Automated Cybersecurity Policy Compliance Checker Project — Complete Documentation & Simulation

Overview & System Context

Automated Cybersecurity Policy Compliance Checker Project: Comprehensive Web-Sourced Technical Investigation Exhaustive Research Dossier · Pure Web-Scraped Content: ~8885 Words · Real Software Screenshots: 3 1. Executive Overview & Technical Background Search engine privacy is a subset of internet privacy that deals with user data being collected by search engines. Both types of privacy fall under the umbrella of information privacy. Privacy concerns regarding search engines can take many forms, such as the ability for search engines to log individual search queries, browsing history, IP addresses, and cookies of users, and conducting user profiling in general. The collection of personally identifiable information (PII) of users by search engines is referred to as tracking. This is controversial because search engines often claim to collect a user's data in order to better tailor results to that specific user and to provide the user with a better searching experience. However, search engines can also abuse and compromise its users' privacy by selling their data to advertisers for profit. In the absence of regulations, users must decide what is more important to their search engine experience: relevance and speed of results or their privacy, and choose a search engine accordingly. The legal framework in the United States for protecting user privacy is not very solid. The most popular search engines collect personal information, but other search engines that are focused on privacy have cropped up recently. There have been several well publicized breaches of search engine user privacy that occurred with companies like AOL and Yahoo. For individuals interested in preserving their privacy, there are options available to them, such as using software like Tor which makes the user's location and personal information anonymous or using a privacy focused search engine.

The Fourth Amendment is well known for the protections it offers citizens from unreasonable searches and seizures, but in Katz v. United States (1967), these protections were extended to cover intrusions of privacy of individuals, in addition to simply intrusion of property and people. Privacy of individuals is a broad term, but it is not hard to imagine that it includes the online privacy of an individual.

The Confrontation Clause of the Sixth Amendment is applicable to the protection of big data from government surveillance. The Confrontation Clause essentially states that defendants in criminal cases have the right to confront witnesses who provide testimonial statements. If a search engine company like Google gives information to the government to prosecute a case, these witnesses are the Google employees involved in the process of selecting which data to hand over to the government. The specific employees who must be available to be confronted under the Confrontation Clause are the producer who decides what data is relevant and provides the government with what they've asked for, the Google analyst who certifies the proper collection and transmission of data, and the custodian who keeps records. The data these employees of Google curate for trial use is then thought of as testimonial statement. The overall effectiveness of the Confrontation Clause on search engine privacy is that it places a check on how the government can use big data and provides defendants with protection from human error.

This 1967 case is prominent because it established a new interpretation of privacy under the Fourth Amendment, specifically that people had a reasonable expectation of it. Katz v. United States was about whether or not it was constitutional for the government to listen to and record, electronically using a pen register, a conversation Katz had from a public phone booth. The court ruled that it did violate the Fourth Amendment because the actions of the government were considered a "search" and that the government needed a warrant. When thinking about search engine data collected about users, the way telephone communications were classified under Katz v. United States could be a precedent for how it should be handled. In Katz v.

United States, public telephones were deemed to have a "vital role" in private communications. This case took place in 1967, but surely nowadays, the internet and search engines have this vital role in private communications, and people's search queries and IP addresses can be thought of as analogous to the private phone calls placed from public booths. Figure 1: Compliance Automation Software – Techno PM - Project Management ...

This 1976 Supreme Court case is relevant to search engine privacy because the court ruled that when third parties gathered or had information given to them, the Fourth Amendment was not applicable. Jayni Foley argues that the ruling of United States v. Miller implies that people cannot have an expectation of privacy when they provide information to third parties. When thinking about search engine privacy, this is important because people willingly provide search engines with information in the form of their search queries and various other data points that they may not realize are being collected.

In the Supreme Court case Smith v. Maryland of 1979, the Supreme Court went off the precedent set in the 1976 United States v. Miller case about assumption of risk. The court ruled that the Fourth Amendment did not prevent the government from monitoring who dialed which phone numbers by using a pen register because it did not qualify as a "search". Both the United States v. Miller and the Smith v. Maryland cases have been used to prevent users from the privacy protections offered under the Fourth Amendment from the records that internet service providers (ISPs) keep. This is also articulated in the Sixth Circuit Guest v. Leis case as well as the United States v. Kennedy case where the courts ruled that Fourth Amendment protections did not apply to ISP customer data since they willingly provided ISPs with their information just by using the services of ISPs. Similarly, the current legal structure regarding privacy and assumption of risk can be interpreted to mean that users of search engines cannot expect privacy in regards to the data they communicate by using search engines.

The European Court of Justice ruled in 2014 that its citizens had the "Right to Be Forgotten" in the Google Spain SL v. Agencia Española de Protección de Datos case, which meant that they had the right to demand search engines wipe any data collected on them. While this single court decision did not directly establish the "right to be forgotten", the court interpreted existing law to mean that people had the right to request that some information about them be wiped from search results provided by search engine companies like Google. The background of this case is that one Spanish citizen, Mario Costeja Gonzalez, set out to erase himself from Google's search results because they revealed potentially compromising information about his past debts. In the ruling in favor of Mario Costeja Gonzalez, the court noted that search engines can significantly impact the privacy rights of many people and that Google controlled the dissemination of personal data. This court decision did not claim that all citizens should be able to request that information about them be completely wiped from Google at any time, but rather that there are specific types of information, particularly information that is obstructing one's right to be forgotten, that do not need to be so easily accessible on search engines.

The Steele dossier, also known as the Trump–Russia dossier, is a controversial political opposition research report on the 2016 presidential campaign of Donald Trump compiled by counterintelligence specialist Christopher Steele. It was published without permission in 2017 as an unfinished 35-page compilation of "unverified, and potentially unverifiable" memos that were considered by Steele to be "raw intelligence – not established facts, but a starting point for further investigation". The dossier was written from June to December 2016 as reports from his sources were received, and contains allegations of misconduct, conspiracy, and cooperation between Trump's presidential campaign and the government of Russia prior to and during the 2016 election campaign. U.S. intelligence agencies have reported that Vladimir Putin personally ordered the whole Russian election interference operation, that the Russians codenamed Project Lakhta. While the dossier played a significant role in initially highlighting the general friendliness between Trump and the Putin administration, the corroboration status of specific allegations is highly variable. The following allegations have been publicly corroborated by U.S. intelligence agencies, the January 2017 ODNI report, and the Mueller report: "that the Russian government was working to get Mr. Trump elected"; that Russia sought "to cultivate people in Trump's orbit"; that Trump campaign officials and associates had secretive contacts with Russian officials and agents; that Putin favored Trump over Hillary Clinton; that Putin personally ordered an "influence campaign" to harm Clinton's campaign and to "undermine public faith in the US democratic process"; and that he ordered cyberattacks on both parties. Some other allegations are plausible but not specifically confirmed, and some lack evidence and are considered dubious. The dossier was based on reports from initially anonymous sources known to Steele and his "primary sub-source", Igor Danchenko. Steele, a former head of the Russia Desk for British intelligence (MI6), wrote the report for the private investigative firm Fusion GPS, that was paid by Hillary Clinton's campaign and the Democratic National Committee (DNC). The dossier's 17 reports allege that there was a "well-developed conspiracy" of "cooperation" between Trump campaign members and Russian operatives to aid Russia's election interference efforts to benefit Trump. It also alleges that Russia sought to damage Hillary Clinton's candidacy. It was published by BuzzFeed News on January 10, 2017, without Steele's permission. Their decision to publish the reports without verifying the allegations was criticized by journalists.

However, a judge defended BuzzFeed's action on the basis that the dossier was part of an official proceeding, and therefore "protected by fair reporting privilege". Generally, when the dossier was released with its "explosive, but largely unverified, claims", "former intelligence officers and other national-security experts" urged "skepticism and caution". While compiling the dossier, Steele passed his findings to both British and American intelligence agencies. The U.S. intelligence community took the allegations seriously, and the Federal Bureau of Investigation (FBI) investigated every line of the dossier and identified and spoke with at least two of Steele's sources. The Mueller report contained passing references to some of the dossier's allegations but little mention of its more sensational claims. Both the 2019 OIG report and the 2023 Durham report raised doubts about the dossier's reliability and sources, with the latter stating that "the FBI was not able to corroborate a single substantive allegation contained in the Steele Reports". While the dossier played a central and essential role in the seeking of FISA warrants on Carter Page, according to James Clapper, John Brennan, and Robert S. Litt, it "played no role" in the January 6, 2017, intelligence community assessment of the Russian actions in the 2016 election, and according to the Senate Intelligence Committee, the dossier was not used to "support any of [the assessment's] analytic judgments". Also, it was not the trigger for the opening of the Russia investigation into whether the Trump campaign was coordinating with the Russian government's interference in the 2016 presidential election. The dossier is a factor in several conspiracy theories promoted by Trump and his supporters. Many mainstream sources have described the dossier as "discredited".

Figure 2: AI Powered IT & Security Software - Kitecyber the FBI closed Steele "because he was a control problem. We did not close him because we thought he was [a] fabricator." According to Strzok, Steele's decisions to discuss his reporting with the media and to disclose his relationship with the FBI were "horrible and it hurt what we were doing, and no question, he shouldn't have done it." In September, Steele met with Jonathan Winer, who was then the U.S. deputy assistant secretary of state for international law enforcement, whom he had known since 2009. In a 2018 editorial for The Washington Post, Winer recounted that during their meeting in Washington, he was allowed to review Steele's reports, but not to keep a copy: "I prepared a two-page summary and shared it with [Victoria] Nuland, who indicated that, like me, she felt that the secretary of state needed to be made aware of this material", he wrote.

Later in September, Winer discussed the report with Sidney Blumenthal, who revealed he had received similar information from Cody Shearer, a controversial political activist and former journalist who was close to the Clinton White House in the 1990s. Winer met with Steele again in late September and gave him a copy of Shearer's report, later known as the "second dossier". On September 19, 2016, after the report had been "languishing in the FBI's New York field office" for two months, Steele's handling agent sent six of Steele's reports (80, 94, 95, 100, 101, and 102) to the Crossfire Hurricane team, that had been operational since July 31, 2016. This was the first time they and their leader, Deputy Assistant Director of the FBI's Counterespionage Section, Peter Strzok, received any of Steele's reporting. Strzok cautioned his colleagues: "[The dossier] 'should be viewed as intended to influence as well as to inform' and whoever commissioned it was 'presumed to be connected to the [Clinton] campaign in some way.'" Some reports referred to members of Trump's inner circle. After that point, he continued to share information with the FBI. The IG Report says this material "became an important part of the Crossfire Hurricane investigation and the FBI seeking FISA authority targeting one of the Crossfire Hurricane subjects, Carter Page".

On October 28, 2016, days before the election, Comey notified Congress that the FBI had started looking into newly discovered Hillary Clinton emails. Simpson and Fritsch described their reaction: "Comey's bombshell prompted the Fusion partners to decide they needed to do what they could to expose the FBI's probe of Trump and Russia. It was Hail Mary time." The founders of Fusion GPS were very upset by a misleading November 1, 2016, New York Times article "published a week before the election with the headline: 'Investigating Donald Trump, FBI Sees No Clear Link to Russia'. In fact, Russia was meddling in the election to help Trump win, the U.S. intelligence community would later conclude." Simpson later said that "Steele severed his contacts with [the] FBI before the election following public statements by the FBI that it had found no connection between the Trump campaign and Russia and concerns that [the FBI] was being 'manipulated for political ends by the Trump people'." Steele had become frustrated with the FBI, whom he believed failed to investigate his reports, choosing instead to focus on the investigation into Clinton's emails. According to The Independent, Steele came to believe there was a "cabal" inside the FBI, particularly its New York field office linked to Trump advisor Rudy Giuliani, because it blocked any attempts to investigate the links between Trump and Russia. He "grew concerned that there was a cover-up in progress".

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

On December 29, the Republican foreign-policy expert David Kramer invited Ken [Bensinger] to his office at the McCain Institute. He then did something careful Washington insiders do: He left Ken alone in the room with the document for 20 minutes, without, in Ken's view, giving clear instructions about whether he could make a copy. Ken took a picture of every page. (Kramer later denied that he'd allowed Ken to copy it ...) Steele never intended the dossier become public, because it contained unfinished raw intelligence and could have "compromised sources and methods". Steele also worried about the safety of his sources, and expressed concern that if Trump took office, the new agency heads appointed by Trump might be more loyal to him "and could decide to take action against Steele and his source network".

On January 5, 2017, the chiefs of four U.S. intelligence agencies briefed President Barack Obama and Vice President Joe Biden about the Russian interference in the election and the existence of the dossier and its allegations. On the afternoon of January 6, 2017, President-elect Trump and his transition team received a similar briefing in Trump Tower. All four of the top intelligence chiefs met with Trump and his transition team. They were Director of National Intelligence James Clapper, FBI Director James Comey, CIA Director John Brennan, and NSA Director Admiral Mike Rogers. They informed Trump of the Russian election interference, and Comey told them of "a piece of Steele's reporting that indicated Russia had files of derogatory information on both Clinton and the President-elect". Trump later testified under oath "that he was first made aware of the existence of the Dossier by then FBI Director James Comey on 6 January 2018[sic], at a meeting that took place during the transition period following his election". Michael Cohen wrote that he first learned of the dossier on the day it was published by BuzzFeed. Then, according to a pre-arranged plan, Brennan, Clapper, and Rogers left, and Comey then asked to speak with Trump alone. Comey then informed Trump of the dossier and its allegations about salacious tapes held by the Russians. Comey later reported he was very nervous. The previous day, the secretary of the Department of Homeland Security told Comey to "be very careful", "choose your words carefully", and then "get outta there". Comey described the meeting as "really weird". Trump later said that Comey was trying to blackmail him. In April 2018, Comey said he did not inform Trump the dossier was partly funded by Democrats because that "wasn't necessary for my goal, which was to alert him that we had this information". On December 14, 2018, the FBI released a document called "Annex A", that was "part of [the] Russia dossier summary" used to brief Trump and Obama. The FBI withheld parts of the synopsis on the grounds that it remained classified and "because it pertains to ongoing investigations or court proceedings, originated with a confidential source or describes confidential investigative techniques or procedures". Two days after the publication of the dossier on January 10, 2017, James Clapper issued a statement describing the leaks in the press about their Trump Tower meeting with Trump as damaging to U.S. national security. The statement also included the non-committal wording that the U.S.

intelligence community "has not made any judgment that the information in this document is reliable, and we did not rely upon it in any way for our conclusions". This contradicted Trump's previous claim that Clapper had said the information in the dossier was false; Clapper's statement actually said the intelligence community had made no judgment on the truth of the information. James Comey disagreed with Clapper's wording, but Clapper's wording remained unchanged. Comey later told the Office of the Inspector General of his concerns at that time, because he believed the dossier to be more reliable than indicated in Clapper's non-committal statement: I worry that it may not be best to say "The IC has not made any judgment that the information in the document is reliable." I say that because we HAVE concluded that the source [Steele] is reliable and has a track record with us of reporting reliable information; we have some visibility into his source network, some of which we have determined to be sub-sources in a position to report on such things; and much of what he reports in the current document is consistent with and corroborative of other reporting included in the body of the main IC report. That said, we are not able to sufficiently corroborate the reporting to include in the body of the [ICA] report.

Figure 3: Cybersecurity Compliance | Gap & Risk Assessment | POAM I wonder if BuzzFeed have reflected on the lives and livelihoods they put at risk by publishing the dossier, or the shutter it has drawn down on any further collection efforts on this issue and others by anybody or any government agency. In my view BuzzFeed did the Kremlin's work for them because they were determined not to lose the scoop entirely after CNN broke the original story. One of the most irresponsible journalistic acts. Six years after publishing the dossier, Ben Smith, editor of BuzzFeed, has described his regrets about how it was done: If I had to do it again, I would publish the dossier—we couldn't suppress it ... But I would hold more tightly to the document ... I wouldn't simply publish it as a PDF, destined to float free from our earnest caveats. At best, we could have published the document as screenshots attached to the context we had and the context we would learn. Perhaps in some small way, this would have limited its transformation from a set of claims into a banner of the 'resistance.' But I'm not under the illusion that journalists could have contained its wildfire spread, any more than I think we could have concealed it. Steele does not like the term "dossier": because it wasn't a dossier. It's a series of reports on a live issue, the election campaign, running through time. These reports were not collated and presented in one offering, nor were they analyzed in detail by us. Effectively, it was a running commentary. It wasn't a dossier.

The legal status of the dossier has been questioned, but, because of the legal difference between an "expenditure" by a campaign and a "contribution" to a campaign, it does not run afoul of Federal Election Commission laws (52 U.S. Code § 30121) forbidding foreign nationals from contributing to or aiding political campaigns, and that applies to any form of aid, not just cash donations. The dossier (prepared by a British citizen indirectly hired by the Clinton campaign and DNC) and the 2016 Trump Tower meeting (involving a direct offer of aid by the Russian government to the Trump campaign) are frequently contrasted and conflated in this regard. Philip Bump has explained "why the Trump Tower meeting may have violated the law—and the Steele dossier likely didn't": "Hiring a foreign party to conduct research is very different, including in legal terms, than being given information by foreign actors seeking to influence the election. What's more, Trump's campaign did accept foreign assistance in 2016, as the investigation by special counsel Robert S. Mueller III determined." The Trump Tower meeting involved a voluntary offer of aid ("a campaign contribution") to the Trump campaign from the Russian government, and the offer was thus illegal to accept in any manner. Already before the meeting, the Trump campaign knew the source and purpose of the offer of aid, still welcomed the offer, successfully hid it for a year, and when the meeting was finally exposed, Trump issued a deceptive press release about it. By contrast, Steele's work was a legal campaign expense and did not involve any voluntary offer of aid to the Clinton campaign from the Russian government. FEC law allows such campaign expenditures (properly declared), even if the aid is performed by foreigners. Bump explains that: President Trump has deliberately and regularly conflated the two, arguing that the former meeting was innocuous and that the real malfeasance—the real collusion—was between Clinton's campaign and those Russians who were speaking to Steele.

Trump is incorrect. There is no reason to think that Clinton's campaign is culpable for any illegal act related to the employment of Steele and good reason to think that the law was broken around the meeting at Trump Tower—and that members of the Trump team might face legal consequences. Steven L. Hall, former CIA chief of Russia operations, has contrasted Steele's methods with those of Donald Trump Jr., who sought information from a Russian attorney at a meeting in Trump Tower in June 2016: "The distinction: Steele spied against Russia to get info Russia did not want released; Don Jr took a mtg to get info Russians wanted to give." Jane Mayer referred to the same meeting and contrasted the difference in reactions to Russian attempts to support Trump: When Donald Trump Jr. was offered "dirt" on Clinton as "part of Russia and its government's support for Mr. Trump", instead of "going to the F.B.I., as Steele had" when he learned Russia was helping Trump, Trump's son accepted the support by responding: "If it's what you say, I love it." 3. Software Implementation, Frameworks & Protocols It was a clever ploy on the part of the Trump gang: Deny the unfounded—that Trump was caught on tape consorting with urinating prostitutes and that he conspired directly with Putin—to sidestep the damning reality that Trump and his aides betrayed the nation by both encouraging the Russian attack and trying to cover up Putin's sinister intervention. According to Tommy Vietor, "once a narrative enters the media ether, it can become uncontrollable ... once a rumor gets some traction, it's almost impossible to fix it, even if it is false. The problem with the pee tape allegation is it is so graphic, it is so memorable, that it doesn't matter how many times you knock it down – people are going to remember it." As long as it is not released, the alleged pee tape has a lasting effect. When Steele was asked why the Russians had not released the tape, he replied "It hasn't needed to be released. ... I think the Russians felt they'd got pretty good value out of Donald Trump when he was president of the U.S." The founders of Fusion GPS have written: "Ultimately, whether the incident detailed in the dossier is true or not is likely not of paramount importance. The Russians had ample kompromat against Trump and his top aides with or without any pee tape." Igor Danchenko was Steele's "collector" or his "primary sub-source," who "used a network of [further] sub-sources to gather the information that was relayed to Steele". Steele asked Danchenko to help him in March 2016. Initially Danchenko was asked to look into Manafort. Danchenko told the FBI he didn't know about Manafort at the time, and was out of his depth. In June, Steele asked him to also investigate Trump, Page, Cohen, and Flynn. Danchenko said one of his sources for information such as Cohen's supposed Prague trip was a previously government-affiliated journalist and spokesperson named Olga Kalinka, who later denied being a source for the dossier. District Judge Anthony Trenga analyzed the question of Steele's sources and acknowledged that Steele had other sources than Danchenko. He countered Special Counsel John Durham's contention "that Danchenko was Steele's primary source of information for the Steele Reports writ large" by noting that Steele used other sources than Danchenko: "Nor is there any evidence that ... Steele only, or almost entirely, used Danchenko as his source for the Reports." In an Alfa-Bank lawsuit, Steele revealed that he "did not rely on Danchenko alone, instead obtaining information from "one main source and a couple of subsidiary sources". According to Steele: "The dossier was comprised of intelligence obtained from 3 sources and approximately 20 sub-sources." Paul Wood, writing in The Spectator, wrote: "Steele had '20 to 30' sources for the dossier and in two decades as a professional intelligence officer he had never seen such complete agreement by such a wide range of sources." Simpson has said that, to his knowledge, Steele did not pay any of his sources. According to investigative reporter Jane Mayer of The New Yorker, Orbis has a large number of paid "collectors" (also called subsources) whose information came from a network of often unwitting sub-subsources. Since payment of these sub-subsources can be seen as bribery or might encourage exaggeration, they are unpaid. Steele testified that these sub-subsources "were not paid and were not aware that their information was being passed to Orbis or Fusion GPS". According to British journalist Luke Harding, Steele's sources were not new, but trusted, proven, and familiar sources.

Howard Blum said Steele leaned on sources "whose loyalty and information he had bought and paid for over the years". Steele later informed the Inspector General's investigators that this "source network did not involve sources from his time as a former foreign government employee and was developed entirely in the period after he retired from governmental service." (Footnote 214) Helson testified that Danchenko's reports as a confidential informant were used by the FBI in 25 investigations and 40 intelligence reports during a nearly four-year period from March 2017 to October 2020. ... Danchenko, the FBI agent said, was considered 'a model' informant and 'reshaped the way the U.S. even perceives threats.' Helson said that none of his previous informants had ever had as many sub-sources as Danchenko and that others at the FBI have continued to ask in recent months for Danchenko's assistance amid Russia's invasion of Ukraine.

Danchenko may have gotten his information about the hotel encounter not from Millian but from a Democratic Party operative with long-standing ties to Hillary Clinton. The indictment doesn't name the executive by name, but he has been identified as Charles Dolan Jr. Dolan later stated "that he believed the analyst [Danchenko] 'worked for FSB'. ... Dolan later admitted to the FBI ... that he had 'fabricated' the basis of certain details he had provided to Danchenko. He also reportedly said he was unaware of the specifics of Danchenko's work, or that the information they were trading would be transmitted to the FBI.

Dolan's 'historical and ongoing involvement in Democratic politics,' the indictment asserts, 'bore upon' his 'reliability, motivations, and potential bias as a source of information' for Steele's reports." Dolan told authorities that Clinton campaign officials "did not direct, and were not aware of" his contacts with Danchenko. Journalist Stanley-Becker stated "new allegations make Dolan one of the most mysterious figures in the saga of the Steele dossier".

The footnotes do not confirm that the Steele dossier was the product of Russian disinformation. But two footnotes do indicate that the FBI received reports alleging that portions of Steele's evidence were the product of a Russian disinformation plot—though the footnotes do not establish that these reports were credible. The other two footnotes offer further reason to question the veracity of Steele's reporting, but they do not necessarily implicate the existence of a Russian disinformation operation. Lawfare includes a direct quote from a footnote affirming that, as of June 2017, the FBI had no evidence that Steele's network had been "penetrated or compromised": Footnotes 342 and 350 most directly implicate whether the Steele dossier could have been part of a Russian disinformation operation. ... the footnote's final sentence reveals that "an early June 2017 [U.S. intelligence community] report indicated that two persons affiliated with RIS were aware of Steele's election investigation in early July 2016. The [FBI] Supervisory Intel Analyst told us he was aware of these reports, but that he had no information as of June 2017 that Steele's election reporting source network had been penetrated or compromised. Lawfare rejected the two Senators' claims: "The new information in the two footnotes does not support the senators' initial claim that the footnotes confirm the existence of a Russian operation to disrupt the FBI's investigation. The footnotes only establish that the FBI received certain reports. The veracity of the information also remains unconfirmed." It is a fact that Steele and Oleg Deripaska ("Russian Oligarch 1") have had dealings with each other. While Steele was working for a law firm hired by Deripaska to track down money allegedly stolen from him by Paul Manafort, Steele was also working between 2014 and 2016 with the FBI and Justice Department in an unsuccessful classified effort to flip Deripaska so he could be an FBI informant. This Deripaska/Steele association has been touted as a means whereby the Russians could get disinformation inserted into the dossier. The FBI rejected this theory as Priestap found it implausible, and Steele has denied that Deripaska knew of the dossier's existence. The IG report stated: According to an FBI memorandum prepared in December 2017 for a Congressional briefing, by the time the Crossfire Hurricane investigation was transferred to the Special Counsel in May 2017, the FBI "did not assess it likely that the [Steele] [election reporting] was generated in connection to a Russian disinformation campaign." Priestap told us that the FBI "didn't have any indication whatsoever" by May 2017 that the Russians were running a disinformation campaign through the Steele election reporting. Priestap explained, however, that if the Russians, in fact, were attempting to funnel disinformation through Steele to the FBI using Russian Oligarch 1, he did not understand the goal. Bill Priestap further explained that "the Russians ... favored Trump, they're trying to denigrate Clinton ... [and] I don't know why you'd run a disinformation campaign to denigrate Trump on the side." Jane Mayer describes how Trump's defenders have claimed that Steele fell prey to Russian disinformation, and so, therefore, it is he, not Trump, who has been a useful idiot for the Russians. But Steele tells the authors, 'These people simply have no idea what they're talking about.' He emphasizes that his network of sources 'is tried and tested' and has 'been proven up in many other matters.' He adds, 'I've spent my entire adult life working with Russian disinformation. It's an incredibly complex subject that is at the very core of my training and my professional mission. The IG Report said Steele explained how sophisticated the Russians were at planting and controlling misinformation, but Steele "had no evidence that his reporting was 'polluted' with Russian disinformation". The inspector general's report ultimately concluded "that more should have been done to examine Steele's contacts with intermediaries of Russian oligarchs in order to assess those contacts as potential sources of disinformation that could have influenced Steele's reporting". In 2019, during Trump's first impeachment inquiry, national security expert Fiona Hill stated Steele may have been "played" by the Russians to spread disinformation.

While the dossier played a significant role in initially highlighting the general friendliness between Trump and the Putin administration, the corroboration status of specific allegations is highly variable. The following allegations have been publicly corroborated by U.S. intelligence agencies, the January 2017 ODNI report, and the Mueller report: "that the Russian government was working to get Mr. Trump elected"; that Russia sought "to cultivate people in Trump's orbit"; that Trump campaign officials and associates had secretive contacts with Russian officials and agents; that Putin favored Trump over Hillary Clinton; that Putin personally ordered an "influence campaign" to harm Clinton's campaign and to "undermine public faith in the US democratic process"; and that he ordered cyberattacks on both parties. Some other allegations are plausible but not specifically confirmed, but, according to Lawfare, James Clapper, and Fox News host Shepard Smith, none are disproven. Trump and Putin have repeatedly denied the allegations, and Trump has labeled the dossier "discredited", "debunked", "fictitious", and "fake news". In the sections below, the allegations are simply presented as they are, but in the Corroboration status of specific allegations section, the widely varying verification status for a number of allegations is examined, sometimes with conflicting reports for or against their veracity, including whether some sources have rejected them. Each allegation should be read as "Sources allege that" (and then the allegation).

4. Practical Deployment, Analysis & Case Studies ... that "Russian authorities" had cultivated Trump "for at least 5 years", and that the operation was "supported and directed" by Putin. (Report 80) ... that the Russian government's support for Trump was originally conducted by the Ministry of Foreign Affairs, then by the Federal Security Service (FSB), and was eventually directly handled by the Russian presidency because of its "growing significance over time". (Report 130) The dossier describes two different Russian operations. The first was an attempt, lasting many years, to find ways to influence Trump, probably not so much "to make Mr. Trump a knowing agent of Russia", but most likely to make him a source the Russians could use. This operation utilized kompromat (Russian: short for "compromising material") and proposals of business deals. The second operation was very recent and involved contacts with Trump's representatives during the campaign to discuss the hacking of the DNC and Podesta.

... that there was an extensive and "well-developed conspiracy of co-operation between [the Trump campaign] and the Russian leadership", with information willingly exchanged in both directions. That this cooperation was "sanctioned at the 'highest level' and involved Russian diplomatic staff based in the US". That the Trump campaign used "moles within DNC as well as hackers in the US and Russia". (Report 95) ... that Trump had "so far declined various sweetener real estate business deals", but had "accepted a regular flow of intelligence from the Kremlin", notably on his political rivals. (Report 80) ... that Trump associates had established "an intelligence exchange [with the Kremlin] for at least 8 years". That Trump and his team had delivered "intelligence on the activities, business and otherwise, in the US of leading Russian oligarchs and their families", as requested by Putin. (Report 97) ... that a major goal of the Russians in supporting Trump was "to upset the liberal international status quo, including on Ukraine-related sanctions, which was seriously disadvantaging the country". (Report 130) ... that Putin aimed to spread "discord and disunity" within the United States and between Western allies, whom he saw as a threat to Russia's interests.

(Report 80) ... that "TRUMP was viewed as divisive in disrupting the whole US political system; anti-Establishment; and a pragmatist with whom they could do business." That Trump would remain a divisive force even if not elected. (Report 130) ... that Trump "hated" Obama so much that when he stayed in the Presidential suite of the Ritz-Carlton Hotel in Moscow, he employed "a number of prostitutes to perform a 'golden showers' (urination) show in front of him" in order to defile the bed used by the Obamas on an earlier visit. The alleged incident from 2013 was reportedly filmed and recorded by the FSB as kompromat. (Report 80) ... that Trump was vulnerable to blackmail from Russian authorities for paying bribes and engaging in unorthodox and embarrassing sexual behavior over the years, and that the authorities were "able to blackmail him if they so wished". (Reports 80, 95, 97, 113) ... that the Kremlin had promised Trump they would not use the kompromat collected against him "as leverage, given high levels of voluntary co-operation forthcoming from his team". (Report 97) ... that Trump had explored the real estate sectors in St. Petersburg and Moscow, "but in the end TRUMP had had to settle for the use of extensive sexual services there from local prostitutes rather than business success". (Report 95) ... that witnesses to his "sex parties in the city" had been "'silenced' i.e. bribed or coerced to disappear." (Report 113) ... that Trump had paid bribes in St.

Petersburg "to further his [business] interests". (Report 113) ... that Aras Agalarov "would know most of the details of what the Republican presidential candidate had got up to" in St. Petersburg. (Report 113) ... that Trump associates did not fear "the negative media publicity surrounding alleged Russian interference" because it distracted attention from his "business dealings in China and other emerging markets" involving "large bribes and kickbacks" that could be devastating if revealed. (Report 95) ... that Putin ordered the maintenance of a secret dossier on Hillary Clinton, with content dating back to the time of her husband's presidency. The dossier comprised eavesdropped conversations, either from bugging devices or from phone intercepts; it did not contain "details/evidence of unorthodox or embarrassing behavior", but focused more on "things she had said which contradicted her current positions on various issues". (Report 80) ... that the Clinton dossier had been collated by the FSB and was managed by Dmitry Peskov, Putin's press secretary. (Report 80) ... that then-Trump campaign manager Paul Manafort had "managed" a "well-developed conspiracy of co-operation between [the Trump campaign] and the Russian leadership", and that he used Trump's foreign policy advisor, Carter Page, and others, "as intermediaries". (Report 95) ... that Page had "conceived and promoted" the timing of the release of hacked emails by WikiLeaks for the purpose of swinging supporters of Bernie Sanders "away from Hillary CLINTON and across to TRUMP".

(Reports 95, 102) ... that Page was informed by Igor Divyekin, a senior Kremlin Internal Affairs official, "that the Russians had kompromat on Clinton and Trump, and allegedly added that Trump 'should bear this in mind'." (Report 94) ... that Igor Divyekin told Page of the possibility of releasing "a dossier of kompromat the Kremlin possessed on Democratic presidential rival, Hillary CLINTON ... to the Republican's campaign team". (Report 94) ... that Cohen played a "key role" in the Trump–Russia relationship by maintaining a "covert relationship with Russia", arranging cover-ups and "deniable cash payments", and that his role had grown after Manafort had left the campaign. (Reports 134, 135, 136, 166) ... that "COHEN now was heavily engaged in a cover up and damage limitation operation in the attempt to prevent the full details of TRUMP's relationship with Russia being exposed." (Report 135) ... that Russia was responsible for the DNC email hacks and the recent appearance of the stolen DNC emails on WikiLeaks, and that the reason for using WikiLeaks was "plausible deniability". (Report 95) ... that "the operation had been conducted with the full knowledge and support of TRUMP and senior members of his campaign team". (Report 95) ... that after the emails had been forwarded to WikiLeaks, it was decided to not leak more, but to engage in misinformation: "Rather the tactics would be to spread rumours and misinformation about the content of what already had been leaked and make up new content." (Report 101) ... that Page had "conceived and promoted" the idea of [the Russians] leaking the stolen DNC emails to WikiLeaks during the 2016 Democratic National Convention. (Reports 95, 102) ... that Page had intended the email leaks "to swing supporters of Bernie SANDERS away from Hillary CLINTON and across to TRUMP". (Report 102) ... that the hacking of the DNC servers was performed by Romanian hackers ultimately controlled by Putin and paid by both Trump and Putin. (Report 166) ... that Cohen, together with three colleagues, secretly met with Kremlin officials in the Prague offices of Rossotrudnichestvo in August 2016, where he arranged "deniable cash payments" to the hackers and sought "to cover up all traces of the hacking operation", as well as "cover up ties between Trump and Russia, including Manafort's involvement in Ukraine". (Reports 135, 166) ... that "hackers ... had worked in Europe under Kremlin direction against the CLINTON campaign". (Report 166) ... that Viktor Yanukovych, the former pro-Russian President of Ukraine, had told Putin he had been making supposedly untraceable kickback payments to Manafort while he was Trump's campaign manager. (Report 105) ... that in return for Russia's leaking the stolen documents to WikiLeaks, "the TRUMP team had agreed to sideline Russian intervention in Ukraine as a campaign issue and to raise US/NATO defense commitments in the Baltics and Eastern Europe to deflect attention away from Ukraine, a priority for PUTIN who needed to cauterise the subject." (Report 95) ... that Page had secretly met Rosneft chairman Igor Sechin in Moscow on "either 7 or 8 July", together with a "senior Kremlin Internal Affairs official, DIVYEKIN".

(Reports 95, 135, 166) ... that Sechin "offered PAGE/TRUMP's associates the brokerage of up to a 19 per cent (privatised) stake in Rosneft" (worth about $11 billion) in exchange for Trump lifting the sanctions against Russia after his election. (Reports 94, 166) ... that Russia had hastily withdrawn from Washington their diplomat Mikhail Kalugin (misspelled as "Kulagin"), whose prominent role in the interference operation should remain hidden. (Report 111) 5. Performance Evaluation & Extended Technical Observations ... that Aleksej Gubarev's "XBT/Webzilla and its affiliates had been using botnets and porn traffic to transmit viruses, plant bugs, steal data and conduct 'altering operations' against the Democratic Party leadership" and that Gubarev had been coerced by the FSB and was a significant player. (Report 166) The following allegations have been publicly corroborated by U.S. intelligence agencies, the January 2017 ODNI report, and the Mueller report: "that the Russian government was working to get Mr. Trump elected"; that Russia sought "to cultivate people in Trump's orbit"; that Trump campaign officials and associates had secretive contacts with Russian officials and agents; that Putin favored Trump over Hillary Clinton; that Putin personally ordered an "influence campaign" to harm Clinton's campaign and to "undermine public faith in the US democratic process"; and that he ordered cyberattacks on both parties.

Some other allegations are plausible but not specifically confirmed, and some are dubious in retrospect but not strictly disproven. In a December 2018 Lawfare report titled "The Steele Dossier: A Retrospective", the authors described how, after two years, they "wondered whether information made public as a result of the Mueller investigation—and the passage of two years—has tended to buttress or diminish the crux of Steele's original reporting." To make their judgments, they analyzed a number of "trustworthy and official government sources" and found that "These materials buttress some of Steele's reporting, both specifically and thematically. The dossier holds up well over time, and none of it, to our knowledge, has been disproven." They concluded with: The Mueller investigation has clearly produced public records that confirm pieces of the dossier. And even where the details are not exact, the general thrust of Steele's reporting seems credible in light of what we now know about extensive contacts between numerous individuals associated with the Trump campaign and Russian government officials. However, there is also a good deal in the dossier that has not been corroborated in the official record and perhaps never will be—whether because it's untrue, unimportant or too sensitive. As a raw intelligence document, the Steele dossier, we believe, holds up well so far.

Simpson has described his own and Steele's confidence in Steele's work: "Nothing that I have seen disproves anything in the dossier. Which isn't to say I think it's all true. I don't think Chris thinks it's all true, either. But there's a difference between things being fake or a hoax or a fraud or a lie and things being incorrect." Steele, the author of the dossier, said he believes that 70–90% of the dossier is accurate, although he gives the "golden showers" allegation a 50% chance of being true. The following sections describe how some allegations have been corroborated, while others remain unverified because they may be "untrue, unimportant or too sensitive".

Certain allegations have been corroborated, and the public knows which ones, but the public does not know the status of some other allegations that may have also been corroborated ("portions of the material were corroborated"). When Reince Priebus questioned Comey about why he told Trump about the dossier's salacious allegations, "Comey revealed that elements of the dossier had been confirmed": I explained that the analysts from all three agencies agreed it was relevant and that portions of the material were corroborated by other intelligence,' he wrote. Though parts of the memo are redacted, Comey seems to note that some information 'was consistent with and corroborated by other intelligence, and that the incoming president needed to know the rest of it was out there.' On May 4, the Russian contact with ties to the foreign ministry wrote to Mr. Papadopoulos and Mr. Mifsud, saying ministry officials were 'open for cooperation." Mr. Papadopoulos forwarded the message to a senior campaign official, asking whether the contacts were "something we want to move forward with.' Papadopoulos sent emails about Putin to at least seven Trump campaign officials. Trump national campaign co-chairman Sam Clovis encouraged Papadopoulos to fly to Russia and meet with agents of the Russian Foreign Ministry, who reportedly wanted to share "Clinton dirt" with the Trump campaign. When Donald Trump Jr. learned of the offer, he welcomed it by responding: "If it's what you say, I love it." Later, on June 9, 2016, a meeting in Trump Tower was held, ostensibly for representatives from Russia to deliver that dirt on Clinton. Instead, the meeting was used to discuss lifting of the Magnitsky Act economic sanctions that had been imposed on Russia in 2012, a move favored by candidate Trump. In February 2018, a formerly classified memo was released by Democrats on the House intelligence committee. The memo connects the offer of help made to Papadopoulos in London with a similar offer of help made to Carter Page when he met with Igor Divyekin in Moscow. Steele had told the FBI that he knew nothing of Papadopoulos when preparing the dossier, so this was independent confirmation of the Russian offer of help to the Trump campaign. The dossier alleged that when meeting with Carter Page, Igor Divyekin raised the possibility of releasing "a dossier of kompromat the Kremlin possessed on Democratic presidential rival, Hillary CLINTON ... to the Republican's campaign team". The memo stated that "This closely tracks what other Russian contacts were informing another Trump foreign policy advisor, George Papadopoulos. In subsequent FISA renewals, DOJ provided additional information obtained through multiple independent sources that corroborated Steele's reporting." BBC correspondent Paul Wood wrote: Steele was first to warn that Russia was mounting a covert operation to elect Donald Trump. Fusion GPS – his partners in Washington DC – have called this the dossier's 'foundational initial assertion' and it was correct. Much later, the Mueller inquiry would state that 'the Russian government perceived it would benefit from a Trump presidency and worked to secure that outcome.' Steele wrote about what was happening as early as June 2016...The US intelligence agencies...did not publish their findings until December 2016, too late to prevent the effort to influence the election. On January 6, 2017, the Office of the Director of National Intelligence (ODNI) released the intelligence community assessment (ICA) of the Russian interference in the 2016 United States elections. It stated that Russian leadership favored Trump over Clinton, and that Putin personally ordered the whole interference operation, codenamed Project Lakhta, including an "influence campaign" to harm Clinton's electoral chances and "undermine public faith in the US democratic process", as well as ordering cyber attacks on the Democratic and Republican parties. John Brennan and James Clapper testified to Congress that Steele's dossier "played no role" in the intelligence community assessment about Russian interference in the 2016 election, testimony which was reaffirmed by an April 2020 bipartisan Senate Intelligence Committee report that found the dossier was not used to "support any of its analytic judgments". There were conflicting opinions between the FBI and CIA on whether to include any of the dossier's allegations in the body of the ICA report, with the FBI pushing for inclusion, and the CIA countering that the dossier "was not completely vetted and did not merit inclusion in the body of the report". After much discussion, the CIA prevailed, and the final ICA report only included a short summary of Steele's reporting in the "highly classified" Annex A. There were also other reasons to not include it, and CNN wrote that: The intelligence agencies, particularly the CIA, and the FBI took Steele's research seriously enough that they kept it out of a publicly-released January report on Russian meddling in the election in order to not divulge which parts of the dossier they had corroborated and how. ... And if that report included the dossier allegations, the intelligence community would have to say which parts it had corroborated and how. That would compromise sources and methods, including information shared by foreign intelligence services, intelligence officials believed.

In July 2025, when the second Trump administration resumed attacks on the dossier, John Brennan, and others who contributed to the ODNI assessment, Brennan and Clapper responded in The New York Times: Harvested Online Documentation & Reference Sources • https://en.wikipedia.org/wiki/Search%20engine%20privacy • https://en.wikipedia.org/wiki/Steele%20dossier