' Classified information at any level can be further restricted through compartmentation in Sensitive
Compartmented Information (“SCI”) categories. Only individuals with the appropriate security
clearance and additional SCI clearance(s) can have access to such classified information.
3Page 4 America Online (“AOL”) email account, a Google email account, a non-governmental commercial
messaging application, or other non-governmental systems.
7. While National Security Advisor, BOLTON learned national defense and classified
information through a variety of means, including intelligence briefings, intelligence reports, and
meetings with members of the U.S. intelligence community, including the National Security Agency
(“NSA”) and the Central Intelligence Agency (“CIA”), the U.S. military, and foreign government
officials. In addition to having a home SCIF, while National Security Advisor, BOLTON also had
access to a variety of secure telecommunication systems that he could use to discuss and
communicate classified information. Moreover, BOLTON had access, as the National Security
Advisor, to classified spaces in the White House, the Eisenhower Executive Office Building, and
other locations, in the Washington, D.C., area and elsewhere, where he could readily learn, read,
and discuss classified and sensitive information with others who were authorized to know, receive,
discuss, and make decisions based on such information.
8. From on or about April 9, 2018, through at least on or about August 22, 2025,
BOLTON abused his position as National Security Advisor by sharing more than a thousand pages
of information about his day-to-day activities as the National Security Advisor—including
information relating to the national defense which was classified up to the TOP SECRET/SCI
level—with two unauthorized individuals, namely Individuals 1 and 2. BOLTON also unlawfully
retained documents, writings, and notes relating to the national defense, including information
classified up to the TOP SECRET/SCI level, in his home in Montgomery County, Maryland.
9. Individual 1, whose identity is known to the Grand Jury, was related to BOLTON,
resided in the District of Maryland, never held a U.S. security clearance, and was not authorized to
access, receive, or maintain the classified information that BOLTON shared related to his work as
the National Security Advisor.Page 5 10. Individual 2, whose identity is known to the Grand Jury, was related to BOLTON,
never held a U.S. security clearance, and was not authorized to access, receive, or maintain the
classified information that BOLTON shared related to his work as the National Security Advisor.
11. From on or about April 9, 2018, through on or about September 15, 2019, on a
regular basis, BOLTON sent diary-like entries to Individuals 1 and 2 that contained information
classified up to the TOP SECRET/SCI level. BOLTON wrote many of these diary-like entries by
transcribing his handwritten notes from his day’s activities into word processing documents, which
he then electronically sent to Individuals 1 and 2 through a commercial non-governmental
messaging application. On other occasions, BOLTON used his personal non-governmental email
accounts, such as email accounts hosted by AOL and Google, to email information classified up to
the TOP SECRET/SCI level to Individuals 1 and/or 2 at their personal email accounts. At no point
did BOLTON have authorization to store or transmit the classified information that he sent to
Individuals 1 and 2 via his personal electronic devices and accounts. Nor did, at any time,
Individuals 1 or 2 have authorization to know or store the classified information that BOLTON
gave to them.
12. At some unknown time, but no later than August 22, 2025, many of the diary-like
entries from BOLTON’s time as the National Security Advisor, including entries that contained
national defense information classified up to the TOP SECRET/SCI level, were printed and stored
in BOLTON’s personal residence in Montgomery County, Maryland. Digital copies of some of
the diary-like entries that contained national defense information classified up to the TOP
SECRET/SCI level were also stored on personal electronic devices used by BOLTON and others
located in BOLTON’s personal residence in Montgomery County, Maryland, on August 22, 2025.
13. After BOLTON’s time as National Security Advisor ended on September 10, 2019,
BOLTON’s personal residence was not authorized to store classified information in physical or
5Page 6 electronic format. On or about September 10, 2019, U.S. Government personnel retrieved all
classified equipment and marked classified documents that were stored in BOLTON’s home SCIF.
During that visit, BOLTON was told that he could no longer store classified information at his
home. At no point during BOLTON’s time as the National Security Advisor or afterwards,
including when his home SCIF was decommissioned in or about September 2019, did BOLTON
tell the U.S. Government personnel that he had sent national defense and classified information to
Individuals 1 and 2 over commercial email and messaging services or that such information was
stored on personal electronic devices and in personal electronic accounts belonging to or accessible
by himself and/or Individuals | and 2.
14. At some point between when BOLTON left government service in September 2019
and July 2021, a cyber actor believed to be associated with the Islamic Republic of Iran hacked
BOLTON’s personal email account and gained unauthorized access to the classified and national
defense information in that account, which BOLTON had previously emailed to Individuals 1 and
while he was the National Security Advisor. A representative for BOLTON notified the U.S.
Government of the hack in or about July 2021, but did not tell the U.S. Government that the account
contained national defense information, including classified information, that BOLTON had placed
in the account from his time as National Security Advisor. Nor did BOLTON’s representative tell
the U.S. Government that BOLTON had shared some of that national defense information,
including classified information, with Individuals 1 and 2 via personal email and a non-
governmental messaging application.
Classified Information
15. Executive Order 13526 governed the classification of national security information.
Information in any form may be classified if it: (1) is owned by, is produced by or for, or is under
the control of the U.S. Government; (2) could, if disclosed, cause one or more specified levels of
6Page 7 harm to the United States; and (3) is classified by or under an Original Classification Authority
(“OCA”) who determines that its unauthorized disclosure reasonably could be expected to result in
damage to the national security. OCAs, also called original classifiers, were individuals authorized
to classify information and make classification decisions.
16. Pursuant to Executive Order 12958 signed on April 17, 1995, as amended by
Executive Order 13292 on March 25, 2003, and Executive Order 13526 on December 29, 2009,
national security information was classified as “TOP SECRET,” “SECRET,” or
“CONFIDENTIAL.” National security information was information owned by, produced by,
produced for, and under the control of the U.S. Government that was classified as follows:
a. Information was classified as TOP SECRET if the unauthorized disclosure of that
information reasonably could be expected to cause exceptionally grave damage to
the national security that the original classification authority was able to identify and
describe.
b. Information was classified as SECRET if the unauthorized disclosure of that
information reasonably could be expected to cause serious damage to the national
security that the original classification authority was able to identify and describe.
c. Information was classified as CONFIDENTIAL if the unauthorized disclosure of
that information reasonably could be expected to cause damage to the national
security that the original classification authority was able to identify and describe.
17. | Under Executive Order 13526, “damage to the national security” meant harm to the
national defense or foreign relations of the United States from the unauthorized disclosure of
information, taking into consideration such aspects of the information as the sensitivity, value,
utility, and provenance of that information.
18. The classification marking “NOFORN” indicated that the information was “Not
Releasable to Foreign Nationals” and dissemination of that information was limited to United States
persons. The classification marking “REL TO” indicated that the information was releasable only
to foreign nationals of specified countries, international organizations, or multinational forces. ThePage 8 classification marking “REL TO USA GBR” indicated that the information could only be released
to nationals of the United States and Great Britain.
19. The classification marking “ORCON” indicated that the dissemination and
extraction of the classified information was controlled (“CON”) by the originator (“OR”).
20. Classified information related to intelligence sources, methods, and analytical
processes was designated as SCI and subject to additional controls, such as the SI and HCS controls
described further below.
21. ‘The classification marking “SI” was an SCI control system that indicated that the
information was “Special Intelligence” and that the intelligence information was derived from the
monitoring of foreign communications signals by individuals other than the intended recipients. SI
was intended to protect signals intelligence (“SIGINT”) including communications and electronics
intelligence. The National Security Agency (“NSA”) was responsible for providing foreign SIGINT
to U.S. policymakers and military forces.
22. The classification marking “HCS” was an SCI control system that indicated that the
information was from the most sensitive human intelligence (“HUMINT”) operations and
information acquired from clandestine and/or uniquely sensitive HUMINT sources, methods, and
certain technical collection capabilities, technologies, and methods linked to or supportive of
HUMINT.
23) SCI was to be processed, stored, used, or discussed in an accredited SCIF, and only
individuals with the appropriate security clearance and additional SCI permissions were authorized
to have access to such national security information.
24. The National Institute of Standards and Technology defined a SCIF as an area, room,
group of rooms, buildings, or installation certified and accredited as meeting Director of NationalPage 9 Intelligence security standards for the processing, storage, and/or discussion of sensitive
compartmented information.
25. ‘Intelligence Community Directive 705, titled “Sensitive Compartmented
Information Facilities,” signed on May 26, 2010, by the Director of National Intelligence, provided
that “all SCI must be processed, stored, used, or discussed in an accredited SCIF.”
26. Pursuant to Executive Order 13526, information classified at any level could only be
lawfully accessed by persons determined by an appropriate U.S. Government official to be eligible
for access to classified information, who had signed an approved non-disclosure agreement,
received a security clearance, and had a “need to know” the classified information. Classified
information could only be stored in an approved facility and container.
BOLTON’s Transmission of National Defense Information
to Individuals 1 and 2 While He Was National Security Advisor
27. As set forth above, between on or about April 9, 2018, and September 15, 2019,
BOLTON sent Individuals 1 and 2 contemporaneous notes, on a regular basis, describing in detail
his day-to-day activities as the National Security Advisor. BOLTON often referred to these notes
as his “diary” and sent them to Individuals | and 2 over his personal non-governmental email
accounts or a messaging application. The information contained in these notes included detailed
information that BOLTON learned from meetings with senior members of the U.S. Government,
intelligence briefings from members of the intelligence community and military, discussions with
foreign leaders and foreign intelligence and military organizations, and intelligence products and
reports, which BOLTON had access to because of his role as National Security Advisor. Portions
of the information contained in the “diary” entries that BOLTON sent to Individuals 1 and 2 were
national defense information, including information classified up to the TOP SECRET/SCI level.Page 10 28. Throughout his time as National Security Advisor, BOLTON took detailed notes
documenting his day-to-day meetings, activities, and briefings. Frequently, BOLTON handwrote
these notes on yellow notepads throughout his day at the White House complex or in other secure
locations, and then later re-wrote his notes in a word processing document on an electronic device.
29. The notes that BOLTON sent to Individuals 1 and 2 using his non-governmental
personal email accounts and messaging account described in detail BOLTON’s daily activities as
the National Security Advisor, including national defense and classified information that he learned
during his time as National Security Advisor. Often, BOLTON’s notes described the secure setting
or environment in which he learned the national defense and classified information that he was
memorializing in his notes. For example, a description of classified information related to a foreign
government’s activities might begin with “the intel briefer said...” Or a description of classified
information learned during a military briefing might begin with “while in the Situation Room, |
learned that...” The notes that BOLTON sent to Individuals 1 and 2 often began with the words,
“[Individual 1’s initials/Individual 2’s initials] start here.” In at least one communication,
BOLTON also referred to Individuals | and 2 as his “editors.”
30. Some of the information related to the national defense that BOLTON
communicated, delivered, and transmitted to Individuals | and 2 is described in further detail below
and in Counts One through Eight.
a1. On or about April 8, 2018, the day before BOLTON officially began his duties as
National Security Advisor, Individual | created a group chat with BOLTON and Individual 2 on a
non-governmental messaging application. Individual 2 asked the group, “Why are we using this
now? The encryption?” to which Individual 1 responded, “Yup. Why not?” BOLTON then
responded, “For Diary in the future!!!”Page 11 32, On or about April 22, 2018, BOLTON sent Individuals 1 and 2 via the non-
governmental messaging application a 25-page document which described information that
BOLTON learned while National Security Advisor.
33. | Onor about April 22, 2018, Individual 2 sent BOLTON and Individual | a message
that stated, “Diary finished... .” Individual 1 also asked Individual 2 whether Individual 2 was
“going to call tonight,” to which Individual 2 responded, “Am I supposed to?” Individual 1 then
wrote, “Diaries take time to write, but phone conversations take less time. . . .”
34, On or about July 15, 2018, Individual 2 sent BOLTON and Individual 1 a message
that stated, “Do we get a diary today?” Individual 1 responded, “Don’t think he can do it on this
trip.” BOLTON later added, “Too much going on!!! I’ve done much of Friday in London because
I didn’t take many notes and wanted to get it down before I forgot!!!”
35. On or about July 23, 2018, BOLTON sent Individuals | and 2 a message that stated,
“More stuff coming!!!” A few minutes later, BOLTON sent Individuals 1 and 2 a 24-page
document which described information that BOLTON learned while National Security Advisor.
Less than three hours later, BOLTON sent Individuals | and 2 a follow-up message that stated,
“None of which we talk about!!!" In response, Individual 1 sent a message that stated, “Shhhhh.”
Individual 2 then sent a message that stated, “The only interesting thing is what [senior U.S.
Government official] might have said from [foreign language] interpreter, which you didn’t tell
us...” Approximately two minutes later, Individual 1 sent a message in response that stated, “More
to come with cloak and dagger...or something. So he says....”
36. On or about September 23, 2018, BOLTON sent Individuals 1 and 2 a 10-page
document (“Document A”), which contained information that BOLTON learned while National
Security Advisor, including information classified up to the TOP SECRET/SCI level.
11Page 12 37. On or about November 23, 2018, BOLTON sent Individuals 1 and 2 a 29-page
document (“Document B”), which contained information that BOLTON learned while National
Security Advisor, including information classified up to the SECRET/NOFORN level.
38. On or about December 2, 2018, BOLTON sent Individuals 1 and 2 a 15-page
document, which contained information that BOLTON learned while National Security Advisor.
Individual 2 responded, “Diary arrived” and then sent a message that stated, “But no commentary
on [Foreign Country 1] judicial system article I sent or administration sentiment on [arrest in
Foreign Country 1]?” In response, BOLTON sent a message that stated, “I’m working on it!!!”
39. On or about December 4, 2018, Individual 2 sent additional messages to BOLTON
and Individual 1 regarding the arrest of an individual in Foreign Country 1. Individual 2 told
BOLTON and Individual | that the arrested individual in Foreign Country | was being interrogated
and that a relative of the arrested individual would “be in DC . . . if useful to get him in front of
[senior U.S. Government official] or anyone else.” In response to Individual 2’s message that law
enforcement in Foreign Country | was interrogating the arrested individual, Individual 1 sent a
message that stated, “Ye gods. Next thing they'll pull a Khashoggi? on him.” In response,
Individual 2 sent a message that asked, “But [nickname for BOLTON] has no feedback?”
40. On or about January 2, 2019, BOLTON sent Individuals 1 and 2 a 22-page
document, which contained information that BOLTON learned while National Security Advisor.
BOLTON also sent a message that stated, “Stuff coming!!! Hard copy at home for [nickname for
Individual 1]!!!!"
? Jamal Khashoggi was a Saudi journalist who was murdered in 2018 in the Consulate of Saudi
Arabia in Istanbul, Turkey.
12Page 13 41. On or about January 13, 2019, BOLTON sent Individuals 1 and 2 a 24-page
document (“Document C”), which contained information that BOLTON learned while National
Security Advisor, including information classified up to the TOP SECRET/SCI level.
42. About a week later, on or about January 21, 2019, BOLTON sent Individuals 1 and
a 20-page document, which contained information that BOLTON learned while National Security
Advisor. BOLTON sent an accompanying message that stated, “Stuff coming to cheer you...
up!!!” and that Individual 1 “needs to figure out how to do corrections!!!” In response, Individual
sent a message that stated, “Read [BOLTON’s] thing. I need to also.” Individual | also stated,
“T have edits. Para by para. Not sure how to send them. Mostly typos, caps, incomplete sentences.”
BOLTON then asked, “Did you print it out???” to which Individual 1 responded, “I read it on
phone. ... Took notes.”
43, On or about June 2, 2019, BOLTON sent Individuals 1 and 2 a 10-page document
(“Document D”), which contained information that BOLTON learned while National Security
Advisor, including information classified up to the TOP SECRET/SCI level.
44. On or about July 6, 2019, BOLTON sent Individuals 1 and 2 a 77-page document
(“Document E”), which contained information that BOLTON learned while National Security
Advisor, including information classified up to the TOP SECRET/SC] level.
45. On or about July 28, 2019, BOLTON sent Individuals 1 and 2 a message that stated,
“STUFF COMING, BUT ONLY FOR [Individual 2]??? [Individual 1] TO READ HARD COPY
WHEN [Individual 1] IS BACK IN USI!!!”
46. On or about August 18, 2019, BOLTON sent Individuals 1 and 2 a 50-page
document (“Document F”), which contained information that BOLTON learned while National
Security Advisor, including information classified up to the TOP SECRET/SCI level.
13Page 14 47. On or about September 8, 2019, BOLTON sent Individuals 1 and 2 a 47-page
document (“Document G”), which contained information that BOLTON learned while National
Security Advisor, inotadiag information classified up to the TOP SECRET/SCI level.
48. On or about September 15, 2019, five days after he was no longer the National
Security Advisor, BOLTON sent Individuals 1 and 2 a six-page document (“Document H”), which
contained information that BOLTON learned while National Security Advisor, including
information classified up to the TOP SECRET/SCI level. In a related message, BOLTON told
Individuals 1 and 2, “Stuff coming!!!” Individual 2 responded, “Dramatic ending. But will there
be a new diary,” to which Individual 1 responded, “Nope on diary. Now bookwriting [sic].”
BOLTON then sent a message that stated, “Talking with [book publisher] because they have a right
of first refusal!!!”
49. On or about September 24, 2019, fourteen days after he was no longer employed as
the National Security Advisor, BOLTON left the messaging chat group with Individuals 1 and 2
that he had used to send them more than a thousand pages of notes memorializing his time as
National Security Advisor.
Relevant Activities Before and After BOLTON’s Tenure as National Security Advisor Ends
BOLTON Publishes “The Room Where It Happened: A White House Memoir”
50. On or about September 11, 2019, the day after BOLTON’s tenure as National
Security Advisor ended, a literary agent representing BOLTON sent an email to a book publisher
describing a book about BOLTON’s time as the National Security Advisor that BOLTON intended
to publish. In that email, the literary agent stated, among other things, that BOLTON’s forthcoming
book would include BOLTON’s impressions of his time as National Security Advisor “in a
meticulously observed manner with direct quotes from all parties based on contemporaneous notes.”
Two months earlier and while BOLTON was still the National Security Advisor, on or about July
14Page 15 19, 2019, the literary agent sent BOLTON a letter stating that it was “with enthusiasm” that the
literary agent was “again exploring a book” with BOLTON. Ultimately, BOLTON earned more
than a million dollars by selling the rights to publish his book about his time as National Security
Advisor.
51. Onor about December 12, 2019, BOLTON began sending drafts of portions of his
book to his publisher and literary agent for review and comments. BOLTON sent these drafts via
a non-governmental messaging application. Over the winter holidays in 2019, BOLTON and his
editors exchanged drafts and comments relating to his forthcoming book.
52, On or about December 30, 2019, BOLTON submitted a manuscript of his book,
titled The Room Where It Happened: A White House Memoir to the NSC for the required pre-
publication review process. Based on an initial review of the manuscript by NSC staff, the U.S.
Government concluded and told BOLTON that the initial manuscript contained significant amounts
of highly classified information that needed to be removed.
53: On or about June 23, 2020, BOLTON’s book, The Room Where It Happened: A
White House Memoir, was published and became readily available to the public. None of the
classified national defense information charged in Counts One through Eighteen, further described
below, was published in BOLTON’s book.
54. On or about June 16, 2021, the United States and BOLTON entered a settlement
agreement resolving civil litigation relating to BOLTON’s book. As a condition of that settlement
agreement, BOLTON agreed to “provide to the United States all materials in his possession,
custody, or control that may contain any classified information.” BOLTON also agreed that his
obligation to return classified material “extends to any written or electronic drafts of the manuscript
[of his book] regardless of whether those materials were received from the United States or
generated by [BOLTON].”
15Page 16 BOLTON’s Representative Notifies the FBI that Iran Hacked His Personal Email Account
55: On or about July 6, 2021, a representative for BOLTON contacted the Federal
Bureau of Investigation (“FBI”) via email to alert the FBI that an entity, believed by BOLTON’s
representative to be the Islamic Republic of Iran, had obtained unauthorized access to one of
BOLTON’s personal email accounts. In the email to the FBI, BOLTON’s representative stated
that “evidently someone has gotten into Amb. Bolton’s” personal email account and that “it looks
as though it is someone in Iran. . . .”
56. On or about July 28, 2021, BOLTON’s representative emailed the FBI again to
report that BOLTON and his representative had received the following email, on or about July 25,
2021, which the representative believed was associated with the hack of BOLTON’s account:
I do not think you would be interested in the FBI being aware of the leaked content
of John’s email (some of which have been attached), especially after the recent
acquittal.
This could be the biggest scandal since Hillary’s emails were leaked, but this time
on the GOP side!
Contact me before it’s too late ...
BOLTON’ representative also told the FBI that the representative was “[j|ust sending you the text
(not the documents [the hacker] attached since there might be sensitive information in them).”
57. A day later, on or about July 29, 2021, BOLTON’s representative told the FBI that
BOLTON would be deleting the contents of his personal email account that had been hacked.
58. On or about August 5, 2021, BOLTON received another electronic message related
to the hack of his personal email account which stated, “OK John ... As you want (apparently),
we'll disseminate the expurgated sections of your book by reference to your leaked email...”
59. At no point did BOLTON tell the FBI that, while he was the National Security
Advisor, he had used the hacked email account to send Individuals 1 and 2 documents relating to
16Page 17 the national defense, including classified information. Nor did he tell the FBI that the hackers now
had this information.
The FBI Finds Documents Relating to the National Defense in BOLTON’s Home
60. On or about August 22, 2025, the FBI executed search warrants and seized material
from BOLTON’ residence in Maryland and office in Washington, D.C. Part of the material seized
from BOLTON’s Maryland home included electronic files showing that BOLTON transmitted his
diary entries, many of which related to the national defense and contained classified information, to
Individuals 1 and 2 through a non-governmental messaging application. During the court-
authorized search of BOLTON’s home on August 22, 2025, the FBI also seized hard copy printed
versions of many of BOLTON’s diary entries, including documents that related to the national
defense and contained classified information. Some of the documents related to the national defense
that the FBI found in BOLTON’s home on August 22, 2025, are described in further detail below
in Counts Nine through Eighteen.
BOLTON ’s Public Statements on the Handling of Classified Information
61. From at least on or about September 2, 2016, through on or about April 25, 2025,
BOLTON has made numerous public statements demonstrating his understanding of how to
properly handle classified information and the potential consequences of failing to do so.
62. On or about January 16, 2017, in a media interview, BOLTON stated in response to
a question about allegations that a senior U.S. Government official had communicated sensitive
government information using a personal email account, “Look, as I’ve said before, | believe it still
to this day, if I had done at the State Department what [senior U.S. Government official] did, I°d be
[imprisoned] right now.”Page 18 63.
On or about March 31, 2025, in a media interview, BOLTON stated in response to
questions about allegations that a senior U.S. Government official had communicated sensitive
government information using a non-governmental messaging application:
Well, I don’t, I mean, to me, I just can’t even imagine opening a Signal chat group
or a Telegram chat group or anything else. People say but the communications are
encrypted. Well that’s fine. We have the National Security Agency that has big
computers chug-chug-chugging along trying to deencrypt [sic] any system that we
want to try to get into and our adversaries do as well. . .. The damage that’s done
is that we’ve shown weakness in our operational security that our adversaries will
try to exploit... . What did we build the world’s most secure telecommunications
capability for if not to use it on sensitive matters. And once you’re on a secure
telephone — a U.S. government secure telephone — you don’t worry what the level
of classification you’re discussing. You’re talking about an article in the morning
newspaper or top secret code word items and you’re secure. When you’re on Signal,
did no one in that conversation for days ever say you know maybe we ought to get
off this and get back on a classified system. . . . It just. I’m just, without words, to
understand how that could have happened.
64.
On or about April 18, 2025, in a media interview, BOLTON stated in response to a
question about allegations that a senior U.S. Government official had communicated sensitive
government information using a non-governmental messaging application:
Initially, | was totally without words. I couldn’t-I couldn’t find-I couldn’t find a
way to express how stunned I was that anybody would do this. You simply don’t
use commercial means of communication, whether it’s supposedly an encrypted
app or not for for these kinds of discussions. You know, you don’t know where
they’re gonna go. You could start off talking about a newspaper article, but but
obviously you could get into classified material. I understand why you need to have
group chats, but as I’ve been saying the place for the group chats are the Situation
Room where everybody’s in place some people may have to appear via secure video
teleconference facilities, and and we’ve got great capacity to do that. But, but
having chat groups where you're writing two or three sentences that this is not what
you would call sophisticated national security analysis at work, and on an unsecured
channel. It just, there’s there’s no excuse for it.
6.
In an interview on March 26, 2025, BOLTON discussed the damage to national
security by using a non-governmental communication channel to discuss sensitive government
information:
18Page 19 What were they doing off of secure government channels? That is the original sin
here. That is the question neither one of them has yet answered. . . . I think actual
damage is possible because of the way foreign intelligence services operate, the
way our own intelligence services operate. You take everything you can get. You
take every piece of information in this case about American military operations
against the Houthis in Yemen. It tells you something that otherwise you wouldn’t
know about American capabilities, American tactics, American approaches to this
kind of thing, and that is useful to the Russians, the Chinese, the Iranians, the North
Koreans, and others as well. How that fits into the body of knowledge they already
have is a question I can’t answer, but it can’t help, that’s for sure.
66. On or about April 22, 2025, in a media interview, BOLTON addressed what he
considered the impropriety of discussing sensitive government information with people who do not
have a “need to know” that information (such as family and friends) using a non-governmental
messaging application:
I think the second example of a Signal chat group . . . really shows a terrible lack
of judgment communicating with the people in this group in particular who have
absolutely no need to know about any upcoming U.S. military operation leads me
to wonder what he’s doing on the job on a minute to minute, hour by hour basis that
he’s got time to - to knock out Signal messages to - to friends and family which is
what this group is.Page 20 THE CHARGES
COUNTS ONE THROUGH EIGHT
(Transmission of National Defense Information)
67. Paragraphs | through 66 of this Indictment are incorporated by reference as though
fully set forth herein.
68. On or about the dates indicated below, in the District of Maryland and elsewhere,
the defendant,
JOHN ROBERT BOLTON, II,
lawfully having possession of, access to, control over, and being entrusted with information relating
to the national defense, which information the defendant had reason to believe could be used to the
injury of the United States and to the advantage of any foreign nation, willfully communicated,
delivered, and transmitted and caused to be communicated, delivered, and transmitted the same to
a person not entitled to receive it, to wit: as indicated in the below counts, BOLTON sent via his
personal non-governmental email account(s) and/or his personal non-governmental messaging
application account the information relating to the national defense described below to Individuals
and 2:
COUNT | APPROXIMATE DOCUMENT HIGHEST
DATE OF DESCRIPTION CLASSIFICATION LEVEL
TRANSMISSION OF INFORMATION IN
DOCUMENT
| Sept. 23, 2018 Document A: Reveals TOP SECRET//SI
intelligence about future [redacted ]/NOFORN
attack by adversarial group
in another country.
2 Nov. 23, 2018 Document B: Reveals SECRET//NOFORN
liaison partner sharing
sensitive information with
the U.S. intelligence
community.
20Page 21 COUNT
APPROXIMATE
DATE OF
TRANSMISSION
DOCUMENT
DESCRIPTION
HIGHEST
CLASSIFICATION LEVEL
OF INFORMATION IN
DOCUMENT
Jan. 13, 2019
Document C: Reveals
intelligence that a foreign
adversary was planning a
missile launch in the future;
a covert action in a foreign
country that is related to
sensitive inter-
governmental actions;
sensitive sources and
methods used to collect
human intelligence.
TOP SECRET//HCS
[redacted]
[redacted ]//ORCON/NOFORN
June 2, 2019
Document D: Reveals
intelligence about an
adversary’s knowledge of
planned U.S. actions;
intelligence about
adversary’s plans for attack
conducted against U.S.
Forces in another country;
human intelligence using
sensitive sources and
methods; a covert action
program; intelligence
collected on the leader of an
adversary nation’s military
group.
TOP SECRET//SI [redacted]
[redacted |//HCS|redacted]
[redacted ]//ORCON/REL TO
USA GBR
July 6, 2019
Document E: Reveals
intelligence on an
adversary’s leaders.
TOP SECRET//SI [redacted]
[redacted]//HCS [redacted]
[redacted ]//ORCON/NOFORN
21Page 22 COUNT | APPROXIMATE DOCUMENT HIGHEST
DATE OF DESCRIPTION CLASSIFICATION LEVEL
TRANSMISSION OF INFORMATION IN
DOCUMENT
6 Aug. 18, 2019 Document F: Reveals TOP SECRET//SI [redacted]
intelligence concerning a [redacted]//HCS
foreign country’s [redacted ]//ORCON/NOFORN
interactions with an
adversary; in quotation
marks direct statement
collected via intelligence
sources and methods on a
foreign country; foreign
country’s intelligence
describing an adversary’s
planned attack on a facility;
sensitive sources and
methods used to collect
intelligence on a foreign
country; a covert action and
sources and methods used.
7 Sept. 8, 2019 Document G: Reveals TOP SECRET//SI [redacted]
covert action planned by the | [redacted]//HCS [redacted]//
U.S. Government; ORCON/NOFORN
intelligence confirming a
foreign adversary was
responsible for an attack.
8 Sept. 15, 2019 Document H: Reveals a TOP SECRET//HCS
covert action conducted by | [redacted]//[redacted]//
the U.S. Government, a ORCON/NOFORN
liaison partner country, and
specific information about
the action.
18 U.S.C. § 793(d).
22Page 23 COUNTS NINE THROUGH EIGHTEEN
(Retention of National Defense Information)
69. Paragraphs 1 through 66 of this Indictment are incorporated by reference as though
fully set forth herein.
70. From an unknown date, but no earlier than April 9, 2018, through on or about August
22, 2025, in the District of Maryland and elsewhere, the defendant,
JOHN ROBERT BOLTON, II,
having unauthorized possession of, access to, and control over a document, writing, and note
relating to the national defense, willfully retained the document, writing, and note and failed to
deliver it to the officer or employee of the United States entitled to receive it, to wit: as indicated
in the below counts, BOLTON retained within his home in Montgomery County, Maryland the
following documents, writings, and notes relating to the national defense:
COUNT DOCUMENT DESCRIPTION HIGHEST CLASSIFICATION
LEVEL OF INFORMATION IN
DOCUMENT
9 Document Av2: Reveals intelligence about TOP SECRET//SI
future attack by adversarial group in another [redacted ]/NOFORN
country.
10 Document Bv2: Reveals liaison partner SECRET//NOFORN
sharing sensitive information with the U.S.
intelligence community.
11 Document Cv2: Reveals intelligence that a TOP SECRET//HCS [redacted]
foreign adversary was planning a missile [redacted ]//ORCON/NOFORN
launch in the future; a covert action in a
foreign country that is related to sensitive
inter-governmental actions; sensitive sources
and methods used to collect human
intelligence.
23Page 24 COUNT DOCUMENT DESCRIPTION HIGHEST CLASSIFICATION
LEVEL OF INFORMATION IN
DOCUMENT
12 Document Dv2: Reveals intelligence about an | TOP SECRET//SI [redacted]
adversary’s knowledge of planned U.S.
actions; intelligence about adversary’s plans
for attack conducted against U.S. Forces in
another country; human intelligence using
sensitive sources and methods; a covert action
program; intelligence collected on the leader of
an adversary nation’s military group.
[redacted ]//ORCON/REL TO
USA GBR
13 Document Ev2: Reveals intelligence on an TOP SECRET//SI [redacted]
adversary’s leaders. [redacted]//HCS [redacted]
[redacted ]//ORCON/NOFORN
14 Document Fv2: Reveals intelligence TOP SECRET/SI [redacted]
concerning a foreign country’s interactions [redacted ]//HCS
with an adversary; in quotation marks direct [redacted ]//ORCON/NOFORN
statement collected via intelligence sources
and methods on a foreign country; foreign
country’s intelligence describing an
adversary’s planned attack on a facility;
sensitive sources and methods used to collect
intelligence on a foreign country; a covert
action and sources and methods used.
iS Document Gv2: Reveals covert action planned | TOP SECRET//SI [redacted]
by the U.S. Government; intelligence [redacted]//HCS [redacted]//
confirming a foreign adversary was ORCON/NOFORN
responsible for an attack.
16 Document Hv2: Reveals a covert action TOP SECRET//HCS [redacted ]//
conducted by the U.S. Government, a liaison ORCON/NOFORN
partner country, and specific information about
the action.
17 Document I: Reveals sources and collection TOP SECRET//SI [redacted]
used to obtain statements of a foreign [redacted ]//ORCON/NOFORN
adversary; covert action conducted by the U.S.
Government in a foreign country.
18 Document J: Reveals intelligence that a TOP SECRET//SI [redacted]
foreign country was considering specific force
against another country.
[redacted ]//
ORCON/NOFORN
18 U.S.C. § 793(e).
24Page 25 NOTICE OF FORFEITURE
The Grand Jury for the District of Maryland further finds that:
71. Upon conviction of the offenses in violation of Title 18, United States Code, Sections
793(d) and (e) set forth in Counts One through Eighteen of this Indictment, the defendant,
JOHN ROBERT BOLTON, II,
shall forfeit to the United States of America, pursuant to Title 18, United States Code, Sections
793(h) and 981(a)(1)(C), Title 21, United States Code, Section 853, and Title 28, United States
Code, Section 2461(c), any property, real or personal, which constitutes or is derived from
proceeeds traceable to the offenses.
Td. If any of the property described above, as a result of any act or omission of the
defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided without
difficulty,
25Page 26 the United States of America shall be entitled to forfeiture of substitute property pursuant to Title
21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section
2461(c).
18 U.S.C. § 793(h)
18 U.S.C. § 981(a)(1)(C)
21 U.S.C. § 853
28 U.S.C. § 2461(c)
A TRUE BILL:
SIGNATURE REDACTED
Forepetson,
By:
Kelly O. Hayes
United States Attorney
re
My 0 Hops Fas)
Thomd$s M. Sullivan
Assistant United States Attorney
S. ge Shugert
Trial Attorney
Scott Lara
Acting Chief
Counterintelligence and Export Control Section
Adam Barry
Acting Deputy Chief
Counterintelligence and Export Control Section
Tanner Kroeger
Trial Attorney
National Security Cyber Section
National Security Division
U.S. Department of Justice
Q+tiey lo, 2025
Date
26
the President with respect to the integration of domestic, foreign, and military policies relating to
the national security of the United States. Consistent with the direction of the President, the
functions of the NSC included advising the President with respect to the integration of domestic,
foreign, and military policies relating to national security; assessing and appraising the objectives,
commitments, and risks of the United States in relation to the actual and potential military power of
the United States; and making recommendations to the President concerning policies on matters of
common interest to the departments and agencies of the U.S. Government concerned with national
security. See generally Title 50, United States Code, Section 3021. Membership of the NSC
included “the President, the Vice President, the Secretary of State, the Secretary of Defense, the
Secretary of Energy, the Secretary of the Treasury, the Director of the Office of Pandemic
Preparedness and Response Policy and such other officers of the United States Government as the
President may designate.” Jd.
Bi BOLTON was the National Security Advisor to the President of the United States
between approximately April 9, 2018, and September 10, 2019. National Security Advisors
typically advise the President on all exigent threats to the United States and other issues related to
national security, including foreign relations, intelligence activities, and decisions regarding the use
of military force. As the National Security Advisor, BOLTON had access to some of the U.S.
Government’s most sensitive and closely guarded national security secrets. In order to obtain a
U.S. security clearance that granted him access to the highly classified information inherent in the
job of National Security Advisor, BOLTON signed numerous non-disclosure agreements that
acknowledged, among other things, that “the unauthorized disclosure . . . of classified information
by [him] could cause damage or irreparable injury to the United States,” that he would “never
divulge classified information” without “prior written notice of authorization from” the relevant
government agency, that he would “never divulge anything . . . that [he] kn[e]}w to be [Sensitive
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Compartmented Information (“SCI’)]' to anyone who is not authorized to receive it without prior
written authorization,” and that he understood that the unauthorized disclosure of national security
information “may constitute a violation, or violations, of United States criminal laws.”
4. As the National Security Advisor, BOLTON was granted a TOP SECRET/SCI
security clearance. Before being appointed as the National Security Advisor, BOLTON helda U.S.
security clearance in some of his prior U.S. Government positions.
5. As National Security Advisor, BOLTON directed and supervised the work of the
NSC staff on behalf of the President of the United States. BOLTON had access to, and was
responsible for the safeguarding of, the most sensitive national defense information, including
classified information.
6. Due to BOLTON’s need to have ready access to national defense information,
including classified information, while serving as the National Security Advisor, in or about
September 2018, the U.S. Government installed an accredited Sensitive Compartmented
Information Facility (“SCIF”) within BOLTON’s home located within the District of Maryland.
The SCIF was approved for the processing and closed storage of classified information, including
information classified up to the TOP SECRET level. After BOLTON’s term as National Security
Advisor ended on or about September 10, 2019, the SCIF in BOLTON’s home was decertified by
the U.S. Government on or about October 16, 2019, and from that date through the present, no
location within BOLTON’s home was approved for the lawful storage of classified information.
At no point, including the period when BOLTON had an accredited SCIF in his home, was
BOLTON authorized to store or transmit classified information on unclassified systems such as an
' Classified information at any level can be further restricted through compartmentation in Sensitive
Compartmented Information (“SCI”) categories. Only individuals with the appropriate security
clearance and additional SCI clearance(s) can have access to such classified information.
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America Online (“AOL”) email account, a Google email account, a non-governmental commercial
messaging application, or other non-governmental systems.
7. While National Security Advisor, BOLTON learned national defense and classified
information through a variety of means, including intelligence briefings, intelligence reports, and
meetings with members of the U.S. intelligence community, including the National Security Agency
(“NSA”) and the Central Intelligence Agency (“CIA”), the U.S. military, and foreign government
officials. In addition to having a home SCIF, while National Security Advisor, BOLTON also had
access to a variety of secure telecommunication systems that he could use to discuss and
communicate classified information. Moreover, BOLTON had access, as the National Security
Advisor, to classified spaces in the White House, the Eisenhower Executive Office Building, and
other locations, in the Washington, D.C., area and elsewhere, where he could readily learn, read,
and discuss classified and sensitive information with others who were authorized to know, receive,
discuss, and make decisions based on such information.
8. From on or about April 9, 2018, through at least on or about August 22, 2025,
BOLTON abused his position as National Security Advisor by sharing more than a thousand pages
of information about his day-to-day activities as the National Security Advisor—including
information relating to the national defense which was classified up to the TOP SECRET/SCI
level—with two unauthorized individuals, namely Individuals 1 and 2. BOLTON also unlawfully
retained documents, writings, and notes relating to the national defense, including information
classified up to the TOP SECRET/SCI level, in his home in Montgomery County, Maryland.
9. Individual 1, whose identity is known to the Grand Jury, was related to BOLTON,
resided in the District of Maryland, never held a U.S. security clearance, and was not authorized to
access, receive, or maintain the classified information that BOLTON shared related to his work as
the National Security Advisor.
PDF Page 6
10. Individual 2, whose identity is known to the Grand Jury, was related to BOLTON,
never held a U.S. security clearance, and was not authorized to access, receive, or maintain the
classified information that BOLTON shared related to his work as the National Security Advisor.
11. From on or about April 9, 2018, through on or about September 15, 2019, on a
regular basis, BOLTON sent diary-like entries to Individuals 1 and 2 that contained information
classified up to the TOP SECRET/SCI level. BOLTON wrote many of these diary-like entries by
transcribing his handwritten notes from his day’s activities into word processing documents, which
he then electronically sent to Individuals 1 and 2 through a commercial non-governmental
messaging application. On other occasions, BOLTON used his personal non-governmental email
accounts, such as email accounts hosted by AOL and Google, to email information classified up to
the TOP SECRET/SCI level to Individuals 1 and/or 2 at their personal email accounts. At no point
did BOLTON have authorization to store or transmit the classified information that he sent to
Individuals 1 and 2 via his personal electronic devices and accounts. Nor did, at any time,
Individuals 1 or 2 have authorization to know or store the classified information that BOLTON
gave to them.
12. At some unknown time, but no later than August 22, 2025, many of the diary-like
entries from BOLTON’s time as the National Security Advisor, including entries that contained
national defense information classified up to the TOP SECRET/SCI level, were printed and stored
in BOLTON’s personal residence in Montgomery County, Maryland. Digital copies of some of
the diary-like entries that contained national defense information classified up to the TOP
SECRET/SCI level were also stored on personal electronic devices used by BOLTON and others
located in BOLTON’s personal residence in Montgomery County, Maryland, on August 22, 2025.
13. After BOLTON’s time as National Security Advisor ended on September 10, 2019,
BOLTON’s personal residence was not authorized to store classified information in physical or
5
PDF Page 7
electronic format. On or about September 10, 2019, U.S. Government personnel retrieved all
classified equipment and marked classified documents that were stored in BOLTON’s home SCIF.
During that visit, BOLTON was told that he could no longer store classified information at his
home. At no point during BOLTON’s time as the National Security Advisor or afterwards,
including when his home SCIF was decommissioned in or about September 2019, did BOLTON
tell the U.S. Government personnel that he had sent national defense and classified information to
Individuals 1 and 2 over commercial email and messaging services or that such information was
stored on personal electronic devices and in personal electronic accounts belonging to or accessible
by himself and/or Individuals | and 2.
14. At some point between when BOLTON left government service in September 2019
and July 2021, a cyber actor believed to be associated with the Islamic Republic of Iran hacked
BOLTON’s personal email account and gained unauthorized access to the classified and national
defense information in that account, which BOLTON had previously emailed to Individuals 1 and
2 while he was the National Security Advisor. A representative for BOLTON notified the U.S.
Government of the hack in or about July 2021, but did not tell the U.S. Government that the account
contained national defense information, including classified information, that BOLTON had placed
in the account from his time as National Security Advisor. Nor did BOLTON’s representative tell
the U.S. Government that BOLTON had shared some of that national defense information,
including classified information, with Individuals 1 and 2 via personal email and a non-
governmental messaging application.
Classified Information
15. Executive Order 13526 governed the classification of national security information.
Information in any form may be classified if it: (1) is owned by, is produced by or for, or is under
the control of the U.S. Government; (2) could, if disclosed, cause one or more specified levels of
6
PDF Page 8
harm to the United States; and (3) is classified by or under an Original Classification Authority
(“OCA”) who determines that its unauthorized disclosure reasonably could be expected to result in
damage to the national security. OCAs, also called original classifiers, were individuals authorized
to classify information and make classification decisions.
16. Pursuant to Executive Order 12958 signed on April 17, 1995, as amended by
Executive Order 13292 on March 25, 2003, and Executive Order 13526 on December 29, 2009,
national security information was classified as “TOP SECRET,” “SECRET,” or
“CONFIDENTIAL.” National security information was information owned by, produced by,
produced for, and under the control of the U.S. Government that was classified as follows:
a. Information was classified as TOP SECRET if the unauthorized disclosure of that
information reasonably could be expected to cause exceptionally grave damage to
the national security that the original classification authority was able to identify and
describe.
b. Information was classified as SECRET if the unauthorized disclosure of that
information reasonably could be expected to cause serious damage to the national
security that the original classification authority was able to identify and describe.
c. Information was classified as CONFIDENTIAL if the unauthorized disclosure of
that information reasonably could be expected to cause damage to the national
security that the original classification authority was able to identify and describe.
17. | Under Executive Order 13526, “damage to the national security” meant harm to the
national defense or foreign relations of the United States from the unauthorized disclosure of
information, taking into consideration such aspects of the information as the sensitivity, value,
utility, and provenance of that information.
18. The classification marking “NOFORN” indicated that the information was “Not
Releasable to Foreign Nationals” and dissemination of that information was limited to United States
persons. The classification marking “REL TO” indicated that the information was releasable only
to foreign nationals of specified countries, international organizations, or multinational forces. The
PDF Page 9
classification marking “REL TO USA GBR” indicated that the information could only be released
to nationals of the United States and Great Britain.
19. The classification marking “ORCON” indicated that the dissemination and
extraction of the classified information was controlled (“CON”) by the originator (“OR”).
20. Classified information related to intelligence sources, methods, and analytical
processes was designated as SCI and subject to additional controls, such as the SI and HCS controls
described further below.
21. ‘The classification marking “SI” was an SCI control system that indicated that the
information was “Special Intelligence” and that the intelligence information was derived from the
monitoring of foreign communications signals by individuals other than the intended recipients. SI
was intended to protect signals intelligence (“SIGINT”) including communications and electronics
intelligence. The National Security Agency (“NSA”) was responsible for providing foreign SIGINT
to U.S. policymakers and military forces.
22. The classification marking “HCS” was an SCI control system that indicated that the
information was from the most sensitive human intelligence (“HUMINT”) operations and
information acquired from clandestine and/or uniquely sensitive HUMINT sources, methods, and
certain technical collection capabilities, technologies, and methods linked to or supportive of
HUMINT.
23) SCI was to be processed, stored, used, or discussed in an accredited SCIF, and only
individuals with the appropriate security clearance and additional SCI permissions were authorized
to have access to such national security information.
24. The National Institute of Standards and Technology defined a SCIF as an area, room,
group of rooms, buildings, or installation certified and accredited as meeting Director of National
PDF Page 10
Intelligence security standards for the processing, storage, and/or discussion of sensitive
compartmented information.
25. ‘Intelligence Community Directive 705, titled “Sensitive Compartmented
Information Facilities,” signed on May 26, 2010, by the Director of National Intelligence, provided
that “all SCI must be processed, stored, used, or discussed in an accredited SCIF.”
26. Pursuant to Executive Order 13526, information classified at any level could only be
lawfully accessed by persons determined by an appropriate U.S. Government official to be eligible
for access to classified information, who had signed an approved non-disclosure agreement,
received a security clearance, and had a “need to know” the classified information. Classified
information could only be stored in an approved facility and container.
BOLTON’s Transmission of National Defense Information
to Individuals 1 and 2 While He Was National Security Advisor
27. As set forth above, between on or about April 9, 2018, and September 15, 2019,
BOLTON sent Individuals 1 and 2 contemporaneous notes, on a regular basis, describing in detail
his day-to-day activities as the National Security Advisor. BOLTON often referred to these notes
as his “diary” and sent them to Individuals | and 2 over his personal non-governmental email
accounts or a messaging application. The information contained in these notes included detailed
information that BOLTON learned from meetings with senior members of the U.S. Government,
intelligence briefings from members of the intelligence community and military, discussions with
foreign leaders and foreign intelligence and military organizations, and intelligence products and
reports, which BOLTON had access to because of his role as National Security Advisor. Portions
of the information contained in the “diary” entries that BOLTON sent to Individuals 1 and 2 were
national defense information, including information classified up to the TOP SECRET/SCI level.
PDF Page 11
28. Throughout his time as National Security Advisor, BOLTON took detailed notes
documenting his day-to-day meetings, activities, and briefings. Frequently, BOLTON handwrote
these notes on yellow notepads throughout his day at the White House complex or in other secure
locations, and then later re-wrote his notes in a word processing document on an electronic device.
29. The notes that BOLTON sent to Individuals 1 and 2 using his non-governmental
personal email accounts and messaging account described in detail BOLTON’s daily activities as
the National Security Advisor, including national defense and classified information that he learned
during his time as National Security Advisor. Often, BOLTON’s notes described the secure setting
or environment in which he learned the national defense and classified information that he was
memorializing in his notes. For example, a description of classified information related to a foreign
government’s activities might begin with “the intel briefer said...” Or a description of classified
information learned during a military briefing might begin with “while in the Situation Room, |
learned that...” The notes that BOLTON sent to Individuals 1 and 2 often began with the words,
“[Individual 1’s initials/Individual 2’s initials] start here.” In at least one communication,
BOLTON also referred to Individuals | and 2 as his “editors.”
30. Some of the information related to the national defense that BOLTON
communicated, delivered, and transmitted to Individuals | and 2 is described in further detail below
and in Counts One through Eight.
a1. On or about April 8, 2018, the day before BOLTON officially began his duties as
National Security Advisor, Individual | created a group chat with BOLTON and Individual 2 on a
non-governmental messaging application. Individual 2 asked the group, “Why are we using this
now? The encryption?” to which Individual 1 responded, “Yup. Why not?” BOLTON then
responded, “For Diary in the future!!!”
PDF Page 12
32, On or about April 22, 2018, BOLTON sent Individuals 1 and 2 via the non-
governmental messaging application a 25-page document which described information that
BOLTON learned while National Security Advisor.
33. | Onor about April 22, 2018, Individual 2 sent BOLTON and Individual | a message
that stated, “Diary finished... .” Individual 1 also asked Individual 2 whether Individual 2 was
“going to call tonight,” to which Individual 2 responded, “Am I supposed to?” Individual 1 then
wrote, “Diaries take time to write, but phone conversations take less time. . . .”
34, On or about July 15, 2018, Individual 2 sent BOLTON and Individual 1 a message
that stated, “Do we get a diary today?” Individual 1 responded, “Don’t think he can do it on this
trip.” BOLTON later added, “Too much going on!!! I’ve done much of Friday in London because
I didn’t take many notes and wanted to get it down before I forgot!!!”
35. On or about July 23, 2018, BOLTON sent Individuals | and 2 a message that stated,
“More stuff coming!!!” A few minutes later, BOLTON sent Individuals 1 and 2 a 24-page
document which described information that BOLTON learned while National Security Advisor.
Less than three hours later, BOLTON sent Individuals | and 2 a follow-up message that stated,
“None of which we talk about!!!" In response, Individual 1 sent a message that stated, “Shhhhh.”
Individual 2 then sent a message that stated, “The only interesting thing is what [senior U.S.
Government official] might have said from [foreign language] interpreter, which you didn’t tell
us...” Approximately two minutes later, Individual 1 sent a message in response that stated, “More
to come with cloak and dagger...or something. So he says....”
36. On or about September 23, 2018, BOLTON sent Individuals 1 and 2 a 10-page
document (“Document A”), which contained information that BOLTON learned while National
Security Advisor, including information classified up to the TOP SECRET/SCI level.
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37. On or about November 23, 2018, BOLTON sent Individuals 1 and 2 a 29-page
document (“Document B”), which contained information that BOLTON learned while National
Security Advisor, including information classified up to the SECRET/NOFORN level.
38. On or about December 2, 2018, BOLTON sent Individuals 1 and 2 a 15-page
document, which contained information that BOLTON learned while National Security Advisor.
Individual 2 responded, “Diary arrived” and then sent a message that stated, “But no commentary
on [Foreign Country 1] judicial system article I sent or administration sentiment on [arrest in
Foreign Country 1]?” In response, BOLTON sent a message that stated, “I’m working on it!!!”
39. On or about December 4, 2018, Individual 2 sent additional messages to BOLTON
and Individual 1 regarding the arrest of an individual in Foreign Country 1. Individual 2 told
BOLTON and Individual | that the arrested individual in Foreign Country | was being interrogated
and that a relative of the arrested individual would “be in DC . . . if useful to get him in front of
[senior U.S. Government official] or anyone else.” In response to Individual 2’s message that law
enforcement in Foreign Country | was interrogating the arrested individual, Individual 1 sent a
message that stated, “Ye gods. Next thing they'll pull a Khashoggi? on him.” In response,
Individual 2 sent a message that asked, “But [nickname for BOLTON] has no feedback?”
40. On or about January 2, 2019, BOLTON sent Individuals 1 and 2 a 22-page
document, which contained information that BOLTON learned while National Security Advisor.
BOLTON also sent a message that stated, “Stuff coming!!! Hard copy at home for [nickname for
Individual 1]!!!!"
? Jamal Khashoggi was a Saudi journalist who was murdered in 2018 in the Consulate of Saudi
Arabia in Istanbul, Turkey.
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41. On or about January 13, 2019, BOLTON sent Individuals 1 and 2 a 24-page
document (“Document C”), which contained information that BOLTON learned while National
Security Advisor, including information classified up to the TOP SECRET/SCI level.
42. About a week later, on or about January 21, 2019, BOLTON sent Individuals 1 and
2 a 20-page document, which contained information that BOLTON learned while National Security
Advisor. BOLTON sent an accompanying message that stated, “Stuff coming to cheer you...
up!!!” and that Individual 1 “needs to figure out how to do corrections!!!” In response, Individual
1 sent a message that stated, “Read [BOLTON’s] thing. I need to also.” Individual | also stated,
“T have edits. Para by para. Not sure how to send them. Mostly typos, caps, incomplete sentences.”
BOLTON then asked, “Did you print it out???” to which Individual 1 responded, “I read it on
phone. ... Took notes.”
43, On or about June 2, 2019, BOLTON sent Individuals 1 and 2 a 10-page document
(“Document D”), which contained information that BOLTON learned while National Security
Advisor, including information classified up to the TOP SECRET/SCI level.
44. On or about July 6, 2019, BOLTON sent Individuals 1 and 2 a 77-page document
(“Document E”), which contained information that BOLTON learned while National Security
Advisor, including information classified up to the TOP SECRET/SC] level.
45. On or about July 28, 2019, BOLTON sent Individuals 1 and 2 a message that stated,
“STUFF COMING, BUT ONLY FOR [Individual 2]??? [Individual 1] TO READ HARD COPY
WHEN [Individual 1] IS BACK IN USI!!!”
46. On or about August 18, 2019, BOLTON sent Individuals 1 and 2 a 50-page
document (“Document F”), which contained information that BOLTON learned while National
Security Advisor, including information classified up to the TOP SECRET/SCI level.
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47. On or about September 8, 2019, BOLTON sent Individuals 1 and 2 a 47-page
document (“Document G”), which contained information that BOLTON learned while National
Security Advisor, inotadiag information classified up to the TOP SECRET/SCI level.
48. On or about September 15, 2019, five days after he was no longer the National
Security Advisor, BOLTON sent Individuals 1 and 2 a six-page document (“Document H”), which
contained information that BOLTON learned while National Security Advisor, including
information classified up to the TOP SECRET/SCI level. In a related message, BOLTON told
Individuals 1 and 2, “Stuff coming!!!” Individual 2 responded, “Dramatic ending. But will there
be a new diary,” to which Individual 1 responded, “Nope on diary. Now bookwriting [sic].”
BOLTON then sent a message that stated, “Talking with [book publisher] because they have a right
of first refusal!!!”
49. On or about September 24, 2019, fourteen days after he was no longer employed as
the National Security Advisor, BOLTON left the messaging chat group with Individuals 1 and 2
that he had used to send them more than a thousand pages of notes memorializing his time as
National Security Advisor.
Relevant Activities Before and After BOLTON’s Tenure as National Security Advisor Ends
BOLTON Publishes “The Room Where It Happened: A White House Memoir”
50. On or about September 11, 2019, the day after BOLTON’s tenure as National
Security Advisor ended, a literary agent representing BOLTON sent an email to a book publisher
describing a book about BOLTON’s time as the National Security Advisor that BOLTON intended
to publish. In that email, the literary agent stated, among other things, that BOLTON’s forthcoming
book would include BOLTON’s impressions of his time as National Security Advisor “in a
meticulously observed manner with direct quotes from all parties based on contemporaneous notes.”
Two months earlier and while BOLTON was still the National Security Advisor, on or about July
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19, 2019, the literary agent sent BOLTON a letter stating that it was “with enthusiasm” that the
literary agent was “again exploring a book” with BOLTON. Ultimately, BOLTON earned more
than a million dollars by selling the rights to publish his book about his time as National Security
Advisor.
51. Onor about December 12, 2019, BOLTON began sending drafts of portions of his
book to his publisher and literary agent for review and comments. BOLTON sent these drafts via
a non-governmental messaging application. Over the winter holidays in 2019, BOLTON and his
editors exchanged drafts and comments relating to his forthcoming book.
52, On or about December 30, 2019, BOLTON submitted a manuscript of his book,
titled The Room Where It Happened: A White House Memoir to the NSC for the required pre-
publication review process. Based on an initial review of the manuscript by NSC staff, the U.S.
Government concluded and told BOLTON that the initial manuscript contained significant amounts
of highly classified information that needed to be removed.
53: On or about June 23, 2020, BOLTON’s book, The Room Where It Happened: A
White House Memoir, was published and became readily available to the public. None of the
classified national defense information charged in Counts One through Eighteen, further described
below, was published in BOLTON’s book.
54. On or about June 16, 2021, the United States and BOLTON entered a settlement
agreement resolving civil litigation relating to BOLTON’s book. As a condition of that settlement
agreement, BOLTON agreed to “provide to the United States all materials in his possession,
custody, or control that may contain any classified information.” BOLTON also agreed that his
obligation to return classified material “extends to any written or electronic drafts of the manuscript
[of his book] regardless of whether those materials were received from the United States or
generated by [BOLTON].”
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BOLTON’s Representative Notifies the FBI that Iran Hacked His Personal Email Account
55: On or about July 6, 2021, a representative for BOLTON contacted the Federal
Bureau of Investigation (“FBI”) via email to alert the FBI that an entity, believed by BOLTON’s
representative to be the Islamic Republic of Iran, had obtained unauthorized access to one of
BOLTON’s personal email accounts. In the email to the FBI, BOLTON’s representative stated
that “evidently someone has gotten into Amb. Bolton’s” personal email account and that “it looks
as though it is someone in Iran. . . .”
56. On or about July 28, 2021, BOLTON’s representative emailed the FBI again to
report that BOLTON and his representative had received the following email, on or about July 25,
2021, which the representative believed was associated with the hack of BOLTON’s account:
I do not think you would be interested in the FBI being aware of the leaked content
of John’s email (some of which have been attached), especially after the recent
acquittal.
This could be the biggest scandal since Hillary’s emails were leaked, but this time
on the GOP side!
Contact me before it’s too late ...
BOLTON’ representative also told the FBI that the representative was “[j|ust sending you the text
(not the documents [the hacker] attached since there might be sensitive information in them).”
57. A day later, on or about July 29, 2021, BOLTON’s representative told the FBI that
BOLTON would be deleting the contents of his personal email account that had been hacked.
58. On or about August 5, 2021, BOLTON received another electronic message related
to the hack of his personal email account which stated, “OK John ... As you want (apparently),
we'll disseminate the expurgated sections of your book by reference to your leaked email...”
59. At no point did BOLTON tell the FBI that, while he was the National Security
Advisor, he had used the hacked email account to send Individuals 1 and 2 documents relating to
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the national defense, including classified information. Nor did he tell the FBI that the hackers now
had this information.
The FBI Finds Documents Relating to the National Defense in BOLTON’s Home
60. On or about August 22, 2025, the FBI executed search warrants and seized material
from BOLTON’ residence in Maryland and office in Washington, D.C. Part of the material seized
from BOLTON’s Maryland home included electronic files showing that BOLTON transmitted his
diary entries, many of which related to the national defense and contained classified information, to
Individuals 1 and 2 through a non-governmental messaging application. During the court-
authorized search of BOLTON’s home on August 22, 2025, the FBI also seized hard copy printed
versions of many of BOLTON’s diary entries, including documents that related to the national
defense and contained classified information. Some of the documents related to the national defense
that the FBI found in BOLTON’s home on August 22, 2025, are described in further detail below
in Counts Nine through Eighteen.
BOLTON ’s Public Statements on the Handling of Classified Information
61. From at least on or about September 2, 2016, through on or about April 25, 2025,
BOLTON has made numerous public statements demonstrating his understanding of how to
properly handle classified information and the potential consequences of failing to do so.
62. On or about January 16, 2017, in a media interview, BOLTON stated in response to
a question about allegations that a senior U.S. Government official had communicated sensitive
government information using a personal email account, “Look, as I’ve said before, | believe it still
to this day, if I had done at the State Department what [senior U.S. Government official] did, I°d be
[imprisoned] right now.”
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63.
On or about March 31, 2025, in a media interview, BOLTON stated in response to
questions about allegations that a senior U.S. Government official had communicated sensitive
government information using a non-governmental messaging application:
Well, I don’t, I mean, to me, I just can’t even imagine opening a Signal chat group
or a Telegram chat group or anything else. People say but the communications are
encrypted. Well that’s fine. We have the National Security Agency that has big
computers chug-chug-chugging along trying to deencrypt [sic] any system that we
want to try to get into and our adversaries do as well. . .. The damage that’s done
is that we’ve shown weakness in our operational security that our adversaries will
try to exploit... . What did we build the world’s most secure telecommunications
capability for if not to use it on sensitive matters. And once you’re on a secure
telephone — a U.S. government secure telephone — you don’t worry what the level
of classification you’re discussing. You’re talking about an article in the morning
newspaper or top secret code word items and you’re secure. When you’re on Signal,
did no one in that conversation for days ever say you know maybe we ought to get
off this and get back on a classified system. . . . It just. I’m just, without words, to
understand how that could have happened.
64.
On or about April 18, 2025, in a media interview, BOLTON stated in response to a
question about allegations that a senior U.S. Government official had communicated sensitive
government information using a non-governmental messaging application:
Initially, | was totally without words. I couldn’t-I couldn’t find-I couldn’t find a
way to express how stunned I was that anybody would do this. You simply don’t
use commercial means of communication, whether it’s supposedly an encrypted
app or not for for these kinds of discussions. You know, you don’t know where
they’re gonna go. You could start off talking about a newspaper article, but but
obviously you could get into classified material. I understand why you need to have
group chats, but as I’ve been saying the place for the group chats are the Situation
Room where everybody’s in place some people may have to appear via secure video
teleconference facilities, and and we’ve got great capacity to do that. But, but
having chat groups where you're writing two or three sentences that this is not what
you would call sophisticated national security analysis at work, and on an unsecured
channel. It just, there’s there’s no excuse for it.
6.
In an interview on March 26, 2025, BOLTON discussed the damage to national
security by using a non-governmental communication channel to discuss sensitive government
information:
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What were they doing off of secure government channels? That is the original sin
here. That is the question neither one of them has yet answered. . . . I think actual
damage is possible because of the way foreign intelligence services operate, the
way our own intelligence services operate. You take everything you can get. You
take every piece of information in this case about American military operations
against the Houthis in Yemen. It tells you something that otherwise you wouldn’t
know about American capabilities, American tactics, American approaches to this
kind of thing, and that is useful to the Russians, the Chinese, the Iranians, the North
Koreans, and others as well. How that fits into the body of knowledge they already
have is a question I can’t answer, but it can’t help, that’s for sure.
66. On or about April 22, 2025, in a media interview, BOLTON addressed what he
considered the impropriety of discussing sensitive government information with people who do not
have a “need to know” that information (such as family and friends) using a non-governmental
messaging application:
I think the second example of a Signal chat group . . . really shows a terrible lack
of judgment communicating with the people in this group in particular who have
absolutely no need to know about any upcoming U.S. military operation leads me
to wonder what he’s doing on the job on a minute to minute, hour by hour basis that
he’s got time to - to knock out Signal messages to - to friends and family which is
what this group is.
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THE CHARGES
COUNTS ONE THROUGH EIGHT
(Transmission of National Defense Information)
67. Paragraphs | through 66 of this Indictment are incorporated by reference as though
fully set forth herein.
68. On or about the dates indicated below, in the District of Maryland and elsewhere,
the defendant,
JOHN ROBERT BOLTON, II,
lawfully having possession of, access to, control over, and being entrusted with information relating
to the national defense, which information the defendant had reason to believe could be used to the
injury of the United States and to the advantage of any foreign nation, willfully communicated,
delivered, and transmitted and caused to be communicated, delivered, and transmitted the same to
a person not entitled to receive it, to wit: as indicated in the below counts, BOLTON sent via his
personal non-governmental email account(s) and/or his personal non-governmental messaging
application account the information relating to the national defense described below to Individuals
1 and 2:
COUNT | APPROXIMATE DOCUMENT HIGHEST
DATE OF DESCRIPTION CLASSIFICATION LEVEL
TRANSMISSION OF INFORMATION IN
DOCUMENT
| Sept. 23, 2018 Document A: Reveals TOP SECRET//SI
intelligence about future [redacted ]/NOFORN
attack by adversarial group
in another country.
2 Nov. 23, 2018 Document B: Reveals SECRET//NOFORN
liaison partner sharing
sensitive information with
the U.S. intelligence
community.
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COUNT
APPROXIMATE
DATE OF
TRANSMISSION
DOCUMENT
DESCRIPTION
HIGHEST
CLASSIFICATION LEVEL
OF INFORMATION IN
DOCUMENT
Jan. 13, 2019
Document C: Reveals
intelligence that a foreign
adversary was planning a
missile launch in the future;
a covert action in a foreign
country that is related to
sensitive inter-
governmental actions;
sensitive sources and
methods used to collect
human intelligence.
TOP SECRET//HCS
[redacted]
[redacted ]//ORCON/NOFORN
June 2, 2019
Document D: Reveals
intelligence about an
adversary’s knowledge of
planned U.S. actions;
intelligence about
adversary’s plans for attack
conducted against U.S.
Forces in another country;
human intelligence using
sensitive sources and
methods; a covert action
program; intelligence
collected on the leader of an
adversary nation’s military
group.
TOP SECRET//SI [redacted]
[redacted |//HCS|redacted]
[redacted ]//ORCON/REL TO
USA GBR
July 6, 2019
Document E: Reveals
intelligence on an
adversary’s leaders.
TOP SECRET//SI [redacted]
[redacted]//HCS [redacted]
[redacted ]//ORCON/NOFORN
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COUNT | APPROXIMATE DOCUMENT HIGHEST
DATE OF DESCRIPTION CLASSIFICATION LEVEL
TRANSMISSION OF INFORMATION IN
DOCUMENT
6 Aug. 18, 2019 Document F: Reveals TOP SECRET//SI [redacted]
intelligence concerning a [redacted]//HCS
foreign country’s [redacted ]//ORCON/NOFORN
interactions with an
adversary; in quotation
marks direct statement
collected via intelligence
sources and methods on a
foreign country; foreign
country’s intelligence
describing an adversary’s
planned attack on a facility;
sensitive sources and
methods used to collect
intelligence on a foreign
country; a covert action and
sources and methods used.
7 Sept. 8, 2019 Document G: Reveals TOP SECRET//SI [redacted]
covert action planned by the | [redacted]//HCS [redacted]//
U.S. Government; ORCON/NOFORN
intelligence confirming a
foreign adversary was
responsible for an attack.
8 Sept. 15, 2019 Document H: Reveals a TOP SECRET//HCS
covert action conducted by | [redacted]//[redacted]//
the U.S. Government, a ORCON/NOFORN
liaison partner country, and
specific information about
the action.
18 U.S.C. § 793(d).
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COUNTS NINE THROUGH EIGHTEEN
(Retention of National Defense Information)
69. Paragraphs 1 through 66 of this Indictment are incorporated by reference as though
fully set forth herein.
70. From an unknown date, but no earlier than April 9, 2018, through on or about August
22, 2025, in the District of Maryland and elsewhere, the defendant,
JOHN ROBERT BOLTON, II,
having unauthorized possession of, access to, and control over a document, writing, and note
relating to the national defense, willfully retained the document, writing, and note and failed to
deliver it to the officer or employee of the United States entitled to receive it, to wit: as indicated
in the below counts, BOLTON retained within his home in Montgomery County, Maryland the
following documents, writings, and notes relating to the national defense:
COUNT DOCUMENT DESCRIPTION HIGHEST CLASSIFICATION
LEVEL OF INFORMATION IN
DOCUMENT
9 Document Av2: Reveals intelligence about TOP SECRET//SI
future attack by adversarial group in another [redacted ]/NOFORN
country.
10 Document Bv2: Reveals liaison partner SECRET//NOFORN
sharing sensitive information with the U.S.
intelligence community.
11 Document Cv2: Reveals intelligence that a TOP SECRET//HCS [redacted]
foreign adversary was planning a missile [redacted ]//ORCON/NOFORN
launch in the future; a covert action in a
foreign country that is related to sensitive
inter-governmental actions; sensitive sources
and methods used to collect human
intelligence.
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COUNT DOCUMENT DESCRIPTION HIGHEST CLASSIFICATION
LEVEL OF INFORMATION IN
DOCUMENT
12 Document Dv2: Reveals intelligence about an | TOP SECRET//SI [redacted]
adversary’s knowledge of planned U.S.
actions; intelligence about adversary’s plans
for attack conducted against U.S. Forces in
another country; human intelligence using
sensitive sources and methods; a covert action
program; intelligence collected on the leader of
an adversary nation’s military group.
[redacted ]//ORCON/REL TO
USA GBR
13 Document Ev2: Reveals intelligence on an TOP SECRET//SI [redacted]
adversary’s leaders. [redacted]//HCS [redacted]
[redacted ]//ORCON/NOFORN
14 Document Fv2: Reveals intelligence TOP SECRET/SI [redacted]
concerning a foreign country’s interactions [redacted ]//HCS
with an adversary; in quotation marks direct [redacted ]//ORCON/NOFORN
statement collected via intelligence sources
and methods on a foreign country; foreign
country’s intelligence describing an
adversary’s planned attack on a facility;
sensitive sources and methods used to collect
intelligence on a foreign country; a covert
action and sources and methods used.
iS Document Gv2: Reveals covert action planned | TOP SECRET//SI [redacted]
by the U.S. Government; intelligence [redacted]//HCS [redacted]//
confirming a foreign adversary was ORCON/NOFORN
responsible for an attack.
16 Document Hv2: Reveals a covert action TOP SECRET//HCS [redacted ]//
conducted by the U.S. Government, a liaison ORCON/NOFORN
partner country, and specific information about
the action.
17 Document I: Reveals sources and collection TOP SECRET//SI [redacted]
used to obtain statements of a foreign [redacted ]//ORCON/NOFORN
adversary; covert action conducted by the U.S.
Government in a foreign country.
18 Document J: Reveals intelligence that a TOP SECRET//SI [redacted]
foreign country was considering specific force
against another country.
[redacted ]//
ORCON/NOFORN
18 U.S.C. § 793(e).
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NOTICE OF FORFEITURE
The Grand Jury for the District of Maryland further finds that:
71. Upon conviction of the offenses in violation of Title 18, United States Code, Sections
793(d) and (e) set forth in Counts One through Eighteen of this Indictment, the defendant,
JOHN ROBERT BOLTON, II,
shall forfeit to the United States of America, pursuant to Title 18, United States Code, Sections
793(h) and 981(a)(1)(C), Title 21, United States Code, Section 853, and Title 28, United States
Code, Section 2461(c), any property, real or personal, which constitutes or is derived from
proceeeds traceable to the offenses.
Td. If any of the property described above, as a result of any act or omission of the
defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided without
difficulty,
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the United States of America shall be entitled to forfeiture of substitute property pursuant to Title
21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section
2461(c).
18 U.S.C. § 793(h)
18 U.S.C. § 981(a)(1)(C)
21 U.S.C. § 853
28 U.S.C. § 2461(c)
A TRUE BILL:
SIGNATURE REDACTED
Forepetson,
By:
Kelly O. Hayes
United States Attorney
re
My 0 Hops Fas)
Thomd$s M. Sullivan
Assistant United States Attorney
S. ge Shugert
Trial Attorney
Scott Lara
Acting Chief
Counterintelligence and Export Control Section
Adam Barry
Acting Deputy Chief
Counterintelligence and Export Control Section
Tanner Kroeger
Trial Attorney
National Security Cyber Section
National Security Division
U.S. Department of Justice
Q+tiey lo, 2025
Date
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