Redacted Whistleblower Complaint Released

Sep 26, 2019, 7:07 AM | Updated: 7:18 am

FILE: The exterior view of the south side of the White House (Photo by Alex Wong/Getty Images)...

FILE: The exterior view of the south side of the White House (Photo by Alex Wong/Getty Images)

(Photo by Alex Wong/Getty Images)

The following is the full whistleblower complaint against President Donald Trump that was released Thursday morning.

Redacted Whistleblower Complaint

Below is the text version, copied verbatim, from the report made available to the public. No changes have been made to the text.


August 12, 2019

The Honorable Richard Burr

Select Committee on Intelligence
United States Senate

The Honorable Adam Schiff


Permanent Select Committee on Intelligence
United States House of Representatives

Dear Chairman Burr and Chairman Schiff:

I am reporting an ?urgent concern? in accordance with the procedures outlined in 50 U.S.C.
This letter is UNCLASSIFIED when separated from the attachment.

In the course of my of?cial duties, I have received information from multiple U.S.

Government of?cials that the President of the United States is using the power of his of?ce to
solicit interference from a foreign country in the 2020 U.S. election. This interference includes,
among other things, pressuring a foreign country to investigate one of the President?s main
domestic political rivals. The President?s personal lawyer, Mr. Rudolph Giuliani, is a central
?gure in this effort. Attorney General Barr appears to be involved as well.

0 Over the past four months, more than half a dozen U.S. of?cials have informed me of
various facts related to this effort. The information provided herein was relayed to me in
the course of of?cial interagency business. It is routine for U.S. officials with
responsibility for a particular regional or functional portfolio to share such information
with one another in order to inform policymaking and analysis.

0 I was not a direct witness to most of the events described. However, I found my
colleagues” accounts of these events to be credible because, in almost all cases, multiple
of?cials recounted fact patterns that were consistent with one another. In addition, a
variety of information consistent with these private accounts has been reported publicly.

I am deeply concerned that the actions described below constitute ?a serious or ?agrant
problem, abuse, or violation of law or Executive Order? that ?does not include differences of
opinions concerning public policy matters,? consistent with the de?nition of an ?urgent concern?
in 50 U.S.C. I am therefore ful?lling my duty to report this information,
through proper legal channels, to the relevant authorities.

0 I am also concerned that these actions pose risks to U.S. national security and undermine
the U.S. Government?s efforts to deter and counter foreign interference in U.S. elections.

To the best of my knowledge, the entirety of this statement is unclassi?ed when separated
from the classi?ed enclosure. I have endeavored to apply the classi?cation standards outlined in
Executive Order (EO) 13526 and to separate out information that I know or have reason to
believe is classi?ed for national security purposes.1

0 If a classi?cation marking is applied retroactively, I believe it is incumbent upon the
classifying authority to explain why such a marking was applied, and to which speci?c
information it pertains.

I. The 25 July Presidential phone call

Early in the morning of 25 July, the President spoke by telephone with Ukrainian President
I do not know which side initiated the call. This was the ?rst publicly
acknowledged call between the two leaders since a brief congratulatory call after Mr.
won the presidency on 21 April.

Multiple White House of?cials with direct knowledge of the call informed me that, after an
initial exchange of pleasantries, the President used the remainder of the call to advance his
personal interests. Namely, he sought to pressure the Ukrainian leader to take actions to help the
President?s 2020 reelection bid. According to the White House of?cials who had direct
knowledge of the call, the President pressured Mr. to, inter alia:

– initiate or continue an investigation2 into the activities of former Vice President Joseph
Biden and his son, Hunter Biden;

– assist in purportedly uncovering that allegations of Russian interference in the 2016 US.
presidential election originated in Ukraine, with a speci?c request that the Ukrainian
leader locate and turn over servers used by the Democratic National Committee (DNC)
and examined by the U.S. cyber security ?rm which initially reported that
Russian hackers had penetrated the networks in 2016; and

0 meet or Speak with two people the President named explicitly as his personal envoys on
these matters, Mr. Giuliani and Attorney General Barr, to whom the President referred
multiple times in tandem.

Apart from the information in the Enclosure, it is my belief that none of the information contained herein meets the
de?nition of ?classi?ed information? outlined in E0 13526, Part 1, Section 1.1. There is ample open?source
information about the efforts I describe below, including statements by the President and Mr. Giuliani. In addition,
based on my personal observations, there is discretion With respect to the classi?cation of private comments by or
instructions from the President, including his communications with foreign leaders; information that is not related to
US. foreign policy or national security?such as the information contained in this document, when separated from
the Enclosurewis generally treated as unclassi?ed. I also believe that applying a classi?cation marking to this
information would violate EO 13526, Part 1, Section 1.7, which states: ?In no case shall information be classi?ed,
continue to be maintained as classi?ed, or fail to be declassi?ed in order to: (I) conceal violations of law,
inef?ciency, or administrative error; [or] (2) prevent embarrassment to a person, organization, or agency.?

2 It is unclear whether such a Ukrainian investigation exists. See Footnote #7 for additional information.

3 I do not know why the President associates these servers with Ukraine. (See, for example, his comments to Fox
News on 20 July: ?And Ukraine. Take a look at Ukraine. How come the FBI didn?t take this server? Podesta told
them to get out. He said, get out. So, how come the FBI didn?t take the server from the

The President also praised Ukraine?s Prosecutor General, Mr. Yuriy Lutsenko, and suggested
that Mr. might want to keep him in his position. (Note: Starting in March 2019, Mr.
Lutsenko made a series of public allegations?many of which he later walked back?about the
Biden family?s activities in Ukraine, Ukrainian of?cials? purported involvement in the 2016 US.
election, and the activities of the US. Embassy in Kyiv. See Part IV for additional context.)

The White House of?cials who told me this information were deeply disturbed by what had
transpired in the phone call. They told me that there was already a ?discussion ongoing? with
White House lawyers about how to treat the call because of the likelihood, in the of?cials?
retelling, that they had witnessed the President abuse his of?ce for personal gain.

The Ukrainian side was the ?rst to publicly acknowledge the phone call. On the evening of
25 July, a readout was posted on the website of the Ukrainian President that contained the
following line (translation from original Russian-language readout):

– ?Donald Trump expressed his conviction that the new Ukrainian government will be able
to quickly improve Ukraine?s image and complete the investigation of corruption cases
that have held back cooperation between Ukraine and the United States.?

Aside from the above-mentioned ?cases? purportedly dealing with the Biden family and the 2016
US. election, I was told by White House of?cials that no other ?cases? were discussed.

Based on my understanding, there were approximately a dozen White House of?cials who
listened to the call?ma mixture of policy of?cials and duty of?cers in the White House Situation
Room, as is customary. The of?cials I spoke with told me that participation in the call had not
been restricted in advance because everyone expected it would be a ?routine? call with a foreign
leader. I do not know whether anyone was physically present with the President during the call.

0 In addition to White House personnel, I was told that a State Department of?cial, Mr. T.
Ulrich Brechbuhl, also. listened in on the call. .

I was not the only non?White House of?cial to receive a readout of the call. Based on my
understanding, multiple State Department and Intelligence Community of?cials were also
briefed on the contents of the call as outlined above.

II. I Efforts to restrict access to records related to the call

In the days following the phone call, I learned from multiple US. of?cials that senior White
House of?cials had intervened to ?lock down? all records of the phone call, especially the
of?cial word-for-word transcript of the call that was produced?as is customary?by the White
House Situation Room. This set of actions underscored to me that White House of?cials
understood the gravity of what had transpired in the call.

0 White House of?cials told me that they were ?directed? by WhiteHouse lawyers to
remove the electronic transcript from the computer system in which such transcripts are
typically stored for coordination, ?nalization, and distribution to Cabinet?level of?cials.

0 Instead, the transcript was loaded into a separate electronic system that is otherwise used
to store and handle classi?ed information of an especially sensitive nature. One White
House of?cial described this act as an abuse of this electronic system because the call did
not contain anything remotely sensitive from a national security perspective.

I do not know whether similar measures were taken to restrict access to other records of the call,
such as contemporaneous handwritten notes taken by those who listened in.

Ongoing concerns

On 26 July, a day after the call, US. Special Representative for Ukraine Negotiations Kurt
Volker visited Kyiv and met with President and a variety of Ukrainian political
?gures. Ambassador Volker was accompanied in his meetings by US. Ambassador to the
EurOpean Union Gordon Sondland. Based on multiple readouts of these meetings recounted to
me by various US. of?cials, Ambassadors Volker and Sondland reportedly provided advice to
the Ukrainian leadership about how to ?navigate? the demands that the President had made of


I also learned from multiple US. of?cials that, on or about 2 August, Mr. Giuliani reportedly
traveled to Madrid to meet with one of President advisers, Andriy Yermak. The
US. of?cials charaCterized this meeting, which was not reported publicly at the time, as a ?direct
follow-up? to the President?s call with Mr. about the ?cases? they had discussed.

0 Separately, multiple US. of?cials told me that Mr. Giuliani had reportedly privately
reached out to a variety of other advisers, including Chief of Staff Andriy
Bohdan and Acting Chairman of the Security Service of Ukraine Ivan Bakanov.4

– I do not know whether those of?cials met or spoke with Mr. Giuliani, but I was told
separately-by multiple US. of?cials that Mr. Yermak and Mr. Bakanov intended to travel
to Washington in mid?August.

On 9 August, the President told reporters: think [President is going to make a
deal with President Putin, and he will be invited to the White House. And we look forward to
seeing him. He?s already been invited to the White House, and he wants to come. And I think
he will. He?s a very reasonable guy. He wants to see peace in Ukraine, and I think he will be

coming very soon, actually.?
IV. Circumstances leading up to the 25 July Presidential phone call

Beginning in late March 2019, a series of articles appeared in an online publication called
The Hill. In these articles, several Ukrainian of?cials?most notably, Prosecutor General Yuriy
Lutsenko??made a series of allegations against other Ukrainian of?cials and current and former
US. of?cials. Mr. Lutsenko and his colleagues alleged, inter alia:

In a report published by the Organized Crime and Corruption Reporting Project (OCCRP) on 22 July, two
associates of Mr. Giuliani reportedly traveled to Kyiv in May 2019 and met with Mr. Bakanov and another close

adviser, Mr. Serhiy She?r.

– that they possessed evidence that Ukrainian of?cials?namely, Head of the National
Anticorruption Bureau of Ukraine Artem and Member of Parliament Serhiy
Leshchenko~had ?interfered? in the 2016 US. presidential election, allegedly in
collaboration with the DNC and the US. Embassy in Kyiv;S

– that the US. Embassy in Kyivmspeci?cally, US. Ambassador Marie Yovanovitch, who
had criticized Mr. Lutsenko?s organization for its poor record on ?ghting corruption??
had allegedly obstructed Ukrainian law enforcement agencies? pursuit of corruption
cases, including by providing a ?do not prosecute? list, and had blocked Ukrainian
prosecutors from traveling to the United States expressly to prevent them from delivering
their ?evidence? about the 2016 US. election;6 and

0 that former Vice President Biden had pressured former Ukrainian President Petro
Poroshenko in 2016 to ?re then Ukrainian Prosecutor General Viktor Shokin in order to
quash a purported criminal probe into Burisma Holdings, a Ukrainian energy company on
whose board the former Vice President?s son, Hunter, sat.7

In several public comments,8 Mr. Lutsenko also stated that he wished to communicate directly
with Attorney General Barr on these matters.9

The allegations by Mr. Lutsenko came on the eve of the ?rst round of Ukraine?s presidential
election on 31 March. By that time, Mr. Lutsenko?s political patron, President Poroshenko, was
trailing Mr. in the polls and appeared likely to be defeated. Mr. had made
known his desire to replace Mr. Lutsenko as Prosecutor General. On 21 April, Mr. Poroshenko
lost the runoff to Mr. by a landslide. See Enclosure for additional information.

5 Mr. Sy?myk and Mr. Leshchenko are two of Mr. Lutsenko?s main domestic rivals. Mr. Lutsenko has no legal
training and has been widely criticized in Ukraine for politicizing criminal probes and using his tenure as Prosecutor
General to protect corrupt Ukrainian officials. He has publicly feuded with Mr. who heads Ukraine?s only
competent anticorruption body, and with Mr. Leshchenko, a former investigativejournalist who has repeatedly
criticized Mr. Lutsenko?s record. In December 2018, a Ukrainian court upheld a complaint by a Member of
Parliament, Mr. Boryslav Rozenblat, who alleged that Mr. and Mr. Leshchenko had ?interfered? in the 2016
US. election by publicizing a document detailing corrupt payments made by former Ukrainian President Viktor
Yanukovych before his ouster in 2014. Mr. Rozenblat had originally ?led the motion in late 2017 after attempting
to ?ee Ukraine amid an investigation into his taking of a large bribe. On 16 July 2019, Mr. Leshchenko publicly
stated that a Ukrainian court had overturned the lower court?s decision.

5 Mr. Lutsenko later told Ukrainian news outlet The Babel on 17 April that Ambassador Yovanovitch had never
provided such a list, and that he was, in fact, the one who requested such a list.

7 Mr. Lutsenko later told Bloomberg on 16 May that former Vice President Biden and his son were not subject to
any current Ukrainian investigations, and that he had no evidence against them. Other senior Ukrainian officials
also contested his original allegations; one former senior Ukrainian prOsecutor told Bloomberg on 7 May that Mr.
Shokin in fact was not investigating Burisma at the time of his removal in 2016.

3 See, for example, Mr. Lutsenko?s comments to he Hill on 1 and 7 April and his interview with The Babel on 17
April, in which he stated that he had spoken with Mr. Giuliani about arranging contact with Attorney General Barr.
9 In May, Attorney General Barr announced that he was initiating a probe into the ?origins? of the Russia .
investigation. According to the above-referenced OCCRP report (22 July), two associates of Mr. Giuliani claimed
to be working with Ukrainian of?cials to uncover information that would become part of this inquiry. In an
interview with ox News on 8 August, Mr. Giuliani claimed that Mr. John Durham, whom Attorney General Barr
designated to lead this probe, was ?spending a lot of time in Europe? because he was ?investigating Ukraine.? I do
not know the extent to which, if at all, Mr. Giuliani is directly coordinating his efforts on Ukraine with Attorney
General Barr or Mr. Durham.

It was also publicly reported that Mr. Giuliani had met on at least two occasions with Mr.
Lutsenko: once in New York in late January and again in Warsaw in mid-February. In
addition, it was publicly reported that Mr. Giuliani had spoken in late 2018 to former
Prosecutor General Shokin, in a Skype call arranged by two associates of Mr. Giuliani.?0

On 25 April in an interview with Fox News, the President called Mr. Lutsenko?s claims
?big? and ?incredible? and stated that the Attorney General ?would want to see this.?

On or about 29 April, I learned from US. of?cials with direct knowledge of the situation that
Ambassador Yovanovitch had been suddenly recalled to Washington by senior State Department
of?cials for ?consultations? and would most likely be removed from her position.

0 Around the same time, I also learned from a US of?cial that ?associates? of Mr.
Giuliani were trying to make contact with the incoming team.l1

. On 6 May, the State Department announced that Ambassador Yovanovitch would be
ending her assignment in Kyiv ?as planned.?

I However, several US of?cials told me that, in fact, her tour was curtailed because of
pressure stemming from Mr. Lutsenko?s allegations. Mr. Giuliani subsequently stated in
an interview with a Ukrainian journalist published on 14 May that Ambassador
Yovanovitch was ?removed. . .because she was part of the efforts against the President.?

On 9 May, he New York Times reported that Mr. Giuliani planned to travel to Ukraine to
press the Ukrainian government to pursue investigations that would help the President in his
2020 reelection bid.

In his multitude of public statements leading up to and in the wake of the publication of
this article, Mr. Giuliani con?rmed that he was focused on encouraging Ukrainian
authorities to pursue investigations into alleged Ukrainian interference in the 2016 US.
election and alleged wrongdoing by the Biden family. 12

On the a?emoon of 10 May, the President stated in an interview with Politico that he
planned to speak with Mr. Giuliani about the trip.

. A few hours later, Mr. Giuliani publicly canceled his trip, claiming that Mr.
was ?surrounded by enemies of the of the United States.?

On 11 May, Mr. Lutsenko met for two hours with President-elect according to a
public account given several days later by Mr. Lutsenko. Mr. Lutsenko publicly stated that he
had told Mr. that he wished to remain as Prosecutor General.

?0 See, for example, the above-referenced articles in Bloomberg (16 May) and OCCRP (22 July).

I do not know whether these associates of Mr. Giuliani were the same individuals named in the 22 July report by
OCCRP, referenced above.

?2 See, for example, Mr. Giuliani?s appearance on Fox News on _6 April and his tweets on ’23 April and 10 May. In
his interview with The New York Times, Mr. Giuliani stated that the President ?basically knows what I?m doing,
sure, as his lawyer.? Mr. Giuliani also stated: ?We?re not meddling in an election, we?re meddling in an
investigation, which we have a right to There?s nothing illegal about Somebody could say it?s improper.
And this isn?t foreign policy I?m asking them to do an investigation that they?re doing already and that other
people are telling them to stop. And I?m going to give them reasons why they shouldn?t stop it because that
information will be very, very helpful to my client, and may turn out to be helpful to my government.?

Starting in mid-May, I heard from multiple US of?cials that they were deeply concerned by
what they viewed as Mr. Giuliani?s circumvention of national security decisionmaking processes
to engage with Ukrainian of?cials and relay messages back and forth between Kyiv and the
President. These of?cials also told me:

that State Department of?cials, including Ambassadors Volker and Sondland, had spoken
with Mr. Giuliani in an attempt to ?contain the damage” to US. national security; and

0 that Ambassadors Volker and Sondland during this time period met with members of the
new Ukrainian administration and, in addition to discussing policy matters, sought to help
Ukrainian leaders understand and respond to the differing messages they were receiving
from official US?T?ch?artnels onthe?orrehand, and?fromiVIr. Giuliani on the other.

During this same timeframe, multiple US. of?cials told me that the Ukrainian leadership was
led to believe that a meeting or phone call between the President and President would
depend On whether showed willingness to ?play ball? on the issues that had been
publicly aired by Mr. Lutsenko and Mr. Giuliani. (Note: This was the general understanding of
the state of affairs as conveyed to me by US. of?cials from late May into early July. I do not
know who delivered this message to the Ukrainian leadership, or when.) See Enclosure for
additional information.

Shortly after President inauguration, it was publicly reported that Mr. Giuliani
met with two other Ukrainian of?cials: Ukraine?s Special Anticorruption Prosecutor, Mr. Nazar
and a former Ukrainian diplomat named Andriy Telizhenko. Both Mr.
and Mr. Telizhenko are allies of Mr. Lutsenko and made similar allegations in
the above?mentioned series of articles in he Hill.

On 13 June, the President told George Stephanopoulos that he would acceptdamaging
information on his political rivals from a foreign government.

On 21 June, Mr. Giuliani tweeted: ?New Pres of Ukraine still silent on investigation of
Ukrainian interference in 2016 and alleged Biden bribery of Poroshenko. Time for leadership
and investigate both if you want to purge how Ukraine was abused by Hillary and Clinton

In mid-July, I learned of a sudden change of policy with reSpect to US. assistance for
Ukraine. See Enclosure for additional information.

ENCLOSURE: Classi?ed appendix

(U) Supplementary classi?ed information is provided as follows:

(U) Additional information related to Se’ction II

(II-S- “According to multiple White House of?cials I Spoke with, the transcript of the
President?s call with President was placed into a computer system managed directly
by the National Security Council (NSC) Directorate for Intelligence Programs. This is a
standalone computer system reserved for codeword-level intelligence information, such as covert
action. According to information I received from White House of?cials, some of?cials voiced
concerns internally that this would be an abuse of the system and was not consistent with the
responsibilities of the Directorate for Intelligence Programs. According to White House of?cials
I spoke with, this was ?not the ?rst time? under this Administration that a Presidential transcript
was placed into this codeword-level system solely for the purpose of protecting politically
sensitive?rather than national security sensitive?information. .

(U) Additional information related to Section IV

I would like to expand upon two issues mentioned in Section IV that might have a
connection with the overall effort to pressure the Ukrainian leadership. As I do not know
de?nitively whether the below-mentioned decisions are connected to the broader efforts I
describe, I have chosen to include them in the classi?ed annex. If they indeed represent genuine
policy deliberations and decisions formulated to advance US. foreign policy and national
security, one might be able to make a reasonable case that the facts are classi?ed.

0 I learned from US. of?cials that, on or around 14 May, the President instructed
Vice President Pence to cancel his planned travel to Ukraine to attend President

inauguration on 20 May; Secretary of Energy Rick Perry led the delegation
instead. According to these of?cials, it was also ?made clear? to them that the President
did not want to meet with Mr. until he saw how ?chose to act? in
of?ce. I do not know how this guidance was communicated, or by whom. I also do not
know whether this action was connected with the broader understanding, described in the
unclassi?ed letter, that a meeting or phone call between the President and President
would depend on whether showed willingness to ?play ball?.? on the
issues that had been publicly aired by Mr. Lutsenko and Mr. Giuliani.

On 18 July, an Of?ce of Management and Budget (OMB) of?cial informed
Departments and Agencies that the President ?earlier that month? had issued instructions
to suspend all US. security assistance to Ukraine. Neither OMB nor the NSC staff knew
why this instruction had been issued. During interagency meetings on 23 July and 26
July, OMB of?cials again stated explicitly that the instruction to suspend this assistance
had come directly from the President, but they still were unaware of a policy rationale.
As of early August, I heard from US. of?cials that some Ukrainian of?cials were aware
that U.S. laid might be in jeopardy, but I do not know how or when they learned of it.


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Redacted Whistleblower Complaint Released