Received by NSD/FARA K$&mfani^!W/$lG&P2:45 PM u.s. Department of Justice Exhibit A to Registration Statement Washington, DC 20530 Pursuant to the Foreign Agents Registration Act of 1938, as amended INSTRUCTIONS. Furnish this exhibit for EACH foreign principal listed in an initial statement and for EACH additional foreign principal acquired subsequently. The filing of this document requires the payment ofa filing fee as set forth in Rule (d)(1), 28 C.F.R. § 5.5(d)(1). Compliance is accomplished by filing an electronic Exhibit A form at http://vvwv.fara.gov. Privacy Act Statement. The filing of this document isrequiredby the Foreign Agents Registration Act of 1938, as amended, 22 U.S.C- § 611 etseq,, for the purposes of registration under the Act and public disclosure. Provision of the information requested is mandatory, arid failure tb provide this information is subject to the penalty and enforcement provisions established in Section 8 ofthe 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 public record open 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) of the Act, and copies of any and all documents are routinely made available to other agencies, departments and Congress pursuant to Section 6(c) of the Act. The Attorney General also transmits a semi-annual report to Congress on the administration of the Act which lists the names of all agents registered under the Act and the foreign principals they represent. This report is available to the public in print and online at: http://vvwvv.fara.gov. Public Reporting Burden. Public reporting burden for this collection of information is estimated to average .49 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send commentsregardingthis burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden to Chief, Registration Unit, Counterespionage Section, National Security Division, U.S. Department of Justice, Washington, DC 20530; and to the Office ofinformation and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503. 2. Registration No. I . Name and Address of Registrant Flynn Intel Group, Inc. 44 Canal Center Plaza, Alexandria, VA 22314 6406 3. Name of Foreign Principal Inovo BV 4. Principal Address of Foreign Principal 47 Adriaanstraat, 3581 SC Utrecht, The Netherlands 5. Indicate whether your foreign principal is one of the following: • Government of a foreign country • Foreign political party 1 13 Foreign or domestic organization: If either, check one of the following: • Partnership • Committee EI Corporation • Voluntary group • • Other (specify) Association • [ Individual-State nationality 6. I f the foreign principal is a foreign government, state: a) Branch or agency represented by the registrant b) Name and title of official with whom registrant deals 7. If the foreign principal is a foreign political party, state: a) Principal address b) Name and title of official with whom registrant deals c) Principal aim 1 "Government of a foreign country," as defined in Section 1(e) of the Act, includes any person or group of persons exercising sovereign de facto or de jure political jurisdiction over any country, other than the United States, or over any part of such country, and includes any subdivision of any such group and any group or agency to which such sovereign de facto or de jure authority or functions are directly or indirectly delegated. Such term shall include any faction or body of insurgents within a country assuming to exercise governmental authority whether such faction or body of insurgents has or has not been recognized by the United States. FORM NSD 3 Received by NSD/FARA Registration Unit 03/07/2017 6:02:45 PM Revtadta/u Received by NSD/FARA Registration Unit 03/07/2017 6:02:45 PM 8. If the foreign principal is not a foreign government or a foreign political party: a) State the nature of the business or activity of this foreign principal. See attachment. b) Is this foreign principal: Supervised by a foreign government, foreign political party, or other foreign principal Yes • No 13 Owned by a foreign government, foreign political party, or other foreign principal Yes • No IE! Directed by a foreign government, foreign political party, or other foreign principal See attachment. Yes • No S Controlled by a foreign government, foreign political party, or other foreign principal Yes • No El Financed by a foreign government, foreign political party, or other foreign principal Yes • No H Subsidized in part by a foreign government, foreign political party, or other foreign principal Yes • No S 9. Explain fully all items answered "Yes" in Item 8(b). (If additional space is needed, a full insert page must be used.) 10. If the foreign principal is an organization and is not owned or controlled by a foreign government, foreign political party or other foreign principal, state who owns and controls it. See attachment. 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 A 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 A Name and Title March 07,2017 Michael T. Flynn, Chairman and CEO Signature /s/ Michael T. Flynn Received by NSD/FARA Registration Unit 03/07/2017 6:02:45 PM eSigned Received by NSD/FARA Registration Unit 03/07/2017 6:02:45 PM Flynn Intel Group, Inc., Registration Statement, Exhibit A Attachment Items 8-10 ~ Inovo BV ("Inovo") is a Dutch company incorporated in 2005 to provide business consultancy services. Flynn Intel Group understands the sole owner of Inovo BV to be Mr. Ekim Alptekin. According to Arent Fox, LLP, counsel to Mr. Alptekin: 1. Inovo is a privately owned company that has not received, directly or indirectly^ funds or financial support from any government during the course of its engagement of Flynn Intel Group Inc., including the Republic of Turkey. 2. At the time Inovo hired Flynn Intel Group, Inovo represented a private sector company in Israel that sought to export natural gas to Turkey, and it was for support of its consulting work for this client that Inovo engaged Flynn Intel Group, specifically to understand the tumultuous political climate at the time between the United States and Turkey so that Inovo could advise its client regarding its business opportunities and investment in Turkey. 3. Mr. Alptekin is a businessman who holds a number of positions in international business organizations, such as Honorary Counsul to the Republic of Albania, and Chairman of the Turkish-American Business Council. Mr. Alptekin and any organization in which he participates are not agents of the government of the Republic of Turkey. Flynn Intel Group does not know whether or the extent to Which the Republic of Turkey was involved with its retention by Inovo for the three^month project. Flyrih Intel Group is aware that Mr. Alptekin consulted with officials of the Republic of Turkey regarding potential work by Flynn Intel Group, and Mr. Alptekin introduced officials of the Republic of Turkey to Flynn Intel Group officials at a meeting on September 19, 2016, in New York. Received by NSD/FARA Registration Unit 03/07/2017 6:02:45 PM Received by NSD/FARA R e & m f a b ^ < ^ j $ l c J & $ 2 : 4 5 PM u.s. Department of justice Exhibit B to Registration Statement Washington, DC 20530 Pursuant to the Foreign Agents Registration Act of 1938, as amended INSTRUCTIONS. A registrant must fumish as an 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 byfilingan electronic Exhibit B form at http:/Avww.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 el seg., for the purposes of registration under the Act and public disclosure. Provision of the information requested is mandatory, and failure to provide tlie 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, amendmen t, copy of informational materials or other document or mformationfiledwith the Attorney General under this Act is a public record open to public examination, inspection and copying during the posted business hours ofthe Registration Unit in Washington, DC. Statements are also available online at the Registration Unit's webpage: http:/Avww.fara.gov. One copy of every such document, other than infonnational 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) of the Act. The Attorney General also transmits a semi-annual report to Congress on the administration of the Act which lists the names of all agents registered under the Act and the foreign principals they represent. This report is available to the public in print and online at: http://wvvw.fara.gov. Public Reporting Burden. Public reporting burden 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 and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden to Chief, Registration Unit, Counterespionage Section, National Security Division, U.S. Department of Justice, Washington, DC 20530; and to the Office ofinformation and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503. 1. Name of Registrant 2. Registration No. 6406 Flynn Intel Group, Inc. 3. Name of Foreign Principal Inovo BV Check Appropriate Box: 4. [x] The agreement between the registrant and the above-named foreign principal is a formal written contract. If 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. If 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, if any, to be received. 7. Describe fully this nature and method of performance of the above indicated agreement or understanding. See attached contract. _ • Received by NSD/FARA Registration Unit 03/07/2017 6:02:45 PM FORM NSD-4 Revised 03/14 Received hy NSD/FARA Registration Unit 03/07/2017 6:02:45 PM 8. Describe fully the activities the registrant engages in or proposes to engage in on behalf of the above foreign principal. Flynn Intel Group was tasked to perform investigative research for a specified scope of work using its laboratory team of senior defense, diplomacy, development, and intelligence professionals over a three-month period. Flynn Intel Group was to retain an experienced filming and production crew in order to develop a short film piece on the results of its investigation, and a public affairs firm to utilize for public affairs as needed. Flynn Intel Group held weekly calls with the client to report engagement progress. 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 H 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. See response to item 8. 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 07,2017 Name and Title Michael T. Flynn, Chairman and CEO Signature Isl Michael T. Flynn eSigned Footnote: "Political activity," as defined in Section 1(6) 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 Government of the United States or any section ofthe 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 pol itical or public interests, policies, or relations of a government of a foreign country or a foreign political party. Received by NSD/FARA Registration Unit 03/07/2017 6:02:45 PM Received by NSD/FARA Registration Unit 03/07/2017 6:02:45 PM Independent Advisory Services Agreement This agreement is executed by and between INOVO BV, en entity organized end operating under die law* of the Netherlands with itt principal offices located at 47, Adriaanstraat, 3581 SC Utrecht, The Netherlamb (VAT NL8146.4S.756B02) hereinafter referred to as "client" end, Flynn Intel Group, me, an entityregisteredIn ths State of Delaware in the United Stats with Its principal offices located at 44 Canal Center Plaza, Suite 400, Alexandria, Virginia, 32314 hereinafterreferredto as the "advisor". Together, ttedleiu and die advisor *haU to the"partlet" in this agreement. Redtah The client is desirous of engaging the advisor for a specified scope of wok aimed at design and delivery of a series ofresultsin discovery, analysis, packaging and presentation offindingsin a credible, disable and easy to disseminate fonnatovtf aperiodofthimmmlhsftem of this agreement The advisor is uniquely qualified to accept this task and has a dear undenttanding ofthe reqiuVehtents ofthis mdependent study and investigation engagement. The advisor is an entity led by senior defense, diplomacy, development end intelligence professionals. Further, d» advisw has assembled a team of experts wh^spee^ expertise required by die scope of this engagement. A complete list of Professionals carefully selected for this assignment has been presented ami approved by the client The client expects and the advisor is prepared to deliver foldings and results including but not limited to making criminal referrals if warranted and supported by the findings. The advisor's team dedicated to thb engagement includes Sphere Cbnsuttmg, a top tier public affairs and strategic reputation managementfirmbased m VIbshingtm DC wiA global reach. Mature of the refa«nn«arn between the client and Mmndvhar The advisoris not an employee or an ageu ofthe cUentTteedvlswb an linl^ engaged for specific purpose of providing advice relating to eulsllng the client With accomplishing the objectives of this engagement the client expects the advisor to act with complete objectivity in the design and execution of its Investigative mission pertaining to this engagement Further; the client is by no means dictating to atfriw outcome or particular result the advisor acts in good faith and on the basts of best effort to obtamttegcaUofnwengagoiumtttoparto in a posiuta to guarantee resutamm^ a Scone of services The advisor wttl activate its Investigative laboratory comprised of its most senior principals including but not limited to former Director of United States Central intelligence Agency, Former Dimeter of the United States Defense Intelligence Agency, Former chairman of the Audit Committee ofthe Export Import Bank ofthe United States, former Director of Intelligence for the Joint Chiefs of Staff, Former Special Operations (Green Beret) Investigator and Inteulgenco officer, former Deputy Assistant Director of Federal Bureau of Investigations of the United States, Former senior legal counseltotlte United States Senate Gmmiittee c* two senior former FBI specialist investigators, Chairman of die Asymmetric Institute of the Department ofMUItary Studies at Johns Hopkins University and the head of Frynn Intel Group's Special Operations Cyber Force. The advisor has also retained an experiencedfilmingand I Received by NSD/FARA Registration Unit 03/07/2017 6:02:45 PM Received by NSD/FARA Registration Unit 03/07/2017 6:02:45 PM production crew with top quality experience with outlet! such as Reuters, Aljazeera, CNN, France 24 and other major media outlets. Tteedvto over the period of ninety days toreportengagement progress to the client Ihe advisor's Public Aflaia unit will continue Its specialized work tluoughout the engagement period. Lieutenant General Michael T. Flynn, Ret VS. Army,formerDirector of Defense Intelligence Agency shall lead this engagement. Term and termination The initial term of this agreement is fbr ninety days effective as of August IS, 2016 and shall continue to November IS, 2016. The agreement may be extended for another year on terms mutually agreed upon and can be subsequently terminated with a 30-day advance written notice by either party. Notifications may be made through electronic mail addressed to each party's respective electronic entail address. The term of this agreement may be extended by mutual cmtsenl of the parties Mwrffirig(eri^ Compensation Compensation for advisor's professional services is afirm,fixed price of S6Q0,00O (Six hundred thousand dollars) comprised of three payments of $204000 (Two hundred thousand dotlais) following die schedule below: * fM lastalhaatt of$200,