President Donald Trump listed a reimbursement to his lawyer Michael Cohen on his 2018 financial disclosure form.

Cohen had paid $130,000 in October 2016 to Stormy Daniels, the adult-film star who says she had an affair with Trump in 2006.

Experts say the disclosure introduces new headaches for Trump.

The Office of Government Ethics sent a letter to Deputy Attorney General Rod Rosenstein regarding the report.

In his 2018 financial disclosure report, President Donald Trump revealed that he reimbursed his longtime lawyer Michael Cohen for the $130,000 hush-money payment to the adult-film actress Stormy Daniels that Cohen had facilitated just before the 2016 presidential election.

Daniels says she had an affair with Trump in 2006, and Cohen made the payment to keep her from discussing that in the press. She is now suing Cohen.

The 92-page financial disclosure form, released Wednesday, says the payment was "not required to be disclosed as 'reportable liabilities,'" though it said Trump disclosed it "in the interest of transparency."

"In 2016 expenses were incurred by one of Donald J. Trump's attorneys, Michael Cohen," the form says. "Mr. Cohen sought reimbursement of those expenses and Mr. Trump fully reimbursed Mr. Cohen in 2017. The category of value would be $100,001-$250,000 and the interest rate would be zero."

The Office of Government Ethics, which released the form, disagreed with the assessment, saying Trump should have disclosed the payment in last year's filing.

"OGE has concluded that the information related to the payment made by Mr. Cohen is required to be reported and that the information provided meets the disclosure requirement for a reportable liability," the agency wrote.

David Apol, the director of the OGE, sent a letter to Deputy Attorney General Rod Rosenstein, saying he "may find the disclosure relevant to any inquiry you may be pursuing regarding the President's prior report that was signed on June 14, 2017."

"This is tantamount to a criminal referral," said Walter Shaub, the former director of the OGE under Trump who has since become one of his chief critics. "OGE has effectively reported the president to DOJ for potentially committing a crime."

Earlier this month, Trump's attorney Rudy Giuliani said in media interviews that Trump had reimbursed Cohen for the payment via a retainer and that Trump did not know the purpose of the payment until recently.

Cohen initially said Trump did not reimburse him for the hush-money payment to Daniels, whose real name is Stephanie Clifford. Cohen and the White House have denied that any affair took place.

Shaub tweeted that the disclosure meant Trump was "sticking with the claim that he did not know about the debt last year, which is implausible." Shaub added that Trump is claiming there are no other debts and that Giuliani "may have lied" when he said Trump paid Cohen as much as $460,000 through the retainer.

"In turn, that means that Trump committed a crime if the omission was 'knowing and willful," Shaub wrote. "Trump may be wondering today whether the information DOJ seized from Cohen's office included any emails or other documents showing he knew of the debt when he filed last year's report."