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 Government of Ukraine had taken substantial anticorruption reform actions.$294$ Ms. Cooper and others at DOD conducted a review to evaluate whether Ukraine had met the required benchmarks.$295$ Ms. Cooper explained that the review involved "pulling in all the views of the key experts on Ukraine defense, and coming up with a consensus view," which was then run "up the chain in the Defense Department, to ensure we have approval."$296$

On May 23, 2019, Under Secretary Rood certified to Congress that Ukraine had completed the requisite defense institutional reforms to qualify for the remaining $125 million in funds. He wrote:

"On behalf of the Secretary of Defense, and in coordination with the Secretary of State, I have certified that the Government of Ukraine has taken substantial actions to make defense institutional reforms for the purposes of decreasing corruption, increasing accountability, and sustaining improvements of combat capability enabled by U.S. assistance.$297$"

Congress then cleared the related Congressional notification, which enabled DOD to begin obligating the remaining $125 million in funds.$298$

On June 18, 2019, DOD issued a press release announcing its intention to provide $250 million in security assistance funds to Ukraine "for additional training, equipment, and advisory efforts to build the capacity of Ukraine's armed forces." DOD announced that the security assistance would provide Ukraine with sniper rifles, rocket-propelled grenade launchers, and counter-artillery radars, command and control, electronic warfare detection and secure communications, military mobility, night vision, and military medical treatment.$299$

On February 15, 2019, Congress also appropriated $115 million for Ukraine through the State Department-administered Foreign Military Financing Program (FMF).$300$ The Foreign Military Financing Program is administered by the State Department and provides grants or loans to foreign countries to help them purchase military services or equipment manufactured by U.S. companies in the United States. In addition to the $115 million appropriated for fiscal year 2019, approximately $26 million carried over from fiscal year 2018.$301$ Thus, the total amount of foreign military financing available for Ukraine was approximately $141 million.

Before a country receives foreign military financing, the State Department must first seek Congressional approval through a notification to Congress.$302$ The State Department never sent the required Congressional notification to Congress in the spring or summer of 2019. As described below, OMB blocked the notification.$303$

President Trump Had Questions About Ukraine Security Assistance

The day after DOD issued its June 18 press release announcing $250 million in security assistance funds for Ukraine, President Trump started asking OMB questions about the funding for Ukraine. On June 19, Mark Sandy, Deputy Associate Director for National Security Programs at OMB, was copied on an email from his boss, Michael Duffey, Associate Director for National Security Programs at OMB, to Elaine McCusker, Deputy Under Secretary of