FBI OVERSIGHT by Zoë Hopkins

FBI OVERSIGHT By Zoë Hopkins

INTRODUCTION

Recent FBI investigations into the 2016 presidential elections have become a political battleground. In December 2018, James Comey gave his second Congressional testimony. Comey, the former director of the Federal Bureau of Investigation (FBI), was under fire for his investigations into the 2016 presidential campaigns of Donald James Comey, Trump and Hillary Clinton, only the latter of which he had chosen to the 7th director of disclose. However, according to Congressional representatives, the public will never know the whole of what was discussed during the the FBI hearing. Much of the information Comey disclosed pertaining to the Wikipedia FBI is not allowed to reach public ears because it is highly classified. FBI rules surrounding classification have also prevented congressional investigators from releasing a report on their findings surrounding Comey, his investigations, and their relationship to the The [Comey story elections. The hearing and events surrounding it have sparked a national debate about transparency within intelligence has] sparked a organizations, the FBI in particular. national debate The murkiness around the Comey investigations is part of a larger about transparency pattern of lies and cover ups that has recently seemed to plague the FBI, its agents, and its leadership. Comey himself has advocated for increased transparency within the FBI and other intelligence organizations. This past March, the former FBI director wrote an opinion piece in the Washington Post arguing for this possibility on the grounds that opacity often “challenges law enforcement’s credibility.” But Comey’s own actions concerning the presidential election investigations suggest that reforms in both transparency and oversight are perhaps necessary. The Comey story is symptomatic of larger problems with the agency and beg important questions about who is overseeing the FBI and how they are succeeding – or failing –

HARVARD MODEL CONGRESS

to do so. Your task is to find a solution to the growing issues in transparency plaguing the FBI.

EXPLANATION OF THE ISSUE

Historical Development The problems and complexities behind FBI oversight and Your task is to transparency have existed since the birth of the organization. The find a solution to Bureau was established in 1908, a year marked with growing organized crime and violence in America’s larger cities. It was also the growing an era of immense corruption within big business and local, state, issues in and national political theaters. The FBI developed as a branch of the transparency Department of Justice, which no longer had the capacity to oversee plaguing the FBI. investigations and intelligence operations. Today, the FBI is “an intelligence-driven and threat-focused national security organization with both intelligence and enforcement responsibilities”. The FBI technically functions as an independent organization, but its oversight is largely handled by The seal of the Congress, the Department of Justice, and the Director of National FBI Intelligence. Committees in both the Senate and the House review Wikipedia the Bureau’s budget, programs, and selected investigations. The Director of the FBI reports to the Department of Justice, an organization that is also entitled to investigate the FBI for internal misconduct. The Director of National Intelligence, who is the President’s principal intelligence advisor, also oversees the FBI’s intelligence activities. According to a number of authorities in Congress and the intelligence community, this sprawling and complex web of oversight has actually made the FBI less efficient and Steele Dossier – A more prone to internal problems such as the abuse of power. private intelligence The implications of this problem have been far reaching. In report by former January 2018, the House Intelligence Committee voted to release a British intelligence memo on the FBI alleging that the agency had abused its power to officer Christopher surveil. Specifically, the memo accused the FBI of abusing the Steele written in 2016 Foreign Intelligence Surveillance Act (FISA) over its use of the and released January opposition research “Steele dossier” on President Trump and 2017. The dossier Russia as part of the case to obtain a FISA warrant for former Trump alleges misconduct campaign adviser Carter Page. Since, a series of reports by DOJ and conspiracy Inspector General Michael Horowitz have detailed the extent of between the Trump power abuses and misconduct within the FBI. In March of 2018 FBI campaign and the retaliation against internal whistle blowers was exposed, despite Russian government years of bureau pledges to fix the problem. A subsequent report that before and during the April revealed that former FBI deputy director Andrew McCabe had 2016 election. lied to the bureau’s internal investigations branch to cover up a leak he orchestrated. As of April 2019, two dozen people in the FBI and a

DOJ are facing criminal referral over events related to the Trump- Russia investigation. However, these cases, including McCabe’s, have not yet been decided in the courts, meaning they have not yet been found guilty of any criminal conduct. Nevertheless, this recent litany of internal corruption and power breeching is tied to a number of policy problems. Scope of the Problem Structure of the Agency: Current Oversight Both the internal structure of the FBI and its relationships with other government entities is complicated. The FBI is led by a Director who is responsible for overseeing the FBI’s six branches and its investigations; staffing leadership; and ensuring its operations are handled correctly. The Director is appointed by the President and confirmed by the Senate. While the Senate’s role of confirming the Director demonstrates the agency’s reliance on democratic structures, some question whether the FBI can be a truly independent, non-partisan organization given that the President is responsible for appointing the director. Again, given that the FBI is part of the Department of Justice, the FBI Director reports to the Attorney General of the United States, who is in charge of the DOJ. The seal of the Considering that both FBI and DOJ members have been recently FBIThe seal of the The seal of the implicated in the scandal surrounding the Trump-Russia FBI investigation, a number of members of the intelligence community, FBI WikipediaWikipedia The seal of the including House Intelligence Committee Chair Devin Nunes have Wikipedia FBI expressed doubt over whether the DOJ and Attorney General can Wikipedia provide adequate oversight over the FBI. The FBI is also subject to congressional oversight spearheaded by a number of committees including the House and Senate Intelligence committees, the Senate Appropriations Committee, and the House Committee on Ways and Means. The intelligence committees are Both the internal responsible for holding hearings in which members of the intelligence community, including agents and leadership from the structure of the FBI are required to give testimony about their operations and FBI and its investigations. They subsequently conduct reviews of intelligence relationships programs or events and of intelligence analysis. However, the with other intelligence committees are subject to certain limitations: in many government cases the Executive branch can restrict access to highly classified entities is materials from ranking members of the committee. The Appropriations and Ways and Means committees are even more complicated stringently restricted. These two committees are licensed to hear and decide the FBI budget; however, they are not privy to all details of FBI operations.

Surveillance and Intelligence For decades, the FBI has been criticized for its tactics of surveillance and amassing intelligence. NGOs like the American Civil Much of the Liberties Union (ACLU) have called out the FBI for its surveillance public concern that they deem an “intrusion upon the private communications of ...tied to the innocent citizens” that is based on “the vaguest standards.” In a 2013 belief that their report, the ACLU gave an extensive account of FBI surveillance over the course of the 21st century that unfairly targets immigrants, racial surveillance and religious minorities, and political dissidents. Much of the public tactics violate concern surrounding lack of FBI oversight is tied to the belief that privacy and their surveillance tactics violate privacy and Fourth Amendment Fourth rights. The FBI has defended itself against these criticisms with Amendment appeals to national security, while denying the allegations that their rights surveillance tactics are based on discriminatory profiling. Considerable criticism has fallen on the Foreign Intelligence Surveillance Court (FISC). The FISC, established by the Foreign Intelligence Surveillance Act (FISA) is a federal court built to grant and/or deny requests by the FBI and the DOJ for surveillance warrants against foreign entities. However, the FISC has been criticized for providing too little oversight. These critiques largely fall on three problems. Firstly, only the government is represented The seal of the before the FISC--there is no defense to challenge the prosecution, FBIThe seal of the namely the request for the warrant. Secondly, the FISC approves the The seal of the FBI overwhelming majority, 99.7%, of the requests for warrants it FBI Wikipedia receives. This structure allowed for the FBI to collect sweeping Wikipedia quantities of phone data starting in 2007. Finally, FISA stipulates Wikipedia that “a U.S. citizen may be classified as an agent of a foreign power,” broadening the FBI’s power over national security issues. Whistleblowers and Lack of Transparency

The seal of the The FBI, like many intelligence agencies, has fallen under criticism for its opacity. But the FBI’s opacity functions in unique US Foreign capacities. Perhaps most notable is its retaliation against employees Intelligence who reported fraud, abuse, and illegality within the agency. In a 2012 Surveillance survey by the Inspector General, 28% of rank and file FBI employees Court said they never reported the misconduct that they saw or heard about Wikipedia within the agency, a pattern of behavior the ACLU claims is indicative of fear of being censured. The FBI has also encountered similar critiques for its treatment of journalists and using FISA warrants to target journalists for investigation. The FBI has defended itself against these critiques by claiming that it will make efforts towards greater transparency that would include a more liberal treatment of whistleblowers. The FBI’s lack of transparency has also manifested in dishonesty from its leadership and its agents. The DOJ investigation into former deputy director Andrew McCabe is a salient example of this problem.

McCabe was found to have misled investigators on a leak that he himself orchestrated, lying to authorities to cover up his actions. McCabe was fired from the FBI after the findings of the DOJ investigation were released, punished for both the leakage and the subsequent cover up, but the DOJ declined to prosecute him. Leaks and Internal Security Breaches In addition to suffering from security threats and breaches from external sources like hackers, the FBI is also facing problems with leakage and security from its own ranks. Former deputy director McCabe is just one example of a series of leaks and internal security Andrew McCabe, breaches that have recently plagued the FBI. In April 2018, an the 16th Deputy unnamed FBI special agent leaked sensitive informati0n to witnesses, mishandled classified information, and lied to Director of the investigators about his doings. The agent did not face prosecution FBI who was and retired during an inquiry into his conduct. In October 2018, accused of former FBI agent Terry A. Albury was sentenced to four years in purposefully prison for leaking classified documents that delineated the FBI’s plan leaking classified to recruit potential informants and identify potential extremists. The information to culture of leaking within the FBI adds a layer of complexity to the debate around the importance of FBI transparency. the media Wikipedia Congressional Action Largely, congressional action seeking to improve oversight of the FBI has been tied to reforming the internal structure of the FBI, as well as its infrastructure of surveillance. These efforts began as early as 2001, when Senator Charles Schumer (D-NY) introduced the FBI Reform Commission Act. The Act sought to establish a special

FISA Court in commission for FBI review “examine the systemic and structural aspects of the FBI, as well as the FBI's relationship with other law Washington DC enforcement entities; to make recommendations for improving the ZDNet FBI's performance; and to undertake related reviews and studies.” This FBI Reform Commission Act, perhaps one of the only recent pieces of legislation to focus so narrowly on the FBI, did not pass out of the Senate. In 2017, Congress passed the FISA Amendments Reauthorization Act, which revised Title VII of the Foreign Intelligence Surveillance Act, which requires the attorney general and the Director of National Intelligence, both of whom have central in FBI oversight, to adopt procedures “consistent with the requirements of the fourth amendment” in order to request warrants. Subsequently, it stipulates that these procedures must include a detailed record of each “United States person query term” used. It also requires the FBI to procure a court order to access the contents of communications responsive to U.S. person search terms where the request was not designed specifically to investigate foreign

intelligence information. Finally, the bill requires a disclosure of the number of investigations which the FBI opens into a United States person who is not considered a threat to national security “based wholly or in part on acquisition” of information under Title VII. Polygraph – Lie detector test Other Policy Action In 2002, the Department of Justice released a report and recommendation called A Review of FBI Security Programs. The Sensitive DOJ recommended that the FBI implement a counterintelligence Compartmented polygraph program for employees and non-FBI personnel with Information – An access to Sensitive Compartmented Information (SCI) and echelon of special access clearance. The FBI has since elevated the role of information classified personnel security within the FBI, brought personnel security by the U.S. expertise to the FBI from other intelligence agencies, and in 2005 government. SCI are established a Security Division. This policy recommendation and the handled within access subsequent reform represents an attempt to tackle the FBI’s internal and control problems with leakage and breaches of security. determined by the Director of National Intelligence. IDEOLOGICAL VIEWPOINTS

Conservative View Historically, conservatives have almost always supported the FBI. However, since the genesis of the controversy around the FBI investigations into the 2016 elections, conservatives and members of the GOP have demonstrated a heightened lack of trust in the agency, which they have come to view as corrupt and condemnable. President Trump has become known for his attacks on the FBI, which Historically, he labelled “treasonous” in May 2019. In September 2018, President Trump ordered the release of classified documents pertaining to the conservatives have FBI’s investigation of ties between Trump and Russia, subsequently almost always claiming that this act of declassification was “a great service to the supported the FBI country, really.” On a number of occasions, Trump has labelled this investigation a “witch hunt.” President Trump has also criticized the FISC’s approval of warrants for the surveillance of Carter Page, a former Trump campaign aid. Many Republican members of Congress have demonstrated that they share Trump’s views on the FBI. After an anti-Trump text exchange between FBI agent Peter Strzok and FBI attorney Lisa Page emerged in July 2018, House Republicans called a hearing to investigate the issue during which they levied intense criticism on both Strzok and the FBI. House Republicans then launched an investigation into the FBI’s handling of their own investigations into the 2016 elections. The Republican representatives claimed that they

doubted the “thoroughness and impartiality” of these investigations, accusing the FBI of being biased against President Trump. In turn, conservatives have advocated for increased transparency surrounding FBI investigations. In January 2018, House Republicans, including then Speaker of the House Paul Ryan, called on the release of the memo prepared by Devin Nunes that alleged misconduct by the FBI and the DOJ. The memo accused the FBI and DOJ of abusing its surveillance powers in their investigation into ties between Trump and Russia, claiming that the investigation had relied on the supposedly unfounded Steele dossier to request a Senator Charles warrant from the FISC. The memo was ultimately released, a “Chuck” Schumer decision President Trump vocalized support for. The New Yorker Liberal View During the 20th century, and much of the early 21st century, Democrats generally advocated for more intense scrutiny of the FBI. Democrats have tended to take on a skeptical view of the FBI’s use of During the 20th mechanisms like wiretapping and have been critical of its century, and much surveillance of civil rights leaders, activists, and political dissidents. of the early 21st Historically, much of the legislation aimed at reforming FBI oversight and review has been introduced by Democrats. However, century, Democrats in light of President Trump’s attacks on the agency, liberals and generally advocated Democrats in Congress have expressed more approval of the agency. for more intense House Democrats, led by Representative Adam Schiff (D-CA), scrutiny of the FBI released a memo rebutting the Nunes memo that had alleged FBI misconduct. In this memo, Democrats state that the FISA warrant on Carter Page was rational and well based. It also argues that the Steele dossier had no bearing on the FBI’s decision to investigate President Trump’s ties with Russia. Overall, the memo supports FBI independence and the capacity of the agency to investigate as it sees fit.

AREAS OF DEBATE Blue Ribbon Commission– A Establish an FBI Review and Oversight Commission group of experts Politicians on both side of the partisan aisle have expressed appointed to support for establishing an FBI Reform and Oversight Commission. investigate a given Most likely, this would be a bipartisan blue ribbon commission subject established through legislation but independent from the legislature and from the DOJ. The commission would conduct a strategic, thorough review of the FBI and make recommendations for its improvement. Those who have advocated for this reform measure, prominent among them Senator Chuck Schumer (D-NY) Senator Patrick Leahy (D-VT), have cited concern around the objectivity of

present practices of congressional investigation of the FBI, a problem the establishment of an objective, bipartisan reform and oversight commission seeks to address. They also worry that the investigations and reviews conducted by the Inspector General are not designed for They claim that the strategic, long-term recommendations on policy and managerial issues. The blue-ribbon commission can fill that gap. It is bipartisan, FBI’s investigatory objective, and focused upon solutions, not headlines. and intelligence Those opposed to creating independent commission, like Senator aims need to be in Chuck Grassley (R-IA), are mainly concerned that doing so will conversation and create a layer of bureaucracy that will isolate the FBI from the function holistically broader law enforcement and intelligence community the agency is a with its law part of. They suggest that instead, the capacity and scope of the DOJ Inspector General investigations should be enhanced so that they are enforcement aims equipped to make strong policy recommendations. Restrict Scope of Agency Powers Some groups concerned that the FBI’s power is growing unchecked have argued for strict limitations on the scope of the agency’s power. For example, the Brennan Center for Justice, a public policy research institute, have argued that the FBI should not exist as an intelligence organization, but solely as a law enforcement organization. The Brennan Center and other groups with a similar position believe that the FBI’s position as an intelligence agency has allowed it to circumvent constitutional checks on its authority through its “near-impenetrable secrecy” and capacity to “collect information against people not even suspected of wrongdoing.” This supposedly allows the FBI to unfairly profile and police certain groups by abusing its power as an intelligence agency to surveil. Many… have Thus, these groups argue that in order for it to be properly overseen, advocated for and to avoid abuse of power, the agency’s capacity to surveil and narrowing the collect intelligence must be isolated from its capacity to police. scope of data Some members of the intelligence community have condemned this reform approach for being too broad and radical of a shift. They collection allowed claim that the FBI’s investigatory and intelligence aims need to be in by FISA warrants conversation and function holistically with its law enforcement aims. Opposition to this reform measure has claimed that it would result in a fractured and thus ineffectual agency. Reform of FISA and FISC Even after the FISA Amendments Reauthorization Act was passed in 2017, amendment of the FISA and reform of the FISC have remain central in the debate around FBI reform. The most visible concern is that FISA warrants allow for data to be collected in quantities many deem too large. In turn, members of Congress, many from the House Permanent Select Committee on Intelligence have

advocated for narrowing the scope of data collection allowed by FISA warrants. This reform measure is meant as a check on the FBI’s capacity to abuse power. Additionally, members of Congress supporting FISA reform have demanded deep reforms in the infrastructure of the FISC. Specifically, these individuals are calling for an infrastructure that allows for more impartial proceedings, in which the interests of the defendant are represented by a Special Advocate for privacy and civil liberties. In light of the recent Nunes memo and its role in the Trump- Russia investigation, FISA has recently been subject to heightened attention. As a result, some Democrats have been hesitant to advocate for FISA and FISC reform given its potential implications for the Trump administration. Some Democrats, like Rep. Adam Schiff (D-CA), have argued that Republicans are using FISA and FISC reform as a political tool, and have thus resisted proposed reforms. Whistleblower Protections Protected Disclosures – In Improving support for whistleblowers is also critical to the government agencies, conversation around FBI reform, and is a theme that has received protected disclosure is bipartisan support. Given reports that have shown that FBI disclosure of employees face retaliation for reporting misconduct, members of information to an Congress and government agencies like the Whistleblower appropriate official Protection Program, have advocated for expanding whistleblower which an employee or protections. Specifically, they have proposed redefining and applicant reasonably enlarging the qualifications for protected disclosures. Senate believes evidences: (1) Democrat Chuck Schumer has also highlighted the importance of a violation of a law, ending personnel actions, such as demotions, based on a protected rule, or regulation; or disclosure. Similarly, those seeking to protect whistleblowers have (2) waste, fraud, or demanded that anytime a whistleblower alleges retaliation or seeks abuse reprisal in light of alleged retaliation, the Office of the Inspector General (OIG) investigate the allegation. Those who oppose increased protection for whistleblowers have expressed concern that such an infrastructure will result in dysfunction. More specifically, they claim that expanding whistleblower protection will cause employees to make unnecessary reports, causing complications within the agency. Given the emerging issue with the whistleblower on the Trump call with the Ukrainian President, however, this issue could cause different people to quickly change their perspective – you should be sure to track it in the run-up to the conference.

BUDGETARY CONSIDERATIONS

Requisite budgetary measures will differ based on the type and extent of reform in question. Establishing an FBI Oversight and Review Commission would require expenditure on salaries for those sitting on the commission. This amount would be determined by the Senate Committee on Appropriations. Restricting the scope of the FBI’s powers as an intelligence agency would likely diminish the necessary size of the agency’s budget. Reforming the FISA and FISA would likely not require much expenditure, unless legislation mandating a Special Advocate should be enacted, in which case a salary would need to be determined. Offering increased protections for whistleblowers would likely require little budgetary consideration.

CONCLUSION

In summary, the litany of internal problems the FBI faces including security breaches, abuses of power, and whistleblower maltreatment, as well as their broader abuses of surveillance power, raise meritorious arguments for increased oversight. The complex web of already existing oversight faces certain barriers and limitations that perhaps necessitate revision of this infrastructure. While Congress has addressed or sought to address some of these [Congress] will problems with legislation like the FBI Reform Commission Act and need to take into the FISA Amendments Reauthorization Act, there are other measures that could be meaningful for oversight of the agency such consideration how as establishing an independent Oversight and Review Commission, to best implement a enacting further reforms of FISA and FISC, limiting the scope of the structure of FBI’s intelligence powers, and expanding the safety network for oversight whistleblowers. As Congress seeks to navigate this issue, it will need to take into consideration how to best implement a structure of oversight while maintaining a level of agency independence that allows it to function as needed. Policies aimed at improving oversight will also need to incorporate an understanding of how the FBI can best pursue national interest and national security, while keeping the agency’s power within bounds. Addressing the inadequacies in the current infrastructure of oversight and coming up with solutions is critical for ensuring that the FBI, and in turn other intelligence agencies, are not themselves violating the law and the constitution. Should a government agency’s power go unchecked it can have serious implications for civil rights and privacy. Finally, while the recommendations included in this

briefing provide one frame of reference, there are of course many possible solutions that exist outside the scope of this briefing.

GUIDE TO FURTHER RESEARCH

Further investigation of the subject, recent testimony from House and Senate Intelligence Committee hearings on FBI oversight, as well as FISA and FISC, are useful resource. The FBI website itself is a strong source of information on the history of the agency and the structure of oversight currently in place. Reports by independent organizations like the ACLU and the Brennan Center for Justice provide useful information on issues within the FBI that need oversight. Finally, news reports on internal challenges within the FBI are good places to look to determine where oversight is necessary.

GLOSSARY

Polygraph Examination – Lie detector test

Steele Dossier – A private intelligence report by former British intelligence officer Christopher Steele written in 2016 and released January 2017. The dossier alleges misconduct and conspiracy between the Trump campaign and the Russian government before and during the 2016 election

Protected Disclosure – In government agencies, protected disclosure is disclosure of information to an appropriate official which an employee or applicant reasonably believes evidences: (1) a violation of a law, rule, or regulation; or (2) waste, fraud, or abuse

Blue Ribbon Commission – A group of experts appointed to investigate a given subject

Sensitive Compartmented Information (SCI): An echelon of information classified by the U.S. government. SCI are handled within access and control determined by the Director of National Intelligence

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