Under Department of Justice regulations governing the Special Counsel's work, Mueller is required to consult with Deputy Attorney-General Rod Rosenstein if his team finds information worth investigating that does not fall under his mandate.

Rosenstein, as the acting attorney-general supervising Mueller's work, has the responsibility of deciding whether to expand Mueller's mandate to include the new topic or to refer it to a US attorney's office.

Known for his combative style and fierce loyalty to Trump, Cohen served for a decade as a top lawyer at the Trump Organisation, tangling with reporters and Trump's business competitors on behalf of the celebrity real estate mogul.

He never formally joined Trump's campaign but was in close contact with his longtime boss from his Trump Tower office throughout the 2016 race and presidential transition.

Cohen's aggressive tactics came into public view when he acknowledged he facilitated a US$130,000 payment in October 2016 to Daniels, who claims she had a sexual relationship with Trump in 2006.

Cohen left the Trump Organisation in January 2017, around the time of Trump's inauguration, and since then has served as a personal lawyer to the President.