and still is a counterintelligence investigation into Trump that we don't know about. He strongly suggests that such investigations were opened on more Trump administration officials than we know.
Secondly, there's no good reason why one couldn't be opened (or, similarly, a counterespionage investigation) if there is sufficient grounds for doing so. His communications could legally be monitored.
The FBI could currently be monitoring individuals with whom Trump might come into contact if he does mess around with foreign adversaries, just like Carter Page (?), Mike Flynn and George Papadopoulos (?) were wrangled into investigations because of their contacts with people already being monitored.
Thirdly, in the 2018/19 timeframe, we heard a lot about sealed indictments. I'm not aware of any follow-up, so I don't know if those indictments were ever unsealed. Is it possible there are unsealed indictments already waiting for Trump?