The United States Federal Bureau of Investigation (FBI) has disclosed that it searched a multi-subject file using the terms “Bola” and “Tinubu” separately while processing a Freedom of Information Act (FOIA) request involving Nigerian President Bola Ahmed Tinubu.
The disclosure was contained in a September 23, 2026 court filing by the FBI and the U.S. Drug Enforcement Administration (DEA) in a FOIA lawsuit before the U.S. District Court for the District of Columbia.
The case was filed by Aaron Greenspan against the Executive Office for U.S. Attorneys and other United States government agencies.
In the filing, the FBI said it conducted a term search as well as a manual page-by-page review within a multi-subject file to locate records responsive to FOIA request 1588244-000.
The agency said the search was conducted using “Bola” and “Tinubu” separately.
“The FBI conducted a term search along with a manual page-by-page review within this multi-subject file to locate records responsive to Plaintiff’s request 1588244-000, utilizing the search term ‘Bola’ and the search term ‘Tinubu’ separately,” the government said in the filing.
The FBI made the disclosure while responding to Greenspan’s challenge to the adequacy of the agencies’ searches for records.
Greenspan had questioned whether the FBI’s search adequately accounted for possible misspellings and routine typographical errors that could have affected the identification of responsive records.
The FBI rejected the concern, arguing that its manual page-by-page review addressed the issue and demonstrated that the search was adequate.
“Knowing the FBI conducted a manual page-by-page review for responsiveness, Plaintiff’s complaint that ‘Defendant FBI fails to describe any measures it undertook to account for misspellings and routine typographical errors [in its search for responsive records]’ … falls flat,” the agency stated.
The latest filing, however, does not disclose what the FBI found after searching for “Bola” and “Tinubu.”
It does not state whether the search produced new information concerning Tinubu, nor does it reveal the contents of any records identified through the search.
Instead, the government’s filing focuses on defending the adequacy of the searches conducted by the FBI and DEA and the agencies’ decisions to withhold portions of responsive records under various exemptions contained in the Freedom of Information Act.
The FBI said it and the DEA had conducted searches that were “adequate and reasonable,” processed responsive records and released all reasonably segregable non-exempt information subject to FOIA.
The filing further reveals that the FBI withheld some material under FOIA Exemption 3, citing federal grand-jury information and laws protecting certain electronic surveillance information.
Among the material covered by the exemption were records relating to pen registers and information protected under Title III.
The FBI said descriptions of the withheld material were limited to avoid revealing information that could compromise the secrecy of federal grand-jury proceedings or disclose non-public details about the use of pen registers and information collected and analysed through the technique.
The agency also defended its use of FOIA Exemption 5 to withhold material relating to prosecutorial strategy and internal legal deliberations.
According to a supplemental declaration cited in the filing, the records sought by Greenspan include material that could disclose the “thought process, strategy and legal impressions” of U.S. Attorney’s Office personnel working on third-party criminal cases.
The government argued that releasing such information could interfere with prosecutors’ ability to develop plans and carry out their duties without concerns that their internal deliberations would subsequently be publicly disclosed and interpreted.
The filing separately addressed records held by the DEA, saying the agency’s responsive material included investigative records such as DEA-6, DEA-292 and DEA-210 reports.
The DEA defended withholding portions of those records under several FOIA exemptions, including provisions protecting confidential sources and non-public investigative techniques.
The latest filing also says the FBI invoked a separate exemption to protect the identities and identifying information of individuals whom it believed could face violence if identified in the records.
The DEA similarly cited the sensitive nature of its investigative work and undercover operations, including investigations involving armed individuals with known violent tendencies.
Despite the disclosure that the FBI searched for the terms “Bola” and “Tinubu” separately, the court filing does not establish what substantive information the agency located or whether the records contain any new allegations or findings concerning the Nigerian president.
The government’s position is that the searches were adequate and that information covered by applicable FOIA exemptions should remain withheld.
The agencies ultimately asked the court to grant summary judgment in favour of the FBI and DEA and enter judgment for the government in the FOIA dispute.