Received by NSD/FARA Reg^WfamtMMZ&klzfrfil-AS PM
u.s. Department of Justice
Supplemental Statement
Washington, DC 20530
Pursuant to the Foreign Agents Registration Act of
1938, as amended
For Six Month Period Ending Nov. 30,2016
(Insert date)

I - REGISTRANT
1. (a) Name of Registrant

(b) Registration No.

Flynn Intel Group, Inc.

6406

(c) Business Address(es) of Registrant
44 Gahal Center Plaza, Alexandria, VA 22314

2. Has there been a change in the information previously furnished in connection with the following?
(a) If an individual:
(1) Residence address(es)
Yes •
No •
(2) Citizenship
Yes •
No •
(3) Occupation
Yes •
No •
(b) If an organization:
(1) Name
(2) Ownership or control
(3) Branch offices

Yes Q
Yes •

No 0
No 0

Yes •

No 0

Flynn Intel Group's sole office closed in November 2016.

(c) Explain fully all changes, i f any, indicated in Items (a) and (b) above.
Flynn Intel Group, Inc. suspended activities in November 2016.

IF THE REGISTRANT IS AN INDIVIDUAL, OMIT RESPONSE TO ITEMS 3, 4, AND 5(a).
3. If you have previously filed Exhibit C', state whether any changes therein have occurred during this 6 month reporting period.
Yes •
No H
If yes, have youfiledan amendment to the Exhibit C?
Yes •
No •
If nOj please attach the required amendment.
?

1 The Exhibit C, for which no printed form is provided, consists of a true.copy ofthe charter, articles of incorporation, association, and by laws of a registrant that is an
organization. (A waiver ofthe requirement to file an Exhibit C may be obtained for good cause upon written application to the Assistant Attorney General, National Security
Division, U.S. Department of Justice, Washington, DC 20530.)
-

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FORM NSD-2
Revised 03/14

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(PAGE 2)
4. (a) Have any persons ceased acting as partners, officers, directors or similar officials of the registrant during this 6 month reporting period?
Yes •
No H
If yes, furnish the following information:
Name
Position
Date Connection Ended

(b) Have any persons become partners, officers, directors or similar officials during this 6 month reporting period?
Yes •
No 0
Ifyes, furnish the following information:
Name
Residence Address
Citizenship
Position
Date Assumed

5. (a) Has any person named in Item 4(b) rendered services directly in furtherance of the interests Of any foreign principal?
Yes •
No •
If yes, identify each such person and describe the service rendered.

(b) During this six month reporting period, has the registrant hired as employees or in any other capacity^ any persons who rendered
or will render services to the registrant directly Ln furtherance of the interests of any foreign principal(s) in other than a clerical or
secretarial, or in a related or similar capacity?
Yes •
No S
Name

Residence Address

Citizenship

Position

Date Assumed

(c) Have any employees or individualSi who have filed a short form registration statement, terminated their employment or
connection with the registrant during this 6 month reporting period? Yes H
NoD
Ifyes, furnish the following informationName
Position or Connection
Date Terminated
Flynn Intel Group, Inc. suspended activities in
November 2016.

(d) Have any employees or individuals, who havefileda short form registration statement, terminated their connection with any foreign
principal during this 6 month reporting period? Yes H
NoD
If yes, furnish the following information:
Name
Position or Connection
Foreign Principal
Date Terminated
The contract between Inovo BV and
Flynn Intel Group ended by its terms
on November 15,2016.

6. Have short form registration statements beenfiledby all ofthe persons named in Items 5(a) and 5(b) ofthe supplemental statement?
Yes •
No •
Ifno, list names of persons who have notfiledthe required statement.

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(PAGE 3)

II - FOREIGN PRINCIPAL
7. Has your connection with any foreign principal ended during this 6 month reporting period?
If yes, furnish the following information:
Foreign Principal

Yes H

NoD

Date of Termination

Inovo BV

November 15,2016

2

8. Have you acquired any new foreign principal(s) during this 6 month reporting period?
If yes, furnish th following information:
Name and Address of Foreign Principal(s)

Yes •

No H

Date Acquired

2

9. In addition to those named in Items 7 and 8, if any, list foreign principal(s) whom you continued to represent during the 6 month
reporting period.

10. (a) Have you filed exhibits for the newly acquired foreign principal(s), if any, listed in Item 8?
Exhibit A
Yes •
No •
Exhibit B
Yes •
No •
If ho, please attach the required exhibit.
3

4

(b) Have there been any changes in the Exhibits A and B previously filed for any foreign principal whom you
represented during this six month period?
Yes •
No 13
If yes, have you filed an amendment to these exhibits?
YesD
NoD
If no, please attach the required amendment.

2 The term "foreign principal" includes, in addition to those defined in Section 1(b) of the Act, an individual organization any of whose activities are directly or indirectly
supervised, directed, controlled,financed,or subsidized in whole or in major part by a foreign government, foreign political patty, foreign organization or foreign individual.
(See Rule 100(a) (9)). A registrant who represents more than one foreign principal is required tb list in the statements hefilesunder the Act only those principals for whoni he
is not entitled to claim exemptionunder Section 3 of the Act. (See Rule 208.)
3 The Exhibit A, which isfiledon Form NSD-3, sets forth the information required to be disclosed concerning each foreign principal.
4 The Exhibit B, which isfiledon Form NSD-4, sets forth the infonnation concerning the agreement or understanding between the registrant and the
foreign principal.

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(PAGE 4)

III - ACTIVITIES
11. During this 6 month reporting period, have you engaged in any activities for or rendered any services to any foreign principal
named in Items 7, 8, or 9 of this statement?
Yes H
No •
Ifyes, identify each foreign principal and describe in full detail your activities and services:
See attachment.

5

12. During this 6 month reporting period, have you on behalf of any foreign principal engaged in political activity as defined below?
Yes 0
No •
If yes, identify each such foreign principal and describe in full detail all such political activity, indicating, among other things,
the relations, interests and policies sought to be influenced and the means employed to achieve this purpose. If the registrant
arranged, sponsored or delivered speeches, lectures or radio and TV broadcasts, give details as to dates, places of delivery,
names of speakers and subject matter.
See attachment.

13. In addition to the above described activities, if any, have you engaged in activity on your own behalf which benefits your
foreign principal(s)?
Yes H
No •
If yes, describe fully.
Because of its expertise, Flynn Intel Group officials frequently write, speak, and give interviews on issues related to
national security. Although not undertaken at the direction or control ofa foreign principal, it is possible that such
activities may have an indirect benefit to a principal. On his own initiative, Michael T. Flynn published an op-ed in The Hill
on November 8,2016, that related to the same subject matters as the Flynn Intel Group work for Inovo BV. Neither Inovo
BV, nor any other person requested or directed publication ofthe op-ed.

5 "Political activity," as defined in Section l(o) of the Act, means any activity that 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 of the public within the United States with reference to formulating, adopting or changing the domestic
or foreign policies ofthe United States or with reference to political or public interests, policies, or relations of a government of a foreign country or a foreign political party.

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(PAGE 5)

IV - FINANCIAL INFORMATION
14. (a) RECEIPTS-MONIES
During this 6 month reporting period, have you received from any foreign principal named in Items 7, 8, or 9 of this
statement, or from any other source, for or in the interests of any such foreign principal, any contributions, income or
money either as compensation or otherwise?
Yes H
No •
If no, explain why.

6

If yes, set forth below in the required detail and separately for each foreign principal an account of such monies.
Date
See attachment.

From Whom

Purpose

Amount

Total
(b) RECEIPTS - FUNDRAISING CAMPAIGN
During this 6 month reporting period, have you received, as part of a fundraising campaign , any money on behalf of any
foreign principal named in I tems 7, 8, or 9 of this statement?
Yes •
No El
7

8

Ifyes, have you filed an Exhibit D to your registration?
If yes, indicate the date the Exhibit D was

filed.

Yes •

No •

Date

(c) RECEIPTS-THINGS OF VALUE
During this 6 month reporting period, have you received any thing of value other than money from any foreign principal
named in Items 7, 8, or 9 of this statement, or from any other source, for or in the interests of any such foreign principal?
Yes •
No H
9

If yes, furnish the following information:
Foreign Principal

Date Received

Thing of Value

Purpose

6, 7 A registrant is required to file an Exhibit D if he collects or receives contributions, loans, moneys, or other things of value for a foreign principal, as part of a fundraising
campaign. (See Rule 201(e)).
8 An ExhibitD, for which no printed form is provided, sets forth an account of money collected or received as a result of a fundraising campaign and transmitted for a foreign
principal.
9 Things of value include but are not limited to gifts, interest free loans, expense free travel, favored stock purchases, exclusiverights,favored treatment over competitors,
"kickbacks," and the like.

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(PAGE 6)

15. (a)

DISBURSEMENTS-MONIES
During this 6 month reporting period, have you •
(1) disbursed or expended monies in connection with activity on behalf of any foreign principal named in Items 7, 8, or
9 of this statement? Yes El
NoD
(2) transmitted monies to any such foreign principal?
Yes •
No •
Ifno, explain In full detail why there were no disbursements made on behalf of any foreign principal.

If yes, set forth below in the required detail and separately for each foreign principal an account of such monies, including
monies transmitted, if any, to each foreign principal.
Date
See attachment.

To Whom

Purpose

Amount

Total

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(PAGE 7)

(b) DISBURSEMENTS-THINGS OF VALUE
During this 6 month reporting period, have you disposed of anything of value other than money in furtherance of or in
connection with activities on behalf of any foreign principal named in Items 7, 8, or 9 of this statement?
Yes •
No IS]
10

If yes, furnish the following information:
Date

(c)

Recipient

Foreign Principal

Thing of Value

Purpose

DISBURSEMENTS-POLITICAL CONTRIBUTIONS
During this 6 month reporting period, have you from your own funds and on your own behalf either directly or through any
other person, made any contributions of money or other things of value" in connection with ah election to any political
office, or in connection with any primary election, convention, or caucus held to select candidates for political office?
Yes H

No •

If yes, furnish the following information:
Date

Amount or Thing of Value

Political Organization or Candidate

Location of Event

Rafiekian
10/31/16

$250

Trump Make American Great Again
Committee

Rafiekian
*

*

Zinke For Congress

* Mr. Rafiekian is searching for
records ofthe date and amount of
the contribution, which he believes
he made, and will amend this
report when the information is
located.

10, 11 Things of value include but are not limited to gifts, interest free loans, expense free travel, favored stock purchases, exclusive rights, favored treatment over competitors,
"kickback's," and the like.

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(PAGE 8)

V - INFORMATIONAL MATERIALS
12

16. (a) During this 6 month reporting period, did you prepare, disseminate or cause to be disseminated any informational materials?
Yes H
No •
IfYes, goto Item 17.
(b) If you answered No to Item 16(a), do you disseminate any material in connection with your registration?
Yes •
No •
If Yes, please forward the materials disseminated during the six month period to the Registration Unit for review.
17. Identify each such foreign principal
Inovo BV.

18. During this 6 month reporting period, has any foreign principal established a budget or allocated a specified sum of money to
finance your activities in preparing or disseminating informational materials?
Yes •
No H
Ifyes, identify each such foreign principal, specify amount, and indicate for what period of time.
See attachment.

19. During this 6 month reporting period, did your activities in preparing, disseminating or causing the dissemination of informational
materials include the use of any of the following:
• Radio or TV broadcasts
• Magazine or newspaper • Motion picture films
• Letters or telegrams
• Advertising campaigns
• Press releases
• Pamphlets or other publications • Lectures or speeches
H Other (specify) See attachment.
'
Electronic Communications
•
•
•
H

Email
Website L'RL(s):
;
Social media websites URL(s): _ ^
Other (specify) See attachment.

_
.

'
.

20. During this 6 month reporting period, did you disseminate or cause to be disseminated informational materials among any of
the following groups:
•

Public officials

• Newspapers

• Libraries

•

Legislators

• Editors

• Educational institutions

•

Government agencies

• Civic groups or associations

• Nationality groups

0 Other (specify) See attachment.

•

21. What language was used in the informational materials:
0 English

• Other (specify)

22. Did youfilewith the RegistratiorTUhit, U.S. Department of Justice a copy of each item of such informational materials
disseminated or caused to be disseminated during this 6 month reporting period?
Yes d
No D See attachment
23. Did you label each item of such informational materials with the statement required by Section 4(b) of the Act?
Yes •
No •
See attachment,
12 The term informational materials includes any oral, visual, graphic, written, or pictorialinfonnation or matter of any kind, including that published by means of advertising,
books, periodicals, newspapers, lectures, broadcasts, motion pictures, or any means or instrumentality of interstate or foreign commerce or otherwise. Informational materials
disseminated by an agent of aforeignprincipal as part of an activity in itself exempt from registration, or ah activity which by itself would not require registration; need hot be
tiled pursuant to Section 4(b) of the Act.

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(PAGE 9)

VI-EXECUTION
In accordance with 28 U.S.C. § 1746, the undersigned swear(s) or affirm(s) Under penalty of perjury that he/she has (they have) read
the information set forth in this registration statement and the attached exhibits and that he/she is (they are) familiar with the contents
thereof arid that such contents are in their entirety true and accurate to the best of his/her (their) knowledge and belief, except that the
undersigned make(s) no representation as to truth or accuracy of the information contained in the attached Short Form Registration
Statement(s), if any, insofar as such information is not within his/her (their) personal knowledge.
(Date of signature)
March 07,2017

13

(Print or type name under each signature or provide electronic signature )
Isl Michael T. Flynn

eSigned

13 This statement shall be signed by the individual agent, if the registrant is an individual, or by a majority of those partners, officers, directors or persons performing.similar
functions, if the registrant is an organization, except that the organization can, by power of attorney, authorize one or more individuals to execute this statement on its behalf.

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Registration Unit 03/07/2017 6:02:45 PM

Flynn Intel Group, Inc., Supplemental Statement
Attachment
Items 11-12

Note: In September 2016, the Flynn Intel Group filed a registration under the Lobbying
Disclosure Act for its representation of Inovo BV ("Inovo"). Upon further review, and to
eliminate any potential doubt, the Flynn Intel Group is electing to file a registration and
supplemental statement under the Foreign Agents Registration Act in lieu of its prior
LDA registration. Although the Flynn Intel Group was engaged by a private firm, Inovo
BV, and not by a foreign government, because of the subject matter of the engagement,
Flynn Intel Group's work for Inovo could be construed to have principally benefitted the
Republic of Turkey. The Department's regulations provide that the LDA exemption
from FARA registration is not available if a foreign government or political party is the
principal beneficiary. See 28 C.F.R. § 5.307. This retroactive supplemental statement is
being filed after the Flynn Intel Group closed its operations in November 2016, and the
supplemental statement is therefore based on information that is currently available to
Flynn Intel Group, to the best of its knowledge, after undertaking due diligence with the
assistance of counsel.

In August 2016, Flynn Intel Group entered into a contract with Inovo, a consulting firm
based in the Netherlands. The contract provided that Flynn Intel Group would perform research,
engage a public relations firm and afilmingand production crew to potentially distribute the
results of its research, and hold weekly calls with the client to discuss progress on the project.
Flynn Intel Group understood the engagement to be focused on improving U.S. business
organizations' confidence regarding doing business in Turkey, particularly with respect to the
stability of Turkey and its suitability as a venue for investment and commercial activity. Inovo
has represented, through its counsel, that no part of the fees paid to Flynn Intel Group by Inovo
was provided by any foreign government.
Under the contract, Flynn Intel Group conducted open-source research for Inovo and at
Inovo's direction. The research, which was conducted by independent contractors retained for
this purpose, focused on Mr. Fethullah GUjen and charter schools in the United States that are
associated with, or allegedly associated with, Mr. Gulen. The results of Flynn Intel Group's
research were provided to Inovo, and to S.G.R. LLC Government Relations and Lobbying, the
public relations firm engaged by Flynn Intel Group. Flynn Intel Group and the public relations
firm developed various materials and documents related to this research for potential
dissemination. Because the project was terminated early, the full scope of the contract was not
performed, and to the best of Flynn Intel Group's knowledge, none ofthe research materials
prepared by the Flynn Intel Group were disseminated to third parties.
In early September 2016, Flynn Intel Group was invited by Mr. Alptekin to meet with a
group of government officialsfromTurkey for the purpose of understanding better the political
climate in Turkey at the time, as background for the project. Officials of the Republic of Turkey

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attending this meeting on September 19, 2016, in New York, were the Minister of Foreign
Affairs and the Minister of Energy, to the best of Flynn Intel Group's current understanding.
Mr. Rafiekian met with Miles Taylor, National Security Advisor to the House Committee
on Homeland Security, on two occasions in approximately October 2016, at Mr. Taylor's office
and at Flynn Intel Group's office. A representative of S.G.R. LLC Government Relations and
Lobbying attended the meeting at Flynn Intel Group's office. Over the course of the discussions,
Mr. Rafiekian raised the firm's representation of Inovo and issues related to the research
conducted for Inovo concerning Mr. GUlen and Turkey. Flynn Intel Group also oversaw
outreach, which was conducted by the public relations firm, to a state government official in
Arkansas.
Pursuant to its contract with Inovo, Flynn Intel Group informally engaged a group of
individuals (independent contractors) to form a film and production crew for the purposes of
producing a video documentary based on its research associated with Mr. GUlen. The activities
included a couple of videotaped interviews and other initial development of content. Because
the contract was not extended, the full scope of anticipated work was not performed and, to the
best of Flynn Intel Group's current knowledge, the video Was neither finished nor disseminated
to any third parties. S.G.R. LLC Government Relations and Lobbying created a Gulen-themed
monopoly graphic at the direction of Flynn Intel Group. To the best of its knowledge, Flynn
Intel Group did not disseminate this document or associated research (other than to Inovo).
In late October and early November 2016, Gen. Flynn of Flynn Intel Group developed an
op-ed article based, in part, on the research conducted by Flynn Intel Group under the Inovo
engagement. The op-ed was not written or published at the request of, or under the direction or
control of, Inovo, the Republic of Turkey, or any other party. No compensation was received for
the publication of the op^ed. In addition to Gen. Flynn, Bijan Rafiekian and an editor, Hank
Cox, participated in the drafting. Inovo, Mr. Alptekin, and the Republic of Turkey did not
participate in the drafting. Nonetheless, the op-ed addresses subject matter related to the
research that Flynn Intel Group conducted for Inovo, and a draft of the op-ed was shared with
Inovo in advance of publication. No changes, other than technical edits, were made to the op-ed
based on feedbackfromInovo. To the best of our knowledge, Inovo did not communicate with
the Republic of Turkey regarding the op-ed or provide the draft op-ed to the government. S.G.R.
LLC Government Relations and Lobbying assisted Flynn Intel Group with placement of the oped with The Hill publication.
Item 14
Payments received by Flynn Intel Group in connection with the project and purpose based on
information contained in Flynn Intel Group's general ledger and accounting records.
Date Received
09/09/2016
10/11/2016
11/14/2016

Foreign
Principal
Inovo BV
Inovo BV
Inovo BV

Purpose
Consulting
Consulting
Consulting

Amount
$200,000.00
$185,000.00
$145,000.00

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Item 15
Disbursements by Flynn Intel Group in connection with the project and purpose based on
information contained in Flynn Intel Group's general ledger and accounting records.
Date
10/1472016
10/31/2016
11/21/2016
10/04/2016
10/13/2016
11/14/2016
12/05/2016
09/19/2016
10/25/2016
11/16/2016
10/11/2016
10/11/2016
12/02/2016
12/02/2016
9/13/2016
10/17/2016
09/13/2016
10/21/2016
11/22/2016
10/11/2016
10/14/2016
11/21/2016
11/10/2016
10/13/2016
11/22/2016
10/12/2016
10/11/2016
10/24/2016
11/16/2016
10/05/2016
12/16/2016

To Whom
Bob Kelley
Bob Kelley
Bob Kelley
Brian McCauley
Brian McCauley
Brian McCauley
Brian McCauley
Carl Pilgram
Carl Pilgram
Carl Pilgram
David Enders
David Enders
David Enders
Hank Cox
Inovo BV
Inovo BV
Michael G. Flynn
Michael G. Flynn
Michael G. Flynn
Mike Boston
Mike Boston
Mike Boston
Operational
Behavioral
Services .
Paul Becker
Paul Becker
Rudi Bakhtiar
SGR LLC
SGR LLC
SGR LLC
White Canvas
Group
White Canvas
Group _

Purpose
Consultancy Fee
Consultancy Fee
Consultancy Fee
Consultancy Fee
Consultancy Fee
Consultancy Fee
Consultancy Fee
Administrative Support
Administrative Support
Administrative Support
Videography
Videography
Videography
Editing
Consultancy Fee
Consultancy Fee
Administrative Support
Administrative Support
Administrative Support
Consultancy Fee
Consultancy Fee
Consultancy Fee
Consultancy Fee

Amount
$2,500.00
$2,500.00
$5,000.00
$5,000.00
$3,000.00
$5,000.00
$15,000.00
$4,000.00
$4,000.00
$4,000.00
$1,700.00
$850.00
$850.00
$300.00
$40,000.00
$40,000.00
$4,000.00
$4,000.00
$4,000.00
$ 8,000.06
$8,000.00
$8,000.00
$20,000.00

Consultancy Fee
Consultancy Fee
Interview
Public Affairs
Public Affairs
Public Affairs
Public open source research

$1,500.00
$6,000.00
$1,200
$15,000.00
$10,000.00
$15,000.00
$7,500.00

Public open source research

$7,500.00

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Items 16-23
Pursuant to the contract between Flynn Intel Group and Inovo BY, the parties anticipated
that Flynn Intel Group would engage a public relations firm, Sphere Consulting, and engage a
film production crew for the creation of a video. The public relations firm (S.G.R. LLC
Government Relations and Lobbying) was engaged but the video was not completed or
disseminated, to the best of our understanding. The budget for these activities was reflected in
the engagement contract with S.G.R. LLC Government Relations and Lobbying; no separate
budget related to informational materials. Because this is a retroactive registration prepared after
Flynn Intel Group had already begun to close operations, this registration is based on
documentation currently available to Flynn Intel Group, If additional relevant information is
later identified, Flynn Intel Group will amend its registration.

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