Received by NSD/FARA Registration Unit 01/12/2018 1:37:53 PM

OMB No. 1124-0005; Expires May 31.2020
U.S. Department of Justice
Washington, DC 20330

Short Form Registration Statement
Pursuant to the Foreign Agents Registration Act of
1938, as amended
illiajiisLIUHuiiftl—lit-.IUlUi-IWXi» aiL— mnu.

■

........... -J

1UUI.IJM—

INSTRUCTIONS, linclt partner, officer, director, associate, employee, mul agent of u registrant is required lo file a short form registration statement
unless lie engages in no activities in furtherance of the interests of the registrant's foreign principal or unless the services he renders to the registrant
nrc in a secretarial, clerical, or in a related or similar capacity. Compliance is accomplished by filing an electronic xliort form registration statement

at
Privaoy Act Statement. The filing of tills document Is required for (lie Foreign Agents Registration Act of 1938, ns amended, 22 ll.S.C. fi 611 el seq„
for the purposes of registration under tho Act and public disclosure. Provision of the Information requested is mandatory, and failure to provide 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 (his 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 arc also available online nt the Registration Unit's webpage: iittps:/Zwww. liirq.eov. One copy of
every such document, other than informational materials, is automatically provided to the Secretary of State pursuant to Section 6(b) of tho Act, and
copies of any and all documents arc routinely made available lo other agencies, departments and Congress pursuant to Section 6(c) of the Act. The
Attorney General also transmits u semi-annual report lo Congress on (he administration of the Act which lists (he names of all ngents registered under
(he Act and the foreign principals they rcpicscnl. This report is available to the public and online at: https://www.limi.pov.
Public Reporting Burden. Public reporting burden lor this collection of information is estimated to overage .429 hours per response. Including the
time for reviewing instructions, searching existing dam sources, gathering and maintaining the data needed, and completing and reviewing the
collection of Information. Send comments regarding (his burden estimate or any other aspect of fills collection of information, including suggestions
for reducing this burden to Chief, Registration Unit, Counterintelligence and Export Control Section, National Security Division, U.S. Department of
Justice, Washington, 1X1 20530; and to the Office of Information and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503.

2. Registration No.

1. Namo
John M. Quinn
3. Residence Address(es)
2159 Dunmore Lane, N.W.
Washington, DC 20007

4. Business Address(es)
Manatt, Phelps & Phillips LLP
1050 Connecticut Avenue, N.W., Suite 600
Washington, DC.20036

5. Year of Birth 1949

6. If present citizenship was not acquired by birth,
indicate when, and how acquired.

Nationality American
Present Citizenship US Citizen
7. Occupation Attorney
8, What is the name aiid address of the primary registrant?
Name Manatt, Phelps & Phillips LLP

1050 Connecticut Avenue, N.W.
Address Suite 600
Washington, DC 20036

9i Indicate your connection with the primary registrant;
(9 partner
□ director
□ officer
Q associate
□ other (specify)
_______________ ____________

□ employee
□ agent

□ consultant
□ subcontractor

10. List every Foreign principal to whom you will render services In support of the primary registrant.
Banque Centralde Mauritanie

11. Describe separately and.in detail all services which you will render to the foreign principals) listed in Item 10 either directly, or
through the primary registrant listed in Item 8, and die date(s) of such services. (Ifspace is insufficient, a full insert j>agc must be

used.)

A page Is insert with the terms of reference on the mission.

FORM NSD-4
Revised 05/17

Received by NSD/FARA Registration Unit 01/12/2018 1:37:53 PM

 Received by NSD/FARA Registration Unit 01/12/2018 1:37:53 PM

12. Do any of the above described services include political activity as defined in Section l(o) of the Act and in the footnote below?
Yes □
No 0
If yes, describe separately and in detail such political activity.

13. The services described in Items 11 and 12 are to be rendered on a
□ full time basis
0 part time basis

□ special basis

14. What compensation or thing of valuo have you received to date or will you receive for the above services?
□ Salary: Amountsper__________

□ Commission at%of

0 Salary: Not based solely on services rendered to the foreign principal(s),
□ Fee: Amounts___________

□ Other thing of value________________________

. 15. During the period beginning 60 days prior to the date of your obligation to register to the time of filing this statement, did you
make any contributions of money or other things of value from your own funds or possessions and on your own behalf In
connection with any election to political office or in connection with any primary election, convention, or caucus held to select
candidates for any politicaloffice?
Yes D
No El
If yes, furnish the following information:
Date'

Amount or Thing of Value

Political Organization or Candidate

Location of Event

EXECUTION
In accordance with 28 U.S.C. § 1746, the undersigned swears or affirms under penalty ofperjury that he/she has read the
information set forth in thisregistration 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 beliei

VsnJ

(Date ofsignature)

(Signaturej

Footnote: "Polllical activity," os Ueimetl in .Section I(o) of the Act, means any activity which the )>ciwui'efiijoi;in)j in believes will, or that the person intends In. in any wny mltucncc
any agency or official of the Government of the United States or tiny section of the public within the United Suites with reference to formulating, adopting, or cltnngiiig the
domestic or foreign policies of the United States or with reference to the political or public interests, policies, or relations of n government of a foreign country or u foidgii political
puny.

Received by NSD/FARA Registration Unit 01/12/2018 1:37:53 PM

 Received by NSD/FARA Registration Unit 01/12/2018 1:37:53 PM

The Terms of Reference of Manatt’s mission before the BCM
The purposes of this first three days visit is to:
1. Gather all information and documentation relating to the laws and regulations
. regarding anti-money laundering and the fight against financing of terrorism (“AML/CFT”).
2. Obtain detailed information on current stock of foreign currencies at the Central
Bank of Mauritania (US dollars, Euros, GBP, and CHF).
3. Obtain copies of inspection reports can-ied out by the banking supervision authority
or the inspector general on banks operating in Mauritania. With a particular emphasis on
measures taken by commercial banks and bureaux de change, if any, to conform to
AML/CFT laws and regulations and more specifically on the identity, origin of deposits,
depositors in foreign currencies, the usual destination of recurrent transfers in certain
countries or for the benefits of certain individuals or corresponding banks/intermediaries used
by these transfers.
4. Verify if the official bureaux de change have their registers kept update with
information on the identity of deposits and depositors in foreign currencies.
5. Examine measures regarding the security of the payment system put in place and
the respect of the rules of confidentiality by the commercial banks. Verify if there-are policies
which would allow commercial banks to execute wire transfers or receive payments directly
without going through the BCM,
6. Examine if the BCM has conducted an evaluation on its own operations of the risks
associated with AML/CFT, protection against cybersecurity or theft of data.
7. Inquire on actions undertaken by BCM or the public prosecutor to prosecute and
fine the principles and accomplices of illegal activities which were deemed lion-compliant
with AML/CFT national laws.
8. Provide to Manatt copies of all communication orally or in writing which were
exchanged with corresponding banks and relatively to questions that might have been raised
with respect to certain payments between you and your corresponding banks. It may be
correspondences seeking for example a certificate of conformity in compliance with the USA
Patriot Act; request for submission of policies and procedures regarding AML/CFT. Also to
provide copies of the responses given by the BCM to request from corresponding banks.
9. Obtain copies of verbal communication or telephonic calls which took place and
the reports or notes token thereto or exchanged with corresponding banks or institutions such
as but riot only the World Bank and the International Monetary Fund. What actions have been
taken in responses to issues raised and questions asked by the foregoing corresponding banks
and or institutions.
10. Prepare a list of recommendations based on the findings on site arid agreed upon
with the BCM on the different steps to be followed to strictly comply with, the AML/CF
regulations. This step is a condition for Manatt to prepare a report to be submitted to the
corresponding banks Mid the Arherican federal authorities with a view to restore, and or
preserve corresponding banking relationship with American financial institutions.

Received by NSD/FARA Registration Unit 01/12/2018 1:37:53 PM

 Received by NSD/FARA Registration Unit 01/12/2018 1:37:53 PM

The mission team will be composed of as follows: Kalidou Gadio, Esq ( head of mission) and
he shall be accompanied by Joe Passaic,Esq (Manatt), Douglas Boggs Esq, (Manatt),
Bradely Wears, consultant (Promontory)

Received by NSD/FARA Registration Unit 01/12/2018 1:37:53 PM