Trump and his White House staff had for months denied knowing anything about Cohen's $130,000 payment to Daniels to buy her silence about the affair the porn star said she had with Trump a decade earlier. Trump's newest outside lawyer Rudy Giuliani finally admitted that Trump had repaid Cohen in a Fox News interview earlier this month.

The White House did not respond to requests for comment.

In a Wednesday interview with HuffPost, Giuliani continued to insist that Cohen's payment to Daniels ? which he previously described as the settlement of a nuisance claim ? was fully aboveboard.

"This is a perfectly legitimate thing," Giuliani said. "There's nothing wrong with it."

When asked why an ostensibly legitimate payment had been funneled through the newly registered Delaware shell company Essential Consultants, Giuliani said: "No, it wasn't." He then added that there was no need to list Trump's monthly payments to Cohen at all. "It was listed out of an excess of caution."

Both of Giuliani's assertions, however, are incorrect.

"OGE has concluded that, based on the information provided ... the payment made by Mr. Cohen is required to be reported as a liability," Apol wrote in his letter to Rosenstein.

The payment to Daniels ? whose real name is Stephanie Clifford ? was made on Oct. 27, 2016, by Essential Consultants LLC to her lawyer at the time, Keith Davidson, according to a copy of the wire transfer.