A Review of Various Actions by the Federal Bureau of Investigation and Department of Justice in Advance of the 2016 Election

Oversight and Review Division 18-04 June 2018

Attachment A

 

U.S. Department of Justice

Office of the Deputy Attorney General

Washington, D.C. 20530

Associate Deputy Attorney General

June 11, 2018

 

MEMORANDUM

TO: Michael E. Horowitz

Inspector General

U.S. Department o

 

FROM: Scott N. Schools

Associate Deputy Attorney General

Office of the Deputy Attorney General

 

 

SUBJECT: Response to “A Review of Various Actions by the Federal Bureau of

Investigation and Department of Justice in Advance of the 2016 Election”

 

The Department of Justice (Department) appreciates the review your office conducted

regarding various actions by the Federal Bureau of Investigation (FBI) and the Department in advance of the 2016 election and the resulting report of investigation. This response addresses only the report and recommendations as they pertain to the Department as the FBI is responding separately.

 

Based on the findings in the report, your office made six recommendations for the

Department to consider. The Department concurs in Recommendations 1-5 and 9 and will expeditiously consider taking steps in response to them.

 

cc: Hon. John Demers

Assistant Attorney General

National Security Division

 

Hon, Christopher Wray

Director

Federal Bureau of Investigation

Att
A Review of Various Actions by the Federal Bureau of Investigation and Department of Justice in Advance of the 2016 Election

Oversight and Review Division 18-04 June 2018

 

Attachment B

 

U.S. Department of Justice

Federal Bureau of Investigation

Washington, D.C. 20535-000/

June 12. 2018

Office of the Director

 

The Honorable Michael E. Horowitz

Inspector General

U.S. Department of Justice

Washington. D.C.

Dear Mr. Horowitz:

 

 

The Federal Bureau of Investigation (FBI) greatly values the opportunity to review

and respond to the fo rthcoming Report entitled ··A Review of Various Actions by the Federal

Bureau of Investigation and Department of Justice in Advance of the 2016 Election.” The FBI’s

formal response is enclosed, including a Law Enforcement Sensitive portion appended at the end.

The FBI recognizes and appreciates the importance of the Inspector General’s

oversight role and thanks you for the thoroughness of your Report and recommendations

regardi ng FBI actions and policies.

 

Enclosure

 

Sincerely yours,

Christopher A. Wray

 

 

FBI RESPONSE TO THE REPORT OF

THE DEPARTMENT OF JUSTICE’S OFFICE OF THE INSPECTOR GENERAL

The mission of the Federal Bureau of Investigation (FBI or Bureau) is to protect the

American people and uphold the Constitution of the United States. Within this mission, the FBI has certain priorities, including protecting the United States against terrorist attack, foreign intelligence operations and espionage, cyber-based attacks and high-technology crimes, combatting public corruption at all levels, protecting civil rights, and combating major criminal offenses. Sometimes, the investigations and operations conducted by the FBI in furtherance of its mission may cut against the personally held views of certain Special Agents and other employees supporting those cases. There is nothing inherently wrong with this; indeed, the Constitution contains robust protections for personally held and espoused beliefs and the freedom of association. The FBI endeavors to, and as reflected in the Department of Justice (DOJ) Office of the Inspector General’s (OIG) “A Review of Various Actions by the Federal Bureau of Investigation and Department of Justice in Advance of the 2016 Election” Report,

succeeds in its efforts, to maintain separation between personally held views and the actual work of the FBI. Nevertheless, proper oversight is required in order to ensure this separation remains effective, that the mission comes first regardless of personal view, that all investigations proceed objectively, and that the American people maintain their trust and confidence that the critically important work of the FBI remains unbiased and apolitical. The FBI appreciates the key role of the DOJ Office of the Inspector General (OIG) in the oversight process.

 

Below, the FBI sets forth a response to the findings and recommendations contained in

the OIG Report. The FBI recognizes that mistakes were made. These mistakes were errors of judgment, violations of or disregard for policy, or, when viewed with the benefit of hindsight, simply not the best courses of action. They were not, in any respect, the result of bias or improper considerations. Further, the OIG Report focuses on the conduct of several individuals acting in extraordinary and unprecedented circumstances. None of the actions or conduct faulted by the OIG impugn the integrity of the FBI as an institution, or of the Bureau’s dedicated 37,000-person workforce as a whole.

 

  1. Summary of FBI Response

The FBI identified eight (8) focal points, specific to the FBI, in the OIG Report: (1)

conduct creating a perception that political bias could have influenced certain actions or

decisions; (2) violation of or disregard for DOJ or FBI policies by former Director James

Comey’s July 5, 2016, announcement and October 28, 2016, letter; (3) issues involving media contacts, leaks, and ethics rules on acceptance of gifts; (4) former Deputy Director Andrew McCabe’s recusal obligations; (5) the use of personal email accounts; (6) missteps in certain investigatory processes; (7) insubordination by former Director Comey; and (8) the potentially improper use of FBI systems and devices to exchange messages, the related referrals for investigation, and the creation of additional warning banners and guidance.

The FBI’s accepts the OIG’s findings that certain text messages, instant messages, and

statements, along with a failure to consistently apply DOJ and FBI interview policies, were

inappropriate and created an appearance that political bias might have improperly influenced investigative actions or decisions. The Bureau also agrees with the OIG that, despite these errors.

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and the damage they may have caused to the FBI’s reputation, there was no evidence of bias or other improper considerations affecting the handling of the Midyear Exam (MYE) investigation.

The FBI is taking immediate remedial actions to reinforce the importance of maintaining a work environment free from the appearance of political bias. This includes a review of whether the intermixing of work-related discussions with political commentary implicates any of the FBI’s Offense Codes and Penalty Guidelines. It will further include political bias training, Hatch Act training, and, as applicable, will also include a review of how the FBI staffs, structures, and supervises sensitive investigations.

The FBI also accepts the OIG’s findings that former Director Comey’s July 5, 2016,

announcement violated DOJ’s media policy and may have violated regulations regarding the public release of information, and that his October 28, 2016, letter was a serious error in judgment. In the judgment of the OIG, there was no evidence that these actions were the result of bias, political preference, or an effort to influence the election. The Bureau takes seriously its obligations to control public statements, especially those related to charging recommendations in criminal investigations and uncharged conduct. Accordingly, the FBI has issued a revised media policy, will act to further ensure that all personnel are aware of the new policy and the serious consequences for non-compliance, and will provide further training on media contact and the limited authority to release information.

 

The OIG also identified a need to change the “cultural attitude” regarding media contacts

and leaks at the FBI. The Director has ordered the Office of Integrity and Compliance (OIC), the Office of the General Counsel (OGC), and the Office of Professional Responsibility (OPR) to review how personnel are trained rthose related to the acceptance of gifts, and whether current disciplinary penalties are adequate to

deter unauthorized media contact or leaks.

The OIG made several determinations regarding former Deputy Director McCabe’s

recusal from the Clinton-related investigations. Because he may not have fully complied with his voluntary recusal obligations, the FBI OIC has been instructed to review recusal policy and training, and make updates as necessary to help more quickly identify and mitigate actual or

perceived conflicts of interest.1 The FBI OGC and OIC have also been directed to work together to develop a framework for earlier notification of potential conflicts caused by campaign contributions to covered persons and to provide additional training on recusal obligations and conflicts of interest. The Director has called for the framework to be completed within 60 days.

Upon finding that former Director Comey, Lisa Page, and Peter Strzok used personal

email accounts for unclassified FBI business, the OIG referred Mr. Strzok for an investigation into whether his actions violated FBI and DOJ policies. This referral will be investigated and adjudicated pursuant to FBI and DOJ policies. While, there is no finding or indication that any classified material ever transited former Director Comey’s, Ms. Page’s, or Mr. Strzok’s personal devices or accounts, the FBI OGC and OIC have been tasked to evaluate whether additional training and messaging would reinforce the existing policies and protocols on the use of non-FBI

1 The OIG’s findings and recommendations related to other recusal issues and contained in the Law Enforcement Sensitive (LES) Appendix Two, are addressed separately in the appended LES response.

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devices and accounts and further minimize any non-compliance, and to report back to the

Director on their findings within 60 days.

The OIG concluded that certain MYE investigatory missteps were made. The FBI

accepts the OIG’s conclusions that, in hindsight, it could have taken additional or different investigatory actions, including moving more quickly to secure a search warrant for Anthony Weiner’s laptop, and staffing the investigation differently so as to avoid affecting the MYE investigation when senior members of the MYE team were assigned to the Russia investigation.

The FBI appreciates, however, that the OIG recognized that many of the identified missteps were judgment calls by seasoned investigators and prosecutors, and that there was no evidence thatany decision was made as the result of bias or other improper considerations. This includes the decision not to seek personal devices from former Secretary Clinton’s senior aides, the prioritization of the Russia investigation at the time, and the delay in seeking a search warrant for the Weiner laptop. The FBI is convening a working group to provide recommendations, within120 days, for the staffing, structuring, and supervision of sensitive investigations to help avoid or mitigate similar missteps in the future.

The OIG also stated that former Director Comey was insubordinate by intentionally

concealing from DOJ his intentions regarding the July 5, 2016, announcement and instructing his subordinates to do the same. The FBI does not condone insubordination at any level.

Compliance with policy – and the chain of command as appropriate – will be reinforced through training.

In its review of collected materials, the OIG found that several FBI employees had

exchanged text messages, instant messages, or both, that included political statements hostile to or favoring particular candidates, and appeared to mix political opinion with discussions about the MYE investigation. The OIG found no evidence to connect the political views expressed by these employees with the specific investigative decisions, but referred five employees for investigation into whether the messages violated the FBI’s Offense Codes and Penalty Guidelines. The FBI will handle these referrals pursuant to the FBI’s disciplinary investigation and adjudication processes, and will impose disciplinary measures as warranted. The OIG

separately recommended that the FBI add privacy warning banners to FBI-issued mobile devices and consider assessing whether employees are properly trained on the use of text messages and instant messages, as well as whether it should provide additional guidance about the use of FBI devices for non-governmental purposes. Although the FBI has clear and unambiguous warnings related to the use of FBI Information Technology and Systems, including FBI-issued devices, the Executive Assistant Director of the Information and Technology Branch has been directed to implement the suggested warnings in the most technologically expeditious and feasible manner.

The Bureau will also provide renewed training on the governing policies related to device use.

Each of these areas is discussed in more detail below.

  1. Detailed Response to the Eight Focal Points of the OIG Report

While the OIG Report contains several findings of poor judgment, violations of or

disregard for policy, and investigatory actions that might have benefitted from a better decisionmaking process, it contains no finding that any error in judgment, violation of policy, or investigatory action was motivated by political bias or other improper considerations. This is critical to the operation of the FBI and the ability of the American people to count on the FBI to

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act impartially and objectively. For the same reasons, it is equally important to note again that the OIG Report is narrowly focused on the handful of individuals who were the most deeply involved in running the MYE investigation, and does not generally find fault with the FBI’s policies, practices, or procedures as they pertain to investigations, ethical conduct, or media contacts.

  1. Conduct creating a perception that political bias could have influenced certain

actions or decisions

The OIG identified several separate acts that created an appearance that political bias

could have influenced certain actions or decisions. The FBI accepts that text messages

exchanged over FBI-issued devices by certain FBI employees, primarily Peter Strzok and Lisa Page, demonstrated extremely poor judgment and a lack of professionalism. The FBI also          accepts that the content of these messages, critical of political candidates, brought discredit upon those exchanging them and harmed the FBI’s reputation. Similarly, the FBI accepts that the decision to allow Cheryl Mills and Heather Samuelson to be present during the interview of former Secretary Clinton was inconsistent with typical investigative strategy and created an appearance that political bias could have influenced this decision, especially when viewed in the light of messages exchanged between Mr. Strzok and Ms. Page.2

Despite the appearance of bias created by these actions, the OIG found no evidence that

bias affected any investigatory decision or action. As determined by the OIG, there was noevidence of bias or other improper considerations in former Director Comey’s instruction to

complete the MYE investigation “promptly.” Likewise, the OIG considered multiple decisions and actions taken by the MYE team related to obtaining evidence, interview timing and procedures, and the use of consent or immunity agreements. No evidence of bias or other improper considerations was found by the OIG in the MYE team’s: use of consent, rather than subpoenas, search warrants, or other legal process to obtain evidence; decisions regarding how to limit consent agreements; decision not to seek personal devices from former Secretary Clinton’s senior aides; decisions to enter into immunity agreements; decisions regarding the timing and scoping of former Secretary Clinton’s interview, or to proceed with the interview with Cheryl Mills and Heather Samuelson present; and, the decision to obtain testimony and other evidence from Ms. Mills and Ms. Samuelson by consent agreement and with act-of-production immunity.

 

Although no bias or other improper consideration was found in the FBI’s decisions or

actions, the appearance of bias is disconcerting and potentially damaging to the FBI’s ability to perform its mission. Accordingly, the FBI is instituting new political bias training, drawing from, among other sources, the training, guidance, and practices of the federal judiciary. To commence within 120 days, training will begin with senior leadership and the Senior Executive Service (SES) ranks, with the objectives of discussing the OIG Report, lessons learned, and the need for scrupulous, unwavering adherence to the policies and procedures intended to combat potential political bias. After this initial training, the Director will require all employees to Identifying a different type of potential bias, the OIG Report also found it improper for Ms. Page to comment on or consider how the approach to interviewing former Secretary Clinton might affect the FBI’s interests if she won the presidency. The FBI agrees with this finding.

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undergo similar training to reinforce the importance of maintaining a work environment free from political bias. The training will cover multiple areas, including at a minimum ethics and integrity, objectivity, and the avoidance of political bias, and will occur across multiple settings, such as Special Agent in Charge onboarding, Senior Executive Service onboarding, Senior Leader courses, Leading People courses, and the Basic Field Training Course. If necessary, supplementary Hatch Act and ethics training may also be required.

Additionally, the Director has tasked the Associate Deputy Director with establishing a

working group to provide recommendations, within 120 days, on the staffing, structuring, and

supervising of sensitive investigations in order to ensure that the full suite of the FBI’s

investigative strengths, a balance of operational experience, and proper resources are provided such that every future sensitive investigation is conducted to the highest standards of the Bureau. This will include, among other things, consideration of when and whether to increase field office participation in such matters, and when and whether it would be beneficial to team agents from different components and backgrounds to leverage respective skill sets and experiences, e.g., drawing on the experience of public corruption agents when conducting counterintelligence investigations.

Disciplinary referrals from the OIG Report will be handled pursuant to the FBI’s

disciplinary investigation and adjudication processes. Any allegation of misconduct by an FBI employee is reviewed, and if merited, investigated by either the FBI Inspection Division or the DOJ OIG, as occurred here. At the conclusion of the investigation, the matter is referred to the FBI’s OPR for adjudication. FBI employees must maintain the highest standards of personal and institutional responsibility. The FBI OPR ensures that the FBI maintains its rigorous standards of integrity and professionalism by impartially adjudicating allegations of employee misconduct.

OPR’s prompt, thorough, and fair adjudication of employee misconduct cases materially

enhances confidence in and support for the FBI and its mission. With that said, the FBI OPR has already opened and is conducting investigations, or has concluded misconduct investigations arising out of or related to the conduct identified in the Report. It would not be appropriate to comment here on any particular individual who was or may be the subject of such an investigation.

  1. Violation of or disregard for DOJ or FBI policies by former Director James

Comey’s July 5, 2016, announcement and October 28, 2016, letter

The OIG found that former Director Comey violated DOJ’s media policy, and potentially

regulations related to the public release of information, when he made his July 5, 2016,

announcement. He was also found to have committed a serious error in judgment by sending his October 28, 2016, letter, in disregard of FBI and DOJ policy, without DOJ approval, and in usurpation of the Attorney General’s authority. The FBI does not contest these findings. The FBI will implement the OIG’s recommendation that the FBI adopt a policy on the appropriateness of employees addressing uncharged conduct in public statements. The Director is also tasking the FBI’s OGC to develop, within 30 days, guidance requiring prior consultation

with DOJ preceding any public reference to FBI charging recommendations in criminal

investigations. Pursuant to the new FBI media policy, FBI personnel authorized to communicate with the media must abide by DOJ guidelines contained in 28 CFR 50.2 “Release of information by

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personnel of the [DOJ] relating to criminal and civil proceedings,” and in the U.S. Attorney’s Manual Title 1-7.000 “Confidentiality and Media Contacts Policy.” This would include receiving advanced approval by the appropriate United States Attorney or Assistant Attorney General before communicating with the media about a pending investigation or case, except in emergency circumstances. Training on these policies will be included in the training described

above.

  1. Issues involving media contacts, dissemination of information, and leaks

The OIG’s conclusion that there is a need to change the “cultural attitude” regarding

media contacts and leaks at the FBI is troubling. The FBI is acutely aware of the damage

unauthorized communications or leaks can cause to investigations, prosecutions, the personal lives of those involved in the case or who may be subjects or targets, and the reputation of the Bureau. Leaks or unauthorized communications are not taken lightly, are never condoned, and may result in discipline, up to and including termination, and potentially prosecution. Given the conclusions reached in the OIG report, the Director instructed the Assistant Director of OPR to review whether current disciplinary penalties are adequate to deter unauthorized media contact or leaks and to report back on their adequacy, or the need for additional penalties, within 30 days.

The FBI protects information on a need-to-know basis and, to reinforce the limitations on

sharing that information, revised its media policy effective November 15, 2017. As an additional step, the FBI will ensure that, within 30 days, all personnel are fully aware of the media policy and the serious potential consequences for noncompliance. The new media policy restricts who is authorized to communicate with the media (i.e., within FBI Headquarters, the Director, Deputy Director, Associate Deputy Director, Assistant Director of the Office of Public Affairs, and designated OPA staff; in a field office, the Assistant Director in Charge or Special Agent in Charge, designated public affairs officer, or other personnel specifically authorized by the field office head). The new policy requires that “all contact with members of the media about FBI matters must be reported” to the relevant Headquarters or field office officials. It also requires that personnel “must immediately notify their supervisors if contact with a member of the media concerns suspected classified or grand jury subject matter.” The policy also requires conformance with DOJ guidelines contained in 28 CFR 50.2 “Release of information by personnel of the [DOJ] relating to criminal and civil proceedings,” and in the U.S. Attorney’s Manual Title 1-7.000 “Confidentiality and Media Contacts Policy.” The FBI’s policies, training, and disciplinary measures related to media contact and ethics rules, combined with any additional policies and training developed after this review, will sufficiently mitigate the risk and

continue to deter this type of misconduct.

  1. Former Deputy Director Andrew McCabe’s recusal obligations

The OIG found that the former Deputy Director and the Bureau acted appropriately with

regard to his involvement in and recusal from the Clinton-related investigations. The OIG

concurred with the FBI’s determination that former Deputy Director McCabe was not required to recuse from those investigations and found that he notified the appropriate persons in the FBI to seek guidance on ethics issues. The OIG Report also makes clear that former Deputy Director McCabe generally abided by his voluntary recusal from Clinton-related matters after November 1, 2016, in that there is no evidence that he continued to supervise investigative decisions in those matters after his recusal. The FBI agrees with the OIG that in a few instances, the former Deputy Director did not fully comply with his voluntary recusal.

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Based on the OIG’s findings related to the analysis of recusal decisions and recusal

obligations, in particular the finding that FBI ethics officials and attorneys did not fully

appreciate the potential significant implications of campaign contributions to Dr. McCabe’s campaign, and the ninth recommendation in the OIG Report, the FBI’s OGC and OIC have been directed to work together to develop a framework for earlier notification of potential conflicts caused by campaign contributions to covered persons and to provide additional training on recusal obligations and conflicts of interest. The Director has mandated that the framework be completed within 60 days.

 

  1. The use of personal email accounts by former Director Comey and Peter Strzok

The OIG found that former Director Comey used personal email accounts for unclassified

FBI business, absent exigent circumstances, in contravention of FBI and DOJ policy. The OIG also found that Peter Strzok and Lisa Page used personal email accounts for unclassified FBI business. Although former Director Comey and Ms. Page are no longer employed by the FBI, the OIG referred Mr. Strzok for an investigation into whether his use of personal email accounts violated FBI or DOJ policy. The FBI will handle this referral pursuant to the FBI’s disciplinary investigation and adjudication processes. The FBI notes that there is no finding or indication in the OIG Report that any classified material ever transited former Director Comey’s, Ms. Page’s, or Mr. Strzok’s personal devices or accounts.

The Bureau will evaluate whether additional training and messaging would clarify and

reinforce the existing policies and protocols on the use of non-FBI devices and accounts and further minimize any non-compliance by FBI personnel. Further, the Director has tasked the Executive Assistant Director of the Information and Technology Branch with evaluating the benefits of consolidating existing relevant policies and guidance concerning the use of personal devices and accounts for FBI business, in order to underscore the requirement for exigency in such use.

  1. Missteps in certain investigatory processes

Two complex, exceptionally important investigations were being conducted concurrently

by the FBI in 2016, MYE and the Russia influence investigation. The FBI sought to staff both investigations with the people it thought at the time were the best qualified (as it always does).

Both were close-hold, sensitive, and multifaceted. At the highest levels of leadership then in the FBI, judgment calls and decisions were made regarding how each investigation should proceed and how investigatory actions should be prioritized. The OIG questioned some of the judgment calls and decisions, including reassigning senior members from the MYE team to the Russia influence investigation, the delay in seeking a search warrant for Anthony Weiner’s laptop, and the decision by agents and prosecutors not to subpoena or seek search warrants for the personal devices of three senior aides to former Secretary Clinton. The FBI agrees that it could have moved more quickly to secure a search warrant for Weiner’s laptop and could have staffed the two investigations differently to minimize any detrimental effect to the MYE investigation. The addition of staff or resources may have impacted how agents and prosecutors decided what devices to seek and review, even if their judgment that certain devices were likely of limited evidentiary value remained the same. While the OIG was critical of these judgment calls and decisions, it did not find that these were the result of bias or other improper considerations. Rather, the OIG specifically concluded

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that there was no evidence of bias or improper considerations in the decision not to seek the personal devices from former Secretary Clinton’s senior aides, the lack of urgency in seeking a search warrant for the Weiner laptop, and the prioritization of the Russia influence investigation.

As previously described, in an effort to learn from its past decisions, good and bad, the

FBI is establishing a working group to provide recommendations for the staffing, structuring, and supervision of sensitive investigations to help avoid or mitigate similar missteps in the future.

  1. Insubordination by former Director Comey

The OIG found that former Director Comey was insubordinate when he intentionally

concealed from DOJ his intentions regarding the July 5, 2016, announcement and instructed his subordinates to do the same. The FBI does not condone insubordination at any level and will institute training to ensure compliance with policy and the chain of command, as appropriate.

  1. The potentially improper use of FBI systems and devices to exchange messages,

the related referrals for investigation, and the recommendations to create

additional warning banners and guidance.

The OIG found that several FBI employees had exchanged text messages, instant

messages, or both that included political statements. The OIG also found that some messages appeared to mix political opinion with discussions about the MYE investigation. The OIG concluded there is no evidence to connect the political views expressed by these employees with the specific MYE investigative decisions. Regarding the messages, the FBI will handle the OIG’s referrals pursuant to its disciplinary investigation and adjudication processes and will impose disciplinary measures as warranted.

Based on its review of these messages, the OIG separately recommended that the FBI add

privacy warning banners to FBI-issued mobile devices and consider assessing whether

employees are properly trained on the use of text messages and instant messages and whether it should provide additional guidance about the use of FBI devices for non-governmental purposes.

FBI employees sign a Rules of Behavior Agreement expressly consenting to the monitoring of data communications over FBI information systems (emails, facsimile, computer database use and data storage, digital transmission of data, but not voice communications). This agreement form must be signed before access to any FBI Information Technology or Information Systems is granted. Existing policy also advises employees that “FBI personnel using FBI information

systems have no reasonable expectation of privacy.” Further, the warning banners that appear at login on the FBI’s computer systems expressly apply to “all devices [or] storage media attached to this network or to a computer on this network.” Although the FBI has clear and unambiguous warnings related to the use of FBI Information Technology and Systems, including FBI-issued devices, the Executive Assistant Director of the Information and Technology Branch has been

directed to implement the suggested warnings in the most technologically expeditious and feasible manner. The Bureau will also provide enhanced training on the governing policies related to device use, including but not limited to the use of FBI Information Technology and Systems for political conversations.

* * * *

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In addition to the focal points addressed above, which the FBI believes are responsive to

findings and recommendations in the OIG report, one other specific and narrow recommendation deserves a brief response.

The OIG recommends that the Office of the Deputy Attorney General (ODAG) consider

taking steps to improve the retention and monitoring of text messages Department-wide. The Bureau already goes to great lengths, within the restrictions imposed by existing technology and practicality, to capture and retain text messages sent or received on FBI-issued devices. Still, the FBI stands ready to work with ODAG to improve its processes and capabilities.

III. Conclusion

The FBI appreciates the role of the OIG, its dedication to its task, and the thoroughness of

its investigation in bringing to light ways in which the FBI can improve the performance of its mission. The Bureau also appreciates the finding that there was no evidence that bias or improper considerations affected its investigative actions or decisions. Further, while the OIG Report focused on only a handful of individuals, as described above, the FBI is reviewing the recommendations of the OIG and will be taking action that applies far more broadly to FBI leadership, career Special Agents and Intelligence Analysts, and all the various personnel that make the FBI the premiere law enforcement and national security agency in the world. The FBI is extraordinarily cognizant of the need to maintain impartiality and objectivity, and to make certain that the American people trust it to always do so.

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