Merrick Garland, Lisa Monaco and Christopher Wray each signed off on Arctic Frost (Credit: New York Post)
Thanks to releases by FBI Director Kash Patel and Senate Republicans (here and here and here), we are finally getting sunlight into the FBI’s overarching investigation of not only President Trump but of nearly everyone in his orbit – the investigation assigned the name “Artic Frost.”
(…) What has been lost is also that the FBI’s Washington Field Office (WFO), back in October 2020, assessed that “the use of American Made Media Consultants (AMMC) as a clearinghouse for Donald J. Trump for President, Inc. (the Trump campaign) spending is likely vulnerable to campaign finance crimes by campaign-connected sub-vendors.”
This campaign finance investigation – which was opened by the FBI’s New York Field Office – stemmed from an AMMC member’s potential gambling activities, his efforts to allegedly evade federal $10,000 reporting requirements when cashing-in his winnings, and the alleged pay-off of a Senegalese government official. The FBI’s thought was that the party (the gambler) potentially used Trump campaign funds distributed through AMMC “for personal or unauthorized use.” It should be noted that the FBI’s October 2020 “Tactical Intelligence Report” made its assessment with “low confidence.”
In June 2022, the FBI re-assessed the financial investigation (or at least had renewed interest in the financial investigation), citing to the House January 6th Committee’s “investigation” into the Trump Campaign’s post-2020 election fundraising, which was promoted as the “Election Defense Fund.” See the FBI email below.
We mention campaign finance and the use of funds to challenge the 2020 election because of Senator Grassley’s recent release of 1700+ pages of grand jury subpoenas requesting financial records from a number of individuals and entities, including:
- Donald J. Trump for President
- Jeff Clark
- American Voting Rights Foundation (which helped fund the Arizona audit)
- Conservative Partnership Institute (which assists Republicans in training and educating staff, builds coalitions, and helps with staffing)
- A large number of vendors and contractors involved with the Trump Campaign
- Cyber Ninjas (who were involved in the Arizona election audit)
- Sidney Powell
- Individuals and attorneys who assisted with fundraising for, or distributing funds concerning, election audits.
- MyPillow
- Representation or legal fee agreements between fundraising committees and their attorneys
- Dan Scavino
- Mark Meadows
Some of these subpoenas were issued by the grand jury before Jack Smith was appointed Special Counsel. But most of them came after Smith’s November 18, 2022 appointment – some just days after.
It’s pretty clear what happened.
By April 2022 (at the latest), the Biden DOJ wasn’t just pursuing “election interference” charges against Trump, et al. They were going after conservative fundraising and groups promoting conservative causes, as well as the individuals associated with those groups and entities.
That’s why you see mail fraud – a statute used by federal authorities to charge fundraising-related crimes – in the April 2022 Artic Frost opening communication. (We’re fairly certain they also looked at wire fraud.) And through the use of the grand jury, the Biden Administration was able to reach every single group and individual that pursued truth in the 2020 presidential election.
But it’s not only that. The Biden Administration also targeted those groups formed after the 2020 election – such those groups who weren’t involved in “alternative electors” but who assisted and conducted audits.
The predicate for an expansive financial crimes investigation is not addressed in the Artic Frost opening communication. Nor is it addressed in Special Counsel Smith’s final report. It’s telling that a prosecutor as aggressive as Jack Smith found no financial crimes after receiving the records – an indication of just how weak the predicate was.
This wasn’t just about 2020. It was about 2024 and a plan to not only indict the former President and Republican frontrunner, but to kneecap his support and financial infrastructure. (Read more: Techno Fog/Substack, 10/31/2025) (Archive)