This is a legit question, but Occam's razor suggests this is more Trump retribution against someone he's taken a dislike to. It couldn't happen to a nicer guy, Bolton refused to testify during Trump's first impeachment when he could have moved the needle on Trump running US foreign policy for his own benefit.
The answer is probably yes. There are so many documents and so many rules that it's probably hard to be perfect. The difference is how people respond when notified; do they try to keep them or do they cooperate and give them back?
