With respect to Ukraine, most of the focus, rightfully, rests on President Donald Trump’s conduct, but the conduct of his attorney Rudolph Giuliani also deserves serious attention. Based on the facts already in the public arena, the Department of Justice has more than enough basis to open a federal criminal investigation into the former New York mayor.

Let’s start with the basic facts as reported by multiple news organizations and as essentially confirmed by Trump in public statements: In one conversation between Trump and Ukranian President Volodymyr Zelensky on July 25, Trump made “about eight” demands for Zelensky to work with Giuliani to investigate Democratic rival Joe Biden and his son Hunter. On Tuesday, Trump confirmed reports that his administration froze nearly $400 million in aid to Ukraine, but said that move was unrelated to any requests for information from the Ukrainians.

Based on the facts already in the public arena, the Department of Justice has more than enough basis to open a federal criminal investigation into the former New York mayor.

It is not yet clear if Trump explicitly mentioned the hundreds of millions of dollars in military aid previously promised to Ukraine during the July 25 call — but whether he did or did not is legally irrelevant. It does seem clear, however, that the Trump-Zelensky conversations are part of a broader campaign by Trump to pressure Ukraine into doing election opposition research, using previously promised military aid package as leverage.

And the demands that Ukraine investigate Joe Biden included repeated, personal exhortations by Trump to work with Giuliani. In addition, Giuliani has by his own admission personally pushed Ukrainian officials to conduct such an “investigation.” And Giuliani can’t say definitively that Trump did not threaten Ukraine.