WASHINGTON(TIP): President Trump should have disclosed Michael Cohen’s hush payment to porn star Stormy Daniels as a financial liability last year, the government’s top ethics watchdog concluded Wednesday, potentially opening the President up to legal complications.

David Apol, acting director of the Government Ethics Office, said in a letter appended to Trump’s 2018 financial disclosure form that a payment Cohen made to “a third party” on behalf of the President during the 2016 election meets the requirements for a reportable “loan.”

The letter does not explicitly state what Cohen’s payment was for, but the President’s legal team and Cohen himself have previously acknowledged he paid Daniels $130,000 to keep quiet about allegedly having sex with Trump in 2006. Cohen has also admitted the hush payment was issued 11 days before Trump’s election.

While Apol didn’t say so in his letter, the revelations mean Trump could have committed a crime by not disclosing the liability in his financial disclosure report last year. Apol referred his findings to Deputy Attorney General Rod Rosenstein for any “inquiry” the Justice Department may pursue into the matter.

Trump acknowledged in the disclosure form for the first time that he fully reimbursed Cohen last year for “expenses” ranging between $100,001 and $250,000.

Ex-Mayor Rudy Giuliani insisted Trump disclosed the repayments to Cohen in this year’s report out of “an abundance of caution.”

“It’s not a loan, but he reported it anyway,” Giuliani, the latest addition to Trump’s legal team, told the Daily News, directly contradicting Apol’s findings. “It was in fact an expense, like paying a doctor. If you owe a doctor $2,000 and you pay him back, that’s not a liability.”

Giuliani claimed Trump didn’t list Cohen’s payment to Daniels in last year’s form because he didn’t need to.

“There’s nothing to report,” Giuliani said.

Asked if Trump is worried, Giuliani delivered a one-word rebuke: “Nope.”

Citizens for Responsibility and Ethics in Washington, a legal watchdog group that first flagged Trump’s disclosure omission in March, welcomed Apol’s findings and swiftly filed a criminal complaint against the President. They called on the Justice Department to look into whether he “knowingly and willfully” failed to report required information — an offense punishable by up to one year behind bars.

“There is substantial evidence that President Trump had knowledge of the loan when he filed his public financial disclosures last year,” Noah Bookbinder, the watchdog’s executive director, said in a statement. “If the department is not already investigating the President’s failure to disclose the loan last year, it should open an investigation immediately.”

A spokeswoman for the Justice Department declined to comment.

Attorney Michael Avenatti, who represents Daniels in a civil lawsuit seeking to void her nondisclosure agreement with Cohen, said the financial form “conclusively proves” that Trump, Cohen, Giuliani and the White House deceived the “American people.”

“This was NOT an accident and it was not isolated,” Avenatti tweeted. “Coverups should always matter.”

Cohen, Trump’s longtime attorney and personal fixer, had his Manhattan office, home and hotel room raided by FBI agents last month as part of a criminal investigation launched by federal prosecutors in New York. The agents seized a cache of records, including communications between Cohen and his clients.

Michael Cohen arrives at Manhattan Federal Court on April 16.

Michael Cohen arrives at Manhattan Federal Court on April 16. (Alec Tabak)

Whether Trump committed a crime by not disclosing the Cohen payments last year is a matter of whether or not he knowingly omitted them, according to experts.

“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,” former Government Ethics Director Walter Shaub tweeted.

Shaub, who served as the ethics czar between 2013 and 2017, noted that Apol’s letter to Rosenstein is tantamount to a “criminal referral.”

Shaub also recalled that, while serving as ethics director, Trump attorney Sheri Dillon asked him if the President could submit his 2017 disclosure without certifying its contents as true.

“The strangest moment in my entire career,” Shaub said.

Wednesday’s financial disclosure dump also revealed First Lady Melania Trump raked in as much as $1 million last year in royalties from photos of her owned by Getty Images.

It’s not clear what photos in particular she received royalties for, but her spokeswoman told The News the payments pertained to images taken before Trump took office.