OPINION:
The Biden Justice Department and prosecutor Jack Smith were involved in more than just destroying President Trump in 2022-2023 as a presidential candidate.
We now know, thanks to Sen. Charles E. Grassley and documents provided by an FBI whistleblower, that Attorney General Merrick Garland’s team launched a much more exhaustive investigation.
Called Arctic Frost, the FBI onslaught focused on Mr. Trump and on the conservative movement, its money, infrastructure and brain trusts. The FBI theory was that groups such as the Republican National Committee contributed to Mr. Trump’s claims that the 2020 election count was rigged.
In September, Mr. Grassley disclosed the existence of FBI subpoenas for Republicans’ bank records as special counsel Jack Smith worked toward an indictment of Mr. Trump for attempting to reverse his 2020 election loss. Those fraud charges went dormant after Mr. Trump won the presidency in 2024. Mr. Garland, Mr. Biden’s attorney general, appointed Mr. Smith as special counsel on Nov. 18, 2022. Mr. Smith assumed control of Arctic Frost as FBI agents continued to issue subpoenas into 2023.
Talk about an enemy’s list. Talk about a fishing expedition. The Grassley whistleblower supplied a spreadsheet created by FBI agents from Arctic Frost. The Excel document comprises more than 90 names and groups, a who’s who in Republican power circles, their banks, and the dates subpoenas were issued in 2022-2023.
“Arctic Frost wasn’t just a case to politically investigate Trump. It was the vehicle by which partisan FBI agents and Department of Justice prosecutors could achieve their partisan ends and improperly investigate the entire Republican political apparatus,” Mr. Grassley said.
The FBI subpoenas went right to the top: The Republican National Committee, the Republican Attorneys General Association and the Trump-inspired America First Policy Institute.
The think tank is powered by Trump-aligned movers and shakers who have emerged as critical outside advisers to Mr. Trump’s second term. Its co-founder is Larry Kudlow, a senior economic adviser to Mr. Trump during his first term and now host of “Kudlow” on the Fox Business Network.
In 2022, the FBI sent subpoenas to Wells Fargo Bank, according to the spreadsheet. The result: “No records were found.” The reason for pursuing America First was for its “bogus investigations,” the FBI paper said.
In other words, if you questioned the election and looked into it, and you were close to Mr. Trump, the FBI tried to nail you.
“The inclusion of the America First Policy Institute in the ’Arctic Frost’ investigation is nothing short of an outrageous example of weaponized government by the Biden Administration FBI, who used this effort to abuse taxpayer resources and intimidate and smear conservative organizations,” Jenn Pellegrino, AFPI’s chief spokesperson, told me “Such misuse of federal law enforcement is an affront to our democratic principles and cannot be tolerated.”
I looked at some of the America First Policy Institute’s initiatives. The organization touts 10 “pillars,” and No. 8 is a basic voter integrity approach. These include photo ID requirements, voter roster cleanup of dead people and nonresidents, and a rule that votes must be returned by Election Day — commonsense ideas not favored by the Biden FBI or Democrats.
In September, the Trump administration announced that the America First Policy Institute will lead its America 250 Civics Education Coalition, which is tied to America’s 250th birthday, in partnership with the Department of Education.
Other prominent conservative groups listed on the Excel hit list:
• The Charlie Kirk-founded Turning Point USA. Before he was stopped by an assassin last month, Kirk conducted highly successful college-by-college tours to spread conservative values to students under the control of Democratic-dominated faculty.
• The Republican Attorneys General Association and its Rule of Law Defense Fund, which challenged Biden policies in court, the Tea Party Express, Make America Great Again PAC, Citizens United, and Brad Parscale, a digital guru whom Mr. Trump replaced as campaign manager in 2020.
Mr. Grassley released a second whistleblower document. Dated Jan. 23, 2023, two months after Mr. Smith became prosecutor, the file summarized the FBI’s extensive work to try to catch Republicans in a conspiracy with Mr. Trump. The summary stated: “Investigation into the multifaceted conspiracy to overturn the results of the 2020 Presidential Election so that former President Trump could remain in office. This conspiracy involved subjects from the private sector, in numerous battleground states, and the Department of Justice and the White House.”
The paper listed seven criminal offenses, including “propagating false election fraud allegations.” It also listed the project by some Trump backers to field alternative electors and a plan to pressure Vice President Mike Pence to reject some of the Biden electors as he presided over the House of Representatives. Mr. Pence refused.
Mr. Smith brought a four-count indictment against Mr. Trump in August 2023.
On April 4, 2025, Mr. Grassley and Sen. Ron Johnson released details on how the FBI cranked up Arctic Frost. The two said “anti-Trump” FBI agent Timothy Thibault played a central role in opening and staffing the investigations despite other agents saying he lacked evidence. The senators also disclosed that Jonathan Su, deputy counsel to the Biden White House, facilitated the turnover of government cellphones used by Messrs. Trump and Pence to the FBI.
Mr. Thibault retired in August 2022.
A Senate source said Special Agent Walter Giardina authored the Excel spreadsheet on bank subpoenas targeting conservatives. In a June letter to Attorney General Pam Bondi and FBI Director Kash Patel, Mr. Grassley accused Mr. Giardina of misconduct. He said the agent openly “stated his animosity toward President Trump.” He also vouched for the debunked Democratic-financed dossier extensively used by the FBI to sabotage Mr. Trump.
Mr. Giardina was among five agents the FBI fired in August.
• Rowan Scarborough is a columnist with The Washington Times.
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