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potential
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final
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unit
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you
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new
public
public
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the netherlands
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security
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march
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lda
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department of justice
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may
september
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group
group
down
down
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republic
source
source
language
language
ceo
ceo
the firm
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senate
senate
washington
washington
com
com
shanghai
shanghai
act
act
disclosure
disclosure
corporate
corporate
corporation
corporation
Best Of
Best Of
Sept
Sept
Knowledge
Knowledge
Government
Government
Doubt
Doubt
Turkey
Turkey
Principal
Principal
Netherlands
Netherlands
Michael
Michael
Mail
Mail
Justice
Justice
Intel
Intel
Information
Information
House
House
Best
Best
Work
Work
Party
Party
New York
New York
Advice
Advice

COVINGTON Hobert K Kelner Covington& Burling LLP One CityCenter 850 Tenth Street NW WasblingtonDC20001-4456 T 1202 662 5503 rkelner@covcom NEW YORK BAN PRANCIsCO oUL SHANGHAI SICON VALLY WASHINGTON VIA E-MAIL March 2017 Ms Heather Hunt FARA Registration Unit US Department of Justice 600 E Street NW Washington DC 20004 Dear Ms Hunt Michael T Flynn to submit a Foreign Agents Registration Act FARA registration and representation ofInovo BV a corporation organized in the Netherlands We write on behalf of our clients Flynn Intel Group and its Chairman and CEO General disclosure statement in conneetion with Flynn Iritel Group's previously disclosed In September 2016 Flynn Intel Group publicly disclosed its representation of Inovo BV in a federal Lobbying Disclasure Act LDA registration that was filed with the Secretary of the Senate and Clerk of the House After General Flynn was named in mid-November 2016 to serve as National Security Advisor in the new administration Flynn Intel Group shut down its operations did not renew its contract with Inovo BV and filed on December 1 2016 a final public disclosure report terminating its lobbyist registration for Inovo BV As you know under FARA a US firm that represents a foreign corporate client which is not a foreign government or political party may register under the LDA rather than FARA so long as the firm engages in lobbying activities for its client Flynn Intel Group concluded that because its client was a foreign corporation and the services provided included lobbying activities it could file under the LDA The Department's regulations provide that filing under the LDA is not an option however if a foreign government even though not the client nonetheless is the principal beneficiary' of the work performed This is an uncertain standard not based on the statutory language and not defined in the matter of extradition is sought by the Government of Turkey the engagement could be construed to have principally benefitted the Republic of Turkey To eliminate any potential doubt the Flynn Intel Group therefore is electing to file a registration under FARA in lieu of its prior LDA registration t's regulations Nevertheless because of the subject n Intel Group's work for Inovo BV which focused on Mr Fethullah Gulen whose Because this is a retroactive registration compiled after the Flynn Intel Group shut down its operations in November 2016 the enelosed supplemental disclosure statement is based on information that is currently available to Flynn Intel Group to the best of its knowledge after Meme

found ON 2019-01-19 09:35:03 BY ME.ME

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