The sentencing memo submitted by Cohen’s lawyers attributes to misplaced loyalty his decision to lie to Congress about Trump’s business negotiations over a Moscow hotel project. Cohen does not say that the president instructed him to lie. He was aware, his lawyers write, of the president’s public statements—that he had no such dealings with Russia—and he chose a line of testimony that would not contradict them. For more, see Lawfare’s There’s a Lot Going On in Michael Cohen’s Sentencing Memo and The Atlantic’s Three Remarkable Things About Michael Cohen’s Plea.