Steele dossier history
# Steele dossier history

The Steele dossier came into existence as a response to the need for opposition research on Donald Trump during the 2016 presidential campaigns and election. The Democratic National Committee (DNC) and Hillary Clinton campaign paid their lawyer, Marc Elias of Perkins Coie, for many duties, among them to do opposition research. Elias hired Fusion GPS to do the job, and they in turn hired Christopher Steele of Orbis Business Intelligence to get information on Trump's dealings with Russia. Elias established a "legal barrier" by acting as a "firewall" between Steele and the campaign, enabling the top Democratic leaders to deny any knowledge of Steele and the payments to Fusion GPS until after the election.

Steele prepared the dossier using reports from the 20-30 sources in his network of trusted and familiar sources. Among those sources, he also depended on one paid "collector" (also called a primary "subsource"), Igor Danchenko, who in turn had a number of unpaid and unwitting sub-subsources, some with excellent connections, including inside the Kremlin. Steele produced 17 reports between June and December 2016 and turned over copies of his reports to Fusion GPS as he produced them.

Because Steele's findings alarmed him greatly and had national security implications for both countries, he also passed his information to British and American intelligence agencies. Due to a two-month delay at the FBI's New York field office, copies of his first reports were not received by the FBI's Crossfire Hurricane team until September 19, 2016, long after July 31, when they had already opened their investigation into whether or not the Trump campaign was helping the Russians with their interference in the U.S. elections.

Although the existence of some form of Democratic opposition research became known to some journalists, because they lacked the ability to check Steele's sources, they would not report on anything from those early dossier reports, but there were two exceptions. Before the election, two news sources mentioned allegations that came from dossier reports. Steele had been in contact with both authors. These were a September 23, 2016, Yahoo! News article by Michael Isikoff that focused on Carter Page, and an article by David Corn on October 31, 2016, a week before the election, in Mother Jones magazine.

The Clinton campaign was unable to get much benefit from the opposition research as its revelations were unconfirmed before the election. Philip Bump wrote that the dossier "has never been shown to have informed the Clinton campaign's approach and that was not made public until shortly before Trump was inaugurated." Several key dossier allegations made in June 2016 were later corroborated by the January 2017 report by the Office of the Director of National Intelligence, namely that Vladimir Putin favored Trump over Hillary Clinton; that he personally ordered an "influence campaign" to harm Clinton's campaign and to "undermine public faith in the US democratic process"; that he ordered cyberattacks on both parties; and that many Trump campaign officials and associates had numerous secretive contacts with Russian agents. While Steele's documents played a significant role in initially highlighting the general friendliness between Trump and the Putin administration, the veracity of specific allegations is highly variable. Some have been publicly confirmed, others are plausible but not specifically confirmed, and some are dubious in retrospect but not strictly disproven.

On January 5, 2017, the chiefs of four U.S. intelligence agencies briefed President Obama about the existence of the dossier, and the next day they briefed President-elect Trump. On January 10, CNN reported on the meetings and BuzzFeed News then published the dossier in full.

The legacy of the dossier has been described. Glenn Simpson believes the dossier interrupted a planned renewal of relationships between the United States and Russia that was "not in the interest of the United States"; that it supported the existing FBI investigation into Russian interference; and that it furthered understanding of the hidden relationship between the Russian government and the Trump campaign. Jane Mayer believes the dossier is "perhaps the most controversial opposition research ever to emerge from a Presidential campaign", and Julian Borger described it as "one of the most explosive documents in modern political history".

## Two research operations and confusion between them

The opposition research conducted by Fusion GPS on Donald Trump was in two distinct operations, each with a different client. First were the Republicans, funded by The Washington Free Beacon. Then came the Democrats, funded by the DNC and the Clinton campaign.

* The Republican operation, from October 2015 to May 2016, focused on Trump's domestic business and entertainment activities; was performed by Fusion GPS; and used Wayne Barrett's files and public sources. Immediately after the publication of the dossier, the media sometimes falsely assumed that the dossier started as a product of this research, so the Free Beacon released this statement: "none of the work product that the Free Beacon received appears in the Steele dossier".
* The Democratic operation, from April 2016 to December 2016, was focused on Trump's Russian connections; was subcontracted to Steele/Orbis; and used Steele's own source network and public sources. Only this second operation produced the dossier.

From April to early May 2016, The Washington Free Beacon and the DNC/Clinton Campaign were independently both clients of Fusion GPS. This overlap contributed to the media's confusion.

### Republican operation does not produce dossier

In October 2015, before the official start of the 2016 Republican primary campaign, the founders of Fusion GPS were seeking political work and wrote an email to "a big conservative donor they knew who disliked Trump, [and] they were hired". He arranged for them to use The Washington Free Beacon, an American conservative political journalism website, for their general opposition research on several Republican presidential candidates, including Trump. It is primarily funded by Republican donor Paul Singer. The Free Beacon and Singer were "part of the conservative never-Trump movement". Although Singer was a big supporter of Marco Rubio, Rubio denied any involvement in Fusion GPS's initial research and hiring.

Early in their investigation, they received help from investigative reporter Wayne Barrett, who gave them his files on Trump. They contained findings about "Trump's past dealings, including tax and bankruptcy problems, potential ties to organized crime, and numerous legal entanglements. They also revealed that Trump had an unusually high number of connections to Russians with questionable backgrounds."

For months, Fusion GPS gathered information about Trump, focusing on his business and entertainment activities. When Trump became the presumptive nominee on May 3, 2016, the conservative donor stopped funding the research on him.

Due to media confusion over who produced the dossier, the Free Beacon issued a statement in October 2017 to debunk some false assumptions:

   All of the work that Fusion GPS provided to the Free Beacon was based on public sources, and none of the work product that the Free Beacon received appears in the Steele dossier. The Free Beacon had no knowledge of or connection to the Steele dossier, did not pay for the dossier, and never had contact with, knowledge of, or provided payment for any work performed by Christopher Steele. Nor did we have any knowledge of the relationship between Fusion GPS and the Democratic National Committee, Perkins Coie, and the Clinton campaign.

Although the source of the Steele dossier's funding had already been reported correctly over a year before, and the Free Beacon had issued a statement to this effect in October 2017, a February 2, 2018, story by the Associated Press (AP) contributed to confusion about its funding by stating that the dossier "was initially funded" by The Washington Free Beacon, so the AP posted a correction the next day: "Though the former spy, Christopher Steele, was hired by a firm that was initially funded by the Washington Free Beacon, he did not begin work on the project until after Democratic groups had begun funding it."

By the spring of 2016, researchers at Fusion GPS had become so alarmed by what they had already learned about Trump that they felt the need "to do what they could to keep Trump out of the White House".

### Democratic operation produces dossier

The second operation of opposition research was indirectly funded by the DNC and the Clinton campaign, working through their attorney of record, Marc Elias of Perkins Coie. In an October 2017 letter, Perkins Coie general counsel Matthew Gehringer described how, in March 2016, Fusion GPS approached Perkins Coie and, knowing the Clinton campaign and the DNC were its clients, inquired whether its clients wished to pay Fusion GPS "to continue research regarding then-presidential candidate Donald Trump, research that Fusion GPS had conducted for one or more other clients during the Republican primary contest." In April 2016, Elias hired Fusion GPS to perform opposition research on Trump.

Fusion GPS co-founder Glenn R. Simpson had some reservations, as he did not like the idea of helping Hillary Clinton. In an email, Simpson said, "The only way I could see working for HRC is if it is against Trump."

In June 2016, as part of its work for Perkins Coie, Fusion GPS hired Orbis Business Intelligence, a private British intelligence firm, to look into connections between Trump and Russia. Orbis co-founder Christopher Steele, a retired British MI6 officer with expertise in Russian matters, was hired as a subcontractor to do the job. Prior to his work on the dossier, Steele had been a paid informant for the FBI for information unrelated to the Russia investigation.

In total, Perkins Coie paid Fusion GPS $1.02 million in fees and expenses, of which Fusion GPS paid Orbis $168,000 to produce the dossier. The DNC and Clinton campaign disclosed the total amount paid to Perkins Coie on campaign finance reports. In March 2022, the Federal Election Commission (FEC) fined the DNC $105,000 and the Clinton campaign $8,000 for misreporting those fees and expenses as "legal services" and "legal and compliance consulting" rather than "opposition research".

Orbis was hired between June and November 2016, and Steele produced 16 reports during that time, with a 17th report added in December. The reports were like "prepublication notes" based on information from Steele's sources and were not released as a fully vetted and "finished news article". Steele believes 70–90 percent of the dossier is accurate, a view shared by Simpson.

Steele delivered his reports individually to Fusion GPS as one- to three-page numbered reports. The first report, dated June 20, 2016, was sent to Washington by courier and hand-delivered to Fusion GPS. The names of the sources were redacted and replaced with descriptions to help Fusion judge their credibility.

Luke Harding wrote:

   At first, obtaining intelligence from Moscow went well. For around six months—during the first half of the year—Steele was able to make inquiries in Russia with relative ease. It got harder from late July, as Trump's ties to Russia came under scrutiny. Finally, the lights went out. Amid a Kremlin cover-up, the sources went silent and information channels shut down.

Steele has said he soon found "troubling information indicating connections between Trump and the Russian government". According to his sources, "there was an established exchange of information between the Trump campaign and the Kremlin of mutual benefit". According to Harding, "Steele was shocked by the extent of collusion his sources were reporting", and told his friends: "For anyone who reads it, this is a life-changing experience." Steele felt what he had unearthed "was something of huge significance, way above party politics". American reporter Howard Blum described Steele's rationale for becoming a whistleblower: "The greater good trumps all other concerns."

On his own initiative, Steele decided to also pass the information to British and American intelligence services because he believed the findings were a matter of national security for both countries. In 2018, Steele told a UK parliamentary investigation that Theresa May's British government covered up the evidence he provided them of Trump's Russian ties and took no actions, and that Boris Johnson suppressed a report about the intelligence in the dossier that was prepared by Parliament's Intelligence and Security Committee. After long delay, the report was published on July 21, 2020.

According to Simpson's testimony, Steele, who enjoyed a good working reputation "for the knowledge he had developed over nearly 20 years working on Russia-related issues for British intelligence, approached the FBI because he was concerned that Trump, then a candidate, was being blackmailed by Russia, and he became "very concerned about whether this represented a national security threat". Steele believed the intelligence community "needed urgently to know—if it didn't already—that the next possible U.S. president was potentially under the sway of Russia".

In early July 2016, Steele called seasoned FBI agent Michael Gaeta, who was stationed in Rome, and asked him to come to London so he could show him his findings. Because he was assigned to the U.S. embassy in Rome, Gaeta sought and was granted approval for the trip from Victoria Nuland, who was then the Assistant Secretary of State for European and Eurasian Affairs. When he arrived in London on July 5, 2016, he met with Steele at his office, and he was given a copy of Steele's first report, dated June 20, 2016 (Report $80).^{:95}$ His reaction was "shock and horror". Alarmed by what he read, Gaeta remarked, "I have to show this to headquarters".

As Nuland later shared, "In the middle of July, when he [Steele] was doing this other work and became concerned, he passed two to four pages of short points of what he was finding and our immediate reaction to that was, 'This is not in our purview.' This needs to go to the FBI if there is any concern here that one candidate or the election as a whole might be influenced by the Russian Federation. That's something for the FBI to investigate." Shortly after, in July, the report was sent to an agent with expertise in criminal organizations and organized crime at the FBI's New York field office—essentially, the wrong person to handle a counterintelligence investigation. According to Nancy LeTourneau, political writer for the Washington Monthly, the report "was languishing in the FBI's New York field office" for two months, and "was finally sent to the counterintelligence team investigating Russia at FBI headquarters in Washington, D.C." in mid-September 2016.

In August 2016, the FBI asked Steele for "all information in his possession and for him to explain how the material had been gathered and to identify his sources". In October 2016, Steele "described the sources' access, but did not provide names" to the FBI. By August 22, 2017, Steele had provided them with the names of the sources for the allegations in the dossier.

Meanwhile, in the July to September time frame, according to The Washington Post, CIA Director John Brennan had started an investigation with a secret task force "composed of several dozen analysts and officers from the CIA, the NSA and the FBI". At the same time, he was busy creating his own dossier of material documenting that "Russia was not only attempting to interfere in the 2016 election, they were doing so in order to elect Donald Trump. ... [T]he entire intelligence community was on alert about this situation at least two months before [the dossier] became part of the investigation." The "Steele dossier has so far proven to be fairly accurate", LeTourneau wrote.

In early August, which was after the Crossfire Hurricane investigation was opened, Steele was summoned to Rome where he gave a full briefing to four American FBI officials about the report. At that time, he handed over the June 20 and July 26 reports.

During its intense questioning of Steele, the FBI mentioned their own discoveries of connections between the Trump campaign and Russia and asked Steele about Papadopoulos, but he said he knew nothing about him. The agents "raised the prospect of paying Steele to continue gathering intelligence after Election Day", but Steele "ultimately never received payment from the FBI for any 'dossier'-related information". In October 2022, during questioning from Special Counsel John Durham, Brian Auten, a supervisory counterintelligence analyst with the FBI, testified that, shortly before the 2016 election, the FBI offered Steele "up to $1 million" if he could corroborate allegations in the dossier, but that Steele could not do so. Steele has disputed this description: "And to correct the Danchenko trial record, we were not offered $1 million by the FBI to ‘prove up’ our Trump-Russia reporting. Rather, we were told there were substantial funds to resettle sources in the US if they were prepared to testify in public. Understandably they were not."

The subsequent public release of the dossier stopped discussions between Steele and the FBI. Simpson testified that "Steele wasn't paid by the FBI, but was possibly reimbursed for a trip to Rome to meet with FBI officials." According to Mayer, Steele asked the FBI to cover his travel expenses to Rome, but he received nothing. The Inspector General's report later confirmed that the FBI had initially offered to pay Steele $15,000 for his trip to Rome, but when the FBI dropped Steele as a confidential human source because he had shared information with a third party "in late October 2016" (Mother Jones magazine), the payment was $halted.^{:173}$ Peter Strzok reported that:

   the FBI closed Steele "because he was a control problem. We did not close him because we thought he was [a] fabricator." According to Strzok, Steele's decisions to discuss his reporting with the media and to disclose his relationship with the FBI were "horrible and it hurt what we were doing, and no question, he shouldn't have done $it."^{:173}$

In September, Steele met with Jonathan Winer, who was then the U.S. deputy assistant secretary of state for international law enforcement, whom he had known since 2009. In a 2018 editorial for The Washington Post, Winer recounted that during their meeting in Washington, he was allowed to review Steele's reports, but not to keep a copy: "I prepared a two-page summary and shared it with [Victoria] Nuland, who indicated that, like me, she felt that the secretary of state needed to be made aware of this material," he wrote. Later in September, Winer discussed the report with Sidney Blumenthal, who revealed he had received similar information from Cody Shearer, a controversial political activist and former journalist who was close to the Clinton White House in the 1990s. Winer met with Steele again in late September and gave him a copy of Shearer's report, later known as the "second dossier".

On September 19, 2016, after the report had been "languishing in the FBI's New York field office" for two months, Steele's handling agent sent six of Steele's reports (80, 94, 95, 100, 101, and 102) to the Crossfire Hurricane team, that had been operational since July 31, 2016. This was the first time they and their leader, Deputy Assistant Director of the FBI's Counterespionage Section, Peter Strzok, received any of Steele's $reporting.^{:100}$ Strzok cautioned his colleagues. He wrote the dossier "'should be viewed as intended to influence as well as to inform' and whoever commissioned it was 'presumed to be connected to the [Clinton] campaign in some way.'" Some reports referred to members of Trump's inner circle. After that point, he continued to share information with the FBI. The IG Report says this material "became an important part of the Crossfire Hurricane investigation and the FBI seeking FISA authority targeting one of the Crossfire Hurricane subjects, Carter $Page."^{:80}$

On October 28, 2016, days before the election, Comey notified Congress that the FBI had started looking into newly discovered Hillary Clinton emails. Simpson and Fritsch described their reaction: "Comey's bombshell prompted the Fusion partners to decide they needed to do what they could to expose the FBI's probe of Trump and Russia. It was Hail Mary time." The founders of Fusion GPS were very upset by a misleading November 1, 2016, New York Times article "published a week before the election with the headline: 'Investigating Donald Trump, FBI Sees No Clear Link to Russia'. In fact, Russia was meddling in the election to help Trump win, the U.S. intelligence community would later conclude."

Simpson later said that "Steele severed his contacts with [the] FBI before the election following public statements by the FBI that it had found no connection between the Trump campaign and Russia and concerns that [the FBI] was being 'manipulated for political ends by the Trump people'." Steele had become frustrated with the FBI, whom he believed failed to investigate his reports, choosing instead to focus on the investigation into Clinton's emails. According to The Independent, Steele came to believe there was a "cabal" inside the FBI, particularly its New York field office linked to Trump advisor Rudy Giuliani, because it blocked any attempts to investigate the links between Trump and Russia.

## What the DNC, Clinton campaign, and Steele knew

According to Fusion GPS's co-owners, Glenn Simpson and Peter Fritsch, they did not tell Steele who their ultimate clients were, only that Steele was "working for a law firm", and they "gave him no specific marching orders beyond this basic question: 'Why did Mr. Trump repeatedly seek to do deals in a notoriously corrupt police state that most serious investors shun?'" In testimony to the Senate Intelligence Committee, Simpson said that "it was Fusion GPS's idea to pursue overseas ties—that research was not directed by Perkins Coie, the DNC, or the Clinton Campaign".

Jane Mayer reported that when the Clinton campaign "indirectly employed" Steele, Elias created a "legal barrier" by acting as a "firewall" between the campaign and Steele. Thus, any details were protected by attorney–client privilege and work-product privileges. "Fusion briefed only Elias on the reports, Simpson sent Elias nothing on paper—he was briefed orally", Mayer reported. In its application for a FISA warrant to survey Carter Page, the Department of Justice told the FISC that Simpson had not informed Steele of the motivation behind the research into Trump's ties with Russia. Steele testified to Congress that he did not know the Clinton campaign was the source of the payments "because he was retained by Fusion GPS". By "late July $2016",^{:93–94}$ "several months" after signing the contract with Fusion GPS, Steele became aware that the DNC and the Clinton campaign were the ultimate clients.

A spokesperson for the DNC said neither Tom Perez nor "the new leadership of the DNC were ... involved in any decision-making regarding Fusion GPS, nor were they aware that Perkins Coie was working with the organization." A spokesperson for Perkins Coie said the campaign and the DNC were unaware Fusion GPS "had been hired to conduct the research". The Washington Post reported that it is not clear how much of the research Elias received from Fusion GPS he shared with the campaign and the DNC. It is also not clear who in those organizations knew about the roles of Fusion GPS and Steele, but one person "close to the matter" said the organizations were "not informed by the law firm of Fusion GPS's role". The New York Times revealed that earlier in 2017, "Mr. Elias had denied that he had possessed the dossier before the election." The Clinton campaign did not know about Steele or that he was sharing his findings with the FBI, and "one top Clinton campaign official" told Jane Mayer that "If I'd known the F.B.I. was investigating Trump, I would have been shouting it from the rooftops!"

The firewall was reportedly so effective even campaign principals John Podesta and Robby Mook did not know Steele was on the Democratic payroll until Mother Jones reported on the issue on October 31, 2016, in an article that did not name Steele. When the Mother Jones story broke, John Podesta, chairman of the Clinton campaign, said he was "stunned by the news that the FBI had launched a full-blown investigation into Trump, especially one that was informed by research underwritten by the Clinton campaign." Although they knew Perkins Coie had spent money for opposition research, neither Podesta nor campaign manager Robby Mook knew Steele was on the Democratic payroll. Mayer said they both maintain they "didn't read the dossier until BuzzFeed posted it online". She has also said that "the Clinton campaign never learned that Christopher Steele was on their payroll until it [the dossier] was in the press." "Far from a secret campaign weapon, Steele turned out to be a secret kept from the campaign." In their 2019 book, the founders of Fusion GPS wrote "that no one from Fusion ever met or talked with Clinton and that she herself 'had no idea who they were'."

Philip Bump wrote that the dossier "has never been shown to have informed the Clinton campaign's approach and that was not made public until shortly before Trump was inaugurated."

On February 15, 2022, The Washington Post reported: "So far, there is no evidence that the Clinton campaign directly managed the Steele reporting or leaks about it to the media."

## Hints of existence

When Fusion GPS first hired Steele, "they thought that 'no one would ever find out' about the discreet work Steele would perform. That prediction proved naive", and the founders of Fusion GPS have described how they soon did not hide the fact that they were researching Trump and Russia: "Fusion and Steele tried to alert U.S. law enforcement and the news media to the material they'd uncovered. The firm's office in Washington's Dupont Circle neighborhood became 'something of a public reading room' for journalists seeking information about Trumpworld." In September they arranged private meetings at the Tabard Inn, in Washington, D.C., between Steele and reporters from The Washington Post, The New York Times, The New Yorker, ABC News, and other outlets. Jane Mayer attended one of the meetings. None of these news organizations ran any stories about the allegations at that time.

Although BuzzFeed was not invited to these meetings, Ben Smith, editor of BuzzFeed, wrote that "We were hardly the first journalists to get the document—but we may have been the first to get it without promising to keep it secret...[the journalists at the Tabard Inn meetings] had promised Simpson that they wouldn't write about the dossier itself, its author, or its path through the American government, [and] they couldn't report on these things either."

BBC correspondent Paul Wood was allowed to see "a dozen" pages of the dossier in October 2016.

Before the election, only two news sources mentioned allegations that came from dossier reports. Steele had been in contact with both authors. These were a September 23, 2016, Yahoo! News article by Michael Isikoff that focused on Carter Page, and an article by David Corn on October 31, 2016, a week before the election, in Mother Jones magazine.

At the time, the FBI had assumed that the source for the Yahoo! article was someone, other than Steele, "who had received a copy of the dossier". The 2019 DOJ report by Michael Horowitz criticized the FBI for failing to ask Steele if he had a role in that Yahoo! article.

### Mother Jones story

By the third quarter of 2016, many news organizations knew about the existence of the dossier that had been described as an "open secret" among journalists but chose not to publish information they could not confirm. Mother Jones was the first to report the existence of the dossier and that it was exclusively funded by Democrats.

By October 2016, Steele had compiled 33 pages (16 reports), and he then passed on what he had discovered to David Corn, a reporter from Mother Jones magazine. On October 31, 2016, a week before the election, Mother Jones reported that a former intelligence officer, whom they did not name, had produced a report based on Russian sources and turned it over to the FBI. The article disclosed some of the dossier's allegations:

   The first memo, based on the former intelligence officer's conversations with Russian sources, noted, "Russian regime has been cultivating, supporting and assisting TRUMP for at least 5 years. Aim, endorsed by PUTIN, has been to encourage splits and divisions in western alliance." It maintained that Trump "and his inner circle have accepted a regular flow of intelligence from the Kremlin, including on his Democratic and other political rivals". It claimed Russian intelligence had "compromised" Trump during his visits to Moscow and could "blackmail him". It also reported that Russian intelligence had compiled a dossier on Hillary Clinton based on "bugged conversations she had on various visits to Russia and intercepted phone calls".

## Post-election events

After Trump's election on November 8, 2016, the Democratic client stopped paying for the investigation, but Steele continued working on the dossier for Fusion GPS. According to The Independent, at that time, Simpson "reportedly spent his own money to continue the investigation". According to The New York Times, after the election, Steele's dossier became one of Washington's "worst-kept secrets", and journalists worked to verify the allegations.

On November 18, 2016, Republican Senator John McCain, who had been informed about the alleged links between the Kremlin and Trump, met with former British ambassador to Moscow Sir Andrew Wood at the Halifax International Security Forum in Canada. Wood told McCain about the existence of the collected materials about Trump, and also vouched for Steele's professionalism and integrity.

According to Simpson's August 22, 2017, testimony to the Senate Judiciary Committee, Steele and David J. Kramer, a longtime McCain aide and former U.S. State Department official working at Arizona State University, met each other at the Halifax forum and discussed the dossier. Kramer told Steele that McCain wanted to "ask questions about it at the FBI. ... All we sort of wanted was for the government to do its job and we were concerned about whether the information that we provided previously had ever, you know, risen to the leadership level of the FBI."

Steele had agreed with Fusion GPS to deliver a hard copy of all 16 reports to McCain, that McCain received in early December from Kramer. On December 9, McCain met personally with FBI Director James Comey and gave him a copy of the dossier. On March 25, 2019, Senator Lindsey Graham, a close friend of McCain's, contradicted Trump's attacks against McCain and revealed that when McCain showed him the dossier, he had encouraged McCain to give the dossier to the FBI and that McCain acted appropriately. Graham described how he confronted Trump: "Senator McCain deserves better. There were some McCain people who took a piece of garbage and tried to go after Trump after the election. But I told the president it was not John McCain." Comey later confirmed that counterintelligence investigations were underway into possible links between Trump associates and Moscow.

After delivering his 16 reports to McCain, Steele received more information and composed the two-page "December memo", dated December 13. It mostly contained allegations against Trump's personal attorney, Michael Cohen, that Cohen later denied. In an April 2017 court filing, Steele revealed previously unreported information that he had given a copy of his last report to a "senior UK government national security official acting in his official capacity, on a confidential basis in hard copy form", because it "had implications for the national security of the US and the UK".

Both Simpson and Steele have denied providing the dossier to BuzzFeed. Unsealed documents from the discovery process in Russian entrepreneur Aleksej Gubarev's defamation lawsuit revealed that David Kramer, an associate of John McCain, gave the dossier to BuzzFeed "in December 2016, weeks after the election", in what Fritsch has called an "ill-advised" Hail Mary pass. Ben Smith, editor of BuzzFeed has described how they got the dossier:

   On December 29, the Republican foreign-policy expert David Kramer invited Ken [Bensinger] to his office at the McCain Institute. He then did something careful Washington insiders do: He left Ken alone in the room with the document for 20 minutes, without, in Ken's view, giving clear instructions about whether he could make a copy. Ken took a picture of every page. (Kramer later denied that he'd allowed Ken to copy it...)

It was never intended that the dossier be public because it was unfinished raw intelligence and could have "compromised sources and methods". Steele was also worried about the safety of his source network, and he expressed concern that if Trump won the election, the new FBI director, and other agency heads appointed by Trump, might be more loyal to Trump "and could decide to take action against Steele and his source $network".^{:275}$

### Briefings of Obama and Trump

On January 5, 2017, the chiefs of four U.S. intelligence agencies briefed President Barack Obama and Vice President Joe Biden about the Russian interference in the election and the existence of the dossier and its allegations.

On the $afternoon^{:180}$ of January 6, 2017, President-elect Trump and his transition team received a similar briefing in Trump Tower. All four of the top intelligence chiefs met with Trump and his transition team. They were Director of National Intelligence James Clapper, FBI Director James Comey, CIA Director John Brennan, and NSA Director Admiral Mike Rogers. They informed Trump of the Russian election interference, and Comey told them of "a piece of Steele's reporting that indicated Russia had files of derogatory information on both Clinton and the $President-elect".^{:180}$

Then, according to a pre-arranged plan, Brennan, Clapper, and Rogers left, and Comey then asked to speak with Trump alone. Comey then informed Trump of the dossier and its allegations about salacious tapes held by the Russians. Comey later reported he was very nervous. The previous day, the secretary of the Department of Homeland Security told Comey to "be very careful", "choose your words carefully", and then "get outta there". Trump became very defensive, and Comey described the meeting as "really weird". Trump later expressed that he felt James Comey was trying to blackmail him at the meeting in Trump Tower, held two weeks before the inauguration. In April 2018, Comey said he did not inform Trump the dossier was partly funded by Democrats because that "wasn't necessary for my goal, which was to alert him that we had this information".

The Mueller Report, published on April 18, 2019, contains a footnote that suggests that Trump may have heard that Russia had incriminating tapes of his behavior. On October 30, 2016, Michael Cohen received a text from Giorgi Rtskhiladze reporting that he had successfully stopped the "flow of tapes from Russia". Rtskhiladze told investigators that these were compromising tapes of Trump, and Cohen told investigators he had spoken to Trump about the issue. Rtskhiladze later told investigators "he was told the tapes were fake, but he did not communicate that to Cohen".

On December 14, 2018, the FBI released a document called "Annex A", that was "part of [the] Russia dossier summary" used to brief Trump and Obama. The FBI withheld parts of the synopsis on the grounds that it remained classified and "because it pertains to ongoing investigations or court proceedings, originated with a confidential source or describes confidential investigative techniques or procedures".

Two days after the publication of the dossier on January 10, 2017, James Clapper issued a statement describing the leaks in the press about their Trump Tower meeting with Trump as damaging to U.S. national security. The statement also included the non-committal wording that the U.S. intelligence community "has not made any judgment that the information in this document is reliable, and we did not rely upon it in any way for our conclusions". This contradicted Trump's previous claim that Clapper had said the information in the dossier was false; Clapper's statement actually said the intelligence community had made no judgment on the truth of the information.

James Comey disagreed with Clapper's wording, but Clapper's wording remained unchanged. Comey later told the Office of the Inspector General of his concerns at that time, because he believed the dossier to be more reliable than indicated in Clapper's non-committal statement:

   I worry that it may not be best to say "The IC has not made any judgment that the information in the document is reliable." I say that because we HAVE concluded that the source [Steele] is reliable and has a track record with us of reporting reliable information; we have some visibility into his source network, some of which we have determined to be sub-sources in a position to report on such things; and much of what he reports in the current document is consistent with and corroborative of other reporting included in the body of the main IC report. That said, we are not able to sufficiently corroborate the reporting to include in the body of the [ICA] report. (p. 181)

## Publication by BuzzFeed News and reactions

On January 10, 2017, CNN reported that classified documents presented to Obama and Trump the previous week included allegations that Russian operatives possess "compromising personal and financial information" about Trump. CNN said it would not publish specific details on the reports because it had not "independently corroborated the specific allegations". Following the CNN report, BuzzFeed published a 35-page draft dossier that it said was the basis for the briefing, including unverified claims that Russian operatives had collected "embarrassing material" involving Trump that could be used to blackmail him. BuzzFeed said the information included "specific, unverified, and potentially unverifiable allegations of contact between Trump aides and Russian operatives".

The New York Times commented: "Mr. Steele has made clear to associates that he always considered the dossier to be raw intelligence—not established facts, but a starting point for further investigation." Judge Craig Karsnitz described the purpose of the dossier: "An intelligence report is simply a report of information potentially relevant to an investigation. It can take many forms, be true or false, and can be used as opposition research and an intelligence report." Christopher Burrows, co-founder of Orbis Business Intelligence, does not consider it a "dossier", but "information that is referred to as 'raw intelligence' in intelligence circles. ... a mixture of knowledge, rumor and hearsay. ... [A]n intelligence agency would enrich the findings with data, test probabilities and write analyses. It's an elaborate process. But Steele is not an intelligence agency."

BuzzFeed's decision to publish the dossier was immediately criticized by many major media outlets for releasing the draft dossier without verifying its allegations. Washington Post columnist Margaret Sullivan called it "scurrilous allegations dressed up as an intelligence report meant to damage Donald Trump", while The New York Times noted that the publication sparked a debate centering on the use of unsubstantiated information from anonymous sources. BuzzFeed's executive staff said the materials were newsworthy because they were "in wide circulation at the highest levels of American government and media" and argued that this justified public release. A judge in the Superior Court of the District of Columbia agreed with this reasoning when he threw out a libel suit against Steele and Orbis Business Intelligence.

Although the Columbia Journalism Review had originally (January 11, 2017) backed BuzzFeed's publication of the dossier, and editor Kyle Pope had tweeted his support of that decision, he later (November 17, 2021) described it as "a document that was never designed to meet the standards of good journalism", noting that its credibility had collapsed, and concluding that it was the source of "a lot of nonsense and misdirection" in subsequent media coverage and should not have been published at all. Sara Fischer, media reporter for Axios, was critical of the initial press coverage of the dossier before it had been adequately scrutinized.

The draft dossier's publication by BuzzFeed has always been defended by Jack Shafer, Politico's senior media writer, as well as by Richard Tofel of ProPublica and the Columbia Journalism Review. Shafer defended the public's right to know about the allegations against Trump, and saw a parallel in Judge Ungaro's ruling in the defamation suit filed by Aleksej Gubarev. Ungaro wrote that the "privilege exists to protect the media while they gather information needed for the public to exercise effective oversight of the government". She also noted that, before the FBI received any reports from Steele, they had "already opened a counterintelligence investigation into links between Russia and the Trump campaign".

In relation to a defamation lawsuit filed by Gubarev against BuzzFeed regarding their publication of the draft dossier, Senior Master Barbara Fontaine said Steele was "in many respects in the same position as a whistle-blower" because of his actions "in sending part of the dossier to Senator John McCain and a senior government national security official, and in briefing sections of the US media". She said that "it was not known who provided the dossier to BuzzFeed but Mr Steele's evidence was that he was 'horrified and remains horrified' that it was published at all, let alone without substantial redactions."

The founders of Fusion GPS felt so alarmed by what sources reported to Steele that they have defended the fact that they and Steele used intermediaries to pass dossier content to the authorities, but, regarding the publication by BuzzFeed, if it had been up to them, "Steele's reporting never would have seen the light of day." It was published without Steele's permission, and Christopher Burrows said: "We didn't expect the findings on Russia to reach the public."

They were also alarmed that the publication of the draft dossier would endanger sources, and Glenn Simpson immediately phoned Ken Bensinger at BuzzFeed: "Take those fucking reports down right now! You are going to get people killed!"

Steele wrote:

   I wonder if BuzzFeed have reflected on the lives and livelihoods they put at risk by publishing the dossier, or the shutter it has drawn down on any further collection efforts on this issue and others by anybody or any government agency. In my view BuzzFeed did the Kremlin's work for them because they were determined not to lose the scoop entirely after CNN broke the original story. One of the most irresponsible journalistic acts.

Six years after publishing the dossier, Ben Smith, editor of BuzzFeed, has described his regrets about how it was done:

   If I had to do it again, I would publish the dossier—we couldn't suppress it... But I would hold more tightly to the document... I wouldn't simply publish it as a PDF, destined to float free from our earnest caveats. At best, we could have published the document as screenshots attached to the context we had and the context we would learn. Perhaps in some small way, this would have limited its transformation from a set of claims into a banner of the 'resistance.' But I’m not under the illusion that journalists could have contained its wildfire spread, any more than I think we could have concealed it.

## Format

When BuzzFeed published the 35-page dossier in January 2017, the individual reports were one to three pages long, numbered, and page numbers 1–35 had been handwritten at the bottom. All but one had a typed date at the bottom. Each of the first 16 reports (pre-election memoranda) was assigned a typed number in the heading between 80 and 135, but the numeric order didn't always match the chronological order. The 17th report, known as the "December memo", was numbered 166. Of the original reports numbered 1–166, only certain reports were used for the dossier, and it is unknown what happened with the content of the other reports: "For example, the first report is labeled as '080', with no indication given as to where the original 79 antecedents might have gone. The second report is then labeled '086', creating yet another mystery as to 81 through 85, and what content they might contain that would otherwise bolster or contextualize what came before or what follows."

Each report started with a page heading in the same style as the first one shown here:

   COMPANY INTELLIGENCE REPORT 2016/080
   US PRESIDENTIAL ELECTION: REPUBLICAN CANDIDATE DONALD TRUMP'S ACTIVITIES IN RUSSIA AND COMPROMISING RELATIONSHIP WITH THE KREMLIN

Each report was in two parts, starting with a Summary section, followed by a Detail section. The Summary contained summary paragraphs based on numbered and expanded content and findings in the following Detail section.

## Legal status and comparison to Trump Tower meeting

The legal status of the dossier has been questioned, but, because of the legal difference between an "expenditure" by a campaign and a "contribution" to a campaign, it does not run afoul of Federal Election Commission laws (52 U.S. Code § 30121) forbidding foreign nationals from contributing to or aiding political campaigns, and that applies to any form of aid, not just cash donations. The dossier (prepared by a British citizen indirectly hired by the Clinton campaign and DNC) and the 2016 Trump Tower meeting (involving a direct offer of aid by the Russian government to the Trump campaign) are frequently contrasted and conflated in this regard.

Philip Bump has explained "why the Trump Tower meeting may have violated the law—and the Steele dossier likely didn't": "Hiring a foreign party to conduct research is very different, including in legal terms, than being given information by foreign actors seeking to influence the election. What's more, Trump's campaign did accept foreign assistance in 2016, as the investigation by special counsel Robert S. Mueller III determined."

The Trump Tower meeting involved a voluntary offer of aid ("a campaign contribution") to the Trump campaign from the Russian government, and the offer was thus illegal to accept in any manner. Already before the meeting, the Trump campaign knew the source and purpose of the offer of aid, still welcomed the offer, successfully hid it for a year, and when the meeting was finally exposed, Trump issued a deceptive press release about it.

By contrast, Steele's work was a legal, declared, campaign expense and did not involve any voluntary offer of aid to the Clinton campaign from the Russian government. FEC law allows such declared campaign expenditures, even if the aid is performed by foreigners.

Bump explains that:

   President Trump has deliberately and regularly conflated the two, arguing that the former meeting was innocuous and that the real malfeasance—the real collusion—was between Clinton's campaign and those Russians who were speaking to Steele. Trump is incorrect. There is no reason to think that Clinton's campaign is culpable for any illegal act related to the employment of Steele and good reason to think that the law was broken around the meeting at Trump Tower—and that members of the Trump team might face legal consequences.

Steven L. Hall, former CIA chief of Russia operations, has contrasted Steele's methods with those of Donald Trump Jr., who sought information from a Russian attorney at a meeting in Trump Tower in June 2016: "The distinction: Steele spied against Russia to get info Russia did not want released; Don Jr took a mtg to get info Russians wanted to give."

Jane Mayer referred to the same meeting and contrasted the difference in reactions to Russian attempts to support Trump: When Trump Jr. was offered "dirt" on Clinton as "part of Russia and its government's support for Mr. Trump", instead of "going to the F.B.I., as Steele had" when he learned Russia was helping Trump, Trump's son accepted the support by responding: "If it's what you say, I love it."

## Legacy

Glenn Simpson believes the dossier interrupted a planned renewal of relationships between the United States and Russia that was "not in the interest of the United States"; that it supported the existing FBI investigation into Russian interference; and that it furthered understanding of the hidden relationship between the Russian government and the Trump campaign. Jane Mayer believes the dossier is "perhaps the most controversial opposition research ever to emerge from a Presidential campaign", and Julian Borger described it as "one of the most explosive documents in modern political history".

T.A. Frank has described the dossier as a "case study" in media manipulation. In his 2021 book Spooked: The Trump Dossier, Black Cube, and the Rise of Private Spies, former New York Times journalist Barry Meier commented: "media organizations didn't conduct internal postmortems or public reconstructions about how they handle the dossier story [because] it would have required them to disclose the toxic relationship that had developed between journalists and private $spies."^{:242}$

Political journalist David Corn of the progressive magazine Mother Jones described the dossier as "a convenient foil, their false flag" for the "Trump gang":

   It was a clever ploy on the part of the Trump gang: Deny the unfounded—that Trump was caught on tape consorting with urinating prostitutes and that he conspired directly with Putin—to sidestep the damning reality that Trump and his aides betrayed the nation by both encouraging the Russian attack and trying to cover up Putin's sinister intervention.
