Sen. Chuck Grassley, R-Iowa, on Thursday released a Justice Department memorandum dated April 2022 showing that then-Attorney General Merrick Garland, then-Deputy Attorney General Lisa Monaco, and then-FBI Director Christopher Wray personally authorized an FBI investigation into alleged efforts by associates of Donald Trump’s 2020 campaign to obstruct Congress’ certification of the election.

Grassley posted the four-page document on X, saying it demonstrated that top Biden administration officials “personally approved” the case — identified internally as “Arctic Frost” — and “unleashed unchecked government power at the highest levels.” He added, “My oversight will continue.”

The April 2022 authorization allowed the FBI’s Washington Field Office to open what it classified as a “Sensitive Investigative Matter.”

The memo outlines the bureau’s request to determine whether individuals connected to Trump’s 2020 campaign conspired to obstruct Congress during the certification of the Electoral College on January 6, 2021.

According to the executive summary, “Following the 2020 Presidential and Vice Presidential election, in an apparent effort to obstruct Congress’s certification of Electoral College, fraudulent certificates of electors’ votes were submitted to the Archivist of the United States, purporting to represent the actual elector votes from the states of Arizona, Georgia, Michigan, Nevada, and Wisconsin.”

It continued, “Open source reporting and public statements made by individuals closely associated with Donald J. Trump, Inc. (Trump Campaign) present an articulable factual basis indicating the existence of a federal crime, and thus the FBI seeks to open a full investigation.”

The memo added that “because this investigation involves a SIM as set forth in the Department of Justice memorandum dated February 5, 2020, entitled ‘Additional Requirements for Opening of Certain Sensitive Investigations’ (DOJ Memo), your authorization is required before WFO may initiate this full investigation.”

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Monaco wrote at the bottom of the document, “Merrick- I recommend you approve,” and initialed it on April 5, 2022. Garland signed off on the same day, completing the approval process.

Just received this doc frm DOJ Proof that Biden Atty General Merrick Garland+ Deputy Atty General Lisa Monaco+ FBI Dir Chris Wray all PERSONALLY APPROVED opening Arctic Frost

This investigation unleashed unchecked govt power at the highest levels My oversight will continue pic.twitter.com/atuRnC8ara

— Chuck Grassley (@ChuckGrassley) October 23, 2025

The authorization occurred more than a year after the January 6 Capitol riot and months before Special Counsel Jack Smith was appointed to oversee related cases. The memo marks an early step in the Justice Department’s inquiry into the “fake electors” matter that later became a key focus of Smith’s work.

In 2023, Smith’s office issued subpoenas seeking phone records for eight Republican senators and one House member. The records covered the period from January 4 to January 7, 2021, and included details such as numbers dialed, dates, and call durations.

The targeted senators included Marsha Blackburn of Tennessee, Josh Hawley of Missouri, and Lindsey Graham of South Carolina.

Sen. Ted Cruz, R-Texas, told Fox News host Sean Hannity on Tuesday that he recently learned Smith also attempted to subpoena his toll records but said his provider, AT&T, declined to provide them.

Smith later defended the subpoenas, saying they were “narrowly tailored and entirely proper.” His attorneys told Grassley that the requests complied with Justice Department procedures and were part of routine investigative work.

Republican lawmakers have criticized the operation, alleging it amounted to political surveillance and likening it to the Watergate scandal. Smith’s legal team disputed those claims and argued the subpoenas were appropriately documented and disclosed.

They said the requests were referenced in a footnote of Smith’s final report and were shared with Trump’s defense team during discovery.

Grassley’s release of the memo renewed scrutiny over how senior Justice Department officials managed politically sensitive investigations during the Biden administration, and whether proper oversight and accountability mechanisms were maintained.