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  Horowitz Report Chapter 9 Section II

      Ohr's Communications with Steele, Simpson, and the FBI in 2016 and 2017
      see https://www.justice.gov/storage/120919-examination.pdf
Narrative
II. Ohr 's Communications with Steele, Simpson, and the FBI in 2016 and 2017

This section details Ohr 's communications in 2016 and 2017 with Steele and Simpson regarding alleged Russian connections with Trump or persons associated with the Trump campaign, Ohr 's meetings with FBI personnel concerning the information he received from Steele and Simpson, and the FBI 's internal communications regarding Ohr.

A. Ohr 's 2016 Contacts with Steele and Simpson Regarding Russian Issues

1. Ohr 's July 30, 2016 Meeting with Steele

On Saturday, July 30, 2016, at Steele 's invitation, Ohr and Nellie Ohr had breakfast with Steele and an associate in Washington, D.C. Nellie Ohr told us she initially thought it was going to be a social brunch, but came to understand that Steele wanted to share his current Russia reporting with Ohr. According to Steele, he intended the gathering to be a social brunch, but Ohr asked him what he was working on. Steele told us that he told Ohr about his work related to Russian interference with the election. Ohr told us that, among other things, Steele discussed Carter Page 's travel to Russia and interactions with Russian officials. He also said that Steele told Ohr that Russian Oligarch 1 's attorney was gathering evidence that Paul Manafort stole money from Russian Oligarch 1. Ohr also stated that Steele told him that Russian officials were claiming to have Trump" over a barrel.'' According to Ohr, Steele mentioned that he provided two reports concerning these topics to Handling Agent 1 and that Simpson, who owned Fusion GPS, had all of Steele 's reports relating to the election. Steele did not provide Ohr with copies of any of these reports at this time. Later that evening, Steele wrote to Ohr asking to" keep in touch on the substantive issues'' and advised Ohr that Simpson was available to speak with him.

Ohr told the OIG that he did not know before the breakfast that Steele was working with Nellie Ohr 's then employer, Fusion GPS, and did not know whether Steele was aware of Nellie Ohr 's employment with Fusion GPS. However, Nellie Ohr told us that Steele made a comment during the breakfast indicating to her that he knew about her connection to Fusion GPS and that Simpson was" okay'' with Steele talking to her and Ohr. Steele told us he knew Nellie Ohr was working for Fusion GPS, but he did not know she was doing work related to his project-- Russian interference with the 2016 U.S. elections.

Ohr stated that because Nellie Ohr was unaware of Steele 's information and had never been involved in similar situations, he became uncomfortable during the breakfast and spoke to Steele privately. Ohr said that he did not discuss" the details of the cases that[ he was] working on'' with Nellie Ohr. He said he explained to Steele that he did not want Nellie Ohr involved and that he made sure that she was not present for any future conversations he had with Steele. Steele told us that Ohr advised him not to discuss his reporting in front of Nellie Ohr.

Ohr said that he knew the information Steele provided to him was opposition research, but did not know who was paying for it. He told us that it was" clear'' to him, due to the nature of the research, that Steele and Simpson were hired by a private party" somehow related to the Clinton campaign.'' He said he also surmised that Steele thought that by giving the information to Ohr, the U.S. government would do" something.'' Nellie Ohr similarly stated that she understood from the meeting that Steele hoped Ohr would speak with the FBI regarding the information concerning then candidate Trump.

Steele later told the FBI that, prior to the 2016 elections, he provided information to Ohr and was" pushing Ohr to do something about the[ election] reports.''

Following the July 30 breakfast, Ohr reached out to officials in the FBI and the Department about the information Steele had provided, but did not discuss this information with the DAG or anyone in ODAG. On August 3, 2016, Ohr emailed Handling Agent 1 asking to speak to him. Handling Agent 1 told us he talked with Ohr, who asked him if he had seen Steele 's election reports and whether the FBI was doing anything with them. Handling Agent 1 stated that he told Ohr that an executive assistant director at FBI Headquarters and executive management in the New York Field Office( NYFO) knew about Steele 's reporting and were addressing it.

Ohr told us that because the information provided by Steele on July 30 was" scary'' and he was unsure what to do with it, he also reached out to CRM Deputy Assistant Attorney General Bruce Swartz. According to Ohr 's calendar, he met with Swartz on August 4, and both Ohr and Swartz told us that Ohr provided Swartz with specific details of what Steele had told Ohr on July 30.

Swartz told us that he did not tell his immediate supervisor, CRM Assistant Attorney General Leslie Caldwell( who was a political appointee), or any other senior Department political appointees that Ohr was meeting with Steele or the FBI because he did not want to politicize Steele 's information by providing it to political appointees.

We asked Ohr whether he contemporaneously sought any ethics guidance regarding any of the events connected with Steele, Simpson, and Nellie Ohr. Ohr stated that he did not recall considering at the time whether the connections between Nellie Ohr 's employment and his receipt of information from Steele and Simpson presented any ethics issues, nor did he recall contacting an ethics official for advice. Ohr stated it was possible he did not seek ethics advice because he did not want to" spread'' the information around the Department before it was evaluated.

2. Ohr 's August 22, 2016 Meeting with Simpson

On August 22, 2016, Simpson emailed Ohr requesting that Ohr call him. Later that same day, at Simpson 's request, Ohr met with Simpson, and Simpson provided Ohr with the names of three individuals who Simpson thought were potential intermediaries between Russia and the Trump campaign. The three names are included in notes that Ohr told us he wrote on the same day as his meeting with Simpson. According to these notes, one of the three names provided by Simpson was one of the sub-sources in Steele 's election reports, who we reference as Person 1 in previous chapters. Another of the names was Carter Page 's''[ b] usiness partner'' who was an''[ a] lleged'' Russian intelligence officer and" the` brains ' behind[ Carter] Page 's company-- Global Energy Capital.'' Ohr stated that he was uncomfortable receiving this information from Simpson and did not recall Simpson asking him to do anything with it.

Ohr told the OIG that he was troubled by Simpson 's information. He stated that he could not remember when or how he provided Simpson 's information to the FBI, but would have likely contacted Handling Agent 1 or the FBI 's Transnational Organized Crime-East-LCB- TOC-East) Section Chief. Emails indicate that Ohr and Handling Agent 1 spoke on August 24, 2016, but neither of them could recall what they discussed.

On September 12, 2016, Ohr and Handling Agent 1 exchanged emails referencing Steele. In one email, Handling Agent 1 informed Ohr that an FBI team was looking into Steele 's information. In response, Ohr asked Handling Agent 1 to let him know who to contact with additional information. Handling Agent 1 told us that he did not reply to Ohr 's question, and we did not find a response.

3. Ohr 's September 23, 2016 Meeting with Steele

On September 23, 2016, at Steele 's request, Steele met with Ohr in Washington, D.C. Ohr told us they spoke about various topics related to Russia, including information regarding Russian Oligarch 1 's willingness to talk with the U.S. government about Manafort. Ohr said that Steele identified the person who was funding Fusion GPS 's opposition research; however, according to Ohr, he did not recognize the name and could not remember it long enough to write it down after the meeting. Ohr also said that he and Steele also discussed allegations that an Alfa Bank server in the United States was a link between Russia and the Trump campaign; that Person 1 's Russian/American organization in the United States had used the Alfa Bank server earlier in September; and that an individual working with Carter Page was a Russian intelligence officer.

According to Steele, he and Ohr also discussed Steele 's concerns that if Trump won the election, Steele 's source network may be in jeopardy. Steele said that a new FBI Director and new agency heads appointed by Trump would have a higher degree of loyalty to the new President, and could decide to take action against Steele and his source network. Steele told us that Ohr explained that the FBI Director had a 10-year term and could not be removed from the position by the President, so information about Steele 's source network should be protected. According to Steele, he also asked Ohr about why it appeared from the news that the U.S. government was not addressing his election reporting. Steele said that Ohr told him that the Hatch Act made it a criminal offense for a federal official to make a public statement to the detriment or benefit of a candidate within 90 days of an election. When we asked Ohr about this, he told us he did not recall talking to Steele about either of these concerns.

Ohr did not recall whether he provided anyone with the information he received from Steele at this meeting, but stated that he might have spoken to Swartz and Handling Agent 1 about it. Swartz told us that Ohr provided him with specific information at the time regarding Steele 's reporting, but he could not recall the specific information when interviewed by the OIG. Handling Agent 1 told us he did not recall discussing these topics with Ohr.

4. Ohr 's Early October 2016 Activities Regarding Steele 's Information

Sometime prior to October 13, 2016, Ohr talked to the FBI 's TOC-East Section Chief about Steele 's information, but Ohr could not recall what he told him. The TOC-East Section Chief recalled Ohr mentioning Steele to him starting in mid-2016, but stated that he could not specifically recall the information Ohr relayed concerning Steele 's election reporting.

In an October 13, 2016 email, the TOC-East Section Chief told Ohr that counterintelligence agents had traveled to a European city and spoken with Handling Agent 1. Ohr responded that he had additional information to share, specifically names of possible intermediaries, and asked if the counterintelligence agents had an interest in receiving this information. We did not find a response to Ohr 's email and the TOC-East Section Chief did not recall providing a name to Ohr, but the TOC-East Section Chief said he likely passed the email to a relevant point of contact who could follow up with Ohr.

5. Ohr 's October 18-19, 2016 Communications with Steele and Meeting with McCabe and Lisa Page

Early in the morning of October 18, 2016, Steele emailed Ohr, stating" I have something quite urgent I would like to discuss with you, preferably by[ video call]( even before work if you can).'' Records reflect that Steele and Ohr spoke around 7:00 a.m. Later that morning, Steele wrote Ohr an email referring to U.S. sanctions on the Russian company controlled by Russian Oligarch 1. In the email, Steele referenced their earlier video call and stated that Russian Oligarch 1 's attorney wanted Ohr to receive the information. Ohr told us he could not recall what he talked with Steele about that morning, or what the urgent issue was, but based on this email, he said he believed they likely discussed Russian Oligarch 1. Likewise, Steele said he could not recall the topic of the call, but after reviewing the follow-up email, he said he assumed that the conversation included information about Russian Oligarch 1.

Records reflect that shortly after the video call between Ohr and Steele, Ohr called then Deputy Director Andrew McCabe and made a calendar entry indicating a meeting with McCabe for later that day. Ohr told us he set up the meeting to share Steele 's and Simpson 's information with McCabe. He told us that he contacted McCabe because Ohr had previously worked with McCabe on issues associated with Russian Oligarch 1 and Russian organized crime. Ohr explained that when Ohr was an AUSA in the SDNY, McCabe was leading the Russian organized crime squad at the NYFO. Ohr also stated that he wanted to ensure McCabe knew about Steele 's information and assumed McCabe would provide the information to the right people in the FBI.

We asked Ohr if Steele had asked Ohr to meet with the FBI in order to provide the information that Steele had shared with Ohr.. Ohr said that he did not think so. We asked Ohr what prompted him to seek a meeting at that time with McCabe, if it was not at Steele 's request. He responded that he recalled being concerned sometime between his August conversations with Handling Agent 1 and his later conversation with the TOC-East Section Chief that NYFO was not talking to FBI Headquarters about Steele 's reports. Ohr stated that he wanted to meet with McCabe to ensure that McCabe knew about Steele 's information and then McCabe could direct it to the right place within the FBI. We asked Ohr why the TOC-East Section Chief 's October 13 email advising Ohr that counterintelligence agents were examining Steele 's allegations did not alleviate his concern. He responded that he could not recall.

Ohr met with McCabe during the afternoon of October 18, 2016. Ohr told us that he recalled only meeting with McCabe once concerning Steele 's information. McCabe 's Special Counsel Lisa Page was also present. Ohr told us that he informed McCabe and Lisa Page about his background with Steele and the reporting Steele provided to him. He stated that he told them that Steele and Simpson were hired by a private party to provide opposition research, but said he could not recall whether he specifically mentioned the Clinton campaign. Ohr thought he also shared with them that Steele and Simpson were communicating with others and that their information was generated for a political client and not for the U.S. government. Although Ohr told us that he believed Steele and Simpson were communicating with the media, he said he could not recall whether he specifically mentioned that to McCabe and Lisa Page.

Ohr said that he also told McCabe and Lisa Page that Nellie Ohr had worked for Fusion GPS( by the date of this meeting, Nellie Ohr was no longer working for Fusion GPS). He said he did so because the information he was providing to McCabe and Lisa Page came from Fusion GPS and Steele and that they needed to consider any possible bias. Ohr told us that this was" another reason[ for the FBI] to be cautious'' when assessing the information 's credibility. According to Ohr, he understood from his meeting with McCabe and Lisa Page that he should contact the FBI if Steele contacted him again. Ohr stated that neither McCabe nor Lisa Page discussed the Crossfire Hurricane investigation with him during the meeting.

McCabe told us that he recalled meeting with Ohr in fall 2016. He did not remember Ohr calling him to set up the meeting or how it came to be scheduled. He said that the Crossfire Hurricane team previously told him that Ohr knew Steele and that it was not until the meeting that he better understood Ohr 's connection to Steele. McCabe stated that he could not recall specific details from the meeting with Ohr, but believed that the October 18, 2016 notes by Lisa Page and Deputy Assistant Director( DAD) Peter Strzok( as detailed below) accurately captured the meeting 's details.

Lisa Page told us she attended the meeting, but did not recall Ohr conveying much substantive information. She stated that in general, Ohr told McCabe that Steele had information he wanted to provide to the FBI. Lisa Page 's notes from the meeting show that Ohr discussed Steele, provided Steele 's previous employment background, talked about issues concerning Russian Oligarch 1, and indicated that Simpson provided Ohr with names of intermediaries between the Kremlin and the Trump campaign. Lisa Page also wrote that Ohr met with Russian Oligarch 1 the previous year and" Need report? ''

We also reviewed Strzok 's notes dated October 18 that detail information concerning Ohr. Strzok told us he believed either Lisa Page or McCabe provided the information to him. In addition to the information contained in Lisa Page 's notes, Strzok 's notes also stated:" Bruce 's wife fluent Russian speaker,''" Simpson hired Ohr 's wife to find connections,'' and" She saw no connections[ at] first.'' Additionally, we reviewed Assistant Director E.W." Bill'' Priestap 's notes, which reflect an entry dated October 19 that states:" DOJ Bruce[ Ohr]-- Steele is providing reporting to a variety of people.'' Priestap told us that he did not recall who told him or how he learned this information.

Steele and Ohr spoke on October 19 at Ohr 's request. Ohr and Steele both told us that they could not recall what they spoke about, but Ohr claimed that he did not advise Steele or Simpson that he met with McCabe and Lisa Page. 6. Ohr 's November 2016 Communications with the FBI and State Department Regarding Steele

As described in Chapter Six, Handling Agent 1 determined that Steele should be closed as a CHS on November 1, 2016, following the October 31 publication of the Mother Jones article. Handling Agent 1 told us that he spoke with Ohr that same day and recommended to Ohr that he read the article. According to Handling Agent 1, as a courtesy, he told Ohr that he was not engaging with Steele anymore, warned Ohr to be careful when dealing with Steele, and said that Steele could not be trusted.

Ohr said that he did not recall whether Handling Agent 1 informed him that Steele was closed as a CHS during the November 1 telephone call, but remembered Handling Agent 1 telling him that he would no longer be working with Steele because Steele spoke to the press. Ohr told the OIG that he was not surprised that Steele talked to the press because he knew that Steele and Simpson were collecting the information for political purposes and that they had previously talked to others about it. According to Ohr, his understanding was that Steele was not collecting the information for the U.S. government, so he was not functioning as an FBI source.

Handling Agent 1 met with Ohr 1 week later in Washington, D.C.. According to Handling Agent 1, Ohr apologized for introducing him to Steele and said that he had not realized the impact of the Mother Jones article. Ohr told us that he recalled meeting Handling Agent 1 and discussing the FBI 's closure of Steele as a CHS. He also said that Handling Agent 1 told him that the FBI wanted to interview Ohr about his contacts with Steele.

On the morning of November 21, 2016, at the State Department 's request, Ohr met with Deputy Assistant Secretary Kathleen Kavalec and several other senior State Department officials regarding State Department efforts to investigate Russian influence in foreign elections and how the Department of Justice might assist those efforts. During a break in this meeting, Ohr and Kavalec discussed together Kavalec 's interactions with Steele. Ohr told us that he could not recall how he discovered that Kavalec knew Steele or how he and Kavalec began discussing Steele. Ohr also stated that he recalled meeting with Kavalec on more than one occasion because Ohr was interested in obtaining relevant information about Steele from Kavalec so that he could share it with the FBI 's Crossfire Hurricane team. We asked Ohr if he provided Kavalec with any of the information Steele or Simpson shared with him during these conversations. He said that he could not recall.

Kavalec told us that she could not recall the specifics of her conversations with Ohr regarding Steele. She stated that, just before or after the November 21, 2016 meeting, she asked Ohr if he knew Steele. Kavalec said that she generally shared with Ohr the information that Steele had provided, and she said Ohr appeared to be aware of it already. She told us that Ohr responded that Steele 's information was" kind of crazy... kind of wild... quite a tale.'' She told us that she provided this information to Ohr believing that he would pass it along to whoever needed it. Kavalec said that she did not specifically ask Ohr to do anything with the information and did not expect to receive any feedback from Ohr.

Later on November 21, 2016, in a meeting previously arranged by Lisa Page at Strzok 's request, Ohr met with Lisa Page, Strzok, SSA 1, the Office of the General Counsel( OGC) Unit Chief, and the Chief of the Counterintelligence Division 's( CD) Counterintelligence Analysis Section I( Intel Section Chief). Strzok, the OGC Unit Chief, SSA 1, and the Intel Section Chief told us the purpose of the meeting was to better understand Steele 's background and reliability as a source and to identify his source network.

Notes taken by meeting participants indicate that Ohr shared the following information:

• Ohr thought Steele had" great expertise'' concerning Russia;

• Steele wrote well-sourced reports using a variety of sub-sources that he wrote for other purposes and shared with the FBI;

• Steele had participated in past efforts to connect Ohr to Russian oligarchs through intermediaries;

• Simpson hired Steele to research Trump and hired Nellie Ohr to perform open source research on Trump;

• Ohr met with Simpson in August 2016 and Simpson provided Ohr with the names of three" potential conduits'' of information between Russia and the Trump campaign;

• Steele 's reporting was shared by Simpson with" a lot of people'' including the Clinton campaign and the Department of State;

• Steele was" desperate'' that Trump not be elected, but was providing reports for ideological reasons, specifically that" Russia[ was] bad;'' and

• Reporting of Kremlin activities" may be exaggerated or conspiracy theory talk,'' so Steele can not know whether all the reporting is true.

According to Ohr, he asked the FBI personnel whether there was a prosecutor assigned to their investigation and was told" no.'' He also said that no one at the meeting told him about the Crossfire Hurricane investigation, but that he was advised that the FBI was" pushing ahead'' on a Manafort case.

SSA 1 memorialized the meeting with Ohr in an FD-302, which largely mirrored the attendees ' notes, but also provided additional details. SSA 1 documented in the FD-302 that Ohr told the FBI that:

• Steele was" desperate that Donald Trump not get elected and was passionate about him not being the U.S. President;''

•" Ohr never believed Steele was making up information or shading it;''

•" Simpson and Steele could have met with[ Yahoo] or[ Yahoo News reporter] jointly, but Ohr[ did] not know if they did;'' and

• Ohr" knew'' that Simpson was" hired by a lawyer who does opposition research'' and that Steele 's reporting was being distributed to" the Clinton Campaign, Jon Winer at the U.S. State Department and the FBI.''

The FD-302 also documented that Ohr provided the FBI with copies of the notes he took about the meetings with Steele on July 30, 2016, and in late September 2016. The FBI did not insert this FD-302 into Steele 's closed CHS file.

SSA 1 told us that no one in the meeting directed Ohr to contact Steele or take any action on behalf of the FBI, but added that Ohr likely left the meeting with the impression that he should contact the FBI if Steele contacted him. When asked if the FBI provided him any guidance on what to do if Steele contacted him, Ohr stated that" the general instruction was to let them know... when I got information from Steele,'' though he could not recall who told him this or whether he was told this at the October 18 or November 21 meeting. Ohr told us that SSA 1 became his initial FBI point of contact when Ohr sought to provide more of Steele 's information to the FBI.

7. Ohr 's December 2016 Meetings with the FBI and Simpson

On December 5, 2016, Ohr had a follow-up interview with SSA 1 concerning his contacts with Steele and Simpson. During the interview, Ohr told SSA 1 that Simpson directed Steele to speak to the press, which was part of what Simpson was paying Steele to do, but that Ohr did not know whether speaking with Mother Jones was Simpson 's idea or not. Additionally, according to the FD-302, Ohr gave SSA 1 a document that Nellie Ohr had created, titled" Manafort Chronology'' and told SSA 1 that he would provide the FBI with additional research compiled by Nellie Ohr while working for Fusion GPS.

Ohr told us that he did not recall when or why Nellie Ohr provided him with the Manafort Chronology, but pointed to the July 2016 breakfast with Steele as a possible reason she provided it to him. Nellie Ohr told us that she offered Ohr her Fusion GPS research at the end of September 2016, which included the Manafort Chronology, in an effort to supplement what she believed Ohr would tell the FBI after the July 30 meeting with Steele.

On December 7, 2016, Ohr convened an interagency meeting( including representatives from the FBI) regarding strategy in dealing with Russian Oligarch 1. One of Ohr 's junior Department colleagues who attended the meeting told us that, after the meeting, she talked with Ohr about why the U.S. government would support trying to work with Russian Oligarch 1. Ohr 's colleague said that Ohr told her that Steele provided information that the Trump campaign had been corrupted by the Russians. The colleague told us that she asked Ohr if the allegations went" all the way to the President'' and that Ohr responded" yes.'' She told us that Ohr said to her that this information was" the basis for the[ Russian Oligarch 1] discussion.'' Ohr told us he recalled telling his colleague generally about the information he received from Steele, but said he could not recall when he told her or what prompted him to do so.

According to Ohr 's telephone log, Ohr called Simpson on December 8 and arranged a time to meet, but Ohr told us he could not recall why he contacted Simpson. Ohr said that he met with Simpson on December 10, 2016, and that Simpson gave him a thumb drive. Ohr stated that Simpson did not tell him what was on the thumb drive and that Ohr did not ask him, but that Ohr believed it contained Steele 's election reports. In testimony to the House Permanent Select Committee on Intelligence, Simpson stated that Ohr requested that he provide information regarding Steele 's election reporting.

Ohr stated, and his contemporaneous notes reflect, that Simpson told him during the meeting that Trump 's attorney, Michael Cohen, was an intermediary between the Russian government and the Trump campaign and had replaced Manafort and Carter Page as intermediaries. According to Ohr 's notes, during the meeting Simpson referenced several other alleged links between the Trump campaign and the Russian government. Ohr 's notes show that Simpson told Ohr that Simpson" still thinks[ Person 1] is a key figure connecting Trump to Russia.'' Additionally, Ohr 's notes reflect that Simpson told Ohr that it was Simpson who asked Steele to speak with the Mother Jones reporter as a" Hail Mary attempt.''

On December 11, 2016, Simpson forwarded an article to a personal email account shared by Ohr and his wife( which Nellie Ohr forwarded to Ohr 's Department email account) about a Russian senator 's possible support of Trump. The next day, December 12, Simpson wrote another email, this time requesting to speak with Ohr on the telephone. According to Ohr 's telephone log, he spoke with Simpson that same day, but Ohr could not recall what he and Simpson discussed.

Also on December 12, Ohr met with SSA 1 and told SSA 1 that Simpson had explained to Ohr that it was Simpson who asked Steele to speak with the Mother Jones reporter as a" Hail Mary attempt'' to stop Trump from being elected. Ohr also gave SSA 1 the thumb drive that he had received from Simpson during their December 10 meeting.

On December 20, 2016, Ohr provided SSA 1 with another thumb drive, this one containing open source research that Nellie Ohr had produced for Fusion GPS. Nellie Ohr stated that after the July 30, 2016 brunch, she understood that Ohr was going to talk to the FBI" on request of Steele'' and so she provided her work product to her husband at the end of September 2016 as she finished working for Fusion GPS. Ohr told us he could not recall when Nellie Ohr provided him with her research. According to Nellie Ohr, she removed the Fusion GPS headers from her research because she had not asked Simpson for permission to provide the reports to the FBI and wanted the reports to stand on their own merit.

B. Ohr 's Continued Contacts with Steele and Simpson from January to November 2017

In 2017, Ohr 's written communications with Steele transitioned from emails using Ohr 's Department email account to communications using an encrypted electronic messaging forum. Ohr provided the OIG with a transcript of his encrypted electronic communications with Steele, dating from January 25 to November 27, 2017, and his notes from their conversations. These documents indicate that Ohr and Steele communicated multiple times in 2017 and that Ohr typically informed the FBI of those communications shortly thereafter. The FBI 's interviews with Ohr between January and mid-May 2017 were summarized in nine FD-302s, which we discuss below.

During this timeframe, Ohr 's FBI point of contact changed. As described in Chapter Three, SSA 1 rotated off the Crossfire Hurricane team in January 2017, and SSA 3 became Ohr 's FBI point of contact until April 2017. From approximately May to June 2017, SSA 4 became Ohr 's third point of contact. An agent from the Special Counsel 's Office became Ohr 's final point of contact through November 2017.

In January 2017, Steele expressed concerns to Ohr that the media would identify, and therefore endanger, his employee and the employee 's sub-sources. Ohr conveyed Steele 's concerns to SSA 3 and SSA 4 several times in the early months of 2017. Steele told us that it was clear to him that Ohr was a conduit to the FBI. He said that Ohr told him that he had talked to the FBI about his concern for his sources ' safety, and the FBI had offered to help.

At the end of January 2017 and aware that President Trump had removed Acting Attorney General Sally Yates, Steele asked Ohr for an FBI contact if Ohr were to leave the Department. Ohr provided Steele 's concerns to the FBI and, on February 6, 2017, SSA 3 and Case Agent 8 requested Ohr to ask Steele if he would be willing to talk to the FBI again.

On February 14, 2017, Ohr shared with SSA 3 and Case Agent 8 information on topics Steele was working on for different clients, unrelated to Russia or Crossfire Hurricane. Ohr also informed the agents that he did not speak to Steele about re-engaging directly with the FBI. Ohr told us that the FBI 's offers to talk with Steele in early 2017 were for the purpose of assisting with an emergency with Steele 's sub-sources, but when the danger to the sub-sources passed, the need to re-engage disappeared.

On May 8, 2017, Ohr told SSA 4 and Case Agent 5 that Steele was willing to work with the FBI again. Ohr said that Steele had independently raised with Ohr the subject of re-engaging with the FBI. On May 12, 2017, SSA 4 requested that Ohr ask Steele if he was willing to meet with FBI agents in Europe. According to Ohr, he contacted Steele, who agreed to talk with the FBI agents on May 15, 2017. This meeting did not take place, and, as discussed in Chapter Six, the FBI did not have contact with Steele until September 2017 when he was interviewed by agents assigned to the Special Counsel 's Office. Ohr told us he continued to communicate with Steele through the end of November 2017 and provided the details of those communications to the FBI, which primarily focused on Steele 's interest in being interviewed by the Special Counsel. However, the FBI did not memorialize any meetings its agents had with Ohr after the Crossfire Hurricane investigation was transferred to the Special Counsel 's Office in May 2017. Ohr told us that Steele stopped contacting him after Ohr 's name appeared in news articles at the end of 2017.

C. Ohr 's Lack of Notification to ODAG, NSD, and Others Regarding His Contacts with Steele, Simpson, and the FBI

Ohr stated that it was both his" duty as a citizen'' and a Department employee to provide Steele 's and Simpson 's allegations concerning Russian connections to the Trump campaign to the FBI. Ohr did not inform his supervisors or political leadership in ODAG that he was meeting with Steele, Simpson, or the FBI, and did not seek any ethics advice regarding these activities in light of his wife 's employment with Fusion GPS from October 2015 to September 2016.

Ohr told us that while he had the opportunities to do so, he did not advise ODAG 's political leadership of his interactions with Steele and Simpson, or of the information they provided and that he shared with the FBI, because he viewed the information as" raw'' and" unfinished'' Russian source information that the FBI needed to evaluate. Asked whether he instead considered informing a career employee within ODAG of the information, Ohr responded," I think if I told another ODAG person, then they might have said, well we just got to tell the DAG.'' Asked whether a factor in his reluctance to tell then DAG Yates was because she may have told him to stop speaking with Steele, Ohr responded," It may have been, yeah...'' He further stated that he did not want to stop talking to Steele because he was alarmed by the information he was receiving and believed he needed to get it to the FBI.

Ohr told Swartz about his meetings with Steele and Simpson and the information they had provided. Ohr told us that it was possible that he also told then Counsel to the Criminal Division Assistant Attorney General, Zainab Ahmad, and Chief of the Fraud Section, Andrew Weissmann, about his meetings with Steele, Simpson, and McCabe. When asked why he thought he may have told these Department employees as opposed to individuals in ODAG, Ohr stated he wanted" to get the information to career people... to evaluate it and figure out what to do.''

Weissmann told us that Ohr told him" nothing'' about the allegations Ohr received from Steele. Ahmad told us that Ohr did not provide her with detailed information about what Ohr was hearing from Steele and that Ohr only alluded to the fact that Steele had derogatory information about President-elect Trump.

Former members of ODAG leadership told us they were unaware of Ohr 's communications with Steele, Simpson, and the FBI at the time those communications were occurring. Former DAG Yates told the OIG that she was" stunned'' to learn through media reports in late 2017 that Ohr had engaged in these activities without telling her, and that she would have expected Ohr to inform her about his communications with Steele because they were outside of his area of responsibility and involved the Russia investigation. Yates added that she" would have hoped that[ Ohr and the FBI] would have both told me'' of Ohr 's meetings with Steele and the FBI. She further stated that Ohr 's activities needed to be coordinated with the overall Crossfire Hurricane investigation, which included ensuring that the chain of command at both the Department and FBI were jointly deciding what actions, if any, Ohr might take relating to the Russian interference investigation.

Yates told us that had she learned of Ohr 's activities as they were occurring, she would have ensured that all Department and FBI personnel involved in the investigation were informed and consulted. Specifically with respect to Ohr 's October 18, 2016 meeting with McCabe, Yates told us she expected Ohr to inform her of any meeting with someone at McCabe 's level, regardless of the subject matter, but especially about something" outside of[ Ohr 's] area'' of responsibility.

Then Principal Associate Deputy Attorney General Matthew Axelrod similarly told us that he would have expected to know about Ohr 's activities, communicating with Steele and providing information to the FBI, because these were not responsibilities assigned to Ohr and his activities related to a" sensitive'' matter. Axelrod said that if had he learned of Ohr 's activities as they were occurring, he would have asked questions and sought to determine whether the FBI could stop receiving Steele 's information through Ohr. Axelrod told us that he thought ODAG would have been uncomfortable with Ohr continuing to provide Steele 's information to the FBI. Then Associate Deputy Attorney General Scott Schools, who was the highest-ranking career official in the Department, and ODAG 's ethics advisor, stated that the FBI had a responsibility to fully report Ohr 's involvement to the Department 's National Security Division( NSD) and that Ohr had a duty to report his involvement to ODAG 's managers.

Dana Boente, who became Acting DAG when Yates was removed from the position on January 30, 2017, told us that he was" really surprised'' when he learned that Ohr had multiple conversations with Steele, particularly because Ohr had been a prosecutor and knew that an attorney should never talk to a potential witness without an agent being present. Boente stated that if he had learned about Ohr 's contacts with Steele while he was Acting DAG, he may have allowed Ohr to meet with Steele for the limited purpose of putting Steele in direct contact with an FBI agent.

Ohr also told the OIG that he did not approach anyone in NSD because he talked to Swartz, who once oversaw counterintelligence cases for the Department, and thought Swartz was in contact with NSD concerning" Russia stuff.'' Ohr also said that he did not know whether Swartz passed any of the information to NSD. Ohr said that, in hindsight, he thought he should have told people in ODAG and NSD about his communications with Steele and Simpson so that they could deal with the issues presented and so that Ohr could have guidance about how to proceed when communicating with Steele or Simpson. Swartz told us that he had no recollection of Ohr asking him to do anything with Steele 's information. Swartz further stated that he did not think he informed anyone in NSD about Steele 's information.
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