Originally Published: 09 AUG 23 12:09 ET

Updated: 09 AUG 23 13:26 ET

By Annie Grayer, CNN

(CNN) — House Oversight Republicans laid out their intention to accuse President Joe Biden of corruption even without direct evidence that he financially benefited from Hunter Biden’s foreign business dealings, a clear shift in their strategy that they said was launched to investigate the president.

The new strategy is highlighted in a memo released by the committee on Wednesday.

“President Biden’s defenders purport a weak defense by asserting the Committee must show payments directly to the President to show corruption,” the House Oversight Republicans wrote.

“This is a hollow claim no other American would be afforded if their family members accepted foreign payments or bribes. Indeed, the law recognizes payments to family members to corruptly influence others can constitute a bribe,” the memo says. The panel points to a resource guide of the Foreign Corrupt Practices Act that states “companies also may violate the FCPA if they give payments or gifts to third parties, such as an official’s family members, as an indirect way of corruptly influencing a foreign official.” Hunter Biden has not been charged or convicted of accepting bribes at this point.

The memo follows the increasing drumbeat from many House Republicans – and certainly the GOP presidential frontrunner Donald Trump – to pursue impeachment of the sitting president even without a clear establishment of facts.

But, so far, it appears the committee has not found any direct evidence that President Biden personally benefited from any of his son’s business dealings. Republicans are now insisting they don’t have to.

“No one in the Biden Administration or in the Minority has explained what services, if any, the Bidens and their associates provided in exchange for the over $20 million in foreign payments,” reads the memo.

The White House has long maintained that Comer’s investigation is designed for political purposes as it has yet to find any evidence that Joe Biden directly profited from his son’s foreign business dealings or if Hunter Biden’s entanglements influenced his decision-making while vice president.

President Biden has denied being involved in any of his son’s business dealings.

In a statement following the release of the memo, White House spokesperson Ian Sams said, “Today House Republicans on the Oversight Committee released another memo full of years-old ‘news,’ innuendo, and misdirection – but notably missing, yet again, is any connection to President Biden.”

The top Democrat on the Oversight panel, Democratic Rep. Jamie Raskin of Maryland, added, “Republicans have repeatedly twisted and mischaracterized the evidence in a transparent and increasingly embarrassing attempt to justify their baseless calls for an impeachment inquiry and distract from former President Trump’s dozens of outstanding felony criminal charges in three different cases.”

The memo argues that Hunter Biden selling his father’s “brand” around the world to enrich the Biden family is enough to prove that there was corruption and bribery connected to Joe Biden.

“During Joe Biden’s vice presidency, Hunter Biden sold him as ‘the brand’ to reap millions from oligarchs in Kazakhstan, Russia, and Ukraine,” said Committee Chairman James Comer, a Republican from Kentucky, in a statement. “It appears no real services were provided other than access to the Biden network, including Joe Biden himself. And Hunter Biden seems to have delivered.”

But Hunter Biden’s business associate Devon Archer, testified to the Oversight Committee last week that Hunter gave the false impression to executives of Burisma, the Ukrainian energy company, that he had influence over US policy.

Archer said that Hunter Biden sold the illusion of access to his father, and Archer told the panel he was “not aware of any” wrongdoing by Joe Biden and that “nothing” of importance was discussed the 20 times he recalled then-Vice President Joe Biden being placed on speaker phone during meetings with business partners.

The only evidence Oversight Republicans mention that indirectly connects Joe Biden to his son’s business dealings are a 2014 and 2015 dinner that he attended with Hunter Biden and some of his foreign business associates at Café Milano and that he visited Ukraine as vice president shortly after his son started receiving $1 million a year from Burisma, for joining their board of directors.

Wednesday’s memo comes as CNN previously reported that House Republicans are gearing up to launch an impeachment inquiry into the president as soon as next month.

The memo focuses on a previously known $3.5 million payment from Russian oligarch Yelena Baturina that Archer testified Hunter Biden was “not involved” in the meeting.

Even though Hunter Biden was not directly involved, House Oversight Republicans are attempting to show how a portion of the $3.5 million was transferred into multiple accounts until it entered an account connected to Hunter Biden. Committee Republicans then suggest, without evidence, that the payment was connected to a dinner with Baturina including Hunter and Joe Biden at Café Milano in the spring of 2014 shortly after the initial payment was made. Without presenting evidence that would provide a connection, Republicans suggested that this payment could have something to do with why Baturina is not on the public sanctions list following Russia’s invasion of Ukraine.

Hunter Biden’s business associate involved in this payment, Devon Archer, who testified to the Oversight panel last week described the Café Milano dinner as “like a birthday dinner.”

“He came to dinner, and we ate and kind of talked about the world, I guess, and the weather, and then everybody – everybody left,” Archer, who was also at the dinner, said of Joe Biden.

In a 2020 Senate report, Republicans revealed the existence of the payment from Baturina to a company tied to Hunter Biden’s business associates. But Wednesday’s memo does not detail how much of the $3.5 million Hunter Biden received specifically.

Hunter Biden’s lawyers said in 2020 that the claim that he was paid $3.5 million “is false” and the key financial transactions that Comer flagged – between Hunter Biden and billionaires from Russia and Kazakhstan – are not referenced in any of the plea documents in Hunter Biden’s criminal case and were not mentioned at his court hearing last month.

The memo focuses on deals and transactions Hunter Biden made with foreign oligarchs and leaders in Russia, Ukraine and Kazakhstan. The panel subpoenaed six banks for information regarding specific Biden family business associates, but has not yet subpoenaed bank records from Biden family members themselves.

This story has been updated with additional developments.