAG, were unaware of Ohr 's meetings with Steele, Simpson, the FBI, or the State Department, or of Ohr 's wife 's connection to Fusion GPS, until late November 2017, when Congress requested information from the Department regarding Ohr 's activities.

As the FBI 's Crossfire Hurricane investigation proceeded, the Department submitted three renewal applications to the FISC seeking authority to continue FISA surveillance of Carter Page. Comey and Yates approved the first renewal application, Comey and then Acting Attorney General Dana Boente approved the second renewal, and then Acting FBI Director Andrew McCabe and then Deputy Attorney General( DAG) Rod Rosenstein approved the third renewal. In total, at the request of the FBI, the Department filed four FISA applications, each of which was granted by the FISC: the first FISA application on October 21, 2016, and three renewal applications on January 12, April 7, and June 29, 2017. A different FISC judge considered each application before issuing the requested orders, which collectively resulted in approximately 11 months of FISA coverage of Carter Page from October 21, 2016, until September 22, 2017.

Each of the FISA orders issued authorized the U.S. government to conduct electronic surveillance[ REDACTED] targeting Carter Page for a period of up to 90 days. The authority permitted the government to, among other things,[ REDACTED] by Carter Page. The orders expressly limited the electronic surveillance[ REDACTED] to only[ REDACTED] specifically identified in the order and in the manner specified by the order. Further, the orders required the government to adhere to standard procedures

designed to minimize the government 's acquisition and retention of non-public information about a U.S. person that did not constitute foreign intelligence information. At the request of the government, the orders also included special procedures restricting access to acquired information to only those individuals assigned to the Crossfire Hurricane investigation( and their supervisors), which the Department interpreted to include Department attorneys and officials assisting in and overseeing the investigation. The orders also required higher approval than would normally be required before disseminating the information outside the FBI.

In April and May 2017, following news reports that the FBI had obtained a FISA for Carter Page, Page gave interviews to news outlets denying that he had collected intelligence for the Russian government and asserting instead that he had previously assisted U.S. government agencies. Shortly before the FBI filed the final renewal application with the FISC in mid-June 2017, and in response to concerns expressed by the investigative team and NSD about Page 's claim, an FBI OGC Attorney emailed the U.S. government agency that had provided information to the FBI in August 2016, referenced above, about its prior interactions with Carter Page to inquire about Page 's past status. The other U.S. government agency 's liaison to the Crossfire Hurricane team responded by email to the FBI OGC attorney by directing the attorney to a memoranda previously sent to the FBI by the other U.S. government agency informing the FBI that Page had been approved as an operational contact for the other agency from 2008 to 2013. The email also stated, using the other agency 's terminology, that it was the other agency liaison 's recollection that Page had prior interactions with that other agency. However, when asked by one of the supervisory special agents( SSA) on the Crossfire

Hurricane team( who was going to be the affiant on the final FISA renewal application) about Page 's prior interactions with that other agency, the OGC Attorney advised the SSA that Page was" never a source'' for the other U.S. government agency. In addition, the OGC Attorney altered the email that the other U.S. government agency had sent to the OGC Attorney so that the email inaccurately stated that Page was" not a source'' for the other agency; the OGC Attorney then forwarded the altered email to the SSA. Shortly thereafter, on June 29, 2017, the SSA served as the affiant on the final renewal application, which was again silent about Page 's prior relationship with the other U.S. government agency.

On July 12, 2018, while the OIG 's review was ongoing, NSD submitted a letter to the FISC advising the court of certain factual omissions in the Carter Page FISA applications that had come to NSD 's attention after the final renewal application was filed on June 29, 2017. The Department 's letter stated that, despite the omissions, it was the Department 's view that the applications contained sufficient information to support the FISC 's earlier probable cause findings as to Page. On March 28, 2018, the OIG publicly announced that, in response to requests from the Attorney General and Members of Congress, it had initiated this review to examine:

• Whether the Department and the FBI complied with legal requirements and applicable policies and procedures in FISA applications filed with the FISC relating to surveillance of Carter Page;

• What information was known to the Department and FBI at the time the applications were filed about Christopher Steele; and

• How the Department 's and FBI 's relationships and communications with Steele related to the FISA applications.

In addition, during the OIG 's Review of Various Actions in Advance of the 2016 Election, we discovered text messages and instant messages between some FBI employees, using FBI mobile devices and computers, which expressed statements of hostility toward then candidate Trump and expressed statements of support for then candidate Clinton. Because some of the FBI employees responsible for those communications, including Section Chief Peter Strzok and FBI Attorney Lisa Page, also had involvement in the Crossfire Hurricane investigation, we examined whether their communications evidencing a potential bias affected investigative decisions made in Crossfire Hurricane. We also examined, where available, the government emails, text messages, and instant messages of all Department and FBI employees who played a substantive role in Crossfire Hurricane to determine if there were any additional communications evidencing a potential bias and, if so, whether the views expressed influenced any investigative decisions.

The March 28, 2018 OIG announcement also stated that" if circumstances warrant, the OIG will consider including other issues that may arise during the course of the review.'' In May 2018, in response to Rosenstein 's request, the OIG added to the scope of this review to determine whether the FBI infiltrated or surveilled the Trump campaign. Accordingly, we examined the FBI 's use of CHSs in the Crossfire Hurricane investigation, up through November 8, 2016( the date of the 2016 U.S. elections) to evaluate whether the FBI had placed any CHSs within the Trump campaign or tasked any CHSs to report on the Trump campaign, and, if so, whether any such use of CHSs was in violation of applicable Department and FBI policies or was politically motivated. We subsequently learned of and included in our review certain other CHS activities that took place after the 2016 election.

II. Prior OIG Reports on FISA and Related Issues

In addition to the requests described above from the Attorney General, the Deputy Attorney General, and Members of Congress, our initiation of this review was informed by our prior work over the past 15 years on the Department 's and FBI 's use of national security and surveillance authorities, including authorities under FISA. This prior OIG work considered the challenges faced by the Department and the FBI as they utilized national security authorities while also striving to safeguard civil liberties and privacy. In every year since 2006, the OIG 's annual report on" Top Management and Performance Challenges Facing the Department of Justice has highlighted the difficulty faced by the Department and the FBI in maintaining a balance between protecting national security and safeguarding civil liberties.

The OIG 's prior oversight work, some of which was congressionally mandated, informed our decision to initiate this review. That prior oversight work included OIG reviews of the FBI 's use of specific FISA authorities, the FBI 's use of other national security-related surveillance authorities, and the FBI 's or other Department law enforcement components ' use of CHSs and administrative subpoenas .15 We also conducted reviews that specifically examined the impact of the FBI 's use of investigative authorities on U.S. persons engaged in activities that are protected by the First Amendment of the U.S. Constitution.

III. Methodology

During the course of this review, the OIG conducted over 170 interviews involving more than 100 witnesses. These interviews included former FBI Director Comey, former Attorney General Loretta Lynch, former DAG Yates, former Acting Attorney General and Acting DAG and current FBI General Counsel Dana Boente, former FBI Deputy Director McCabe, former DAG Rod Rosenstein, former FBI General Counsel James Baker, FBI agents, analysts, and supervisors who worked on the Crossfire Hurricane investigation, attorneys from the FBI 's National Security and Cyber Law Branch, NSD attorneys who prepared or reviewed the FISA applications, Department attorneys from ODAG who reviewed the FISA applications, former and current members of the FBI 's senior executive leadership, Department attorney Bruce Ohr and his wife, Nellie Ohr, and additional Department attorneys who supervised and worked with Ohr on matters relevant to this review.

The OIG also interviewed witnesses who were not current or former Department employees regarding their interactions with the FBI on matters falling with the scope of this review, including Christopher Steele and employees of other U.S. government agencies. Steele provided the OIG with access to, but not copies of, memoranda regarding interactions he had with FBI personnel and Bruce Ohr in 2010, 2011, and 2016. Steele represented to us that he drafted the memoranda shortly after each interaction. In addition, we reviewed relevant information that other U.S. government agencies provided to the FBI in the course of the Crossfire Hurricane investigation. Because the activities of other agencies were not within the scope of this review, we did not seek to obtain records from them that the FBI never received or reviewed, except for a limited amount of State Department records relating to Steele. Additionally, our review also did not seek to independently determine whether corroboration existed for the Steele election reporting; rather, our review was focused on information that was available to the FBI prior to and during the pendency of the Carter Page FISAs that related to the Steele reporting.

Two witnesses, Glenn Simpson and Jonathan Winer( a former State Department official), declined our requests for voluntary interviews, and we were unable to compel their testimony. The OIG does not have authority to subpoena for testimony former Department employees or third parties who may have relevant information about an FBI or Department program or operation. Certain former FBI employees who agreed to interviews, including Comey and Baker, chose not to request that their security clearances be reinstated for their OIG interviews.

Therefore, we were unable to provide classified information or documents to them during their interviews to develop their testimony, or to assist their recollections of relevant events.

We also received and reviewed more than one million documents that were in the Department 's and FBI 's possession. Among these were electronic communications of Department and FBI employees and documents from the Crossfire Hurricane investigation, including interview reports( FD-302s and Electronic Communications or ECs), contemporaneous notes from agents, analysts, and supervisors involved in case-related meetings, documents describing and analyzing Steele 's reporting and information obtained through FISA coverage on Carter Page, and draft and final versions of materials used to prepare the FISA applications and renewals filed with the FISC. We also obtained documents from attorneys and supervisors in NSD, Criminal Division( CRM), ODAG, and the Office of the Attorney General( OAG).

As with the OIG 's Review of Various Actions in Advance of the 2016 Election, we obtained electronic communications between and among FBI agents, analysts, and supervisors, and FBI and Department officials to understand what happened during the investigation and identify what was known by the members of the Crossfire Hurricane team as the investigation progressed. In addition to a large volume of unclassified and classified emails, we received and reviewed hundreds of thousands of text messages and instant messages to or from FBI personnel who worked on the investigation. 22 We also were provided with and reviewed transcripts of testimony from numerous witnesses who participated in hearings jointly conducted during the 115th Congress by the House Committee on the Judiciary and the House Committee on Oversight and Government Reform.

Our review included the examination of highly classified information. We were given broad access to relevant materials by the Department and the FBI, including emails, text messages, and instant messages from both the FBI 's Top Secret SCINet and Secret FBINet systems, as well as access to the FBI 's classified Delta database, which FBI agents use to record their interactions with, and information received from, CHSs. Chapter Ten provides more information on the methodology we employed to examine the FBI 's use of CHSs.

As with the OIG 's handling of past reviews, we did not analyze all of the decisions made during the Crossfire Hurricane investigation. Rather, we reviewed the issues described below in Section IV of this chapter. Moreover, our role in this review was not to second-guess discretionary judgments by Department personnel about whether to open an investigation, or specific judgment calls made during the course of an investigation, where those decisions complied with or were authorized by Department rules, policies, or procedures. We do not criticize particular decisions merely because we might have recommended a different investigative strategy or tactic based on the facts learned during our investigation. The question we considered was not whether a particular investigative decision was ideal or could have been handled more effectively, but whether the Department and the FBI complied with applicable legal requirements, policies, and procedures in taking the actions we reviewed or, alternatively, whether the circumstances surrounding the decision indicated that it was based on inaccurate or incomplete information, or considerations other than the merits of the investigation. If the explanations we were given for a particular decision were consistent with legal requirements, policies and procedures, reflected rational investigative strategy and were not unreasonable, we did not conclude that the decision was based on improper considerations in the absence of documentary or testimonial evidence to the contrary.

IV. Structure of the Report

This report consists of twelve chapters. The public version of this report contains limited redactions of information that the FBI and other agencies determined is classified or too sensitive for public release. Following this introduction, Chapter Two summarizes relevant Department and FBI policies concerning counterintelligence investigations, including the policies governing the FBI 's use of CHSs and FISA authority in the context of counterintelligence investigations.

In Chapter Three, we provide an overview of the Crossfire Hurricane investigation, including the information that predicated the investigation, the identification of the subjects of the investigation, the organization and staffing of the Crossfire Hurricane team, and the involvement of Department and FBI leadership. We also describe the context surrounding the Crossfire Hurricane investigation, in particular the conclusion by the USIC that the Russian government was attempting to interfere with the 2016 U.S. elections. In Chapter Four, we discuss the FBI 's receipt and evaluation of information from Steele up and through the first Carter Page FISA application. In Chapter Five, we describe the preparation of the first FISA application which, once granted by the FISC, authorized FISA surveillance of Carter Page. We also describe instances in which information in the first FISA application was inaccurate, incomplete, or unsupported by appropriate documentation.

Chapter Six discusses the FBI 's activities involving Steele after the first FISA application, including the FBI 's decision to close Steele as a CHS and the FBI 's efforts to assess Steele 's election reports. Chapter Seven describes the three renewal applications for FISA surveillance of Carter Page as the Crossfire Hurricane investigation proceeded. In Chapter Eight, we discuss a letter NSD sent to the FISC in July 2018, about one year after the final renewal application was filed, outlining omissions from the FISA applications. We also describe additional instances of inaccurate, incomplete, or undocumented information in the three FISA renewal applications that were not identified in NSD 's letter.

In Chapter Nine, we discuss the interactions between Ohr and the Crossfire Hurricane team, Ohr 's communications with Steele and Simpson, both before and after the FBI closed Steele as a CHS, and Ohr 's interactions with Department attorneys regarding the Manafort criminal case. Chapter Ten discusses the FBl 's use of CHSs other than Steele and its use of Undercover Employees( UCEs) as part of the Crossfire Hurricane investigation. We also describe several individuals we identified who had either a connection to candidate Trump or a role in the Trump campaign, and were also FBI CHSs, and provide the reasons such individuals were not tasked as part of the Crossfire Hurricane investigation. Finally, we describe the attendance of an SSA on the Crossfire Hurricane team at counterintelligence briefings given to the presidential candidates and certain campaign advisors.

Chapter Eleven contains our analysis of the factual information presented in Chapters Three through Ten. Chapter Twelve provides our conclusions and our nine recommendations.

Appendix One to this report contains a chart illustrating the results of our review of the FBI 's compliance with the FISA" Woods Procedures'' that are described in Chapter Two. Appendix Two is the FBl 's official response to this report and the report 's recommendations.
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