Attorney General Merrick Garland had agreed not to make the special counsel's findings public while the Justice Department appealed a judge's dismissal of the case.

Trump has vowed to end the "weaponisation" of the Justice Department and has set about nominating and appointing allies to top posts in the department. Smith himself resigned from the Justice Department shortly before Trump took office, and both federal cases have effectively ended.

More than a dozen officials who worked on the criminal investigations into Donald Trump have been fired, according to sources familiar with the matter.