The newly revealed FBI memo that authorized the Biden-era Arctic Frost investigation into former President Donald Trump and several of his political allies is raising serious questions among former federal prosecutors, legal analysts, and retired FBI officials.
According to experts who reviewed the document, the memo lacked strong supporting evidence, relied on speculative sources, and contained several procedural weaknesses that would ordinarily fall short of triggering such a far-reaching federal probe.
The Arctic Frost investigation was launched in the spring of 2022, roughly the same period in which Trump publicly announced his intention to run for president again.
The internal memo that initiated the probe treated the efforts by certain Republican officials to submit alternate slates of electors during the 2020 election certification as a possible criminal conspiracy.
While the issue of alternate electors is highly debated, historical parallels exist: similar actions occurred in two previous presidential elections without resulting in any criminal prosecutions.
The concerns deepened when analysts noted that the memo reportedly leaned heavily on interview clips from CNN, using them as primary indicators that Trump may have played a role.
For many legal observers, relying on media interviews instead of firsthand investigative evidence is highly unusual for a case classified as a Sensitive Investigative Matter (SIM) — a designation reserved for probes involving political figures, religious organizations, journalists, or other constitutionally protected groups.
Critics Draw Parallels to the 2016 “Crossfire Hurricane” Investigation
House Judiciary Committee Chairman Jim Jordan has been one of the most vocal critics of the Arctic Frost memo.
After obtaining the document from FBI Director Kash Patel, Jordan argued that he sees clear similarities between this investigation and the FBI’s earlier “Crossfire Hurricane” probe into alleged Trump-Russia ties during the 2016 election.
According to Jordan, both cases demonstrate a pattern of political bias, insufficient evidence, and an investigative approach that risked compromising public trust in federal institutions.
“It looks like the same old weaponization, the same old political mindset — going after your political opponents with weak evidence,”
Jordan stated during an interview on Just the News, No Noise.
He further claimed that Arctic Frost appeared to follow the same logic that allowed the discredited Steele dossier to be included in intelligence assessments in 2016, despite internal warnings that it lacked verified evidence.
Special Counsel Jack Smith Responds
Special Counsel Jack Smith, who inherited the investigation later in 2022, has consistently denied any wrongdoing. Smith insists that his office followed proper legal standards and that he intends to share his side of the story when appropriate.
ordan has invited Smith to testify before Congress and warned that a subpoena would follow if Smith chooses not to appear voluntarily.
The Investigation’s Approval Came From the Highest Levels
Recent documents released by Kash Patel further reveal that the Arctic Frost investigation underwent approval by several top officials within the Biden administration, including:
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Attorney General Merrick Garland
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Deputy Attorney General Lisa Monaco
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FBI Director Christopher Wray
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A White House attorney who assisted during the review process
This multi-layered approval structure indicates that senior leadership across multiple agencies reviewed and signed off on the probe — another detail that has amplified public interest.
The Scope of the Investigation Expands Dramatically
Once the investigation moved from the FBI into Special Counsel Jack Smith’s office, its reach expanded significantly.
Smith’s team issued 197 subpoenas, according to materials released by Senator Chuck Grassley, and sought information from more than 400 Republican organizations and individuals.
