Micheal Flynn and the Foreign Agents Registration Act (FARA)

In my lay opinion, for what it’s worth, Flynn Intel Group LLC, had no need to file a FARA registration, based on the work it did for Inovo, between August and October of 2016.

Micheal Flynn’s firm, Flynn Intel Group LLC,  entered into a contract with Inovo BV, a Dutch Firm on August 9, 2016.  After doing so, his firm  registered a new client for existing registrant,  IAW Lobbying Disclosure Act of 1995 on September 30, 2016 with an effective date of September 15, 2016.  The identified lobbyist was Robert Kelly.  It expected to do less than $5,000 for lobbying.

He was not obligated to register under The Foreign Agents Registration Act (FARA) as his firm wasn’t  “an agent representing the interests of foreign principal [1] in a political or quasi-political capacity [2].

Flynn Intel Group was assigned a task to “investigate Fethullah Gulen, a Turkish cleric who lives in Pennsylvania” specifically; “to perform investigative research” on Mr. Gulen and “develop a short film piece on the results of its investigation.”

Mr. Gulen is represented by a prominent Washington lobbyist Tony Podesta  brother and partner in Podesta Group with John D. Podesta, HRC’s campaign manager.
Podesta Group has strong ties to Russia, they represent (as of 2016) the interests of Russia’s largest financial institution Sberbank of Russia, which controls approximately 30 percent of Russian banking assets.

On October 2nd 2016 Mr. Flynn had an Op-Ed article in The Hill “Our ally Turkey is in crisis and needs our support” which referenced Mr. Gulen.

The “short film piece” was never produced.

Flynn Intel Group was closed when Mr. Flynn was appoint to a White House National Security Advisor position.

In a letter to the Justice Department March 14th, Mr. Flynn’s lawyer said that he did not initially register as a foreign agent because the firm that hired him was not a foreign government. But the lawyer, Robert K. Kelner, said Mr. Flynn had decided to register after the fact because “the engagement could be construed to have principally benefited the Republic of Turkey.”

I could find no evidence of any “lobbying” done by Robert Kelly of Flynn Intel Group.

[1] The term “foreign principal” includes —

  1.  a government of a foreign country and a foreign political party;
  2.  a person outside of the United States, unless it is established that such person is an individual and a citizen of and domiciled within the United States, or that such person is not an individual and is organized under or created by the laws of the United States or of any State or other place subject to the jurisdiction of the United States and has its principal place of business within the United States; and
  3. a partnership, association, corporation, organization, or other combination of persons organized under the laws of or having its principal place of business in a foreign country.

[2]  “Political or quasi-political capacity” includes —

  1. engages within the United States in political activities for or in the interests of such foreign principal;
  2. acts within the United States as a public relations counsel, publicity agent, information-service employee or political consultant for or in the interests of such foreign principal;
  3. within the United States solicits, collects, disburses, or dispenses contributions, loans, money, or other things of value for or in the interest of such foreign principal; or
  4. within the United States represents the interests of such foreign principal before any agency or official of the Government of the United States;

As far as I can tell Flynn’s company did none of these acts.



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