Steele Statement

BREDHOFF & KAISER, P.L.L.C.
Attorneys & Counselors

805 Fifteenth Street NW – Suite 1000
Washington, D.C. 20005
STATEMENT ON BEHALF OF
CHRISTOPHER STEELE AND ORBIS BUSINESS INTELLIGENCE
IN RESPONSE TO THE DOJ OIG REPORT INTO THE
CROSSFIRE HURRICANE INVESTIGATION
FOR IMMEDIATE RELEASE
CONTACTS: Robert Weinberg and Joshua Shiffrin

Counsel for Christopher Steele and Orbis Business Intelligence
PHONE: 202-644-5110
DATE: December 10, 2019
Orbis Business Intelligence and Christopher Steele have cooperated voluntarily and fully
with the OIG’s investigation. Christopher Steele gave extensive testimony in person and by
Skype, all subject to 18 U.S.C. § 1001. Orbis also provided the OIG team unprecedented access
to Orbis internal company documentation, including contemporaneous memoranda of meetings
with the FBI.
OIG gave Orbis highly redacted portions of the draft report for review and comment.
Those portions contained numerous inaccurate and misleading statements as to which Orbis
submitted suggested corrections and clarifications. Some of Orbis’s suggestions appear to be
reflected in the final report. At the twelfth hour late Sunday evening, Orbis was informed by the
OIG that previously redacted material had been unredacted and that it contained negative
information about Christopher Steele. Orbis was given no opportunity to review, much less
comment, on this material.
The result is that the OIG Report contains several serious errors and misstatements that
require this response.
1. Orbis Was Never Given an Opportunity to Respond to the Claims of the Purported
“Primary Sub-Source.” The “unredacted” portions of the OIG Report, just described,
includes the material from pages 186 to 193 of the Report addressing alleged
discrepancies found in Orbis’s reporting based on interviews with Orbis’s “Primary Sub-
Source.” Orbis was not given an opportunity to respond to those materials. Public
discussions about a source are always fraught with danger for the source and the source’s
sub-sources. Had Orbis been given the opportunity to respond in a private session, the
statements by the “Primary Sub-Source” would be put in a very different light. The
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“Primary Sub-Source’s” debriefings by Orbis were meticulously documented and

recorded.
2. Orbis’s Investigation Relating to the 2016 Election was Performed on Behalf of a

Private Client, Fusion GPS, Which Owns the Rights to the Intelligence Gathered by
Orbis. Orbis’s 2016 election reports were gathered and written for a private client,
Fusion GPS. Fusion paid for the work, owned the intellectual property, and controlled
what was done with the information in the reports. Fusion consented to Orbis voluntarily
sharing the reports with the FBI, but the FBI had no control over what Fusion or Orbis
did with those reports. The FBI knew Fusion was Orbis’s client from its very first
meeting with Orbis about this work in July 2016. In this regard, the OIG concluded in its
report that “at the outset of Steele’s interactions with the FBI in July 2016 regarding his
election reporting work, it was clear that Steele was operating as a businessperson
working on behalf of a client of his firm, rather than a CHS for the FBI.” OIG Report, p.
387.
3. Christopher Steele Was Never a Confidential Human Source (“CHS”) for the FBI
With Respect to Any Matter. At numerous places in the Report, the OIG applies the
label “CHS” to Christopher Steele. In 2013, after having received a number of Orbis
reports done for private clients, the FBI decided it wanted to engage Christopher Steele to
conduct investigations on the FBI’s behalf. The FBI at that time had no history of
contracting out work to private investigatory firms. The question then was how to
characterize the relationship between Orbis, Christopher Steele, and the FBI. Orbis and
Christopher Steele repeatedly told the FBI that he could not be a CHS because his
obligations to his former government employer prohibited his acting in such a capacity.
The OIG Report acknowledges that “Steele made available for the OIG’s review
documentation referring to such a prohibition.” OIG Report, p. 88. Orbis and
Christopher Steele told the FBI that the only acceptable arrangement was a contractual
relationship between Orbis and the FBI—the same relationship Orbis had with its other
clients. Nevertheless, FBI agents, for internal FBI purposes, decided to call Christopher
Steele a “CHS.”
That label flies in the face of considerable evidence and of reality. Before doing work for
the FBI, Orbis wrote a letter seeking permission to do that work from the UK
government. That letter describes a “commercial relationship” between Orbis and the
FBI and states that the information provided to the FBI would come from the firm. See
Attached Letter; see also OIG Report, p. 87. At about the same time, the FBI also wrote
to the UK Government stating “Steele is providing the FBI with information . . . .
provided primarily through Mr. Steele’s privately owned company, Orbis Business
Intelligence . . . .” OIG Report, p. 87. The FBI’s letter added: “In order to properly
protect this information and Mr. Steele’s relationship with the FBI, our . . . Office will
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treat any material provided as information obtained through a Confidential Human

Source.” OIG Report, p. 87. Christopher Steele’s wife, because of her UK government
employment, disclosed the relationship in the same terms. In fact, work done by Orbis
for the FBI was performed not just by Christopher Steele but also by Orbis Co-Director
Christopher Burrows, various Orbis employees, and Orbis source networks. Discussions
and messages between the FBI and Orbis as to payments for work done included
Christopher Burrows as well as Christopher Steele. All payments from the FBI were
received by Orbis, not by any individual.
The OIG Report acknowledges that there is evidence to support “Steele’s position” that
he was never a CHS and the Report concludes that the FBI and Christopher Steele never
came to “a shared understanding on the terms of their relationship.” OIG Report, pp.
386, 390.
4. The FBI Never Asked Christopher Steele Not to Disclose Information to the Media.
There were two meetings between Christopher Steele and FBI agents that addressed
Orbis’s investigation. At neither meeting, and at no other time, did the FBI ask
Christopher Steele not to disclose information from Orbis reports to the media—a request
he would have, in any event, had to reject given the requirements of his private client.
The FBI’s records and statements recounted in the OIG Report on this point are
unreliable and inaccurate.
The first meeting, initiated by Orbis, was held in July 2016 and attended by one FBI
agent and, for Orbis, Christopher Steele and Christopher Burrows. Significantly, we
understand, the FBI agent’s record of the meeting does not mention that Burrows
attended the meeting, much less, as Orbis’s contemporaneous memorandum of the
meeting shows, that he was an active participant in the meeting. The agent’s failure to
record that Christopher Burrows participated in the meeting is unprofessional and a
serious omission. As such, and as highlighted by us in our review, it should have been
addressed in the body of the OIG Report.
The second meeting occurred on October 3, 2016 and was attended by four FBI agents
and Christopher Steele. The OIG Report devotes considerable attention to this meeting.
The Report shows that the FBI agents who attended the meeting have very different
recollections of what was and was not discussed at the meeting. For Orbis’s part, what
was discussed at the meeting was recorded in detail shortly after the meeting in an
internal Orbis memorandum that has been shown to OIG investigators in unredacted
form. Moreover, the OIG found that “[t]he notes that Steele made available to the OIG to
review . . . were consistent with his testimony to the OIG.” OIG Report, p. 112, n.248.
That memorandum confirms Christopher Steele’s testimony on two key points: First, he
explicitly stated that his client was Fusion and he would not “dump[]” Fusion in favor of
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the FBI. OIG Report, p. 112. Second, the subject of contacts with the media was not
mentioned by anyone at the meeting—a subject that, had it come up, would certainly
have been recorded in Orbis’s internal memorandum since, at the direction of Fusion,
Christopher Steele and Fusion had just had an “off the record” meeting with
representatives the media. See OIG Report, p. 113. Christopher Steele would have had
no reason to deny these media contacts if asked about them by the FBI, as they related to
intellectual property that belonged to Fusion, Orbis’s paying client on this project, and
not the U.S. Government.
5. Carter Page Has Himself Acknowledged the Accuracy of Information in Orbis’s

Reporting About Him. The Report appears to suggest that none of Orbis’s reporting
about Carter Page has been corroborated. To the contrary, Carter Page has himself
corroborated key aspects of Orbis’s reporting. In particular, Page has admitted to having
met with an associate of Igor Sechin, the head of Russian oil company Rosneft, and
having discussed U.S. sanctions lift and the sale of a significant portion of Rosneft. See
Mueller Report, pp. 100-101, 166 n. 1195; see also 11/2/17 Carter Page Testimony
Before the House Permanent Select Committee on Intelligence, pp. 138-140.
6. The Report Inaccurately Attributes an Intelligence Report to Orbis. The Report

suggests that Orbis had reported that there were links between the Alfa Bank server and
Trump Tower. In fact, Orbis did not investigate or report on that issue. Christopher
Steele merely passed on what he had heard from various sources, including public ones,
on this subject, consistent with the FBI’s request that he share with them any relevant
information that he came across. Even a minimal investigation by the FBI would have
found articles in major publications that describe the computer scientists who claimed to
have found this alleged link; indeed, a prominent New Yorker article recounts how one of
those computer scientists brought the analysis to the FBI prior to the 2016 election. Yet
the OIG Report cites an FBI expert as pointing to this issue as a reason to question the
quality of Orbis reports.
###

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BREDHOFF & KAISER, P.L.L.C.

Attorneys & Counselors

FOR IMMEDIATE RELEASE

CONTACTS: Robert Weinberg and Joshua Shiffrin

DATE: December 10, 2019

“Primary Sub-Source’s” debriefings by Orbis were meticulously documented and

2. Orbis’s Investigation Relating to the 2016 Election was Performed on Behalf of a

treat any material provided as information obtained through a Confidential Human

5. Carter Page Has Himself Acknowledged the Accuracy of Information in Orbis’s

6. The Report Inaccurately Attributes an Intelligence Report to Orbis. The Report

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