Former Trump campaign chairman Paul Manafort was wiretapped by U.S. government investigators both before and after the 2016 presidential election, according to a new report.

Manafort is a key figure in Special Counsel Robert Mueller’s investigation into Russia’s involvement with the election.

On “Fox & Friends,” Judge Andrew Napolitano explained that the FBI obtained a warrant from a FISA court to surveil Manafort in 2014 because of his work with the pro-Russia political party in Ukraine. That warrant was discontinued, but investigators received another one that extended into the beginning of this year.

He said it’s not clear if this new one is a FISA or a regular Article III judge warrant, which he said is a “real serious distinction.”