Russian Interference in 2016 US Elections and Ties to Trump Associates

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      Justice Dept. Aims to Keep Secret Part of Barr-Era Memo on Trump

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      The Biden administration has decided to fight to keep secret most of a Trump-era Justice Department memo related to former Attorney General William P. Barr’s much-disputed declaration in 2019 clearing President Donald J. Trump of illegally obstructing justice in the Russia investigation.In a late-night filing Monday, the Justice Department appealed part of a district-court ruling that ordered it to make public the entire memo. It was written at the same time that Mr. Barr sent a letter to Congress claiming the evidence in the then-still secret report by the special counsel, Robert S. Mueller III, was insufficient to charge Mr. Trump with a crime.The Justice Department did release the first page and a half of the nine-page memo. While Mr. Mueller had declined to render a judgment about what the evidence added up to because the department’s policy was not to charge a sitting president, the memo said Mr. Barr was justified in making a decision in order to shape public understanding of the report. “Although the special counsel recognized the unfairness of levying an accusation against the president without bringing criminal charges, the report’s failure to take a position on the matters described therein might be read to imply such an accusation if the confidential report were released to the public,” wrote Steven A. Engel and Edward C. O’Callaghan, two senior Trump-era Justice Department officials.The Mueller report itself — which Mr. Barr permitted to become public weeks after his letter to Congress had created an impression that the fruits of Mr. Mueller’s inquiry cleared Mr. Trump of obstruction — detailed multiple actions by Mr. Trump that many legal specialists say were clearly sufficient to ask a grand jury to consider indicting him for obstruction of justice.Those actions included attempting to bully his White House counsel, Donald F. McGahn II, into falsifying a record to cover up an earlier attempt by Mr. Trump to fire Mr. Mueller, and dangling a potential pardon at Mr. Trump’s former campaign chairman, Paul Manafort, to encourage him not to cooperate with investigators.The new Justice Department filing also apologized for and defended its Barr-era court filings about the memo, which Judge Amy Berman Jackson had labeled “disingenuous,” saying that they could have been written more clearly but were nevertheless accurate.“The government acknowledges that its briefs could have been clearer, and it deeply regrets the confusion that caused,” the Justice Department said. “But the government’s counsel and declarants did not intend to mislead the court, and the government respectfully submits” that any missteps still did not warrant releasing the entire memo.Mr. Barr’s claim — which he made weeks before releasing the Mueller public — that the evidence gathered showed that Mr. Trump did not commit a chargeable offense of obstruction has been widely criticized as deeply misleading.Among other fallout, a government watchdog group, CREW, filed a Freedom of Information Act lawsuit in the United States District Court in Washington seeking disclosure of an internal memo about the matter.Earlier this month, Judge Jackson issued a scathing ruling in that case saying that the Barr-era Justice Department had been “disingenuous to this court” about the nature of the memo in court filings by arguing that it could be lawfully kept secret under an exemption for pre-decisional deliberations. She wrote that she had made the discovery after insisting that she read it herself.While the Barr-era Justice Department told her the memo concerned deliberations about whether Mr. Trump should be charged with obstruction, the memo itself showed that Mr. Barr had already decided not to do so, and the memo was instead about strategy and arguments that could be mustered to quash the idea. She ordered the entire document released.The Biden-era Justice Department had until Monday to respond. In its filing, it acknowledged that its earlier filings “could have been clearer, and it deeply regrets the confusion that caused.” But it also insisted that its “declarations and briefs were accurate and submitted in good faith.”The decision that Mr. Barr was actually making, the department said, was about whether to decide whether the evidence was sufficient to charge Mr. Trump someday — not whether he should be charged at that moment, since longstanding department legal policy is to consider sitting presidents temporarily immune from prosecution while they are in office.And, it said, the legal analysis in the second part of the memo — the portion it is appealing to keep secret — was, in fact, pre-decisional, even though the memo was completed after Mr. Barr made his decision, because it memorialized legal advice that department lawyers had previously provided to the attorney general. More

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      McGahn Likely to Testify on Trump's Efforts to Obstruct Russia Inquiry

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      A delay is said to have stemmed from an initial threat by former President Donald J. Trump to intervene, but he apparently reversed course.WASHINGTON — President Donald J. Trump’s former White House counsel, Donald F. McGahn II, has agreed to testify behind closed doors before the House Judiciary Committee sometime next week about Mr. Trump’s efforts to obstruct the Russia investigation, according to two people familiar with the matter.Lawyers for House Democrats, the Justice Department and Mr. McGahn had tentatively struck a deal to provide the testimony earlier in May. But the scheduling was delayed for weeks while they waited to see what Mr. Trump, who was not a party to the agreement, would do.Mr. McGahn’s agreement to testify — with President Biden’s permission — was contingent upon there being no active legal challenge to his participation in the matter, according to the two people, who spoke on the condition of anonymity because of the legal and political sensitivity of the matter.Immediately after the deal was announced this month in a court filing, a lawyer for Mr. Trump had conveyed that the former president intended to intervene. Former presidents can invoke executive privilege, although courts weigh that against the view of the incumbent president, and Mr. Trump could have sought a court order blocking Mr. McGahn’s testimony.But late last week, the people said, the lawyer for Mr. Trump — Patrick Philbin, a former deputy White House counsel in the Trump administration who is continuing to help handle his post-presidential legal affairs — said that Mr. Trump would not be intervening after all.Mr. Philbin, who did not respond to a request for comment, is said to have provided no reason for the about-face.While he was president, Mr. Trump vowed to stonewall “all” congressional subpoenas, and taxpayer-funded lawyers with the Justice Department fought lengthy court battles and appeals that succeeded in running out the clock on the possibility that House Democrats would obtain the information they were seeking before the 2020 election.Now that Mr. Trump is no longer president, however, there is at least one major difference: To keep litigating over the matter, Mr. Trump would have to pay the legal costs himself.The McGahn case stems from the House Judiciary Committee’s desire in 2019 to question him about matters related to his role as a key witness in the report by the special counsel, Robert S. Mueller III, about efforts by Mr. Trump to impede the Russia investigation.But after the panel subpoenaed Mr. McGahn to testify, he refused to appear, on Mr. Trump’s instructions. The committee sued, and the case went through several rounds of legal fights over various constitutional issues that lacked definitive precedents because previous such disputes had generally been resolved with a negotiated compromise.Currently, the case is pending before the Court of Appeals for the full District of Columbia Circuit on the question of whether Congress has a “cause of action” that permits it to sue the executive branch. Under presidents of both parties, the executive branch has argued that Congress does not, and the Biden Justice Department had signaled that it was prepared to keep arguing that position if no accommodation could be reached.The deal averts the uncertain outcome of further such litigation — but also means that the next time a fight emerges over a subpoena from the House to the executive branch, the Justice Department will be able to start fresh in prolonged litigation over that unresolved issue.Under the deal, according to a court filing, there will be strict limits on the testimony Mr. McGahn will provide. He will testify behind closed doors for a transcribed interview, rather than in public.Only lawmakers on the House Judiciary Committee may attend. And they may ask Mr. McGahn only about information attributed to him, or events involving him, in the publicly available portions of the Mueller report.The deal also says that the parties will get up to seven days to review the transcript for accuracy before it is made public, suggesting that it would be disclosed sometime in the second week of June. More

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      Blinken Jousts With China and Russia in United Nations Meeting

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      President Biden’s top diplomat said the United States would uphold international rules and “push back forcefully” against those who don’t, a sharp contrast to the Trump years.Secretary of State Antony J. Blinken, meeting with counterparts from both China and Russia on Friday, said that the United States would “push back forcefully” against breakers of international rules, even as he acknowledged his own country’s violations under the Trump administration.Mr. Blinken’s counterparts, Foreign Ministers Wang Yi of China and Sergey V. Lavrov of Russia, took their own diplomatic swipes at the United States, accusing it of hypocrisy and of defining international rules in terms designed to assert Western dominance in the world.The exchanges came at a United Nations Security Council meeting, convened by China and held virtually via videoconference link, on the theme of multilateral cooperation against the pandemic, global warming and other common threats.It was in some ways a rematch between Mr. Blinken and Mr. Wang, who was part of a top Chinese delegation that brusquely lectured the United States at a meeting in Alaska two months ago. That unscripted confrontation was regarded heroically in China, where the government has stoked rising anti-Americanism and nationalism.Although the terms and tone used in the Friday meeting were more diplomatic, the differences were stark in the world views espoused by Mr. Blinken and his counterparts. Those differences suggested that the gridlock among the big powers of the Security Council would not ease anytime soon.The session was held the same week that Mr. Blinken, meeting with the foreign ministers of the Group of 7 nations in Britain, emphasized what he described as the importance of “defending democratic values and open societies” — a signal of the Biden administration’s intent to challenge China and Russia on human rights, disinformation and other issues that had been de-emphasized or ignored by the administration of President Donald J. Trump.In another clear signal from the Biden administration, Mr. Blinken also visited Ukraine, where he pledged support for its fight against a Russian-backed insurgency that has claimed 13,000 lives since 2014.Mr. Blinken asserted in his Security Council remarks that the United Nations remained a critical force for good in the world, responsible since its founding at the end of World War II for the most peaceful and prosperous era in modern history, but was now under severe threat.“Nationalism is resurgent, repression is rising, rivalries among countries are deepening — and attacks against the rules-based order are intensifying,” Mr. Blinken said. “Some question whether multilateral cooperation is still possible. The United States believes it is not only possible, but imperative.”Mr. Blinken said the United States would work with any country on the global threats presented by the coronavirus and climate change, “including those with whom we have serious differences.”At the same time, he said, in a clear warning to China and Russia, that the United State would “push back forcefully when we see countries undermine the international order, pretend that the rules we’ve all agreed to don’t exist, or simply violate them at will.”He did not lay out any new positions but clearly sought to emphasize that the Biden administration was committed to reversing the foreign-policy legacy of President Donald J. Trump, who frequently disparaged the United Nations and led the United States down what critics called a destructive, unilateral path.“I know that some of our actions in recent years have undermined the rules-based order and led others to question whether we are still committed to it,” Mr. Blinken said. “Rather than take our word for it, we ask the world to judge our commitment by our actions.”He enumerated how the Biden administration had rejoined the Paris Climate accord, halted Mr. Trump’s withdrawal from the World Health Organization and was seeking to rejoin the U.N. Human Rights Council.“We’re also taking steps, with great humility, to address the inequities and injustices in our own democracy,” he said. “We do so openly and transparently, for people around the world to see. Even when it’s ugly. Even when it’s painful.”Mr. Wang, whose country holds the rotating Security Council presidency for May, sought to depict China as a responsible global citizen that adhered to international law. Without mentioning the United States by name, he chided countries that he said had defined international rules as a “patent or privilege of the few.”He also declared that “no country should expect other countries to lose,” reflecting a Chinese accusation that the United States is seeking to suppress China’s ascendance — an accusation that Mr. Blinken and others have denied.Mr. Lavrov was more direct in his criticisms of the United States and its allies, describing Mr. Blinken’s references to a “rules-based order” as a guise for Western efforts to repress other countries.He was especially critical of the economic sanctions that the United States and European Union have imposed on Russia and others they disagree with, which Mr. Lavrov said were designed to “take opponents out of the game.” More

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      Judge Says Barr Misled on How His Justice Dept. Viewed Trump’s Actions

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      Judge Amy Berman Jackson said in a ruling that the misleading statements were similar to others that William P. Barr, the former attorney general, had made about the Mueller investigation.A federal judge in Washington accused the Justice Department under Attorney General William P. Barr of misleading her and Congress about advice he had received from top department officials on whether President Donald J. Trump should have been charged with obstructing the Russia investigation and ordered that a related memo be released.Judge Amy Berman Jackson of the United States District Court in Washington said in a ruling late Monday that the Justice Department’s obfuscation appeared to be part of a pattern in which top officials like Mr. Barr were untruthful to Congress and the public about the investigation.The department had argued that the memo was exempt from public records laws because it consisted of private advice from lawyers whom Mr. Barr had relied on to make the call on prosecuting Mr. Trump. But Judge Jackson, who was appointed by President Barack Obama in 2011, ruled that the memo contained strategic advice, and that Mr. Barr and his aides already understood what his decision would be.“The fact that he would not be prosecuted was a given,” Judge Jackson wrote of Mr. Trump.She also singled out Mr. Barr for how he had spun the investigation’s findings in a letter summarizing the 448-page report before it was released, which allowed Mr. Trump to claim he had been exonerated.“The attorney general’s characterization of what he’d hardly had time to skim, much less study closely, prompted an immediate reaction, as politicians and pundits took to their microphones and Twitter feeds to decry what they feared was an attempt to hide the ball,” Judge Jackson wrote.Her rebuke shed new light on Mr. Barr’s decision not to prosecute Mr. Trump. She also wrote that although the department portrayed the advice memo as a legal document protected by attorney-client privilege, it was done in concert with Mr. Barr’s publicly released summary, “written by the very same people at the very same time.”A spokeswoman for Mr. Barr did not return an email seeking comment. A Justice Department spokesman declined to comment.Judge Jackson said that the government had until May 17 to decide whether it planned to appeal her ruling, a decision that will be made by a Justice Department run by Biden appointees.The ruling came in a lawsuit by a government watchdog group, Citizens for Responsibility and Ethics in Washington, asking that the Justice Department be ordered to turn over a range of documents related to how top law enforcement officials cleared Mr. Trump of wrongdoing.At issue is how Mr. Barr handled the end of the Mueller investigation and the release of its findings to the public. In March 2019, the office of the special counsel overseeing the inquiry, Robert S. Mueller III, delivered its report to the Justice Department. In a highly unusual decision, Mr. Mueller declined to make a determination about whether Mr. Trump had illegally obstructed justice.That opened the door for Mr. Barr to take control of the investigation. Two days after receiving the report, Mr. Barr sent a four-page letter to Congress saying that Mr. Trump would not be charged with obstructing justice and summarizing the report. Mr. Mueller’s team believed that Mr. Barr’s characterization of the document was misleading and privately urged him to release more of their findings, but Mr. Barr refused.About a month later, around the time that the report was released to the public, Mr. Barr testified to Congress that he had made the decision not to charge Mr. Trump “in consultation with the Office of Legal Counsel and other department lawyers,” and that the decision to clear the president of wrongdoing had been left to Mr. Barr because Mr. Mueller had made no determination about whether Mr. Trump broke the law.Judge Jackson said in the ruling that Mr. Barr had been disingenuous in those assertions, adding that it had not been left to him to make the decision about the prosecution.She also said that in the litigation between the government and Citizens for Responsibility and Ethics in Washington, the Justice Department under Mr. Barr had claimed that the memo, written by his top officials, had been about legal advice he had relied on to make the decision and should be shielded from the public.Under federal law, the Justice Department can claim that such advice should be shielded because it is “deliberative” and the possibility of releasing it could keep advisers from giving their unvarnished counsel because they fear it may become public someday.But instead, Judge Jackson wrote, Mr. Barr and his aides had already decided not to bring charges against Mr. Trump. She reprimanded the department for portraying the memo as part of deliberations over whether to prosecute the president. She noted that she had been allowed to read the full memo before making her decision, over the objections of the Justice Department, and that it revealed that “excised portions belie the notion that it fell to the attorney general to make a prosecution decision or that any such decision was on the table at any time.”The department “has been disingenuous to this court with respect to the existence of a decision-making process that should be shielded by the deliberative process privilege,” Judge Jackson wrote.She oversaw the trial of Mr. Trump’s longtime adviser Roger J. Stone Jr. and one of the cases against Mr. Trump’s onetime campaign chairman Paul Manafort. Although Mr. Trump has publicly attacked Judge Jackson, legal experts say she operated as an unbiased arbiter during the Russia investigation.In late March, the judge similarly called into question the credibility of the Trump-era government’s description of documents in a Freedom of Information Act lawsuit brought by The New York Times for certain White House budget office emails related to Mr. Trump’s freeze on military aid to Ukraine, which led to his first impeachment.The Justice Department argued that the emails were exempt from disclosure and filed sworn affidavits about their contents by lawyers for the Office of Management and Budget during the Trump administration. But Judge Jackson insisted on reading the emails for herself and wrote that “the court discovered that there were obvious differences between the affiants’ description of the nature and subject matter of the documents, and the documents themselves.”Charlie Savage More

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      Biden Administration Says Russian Intelligence Obtained Trump Campaign Data

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      A Treasury Department document shed more light on links between the campaign and Russian spies.WASHINGTON — The Biden administration revealed on Thursday that a business associate of Trump campaign officials in 2016 provided campaign polling data to Russian intelligence services, the strongest evidence to date that Russian spies had penetrated the inner workings of the Trump campaign.The revelation, made public in a Treasury Department document announcing new sanctions against Russia, established for the first time that private meetings and communications between the campaign officials, Paul Manafort and Rick Gates, and their business associate were a direct pipeline from the campaign to Russian spies at a time when the Kremlin was engaged in a covert effort to sabotage the 2016 presidential election.Previous government investigations have identified the Trump aides’ associate, Konstantin V. Kilimnik, as a Russian intelligence operative, and Mr. Manafort’s decision to provide him with internal polling data was one of the mysteries that the special counsel, Robert S. Mueller III, sought to unravel during his two-year investigation into Russia’s election meddling.“During the 2016 U.S. presidential election campaign, Kilimnik provided the Russian Intelligence Services with sensitive information on polling and campaign strategy,” the Treasury Department said in a news release. “Additionally, Kilimnik sought to promote the narrative that Ukraine, not Russia, had interfered in the 2016 U.S. presidential election.”The Biden administration provided no supporting evidence to bolster the assessment that the Russian intelligence services obtained the polling data and campaign information. And the release shed no light on why Mr. Manafort and Mr. Gates gave polling data to Mr. Kilimnik, although previous government reports have indicated that Mr. Manafort thought Trump campaign strategy information could be a valuable commodity for future business deals with Kremlin-connected oligarchs.Having the polling data would have allowed Russia to better understand the Trump campaign strategy — including where the campaign was focusing resources — at a time when the Russian government was carrying out its own efforts to undermine Donald J. Trump’s opponent.Mr. Gates said in a statement on Thursday that the Treasury Department had failed to provide any evidence to back up its claim, adding that “the polling data passed periodically to Kilimnik at Paul Manafort’s direction was simplistic and outdated, never in real time.”“It was from both public and internal sources,” Mr. Gates said. “It was not massive binders full of demographics or deep research. It was ‘topline’ numbers and did not contain any strategic plans.”The new sanctions against Russia are in response to the Kremlin’s election interference, efforts to hack American government agencies and companies, and other acts of aggression against the United States.The sanctions now make it extremely difficult for Mr. Kilimnik, who was indicted by the Justice Department in 2018 on charges of obstruction of justice, to engage in financial transactions that may involve the United States.It is unclear how long American spy agencies have held the conclusion about Mr. Kilimnik. Senior Trump administration officials, fearing Mr. Trump’s wrath, repeatedly tried to keep from the public any information that seemed to show Mr. Trump’s affinity for Russia or its president, Vladimir V. Putin.Mr. Kilimnik had been a longtime business partner during Mr. Manafort’s time as a political consultant in Ukraine. In 2018, prosecutors for Mr. Mueller’s office announced that Mr. Kilimnik had “ties to Russian intelligence” and that Mr. Manafort had instructed Mr. Gates to pass the polling and campaign information to Mr. Kilimnik.The Senate Intelligence Committee went further last August in its bipartisan report that scrutinized the links between the Trump campaign and Russia — calling Mr. Kilimnik a “Russian intelligence officer.”The report contained several significant redactions that appeared related to Mr. Manafort and Mr. Kilimnik but said that Mr. Manafort’s willingness to share the information with him “represented a grave counterintelligence threat.”The report called the relationship between Mr. Manafort and Mr. Kilimnik “the single most direct tie between senior Trump campaign officials and the Russian intelligence services.”The Senate report portrayed a Trump campaign stacked with businessmen and other advisers who had little government experience and “presented attractive targets for foreign influence, creating notable counterintelligence vulnerabilities.”A New York Times article in 2017 said that there had been numerous interactions between the Trump campaign and Russian intelligence during the year before the election. F.B.I. officials had disputed the report, but both the Senate report and the Treasury Department document confirm the article’s findings.The assertion that it was Ukraine, not Russia, that sought to disrupt the 2016 election has long been both a Kremlin talking point and a claim by Mr. Trump that foreign actors tried to help his opponent, Hillary Clinton, rather than him.Mr. Trump’s obsession over Ukraine’s supposed role in the election was the impetus for a 2019 phone call with the Ukrainian president that was central to the first impeachment proceedings against Mr. Trump.Mr. Manafort was brought into the Trump campaign in March 2016, at a time when Mr. Trump had largely sewn up the Republican presidential nomination.Mr. Manafort and his longtime business associate, Mr. Gates, joined the Trump campaign after years of doing political consulting work in Ukraine, where they met Mr. Kilimnik, a Russian Army-trained linguist.The two men met with Mr. Kilimnik several times after joining the campaign, and in June 2016, Mr. Manafort became the Trump campaign chairman.Details about Mr. Manafort’s relationship with Mr. Kilimnik were revealed in 2018 as the government prosecuted Mr. Manafort and charged Mr. Kilimnik with obstruction of justice for trying to coach potential witnesses in the investigation.Mr. Kilimnik never came to the United States to face charges. He is wanted by the F.B.I., and the bureau is offering $250,000 for information that could lead to his arrest. More

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      Subpoenaing the Brookings Institution, Durham Focuses on Trump-Russia Dossier

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      The special counsel scrutinizing the Russia inquiry, a Trump-era leftover, appears to be retreading ground that an inspector general explored in 2019.WASHINGTON — Exiled from Twitter, former President Donald J. Trump issued a sarcastic statement recently inquiring about the ongoing public silence from John H. Durham, the special counsel who has been investigating the Trump-Russia inquiry since May 2019.“Where’s Durham?” said Mr. Trump, who repeatedly predicted before last year’s election that Mr. Durham’s investigation would prove a deep-state conspiracy against him. “Is he a living, breathing human being? Will there ever be a Durham report?”Mr. Durham ignored the complaint publicly, and the scope of his inquiry remains opaque. But one aspect has come into focus recently, according to people familiar with the investigation: Mr. Durham has keyed in on the F.B.I.’s handling of a notorious dossier of political opposition research both before and after the bureau started using it to obtain court permission to wiretap a former Trump campaign adviser in 2016 and 2017 and questioned witnesses who may have insight into the matter.In particular, Mr. Durham has obtained documents from the Brookings Institution related to Igor Danchenko, a Russia researcher who worked there a decade ago and later helped gather rumors about Mr. Trump and Russia for that research, known as the Steele dossier, according to people familiar with the request.By asking about the dossier, Mr. Durham has come to focus at least in part on re-scrutinizing an aspect of the investigation that was already exposed as problematic by a 2019 Justice Department inspector general report and led to reforms by the F.B.I. and the Foreign Intelligence Surveillance Court.A spokesman for Mr. Durham declined to comment.Asked whether the special counsel had briefed his new supervisor — Attorney General Merrick B. Garland — a Justice Department spokesman would only point to a statement by Mr. Garland as a nominee. “If confirmed,” he said, “one of the first things I am going to do is speak with Mr. Durham and learn the status of his investigation.”In February, several weeks before the Senate confirmed Mr. Garland, Mr. Durham obtained old personnel files and other documents related to Mr. Danchenko from the Brookings Institution, a prominent Washington think tank, using a subpoena. Mr. Danchenko had worked there from 2005 until 2010.Mr. Danchenko traveled to Russia in 2016 and gathered rumors about Mr. Trump and his associates on behalf of Christopher Steele, who produced the dossier as a subcontractor for an investigative firm being indirectly paid by Democrats to look into any Trump-Russia ties.Michael Cavadel, the general counsel of Brookings, confirmed the subpoena for records and other materials about Mr. Danchenko, saying that it was received on Dec. 31 and that the think tank had taken until February to gather the files and turn them over to Mr. Durham’s team in part because its office is closed during the pandemic.“Consistent with its practices in such matters, Brookings provided the responsive documents, none of which contained information associated with the reports known as the Steele dossier,” Mr. Cavadel said.Last September, the attorney general at the time, William P. Barr, made public that from 2009 to 2011 Mr. Danchenko had been the subject of an F.B.I. counterintelligence investigation assessing his contacts with several suspected Russian intelligence officials, including at the Russian Embassy.(Skeptics of the Steele dossier have raised the prospect that Russian intelligence may have used Mr. Danchenko or his sources to seed it with disinformation, in order to further sow chaos. Mr. Danchenko was never charged and has denied ever being a Russian agent. He has also noted that during his time at Brookings he put forward analysis embarrassing to President Vladimir V. Putin of Russia: evidence that Mr. Putin plagiarized parts of his dissertation.)Igor Danchenko worked for the Brookings Institution from 2005 to 2010.Jonah M. Kessel/The New York TimesMr. Durham has also asked questions that suggested a focus on skepticism about how the F.B.I. approached issues that might have undermined the dossier’s credibility as a basis for wiretap applications, people familiar with the inquiry said.For example, Mr. Durham’s team is said to have asked why the F.B.I., after identifying Mr. Danchenko as a major source for the dossier and interviewing him in early 2017, did not tell the surveillance court that he had once been the subject of a counterintelligence investigation.Mr. Durham is also said to be interested in a meeting between the F.B.I. and Mr. Steele in Rome in early October 2016, shortly before the bureau submitted the first wiretap application that used information from his dossier.The previous month, Yahoo News had published an article that contained information that overlapped with claims in the dossier, and the F.B.I. later learned that Mr. Steele had been a source for it, prompting the bureau to sever its relationship with him. At the time, as the bureau told the court in its wiretap application, it assumed the source had been someone else who had received a copy of the dossier.Mr. Durham is said to have asked why F.B.I. officials at that October meeting apparently did not ask Mr. Steele whether he was the article’s source — before using his information to apply for permission to wiretap the former Trump adviser, Carter Page.The focus raised the possibility that Mr. Durham has been exploring whether F.B.I. officials knowingly misled the surveillance court. But if Mr. Durham has found credible evidence of such a crime — as opposed to sloppy investigative work — he has yet to file any such charges.Mr. Durham interviewed the former C.I.A. director John O. Brennan in August, but told him he was not the target of any criminal inquiry. But he has yet to interview former F.B.I. officials who held senior roles in 2016 and have been demonized by Trump supporters, including the former director James B. Comey; his former deputy Andrew G. McCabe; and a former senior counterintelligence agent, Peter Strzok, according to people familiar with the matter.To the extent any eventual Durham report focuses on criticizing the F.B.I.’s handling of issues related to the Steele dossier, it would risk largely retreading ground already covered by the 2019 report by the Justice Department’s inspector general, Michael E. Horowitz.Mr. Horowitz has already brought to light the fact that the F.B.I. botched its wiretap applications in numerous ways, including uncovering numerous material facts that law enforcement officials failed to tell the court and that might have undermined their case for receiving wiretap authorization or renewals — including about the dossier.Mr. Horowitz’s report also already unearthed the fact that Mr. Danchenko had been the subject of a counterintelligence investigation when he worked at Brookings, in a footnote that was initially classified before Mr. Barr decided to make it public.The report also already focused criticism on the F.B.I.’s failure to ask Mr. Steele in October 2016 whether he played a role in the Yahoo News article.And the misconduct by the only person Mr. Durham has charged to date — Kevin Clinesmith, a former F.B.I. lawyer who altered an email shown to a colleague during preparations to seek a renewal of the wiretap, preventing another problem from coming to light internally — was uncovered by Mr. Horowitz’s investigation. (Mr. Clinesmith, who pleaded guilty to falsifying the email but insisted that he did not deliberately mislead his colleague, was sentenced to probation.)Mr. Barr assigned Mr. Durham to hunt for any potential wrongdoing by the Trump-Russia investigators in spring 2019, at a time when Mr. Trump and his supporters were pushing the notion that the inquiry had been a “deep state” plot against him. While Mr. Durham’s work has been opaque, accounts by people familiar with his investigation have made clear that he has pursued various Trumpian conspiracy theories and grievances.In seeking to discredit the Russia investigation, Mr. Trump and his allies have frequently conflated it with the flawed Steele dossier. In fact, the Page wiretaps were a minor part of the overall effort, and Mr. Horowitz’s report showed that it played no role in the F.B.I. decision to open the counterintelligence investigation in July 2016.While uncovering numerous ways the F.B.I. had botched those wiretap applications, Mr. Horowitz’s report also concluded that it had lawfully opened the overall investigation on an adequate basis. When the inspector general delivered the report, Mr. Durham intervened with an unusual public statement saying he disagreed with Mr. Horowitz that the investigation’s opening was properly predicated.Mr. Durham provided no details, but Mr. Horowitz later told Congress that Mr. Durham had told him he thought that the F.B.I. should have opened the inquiry as a “preliminary” investigation rather than going straight to a “full” one. More