New: The FBI Played Fast and Loose With A Second Document Despite Being 'Warned Early and Often'

Even those who barely follow the news are familiar with Christopher Steele’s infamous dossier. Most are aware that this unverified document was presented as verified by the FBI in their application to the FISA Court for the warrant to spy on Trump campaign advisor Carter Page. The FBI had been warned several times before submitting their application that none of the information had been verified, that Steele hated Trump and that it had been commissioned by a political campaign.


The FBI used it anyway, because it allowed them to carry out their plan.

But there’s a second document which has played a crucial role in the Russian Collusion story that most people have either forgotten about or never knew existed. This is the Ukrainian “black cash ledger.”

Similar to the dossier, the black cash ledger was believed to be fake. Also, the FBI was warned that it was likely bogus.

The Hill’s John Solomon, a long-time Washington investigative reporter with extensive contacts throughout the intelligence community, has uncovered new information about this document which has been all but forgotten.

The “black cash ledger” materialized in Ukraine the summer of 2016. It showed that Paul Manafort, who was Trump’s campaign manager at that time, had received a $12 million cash payment from the Russian-backed Party of Regions.

When news of this story broke, Manafort was forced to resign from Trump’s campaign and the document led to his ultimate indictment on bank and tax fraud. “In search warrant affidavits, the FBI portrayed the ledger as one reason it resurrected a criminal case against Manafort that was dropped in 2014 and needed search warrants in 2017 for bank records to prove he worked for the Russian-backed Party of Regions in Ukraine.”

Solomon writes that there was one major problem with this document:

The FBI’s public reliance on the ledger came months after the feds were warned repeatedly that the document couldn’t be trusted and likely was a fake, according to documents and more than a dozen interviews with knowledgeable sources.

For example, Ukraine’s top anticorruption prosecutor, Nazar Kholodnytsky, told me he warned the U.S. State Department’s law enforcement liaison and multiple FBI agents in late summer 2016 that Ukrainian authorities who recovered the ledger believed it likely was a fraud.

“It was not to be considered a document of Manafort. It was not authenticated. And at that time it should not be used in any way to bring accusations against anybody,” Kholodnytsky said, recalling what he told FBI agents.


Manafort’s former Ukrainian business partner, Konstantin Kilimnik, was a State Department human intelligence source. Shortly after the ledger story was published in the New York Times, Kilimnik informed the U.S. government that the document was likely fake.

Kilimnik emailed a senior U.S. official on August 22, 2016: He wrote:

Manafort could not have possibly taken large amounts of cash across three borders. It was always a different arrangement — payments were in wire transfers to his companies, which is not a violation.

I have some questions about this black cash stuff, because those published records do not make sense. The time frame doesn’t match anything related to payments made to Manafort. … It does not match my records. All fees Manafort got were wires, not cash.

Solomon said that, according to three sources he spoke to who were familiar with the documents, Special counsel Robert Mueller’s team and the FBI were given copies of Kilimnik’s warning.

This is comparable to the FBI’s receipt of warnings from DOJ official Bruce Ohr and State Dept. official Kathleen Kavalec, both of whom questioned the reliability of the information contained in the Steele dossier and voiced their concern.

Note: The Mueller Report characterized Kilimnik as a Russian operative instead of as an asset for the U.S. State Department and other Western allies. I posted about that here.

According to the FBI operating manual:

Submitting knowingly false or suspect evidence — whether historical or to support probable cause — in a federal court proceeding violates FBI rules and can be a crime under certain circumstances. “To establish probable cause, the affiant must demonstrate a basis for knowledge and belief that the facts are true.”


Solomon notes that in the Manafort case, “the FBI and Mueller’s office did not cite the actual ledger — which would require agents to discuss their assessment of the evidence — and instead cited media reports about it. The feds assisted on one of those stories as sources.”

He gives the example of, when completing the July 25, 2017 affidavit for a search warrant on Manafort’s home (recall the predawn raid), they cited it as a reason they were reopening the 2014 criminal case against Manafort.

The affidavit stated, “On August 19, 2016, after public reports regarding connections between Manafort, Ukraine and Russia — including an alleged ‘black ledger’ of off-the-book payments from the Party of Regions to Manafort — Manafort left his post as chairman of the Trump Campaign.”

Several months later, while trying to demonstrate probable cause for a search warrant for Manafort’s bank records, the FBI cited an Associated Press article dated April 12, 2017, “about the ledger as evidence Manafort was paid to perform U.S. lobbying work for the Ukrainians.” A footnote said:

The April 12, 2017, Associated Press article reported that DMI [Manafort’s company] records showed at least two payments were made to DMI that correspond to payments in the ‘black ledger.’

Solomon points out two glaring problems with that assertion.

The first was the material omission of the fact that none other than DOJ prosecutor Andrew Weissmann (and future leader of the Mueller investigation team), accompanied by both FBI officials “met with those AP reporters one day before the story was published and assisted their reporting.”


The FBI record of that meeting states that “the AP reporters were advised that they appeared to have a good understanding of Manafort’s business dealings” in Ukraine. “So, essentially, the FBI cited a leak that the government had facilitated and then used it to support the black ledger evidence, even though it had been clearly warned about the document.”

The FBI did something similar with the Steele dossier. Steele had met with several journalists in late September 2016, including Yahoo News’s Michael Isikoff. On September 23, 2016, Isikoff broke the story about Trump advisor Carter Page’s alleged “ties” to the Kremlin. The FBI then cited Isikoff’s story to “corroborate” the dossier in their late October application to the FISA Court. This is known in journalism circles as “circular reporting.”

Solomon explains the second glaring problem:

The FBI was told the ledger claimed to show cash payments to Manafort when, in fact, agents had been told since 2014 that Manafort received money only by bank wires, mostly routed through the island of Cyprus, memos show.

During the 2014 investigation, Manafort and his partner Richard Gates voluntarily identified for FBI agents tens of millions of dollars they received from Ukrainian and Russian sources and the shell companies and banks that wired the money. “Gates stated that the amounts they received would match the amounts they invoiced for services. Gates added they were always paid late, and in tranches,” FBI memos I obtained show.


Harvard law professor Alan Dershowitz said it is unusual for an FBI affidavit to cite a news story. “They are supposed to cite the primary evidence and not secondary evidence. It sounds to me like a fraud on the court, possibly a willful and deliberate fraud that should have consequences for both the court and the attorneys’ bar.”

Former FBI intelligence chief Kevin Brock weighed in as well:

Mentioning the ledger in an affidavit for its historical relationship to Manafort’s firing and the start of the investigation might be defensible, but any effort to use the ledger to support probable cause would be “puzzling” since it clearly was not needed to strengthen either affidavit and only risked tainting the warrant. He said it could raise questions about why the special counsel believed it necessary to refer to the ledger in the probable cause narrative.

Solomon says that, “in the end, the best proof that the FBI knew the black ledger was a sham is that prosecutors never introduced it to jurors in Manafort’s trial.

Unlike the Steele dossier, the black cash ledger has received very little media attention. Yet, it’s introduction forced Trump’s campaign manager to resign and began the public narrative about the campaign’s ties to the Kremlin. It was also used to reopen an investigation which had been closed in 2014.

I have no doubt that all of these deviations from standard operating protocol will be scrutinized by John Durham and his team in the coming months. At least, I hope so.



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