Received by NSD/FARA Registration Unit 05/15/2017 7:46:05 PM J a •• U.S. Department of Justice OMB No. 1124-0006; Expires April 30,2017 Exhibit A to Registration Statement Pursuant to the Foreign Agents Registration Act of 1938, as amended Washington, DC 20530 INSTRUCTIONS. Furnish this exhibit for EACH foreign principal listed in an initial statement and for EACH additional foreign principal acquired subsequently. The filing ofthis document requires me payment of a filing fee as set forth in Rule (dKU, 28 C.F.R. § 5.5(d)(1). Compliance is accomplished by filing an electronic Exhibit A form at htlp.:#www.fa.ra,gQy. i Privacy Act Statement The filing of this document is required by 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 ofthe information requested is mandatory, and failure to provide this mformation 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 mfoimatiohal 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 mformational 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: bX^yywy^jfitra-gpyPublic Reporting Burden. Public reporting burden for this collection of information is estimated to average .49 hours perresponse,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 of mformation and Regulatory Affairs, Office of Management and Budget Washington, DC 20503. 2. Registration No. 1. Name arid Address of Registrant Sonoran Policy Group 4915 E Sharon Dr Scottsdale,AZ 85254 6399 3 . Name of Foreign Principal Ministry of Interior, Kingdom of Saudi Arabia 4. Principal Address of Foreign Principal Ministry of Interior, Kingdom of Saudi Arabia PO Box 11134 Riyadh - Kingdom of Saudi Arabia 5. Indicate whether your foreign principal is one ofthe following: 13 Government of a foreign country • Foreign political party 1 • Foreign or domestic organization : If either, check one of the following: • Partnership • Committee D Corporation • Association Individual-State nationality • • Voluntary group • Other (specify) . . 6. If the foreign principal is a foreign government state: a) Branch or agency represented by the registrant Ministry of the Interior, Kingdom of Saudi Arabia b) Name and title of official with whom registrant deals Khalid AL-Ghammam, Dir. of the Dept. of Intellectual Security 7. If the foreign principalis a foreign political party, state: a) Principal address b) Name arid title of official with whom registrant deals c) Principal aim I "Government of a foreign country," as defined in Section 1(e) ofthe Act, includes any person or group of persons exercising sovereign de facto ordejure 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 hot been recognized by the United States. FORM NSD-3 Received by NSD/FARA Registration Unit 05/15/2017 7:46:05 PM ^^03/14 Received by NSD/FARA Registration Unit 05/15/2017 7:46:05 iPM 8. If the foreign principa] isriota foreign government or a foreign political party: a) State the nature of the business or activity of this foreign principal. b) Is this foreign principal: Supervised by a foreign government, foreign political party, or other foreign principal Yes • No • Owned by a foreign government, foreign political parry, or other foreign principal Yes Q No • Directed by a foreign government, foreign political party, or other foreign principal Yes • No • Controlled by a foreign government, foreign political party, or other foreign principal Yes • No • Financed by a foreign government, foreign poHrical party, or other foreign pnncipal Yes • No • Subsidized in part by a foreign government, foreign political party, or other foreign principal Yes D No D 9. Explain fully all items answered "Yes" m 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. EXECUTION In accordance with 28 U.S.C. § 1746, the undersigned swears or affirms under penalty of perjury that he/she has read the mformation set forth in this Exhibit A to dieregistrationstatement 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 Signature May 15,2017 /$/ Christian Bourge Christian Bourge, Chief Executive Officer Received by NSD/FARA Registration Unit 05/15/2017 7:46:05 PM eSigned Received by NSD/FARA Registration Unit 05/15/2017 7:45:59 PM 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 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 by filing an electronic Exhibit B form at http://wwwJTara.gov. Privacy Act Statement The filing ofthis document is required for 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, and failure to provide trie information is subject to the penally and enforcement provisions established in Section 8 of the Act. Every registration statement short fonn registration statement, supplemental statement exhibit amendment copy of informational materials or other document or information filed with the Attorney General under mis Act is a public record open to public, examination, inspection and copy ing during the posted business hours of the Registration Unit in Washington, DC. Statements are also available online at the Registration Unit's webpage:for p://www.farAgQy.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 ofthe 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;//www,fara.gov. Public Reporting Burden. Public reporting burden for this collection of mformation is estimated to average 33 hours per response, including the time for reviewing instructions, searching existing data sources, garnering 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 infohriatiqn, including suggestions for reducing this burden to Chief, Regisfration Unit, Counterespionage Section, National Security Division, U.S. Apartment of Justice, Washington, DC 20530; and to the Office of mformation and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503. 1. Name of Registrant Sonoran Policy Group, LLC 2. Registration No. 6399 3. Name of Foreign Principal Ministry of Interior, Kingdom of Saudi Arabia Check Appropriate. Box: 4. 0 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 resultedfroman 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 ofthe oral agreement or understanding, its duration, the fees and expenses, if any, to be received. 7. Describe fully the nature arid method of performance of the above indicated agreement or understanding. See Attached Contract FORM NSD-4 Revised 03/14 Received by NSD/FARA Registration Unit 05/15/2017 7:45:59 PM Received by NSD/FARA Registration Unit 05/15/2017 7:45:59 PM 8. Describe fully the activities the registrant engages in or proposes to engage in on Behalf ofthe above foreign principal." SPG will provide the Ministry of Interior, Kingdom of Saudi Arabia broad advisory services including public relations and media engagement as well as public affairs counsel along with marketing arid outreach as pertaining to the United States. 9. Will the activities on behalf of the above foreign principal include political activities as defined in Section l(o) ofthe 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. SPG will provide the Ministry of Interior, Kingdom of Saudi Arabia broad advisory services including public relations and media engagement as well as public affairs counsel along with marketing and outreach as pertaining to the United States. 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 isfiuniliarwith 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 May 15,2017 Name and Title Christian Bourge, Chief Executive Officer Signature fsf Christian Bourge 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 ofthe Government ofthe 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 political or public interests, policies, or relations of a government of a foreign country or a foreign political party. Received by NSD/FARA Registration Unit 05/15/2017 7:45:59 PM Received by NSD/FARA Registration Unit 05/15/2017 7:45:59 PM Consulting Agreement Q This Agreement (hereinafter the ''Contract") is made this 5th day of May, 2017 by and between, the Sonoran Policy Group, LLC, a corporation incorporated under the laws of the State of Arizona, and The.Ministry of Interior, the. Kingdom of Saudi Arabia. Sonoran Policy Group, LLC (SPG) will be referred to in this Contract as "Consultant" and The Ministry of Interior, the Kingdom of Saudi Arabia, will be referred to as '-'Client". As defined by this Contract, Consultant and Client represent the following: Section 1 Consultant will act as the Client's government affairs and commercial sector adviser. In this capacity, Consultant will provide U.S. Congressional and Executive Branch brand engagement, along with Washington, DC and corporate engagement more broadly. Consultant shall act solely as an Independent Contractor, not as an Employee or Agent of Client. Accordingly, Client will not exercise control over- the manner, time, or place in which any services rendered by Consultant or its members, officers, agents and, employees, are performed. Unless specifically authorized in writing; Consultant, agrees not to enter into any agreement on behalf of Client and agrees that it shall not represent to any third party that it has authority io enter into such an agreement Additionally. Consultant understands that it will not be eligible for any Client employment benefits currently provided to employees of Client. ; Section 2 Compliance with AnnlicaM Subject to the foregoing, all services, rendered the Consultant in the term ofthis Contract will be rendered in accordance with all applicable Federal and State laws and regulations, including without limitation, the Federal Campaign Act of 1.971, as amended, the Gift Rule guidelines of the United States Senate and United States 'House- of Representatives, the Standards of Ethical Conduct of Employees of the Executive Branch, the Lobbying Disclosure Act of 1995 & 2008, as amended, and the Foreign Agents Registration Act of 1938 (FARA). as amended. Received by NSD/FARA Registration Unit 05/15/2017 7:45:59 PM Received by NSD/FARA Registration Unit 05/15/2017 7:45:59 PM Section 3 Term of Contract; This Contract will become effective on May 5, 2017 and will continue until May 5,2018. Notwithstanding the foregoing- this Contract may be terminated by either party upon thirty (30) days written notice. Section 4 Compensation Consultant will charge Client a monthly rate of $450,000:00 (US dollars) with full payment totaling 55,400,000.00 (U.S. dollars), representing the entire 12-month consulting fee, due by wire transfer from Client to Consultant upon execution of the Contract. Section 5 Confidentiality: From time to time, Client may share with Consultant non-public or proprietary information related to Client business in order to assist Consultant in performing the services outlined in this Contract. All such mformation, whether provided orally or in writing, shall be considered confidential. Consultant agrees not to disclose any such information to any person not an employee or agent of Consultant without die prior written consent of Client and to provide prompt notice to Client of any judicial or quasi-judicial demand for such information. Likewise, the Client may become aware of information about Consultant, its business operations, and its methods of performance that may be highly confidential and proprietary to Consultant and which is generally not known, to the general public or in the business which Consultant and its other client are engaged. Client agrees not to disclose any such information to any person not an employee or agent of the" Client without the prior written consent of Consultant and to provide prompt notice to Consultant and judicial or quasi-judicial demand for such information. The duty to maintain the confidentiality of all such non-public information shall continue during the term of this Contract and for a period of three (3) years after itexpires. Section 6 General: This Contract contains the entire understanding of the parties, shall supersede any oral or written assignments, and shall be binding upon and inure to the benefit of the parties' successors and assigns. It may not he modified in any way without the written consent of both parties. Section 7 All notices, demands or other communications by either party to the other shall be in writing, and 2 Received by NSD/FARA Registration Unit 05/15/2017 7:45:59 PM Received by NSD/FARA Registration Unit 05/15/2017 7:45:59 PM shall be effective upon personal delivery, or if sent by mail,, seventy-two (72) hours after being deposited in the mail, first class postage, prepaid, registered or certified, and all such notices given by mail shall be sent and addressed as follows until such time as another address is given by notice pursuant to this provision: To Consultant: Sonoran Policy Group, LLC 4915 E. Sharon Dr. Scottsdale, AZ 85254 Attn: Executive Chairman To Client: IN WITNESS WHEREOF, the parties hereto have executed this Contract on thc 5th day of May, 2017. CONSULTANT: Robert D.Stryk Exeoidve Chairman Sonoran Policy Group, LLC CLIENT: Name: U*/j£ Intel!*ttul SecMyfty. 3 Received by NSD/FARA Registration Unit 05/15/2017 7:45:59 PM