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 notice to the Department is not enough; the Attorney General must approve the opening of the investigation.

The memorandum also directs: The Attorney General recently reaffirmed the need to adhere to the requirements of the Sensitive Investigations Memorandum that govern “the opening of criminal and counter-intelligence investigations by the Department … related to politically sensitive individuals and entities.”
 * Department components to “review their existing policies governing notification, consultation, and/or approval of politically sensitive investigations,” provide a summary of those policies, and recommend “any necessary changes or updates.”
 * The Department to study, after the 2020 elections, “its experiences and consider whether changes” to the requirements in the memorandum are necessary.

b.&emsp;

In 2020, following various OIG reviews, the FBI undertook a “comprehensive review” of the 2006 CHS Guidelines “to ensure that the FBI’s source validation process was wholly refocused, revised, and improved across the FBI.” The 2020 CHS Guidelines thus provide additional direction to the FBI in the handling of human sources. They require information about whether the CHS “is reasonably believed to be a current or former subject or target of an FBI investigation.” There is also a new requirement for information about a source’s reporting relationship with other government agencies. At the time when the Attorney General approved the Guidelines, he also directed that “pending further guidance” he or the Deputy Attorney General must approve “any use” of a CHS “to target a federal elected official or political campaign … for the purposes of investigating political or campaign activities.”