Received by NSD/FARA Registration Unit 03/01/2016 11:56:05 AM OMB No. 1124-0004; Expires April 30,2017 u.s. Department of justice Washington, DC 20530 ' Exhibit B to Registration Statement Pursuant to the Foreign Agents Registration Act of 1938, as amended INSTRUCTIONS. A registrant must furnish as ah Exhibit B copies of each written agreement and the terms and conditions of each oral agreement with his foreign principal, including all modifications of such agreements, or, where no contract exists, a full statement of all the circumstances by reason of which the registrant is acting as an agent of a foreign principal. Compliance is accomplished by filing an electronic Exhibit B form at http://www.fara.gov • Privacy Act Statement. The filing of this document is required for the Foreign Agents Registration Act of 1938, as amended, 22 U.S.C. § 611 et seq., for the purposes of registration Under the Act and public disclosure. Provision ofthe information requested is mandatory, and failuretoprovide the information is subject to the penalty and enforcement provisions established in Section 8 of the Act. Every registration statement, short form registration statement, supplemental statement, exhibit, amendment, copy of informational materials Or other document or information filed with the Attorney General under this Act is a publicrecordopen to public examination, inspection and copying during the posted business hours of the Registration Unit in Washington, DC. Statements are also available online at the Registration Unit's webpage: http://www:fara.gov. One copy of every such document, other than informational materials, is automatically provided to the Secretary of State pursuant to Section 6(b) ofthe Act, and copies of any and all documents are routinely made available to other agencies, departments and Congress pursuant to Section 6(c) ofthe Act, The Attorney General also transmits a semissnnualreportto Congress on the administration of the Act which lists the names of all agents registered under the Act and the foreign principals theyrepresent.Thisreportis available to the public in print and online at: http://www.fara.gov. Public Reporting Burden. Publicreportingburden for this collection of information is estimated to average .33 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing andreviewingthe collection of information. Send commentsregardingthis burden estimate or any other aspect of this collection of information, including suggestions forreducingthis burden to Chief, Registration Unit, Counterespionage Section, National Security Division, U.S. Department of Justice, Washington, DC 20530; and to the Office Of Information and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503. 1. Name of Registrant LANNY J. DAVIS & ASSOCIATES, LLC 2. Registration No. 6329 3. Name of Foreign Principal OFFICE OF THE PRIME MINISTER, ST. CHRISTOPHER & NEVIS (Note, payment for services shall come from CS Global, a private UK company located at 10 Dover Street, Mayfair, W1S 4LQ, London, UK) Check Appropriate Box: 4. [x The agreement between the registrant and the above-named foreign principal is a formal written contract I f this box is checked, attach a copy of the contract to this exhibit. 5. • There is no formal written contract between the registrant and the foreign principal. The agreement with the above-named foreign principal has resulted from an exchange of correspondence. I f this box is checked, attach a copy of all pertinent correspondence, including a copy of any initial proposal which has been adopted by reference in such correspondence. 6. • The agreement or understanding between the registrant and the foreign principal is the result of neither a formal written contract nor an exchange of correspondence between the parties. If this box is checked, give a complete description below of the terms and conditions of the oral agreement or understanding, its duration, the fees and expenses, i f any, to be received, 7. Describe fully the nature and method of performance of the above indicated agreement or understanding. This is an amended Exhibit, filing a fully-executed copy ofthe written Agreement between the Registrant and Foreign Principal. Registrant will provide legal advice and services to assist the government of St. Christopher & Nevis to address the concerns ofthe US Treasury Department and the Canadian government and to review and advise the Government on achieving enhanced due diligence and background vetting related to the Citizenship-by-lnvestment Program. FORM NSD-4 Revised 03/14 Received by NSD/FARA Registration Unit 03/01/2016 11:56:05 AM Received by NSD/FARA Registration Unit 03/01/201641:56:05 AM 8. Describe fully the activities the registrant engages in or proposes to engage in on behalf of the above foreign principal. This is an amended Exhibit, filing a fully-executed copy ofthe written Agreement between the Registrant and Foreign Principal. Please see attached Agreement, definition of the "Sen/ices." Registrant will provide legal advice and services to assist the government of St. Christopher & Nevis to address the concerns ofthe US Treasury Department and the Canadian government and to review and advise the Government oh achieving enhanced due diligence and background vetting related to the Citizenship-by-lnvestment Program. 9. Will the activities on behalf of the above foreign principal include political activities as defined in Section l(o) of the Act and in the footnote below? Yes E No • Ifyes, describe all such political activities indicating, among other things, the relations, interests or policies to be influenced together with the means to be employed to achieve this purpose. This is an amended Exhibit, filing a fully-executed copy ofthe written Agreement between the Registrant and Foreign Principal. Please see attached Agreement, definition ofthe "Services." Registrant is a law firm. Registrant will provide legal advice and services to assist the govemment of St. Christopher & Nevis to address the concerns ofthe US Treasury Department and the Canadian government and to review and advise the Government on achieving enhanced due diligence and background vetting related to the Citizenship-by-lnvestment Program. EXECUTION In accordance with 28 U.S.C. § 1746, the undersigned swears or affirms under penalty of perjury that he/she has read the information set forth in this Exhibit B to the registration statement and that he/she is familiar with the contents thereof and that such contents are in their entirety true and accurate to the best of his/her knowledge and belief. Date of Exhibit B March 01,2016 Name and Title Lanny J. Davis, Esq., Principal Signature /s/Lanny J. Davis eSigned Footnote: "Political activity," as defined in Section l(o) of the Act, means any activity which the person engaging in believes will, or that the person intends to, in any way influence any agency or official of the Govemment ofthe United States or any section of the public within the United States with reference to formulating, adopting, or changing the domestic or foreign policies of the United States or with reference to the political or public interests, policies, or relations of a government ofa foreign country or a foreign political party. Received by NSD/FARA Registration Unit 03/01/2016 11:56:05 AM Received by NSD/FARA Registration Unit 03/01/2016 11:56:05 AM LANNY J. DAVIS '& A S S O G I A T E S ViAE-MAit;chelesarawlin^ Peefemb^r20,2015 Honorable Tjmbth^ Qffiteof the Prime Minister Saint Christopher and Nevis Government Headquarters Church Street/Post Office Box 186 Basseterre, St. Kitts RE: NEW ENGAGEMENT Dear Prime Minister Harris: This confirms a hew engagement agreement between the law offices of Lanny J. Davis & Associates LLC {UD&A) and Office of the Prime Minister, Saint Christopher and Nevis ("the Client"), to assist the government of $t. Kitts ana* Nevis to address the concerns of the U.S. Treasury Department and the Canadian government and to review and advise the government on due diligence and baelc^rouhd yetting of all applicants to the Citizenship^by-lrty^ Program (the "Program") to assure 100% appropriate individuals are granted passports, with standards of diligence that meet with the approval and after the guidance of the U.S. government and the government of Canada, CBmpfiant^wftri; the recommendations of IPSAi internatipnal for enhancing the efficiency and quality of the work done by the Program and the due diligence required by the USG and Canadian gov*rhmenti(triie "Services"). Such legal advice and strategies, therefore, are rendered with the understanding that their communication to you and reliance on them are subject to the attorneyclient and work product privilege. It is intended that LEViCK Strategic Communications will, pursuant to a subcontract, assist me In the provision of such services, and thus, shall be included under the protection of attorney-client privilege afforded to me as an attorney when providing legal advice to you. Aside from my independent practice of law on the premises of LEVICK, I am also an Executive Vice President of LEVICK. I, as principal of my law firm, will be principally responsible for Services provided to ybu. As circumstances warrant, subject to your approval, other lawyers or non-lawyer professionals might be engaged by me to work on this matter under my superviisioh arid as my subcontractors, including Levick. 1900MSM&£^ Washmgton, DC 2003$ I Mam#: (202l7$6^2M IFax #: (202) 737-1141 Received by NSD/FARA Registration Unit 03/01/2016 11:56:05 AM Received by NSD/FARA Registration Unit 03/01/2016 11:56:05 AM Q LANNY J.DAVIS . Office of the^Prlme Minister^ i A S S O f l A T E S Nevis Engagement Letter December 20,2015 Page Two Fees The Services shall be performed at a fee of $10,000 per month for three months, beginning on December 1, 2015 and ending February 29, 2016. Therefore, a wire transfer of $10,000 is due now and then on the first of each month thereafter. (Please note: All financial and other obligations under the terms of this engagement letter - fees and disbursements - shall be the sole and exclusive responsibility of CS iGtobai Partners and not the government of St. Kitts & Neyis;) Not included in these monthly flat fees are authorized out-of-pocket expenses including necessary travel, authorized by Client (business class airfare, hotel, meals, cab fares, parking, etc.) and inhouse services (such as postage, telephone charges, duplicating charges, etc.). All disbursements shall be due upon invoice at the end of every month. This agreement may be terminated by either party at any time by written notice on the first of any succeeding month sent by registered m a i l - however any monthly fee paid in advance shall not be refundable^ Wire Transfer Information Payments should be made by wire transfer to the following account info: Bank: Address: Acct. Name: ABA#: Account #: Swift Code: PNC Bank 1913 Massachusetts Avenue, NW Lanny J. Davis & Associates LLC In order to avoid misunderstandings concerning potential conflicts of interest, it is my policy to identify and notify you of any clients whose interests may be adverse to yours. My representation of you does not extend to any parent organizations, subsidiaries;^ officers, directors, shareholders, partners or affiliates. Unless I am otherwise instructed by you in writing at or prior to the completion of the matter for which you have engaged me, I will within six (6) months of the completion of the matter for which you have engaged me or the termination of my services, whichever comes first, at my discretion, dispose of documents (hard copies, electronic and any other media) arid other materials that remain in my possession relating to a matter for which my services have been completed or terminated. In the unlikely event that circumstances make it necessary to do so, I reserve the right to withdraw from this engagement for nonpayment of my fees or for any other reason authorized or required by applicable rules of professional responsibility. iWQimStjreeX im^ 200361 Main #: (202) 7S6MtUi-ax#; {202) 737-1141 Received by NSD/FARA Registration Unit 03/01/2016 11:56:05 AM Received by NSD/FARA Registration Unit 03/01/2016 11:56:05 AM :iA:NM¥J>DAVIS .'$vA'.'.S'-.5";0 C I A T E S Office ot the Prim Oecember 20,2015 Page Three Nevis Engagement Letter Indemnification The Services to be provided will be subject to the instruction of you, and so long as those instructions: are followed in good faith, you will indemnify UD&A and LEVICK for all costs and liabilities, including reasonable attorney's fees relating to or in connection with any claims, actions, demands made regarding the performance of the Services; provided that this provision shall not apply in the event of any final judicial or arbitral adjudication that finds that U D&A and LEVICK has been grossly negligent, acted in bad faith or committed fraud. The liability for this indemnification provision shall arise and be deemed to commence immediately upon the notice of any such claim(s). In the event you do not comply with this provision, you shall be liable for any reasonable attorney's fees expended by UD&A to enforce this provision. You agree that all disputes under this agreement or mdemniffcafion provision shall be determined by an expedited, binding arbitration under the rules of the American Arbitration Association, such arbitration to occur in Washington, D.C, with all such judgments of the arbitrator to be enforceable in D.C. U.S. District Court. If the foregoing correctly sets forth the terms of our engagement, please date and sign this letter and e-mail to me at your earliest convenience. I appreciate this opportunity to serve you and look forward to continuing to work with you on this matter. Sincerely, Lanny J. Davis Agreed to and accepted: Date: By: Honorable Timothy Harris Prime Minister Date: By: Ms. Micha Emmett Managing Director CS Global Partners l?MMSlremtM[$^ 2lmC 4 20036 IMain ft: (202) 756-82111 Fax #: (202) 737-1141 wwwJanhyjdavi&com Received by NSD/FARA Registration Unit 03/01/2016 11:56:05 AM