WASHINGTON, D.C. — The Federal Bureau of Investigation (FBI) has submitted confidential, under-seal materials to a federal court in Washington, D.C., as part of an ongoing Freedom of Information Act (FOIA) case involving records sought by American transparency activist Aaron Greenspan concerning President Bola Ahmed Tinubu.
The development was disclosed in a Defendant’s Notice of Compliance filed on August 28, 2026, in Greenspan v. Executive Office for U.S. Attorneys et al., Civil Action No. 23-1816 (BAH) .
According to the filing, the FBI informed the U.S. District Court for the District of Columbia that “ex parte, in camera” declarations had been hand-delivered to the court on August 28 in compliance with an August 20 order . The declarations were submitted in support of the U.S. government’s cross-motion for summary judgment and opposition to Greenspan’s second motion for summary judgment .
The case concerns FOIA requests for U.S. government records relating to Tinubu and alleged investigations dating to the early 1990s. A 2025 ruling by U.S. District Judge Beryl Howell rejected the FBI and Drug Enforcement Administration’s earlier attempts to use so-called “Glomar” responses to refuse to confirm or deny the existence of responsive records .
Claim of 399 Pages
In an update published on X, Von Batten-Montague-York, L.C. (@batten_von) said a search conducted by the FBI for records responsive to requests concerning Tinubu produced 399 pages of documents.
The account said the records include material allegedly connected to a drug-trafficking investigation, including references to heroin-residue laboratory testing, controlled drug purchases involving a cooperating witness, confidential informants, federal grand-jury activity, prosecutorial reports and meetings, surveillance and undercover operations, financial seizures, bank-account seizure warrants, IRS criminal-investigation material and international investigative coordination.
However, the 399-page figure and the specific contents listed in the X post should be attributed to the account rather than presented as findings independently established by the public court filing. The August 28 notice itself confirms the submission of sealed declarations but does not publicly disclose their contents .
Records Remain Sealed
The FBI’s August 28 submission followed an August 20 request seeking permission to explain privately why some information should remain withheld . Reports on the court proceedings indicate that the FBI has invoked FOIA exemptions relating to personal privacy, confidential sources, investigative techniques, and potential threats to individuals’ safety .
The court’s private review does not mean that the records have been released to the public. Judge Howell must still determine which material, if any, can be withheld under the applicable FOIA exemptions and what information must be disclosed .
The broader case began after Greenspan sought records from several U.S. agencies concerning Tinubu and other individuals in connection with an alleged Chicago-area narcotics investigation . The litigation has continued for more than three years .
Tinubu has not been criminally charged or convicted of drug trafficking in the United States, and his position has been that the well-known $460,000 matter involving his funds was a civil forfeiture proceeding rather than a criminal prosecution .
Next Steps in the Court Process
The court has scheduled Greenspan’s response for September 11, 2026, and the government’s final submission for September 18, 2026 . Judge Howell will ultimately rule on whether the FBI’s exemptions are legally justified, and whether any portion of Tinubu’s records will ever be made public .
The latest development therefore does not establish criminal wrongdoing by Tinubu. Rather, it confirms that the FBI has placed additional confidential material before the judge while the court considers whether portions of the records can legally be released.
The central question now is what information, if any, the court will ultimately order the U.S. government to make public.
