Yesterday we noted how yet again a FOIA request had turned up work-related emails from Clinton's personal server that were not part of her original 55,000 page data dump on the State Department (see "New Hillary Emails Expose Bill Pushing Meetings With Foundation Donors, Requests For "Diplomatic Passports""). As we pointed out, all of the new email discoveries continued to "contradict Hillary's claims to Congress that she turned over all of her government emails to the State Department" calling into question her compliance with federal record keeping laws. Despite a decision not to press charges, FBI Director James Comey even admitted to the House Judiciary Committee back in July that Clinton likely had not complied with federal record keeping laws. When pressed about her compliance Comey said simply, "I don't think so."

Today, Circa released a detailed investigation into Clinton's compliance with federal record keeping laws citing "government sources," presumably from within the FBI, with detailed knowledge of the FBI's investigation of Clinton and her team.

According to Circa's sources, the FBI "collected significant evidence suggesting she [Hillary] and her team violated federal record-keeping laws." The source pointed out that this evidence was compelling enough to cause Bryan Pagliano to "raise [his] Fifth Amendment right against self-incrimination during an investigative interview." The source also noted that while the FBI publicly chose not to file criminal charges against Hillary that privately the decision was left to the State Department to make a decision on whether federal record keeping laws had been violated.

"There was plenty of evidence from our interviews, especially from technical and compliance staff, as to the intention of creating a private email system outside the State Department's record keeping. It was well known, and it persisted even after people raised legal and security concerns," one source told Circa. In public, the FBI recommended not filing criminal charges against Clinton on national security grounds. But in private, the Bureau chose to defer to the State Department on whether to recommend anyone to the Justice Department for criminal prosecution on records law violations Each email transmission of a government document that was not preserved or turned over to the State Department from Mrs. Clinton's tenure could theoretically be considered a violation of the Federal Records Act, the main law governing preservation of government records and data. Other federal laws make it a felony to intentionally conceal, remove or destroy federal records as defined under the Act, punishable with a fine and imprisonment of up to three years. A single conviction also carries a devastating impact for anyone looking to work again in government because the law declares that any violator "shall forfeit his office and be disqualified from holding any office under the United States." The FBI "indirectly documented hundreds, and likely thousands, of violations of the Records Act," one source with direct knowledge of the FBI's investigation told Circa. Using forensics, the FBI recovered from computer drives and other witnesses about 15,000 emails from Mrs. Clinton's private account that dealt with government business, most that had not been turned over by her or her aides, the sources said. Some of the emails recovered by agents were germane to Freedom of Information Act (FOIA) requests from the public and congressional investigations and had not yet been produced, the sources said.

In fact, sources told Circa that Clinton's efforts to conceal email communications from public records laws and congressional oversight were "systemic and intentional" and began as soon as Mrs. Clinton took office in 2009.

For instance, the sources said agents secured testimony and documents suggesting that Mrs. Clinton's team: Was informed in 2009 that she had an obligation under the records law to forward any government-related records contained in private email to a new record preservation system known as SMART but chose not to do so because her office wanted to keep control over "sensitive" messages.

Was specifically questioned by a technical worker who was involved with her private email server in the Clinton family home in New York whether the arrangement was appropriate for a government official under the federal records law. The worker was assured there were no problems.

Wanted to keep her private Blackerry email service because of fears a government email address would be subject to public scrutiny under the Freedom of Information Act.

Was aware that government officers complying with FOIA requests did not have access to search Mrs. Clinton's private email for responsive records.

Persisted in allowing her to use private email to conduct State Department business even after a cable was sent under her name in 2011 to all diplomats worldwide urging them to stop using private email because of foreign hacking fears.

Allowed Clinton to keep using the private email system after after she personally received a 2011 presentation warning of dangers of the private email for government business.

Failed to preserve private emails from Clinton that clearly involved significant government business, including discussions with Army Gen. David Petraues, the Benghazi tragedy, meeting requests with foreign leaders and the State Department's quadrennial policy and performance review.

Had prior reason from earlier legal cases involving their conduct to know that emails covering government business were legally required to be preserved and turned over to their agency and the National Archives.

Circa sources also noted that the FBI's investigation found that at least two IT employees at the State Department raised questions about Clinton's personal email and lack of compliance with the Federal Records Act. Of course, those employees were promptly "scolded" for their honesty and told to "never to raise the issue of Secretary Clinton's personal email account again."