The United States Senate
Committee on Finance
Majority Staff Report
accompanying the

Minority Staff Report
The NRA and Russia
Washington, D.C.
September 2019

 INTRODUCTION
During the 2012 presidential campaign between President Obama and his Republican challenger,
former Massachusetts governor and current Utah Sen. Mitt Romney, candidate Romney
described Russia as the United States’ “number one geopolitical foe.” 1 On October 22, 2012,
during a presidential debate between the two candidates, President Obama famously patronized
Mr. Romney with, “The 1980s are now calling to ask for their foreign policy back because the
Cold War’s been over for 20 years.” 2 Indeed, President Obama spent much of his presidency
treating the United States’ often difficult relationship with Russia as a product of his
predecessor’s supposedly failed efforts to work with that nation – a relationship that could
simply be “reset” by a more cooperative U.S. foreign policy. 3 For example, in 2009, then-Vice
President Joe Biden stated, “It is time to press the reset button and to revisit the many areas
where we can and should be working together with Russia.” 4 One month later, then-Secretary of
State Hillary Clinton stressed the same “reset” when presenting Russian Foreign Minister Sergei
Lavrov with a red “Reset” button. 5
Moreover, shortly after both comments by Biden and Clinton, the Obama administration’s
Committee on Foreign Investment in the United States (CFIUS) approved Atomredmetzoloto’s
acquisition of Uranium One, which resulted in the Russian government’s ownership of U.S.
uranium assets. 6 Further, in June 2010, former President Bill Clinton received $500,000 from
Renaissance Capital, a Russian government-linked investment firm, for a speech in Moscow
while his wife was in charge of the State Department and a member of the CFIUS approval
team. 7 In the same month as the speech, the Russian government and Uranium One notified
1

Romney: Russia is our number one geopolitical foe, CNN (Mar. 26, 2012),
http://cnnpressroom.blogs.cnn.com/2012/03/26/romney-russia-is-our-number-one-geopolitical-foe/.
2
Cheyenne Haslett, Mitt Romney Finally Gets Credit Years Later for His Warnings on Russia, ABC NEWS, (Feb.
26, 2014), https://abcnews.go.com/Politics/years-mitt-romney-finally-credit-warnings-russia/story?id=61330530.
3
See generally Mikhail Zygar, The Russian Reset That Never Was, FOREIGN POL’Y (Dec. 9, 2016),
https://foreignpolicy.com/2016/12/09/the-russian-reset-that-never-was-putin-obama-medvedev-libya-mikhail-zygarall-the-kremlin-men/; Letter from William P. Barr, Attorney Gen., Dep’t of Justice, to Members of Congress (Mar.
24, 2019), https://www.documentcloud.org/documents/5779699-Letter-to-Congress-detailing-Robert-Muellers.html.
4
Vice President Joe Biden, Remarks at 45th Munich Conference on Security Policy (Feb. 7, 2009),
https://obamawhitehouse.archives.gov/the-press-office/remarks-vice-president-biden-45th-munich-conferencesecurity-policy.
5
Sue Pleming, Clinton, Lavrov Push Wrong Reset Button on Ties, REUTERS (Mar. 6, 2009),
https://www.reuters.com/article/idUSN06402140.
6
News Release, Sen. Charles E. Grassley, Grassley Seeks Accounting of Government Actions Behind Controversial
Uranium Deal (July 2, 2015), https://www.grassley.senate.gov/news/news-releases/grassley-seeks-accountinggovernment-actions-behind-controversial-uranium-deal.
7
Renaissance is a Russian investment bank whose senior officers include former FSB (Russian intelligence)
personnel. As such, sources have described the Bank as an extension of the Russian government, as most all of the
banks in Russia are controlled in some manner by the Kremlin. At the Senate Judiciary Committee’s July 2017
oversight hearing on the Foreign Agents Registration Act, a witness described Renaissance Bank as follows:
The Chairman was – or I should say another senior official was a British citizen of Russian origin
named Igor Sagiryan. On their staff at Renaissance Capital, they trumpeted the fact that they had a
number of former FSB officers on their staff. I should point out that there is no such thing as a
former FSB officer. It is a lifetime commitment. And in the Department of Justice investigation

1

 CFIUS of its intent to acquire U.S. uranium assets. The next month, in July 2010, Renaissance
Capital assigned a “buy” to Uranium One, a move that would principally benefit Russian
investors. 8
Much has changed since then. Generally, the Obama administration’s optimism toward
improving diplomatic relations with Russia waned in its final years. 9 Then in November 2016,
Donald Trump won the U.S. presidential election against former Secretary of State Hillary
Clinton, which many on the left incorrectly attributed to Russian interference. 10 Eventually, a
Special Counsel was appointed to investigate whether then-candidate Trump colluded with
Russians to help him win the election. After two years, more than 2,800 subpoenas,
approximately 500 search warrants and witness interviews, and $30 million in taxpayer money,
that report found no such collusion. 11
Following two and a half years of endless, feverish speculation about so-called collusion that
cast suspicion on any and all things Russian, the Minority report at issue attempts to paint a
picture of the National Rifle Association with facts and innuendo that together actually
demonstrate little to nothing.
Although this was not a joint investigation, the Minority conferred with the Majority at times
about the inquiry, and the Majority reviewed most of the underlying documents gathered by the
Minority and provided by various NRA officials to the Committee. After reviewing those
documents at great length, two things became clear to the Majority: (1) some question exists as
to whether the NRA paid a relatively insubstantial $6,000 amount for the travel of a private
individual (Joe Liberatore), and (2) the extent of the evidence reviewed does not raise concerns
that the NRA abused its tax-exempt purposes when some of its high-ranking officials traveled to
Russia in December 2015.
This report includes citations to portions of emails reviewed by the Majority and the Minority,
portions of which the Majority views as relevant to the key questions explored in the reports.
Those documents are included in full as attachments to this report for appropriate context.
into Prevezon Holdings, they determined that $13 million from the crime that Sergei Magnitsky
uncovered, exposed, and was killed over went to the bank accounts of Renaissance Capital in the
United Kingdom.
Oversight of the Foreign Agents Registration Act and Attempts to Influence U.S. Elections: Lessons Learned from
Current and Prior Administrations: Hearing Before the S. Comm. on the Judiciary, 115th Cong. 20-21 (2017)
(statement of William Browder, CEO, Hermitage Capital Management); Press Release, Sen. Charles E. Grassley,
Grassley Asks Plaintiffs in Emoluments Suits to Explain Their Narrow, Partisan Focus (Apr. 11, 2017),
https://www.grassley.senate.gov/news/news-releases/grassley-asks-plaintiffs-emoluments-suits-explain-theirnarrow-partisan-focus.
8
Jo Becker & Mike McIntire, Cash Flowed to Clinton Foundation amid Russian Uranium Deal, N.Y. TIMES (Apr.
23, 2015), https://www.nytimes.com/2015/04/24/us/cash-flowed-to-clinton-foundation-as-russians-pressed-forcontrol-of-uranium-company.html.
9
Mikhael Zygar, supra note 3.
10
Philip Rucker, ‘I Would be Your President’: Clinton Blames Russia, FBI Chief for 2016 Election Loss, WASH.
POST (May 3, 2017), https://www.washingtonpost.com/politics/hillary-clinton-blames-russian-hackers-and-comeyfor-2016-election-loss/2017/05/02/e62fef72-2f60-11e7-8674-437ddb6e813e_story.html.
11
See generally DEP’T OF JUSTICE, OFF. OF SPECIAL COUNSEL, REPORT ON THE INVESTIGATION INTO RUSSIAN
INTERFERENCE IN THE 2016 PRESIDENTIAL ELECTION (Mar. 2019), https://www.justice.gov/storage/report.pdf.

2

 It is no secret that the Russian government has always been at the forefront of our intelligence
and military concerns, contrary to the Obama administration’s public posture. By this report, the
Majority does not advocate on behalf of or against any party subject to the Minority’s inquiry,
and it is fair to analyze the wisdom of traveling to Russia in December 2015 to meet with highranking officials. However, the Minority report reads more like a political document directed at
an organization well known in U.S. politics to be despised by Democrats because of its advocacy
for Second Amendment rights. This Majority finds no wrongdoing by the NRA or its officials
that would reasonably call into question the NRA’s tax-exempt status, based on the documents
provided to the Committee.
The Minority report concludes that NRA members’ travel to Russia in 2015 and meeting with
Russian officials “raises concerns about whether the activity in which the NRA, its officers, and
board members engaged were in furtherance of the organization’s exempt purpose.” 12 It also
concludes that NRA officials’ possibly having met with sanctioned individuals “raise significant
concerns under U.S. sanctions law.” 13 Both of these conclusions are meritless. Accordingly, it
is not fair to question the tax-exempt status of an organization associated with such individuals
because of that travel.
BASED ON THE REVIEWABLE EVIDENCE THE NRA’S TAX-EXEMPT STATUS IS
NOT AT RISK.
According to its 2017 filings with the IRS, the National Rifle Association is a tax-exempt social
welfare organization under Section 501(c)(4) of the Internal Revenue Code, and its mission is
“[f]irearms safety, education, and training and advocacy on behalf of safe and responsible gun
owners.” 14 According to its website, Union officers Col. William C. Church and Gen. George
Wingate formed the NRA in New York in 1871 to “promote and encourage rifle shooting on a
scientific basis.” 15 By the end of 2018, it had 5.5 million members and over $412 million in total
revenue. 16 According to the Minority report, all of this is legally jeopardized for tax reasons
because less than a handful of its officials may have turned a goodwill trip to Russia into
multipurpose travel, tending to both an invitation by Russians to NRA personnel as well as their
own professional matters during the same trip. This is an erroneous conclusion, as there is
nothing wrong with taking a trip with two purposes in mind, even if one of those purposes
involves a tax-exempt organization.
In its report, the Minority argues that its “investigation documents the degree to which the NRA
and its leadership were aware of and cooperated with [Maria] Butina and [Alexander] Torshin to
provide them access to the NRA and other domestic organizations.” 17 In support of their
12

MINORITY STAFF OF S. COMM. ON FIN., 116TH CONG., REPORT ON THE NRA & RUSSIA 75 (Comm. Print 2019)
[hereinafter SFC Minority Russia Report].
13
Id.
14
National Rifle Association, I.R.S. Form 990, Return of Organization Exempt from Income Tax (2017),
https://pdf.guidestar.org/PDF_Images/2017/530/116/2017-530116130-10069406-9O.pdf.
15
A Brief History of the NRA, NAT’L RIFLE ASS’N, https://home.nra.org/about-the-nra/ (last visited Sept. 24, 2019).
16
Stephen Gutowski, NRA Membership Dues, Contributions Rebounded In 2018, THE WASH. FREE BEACON (May
30, 2019), https://freebeacon.com/issues/nra-membership-dues-contributions-rebounded-in-2018/.
17
SFC MINORITY RUSSIA REPORT, supra note 12, at 4.

3

 argument, the Minority seeks to use the NRA’s 2015 trip to Russia as evidence that the NRA
engaged in an improper purpose. However, the Minority fails to explain how the NRA, its
officers, or its board members played any role in a Butina/Torshin conspiracy, other than
engaging with these individuals for the purposes of fostering a relationship between two gunrights advocacy organizations. In other words, the Minority report goes into excruciating detail
about a goodwill trip to Russia in order to give the appearance that something nefarious with
Russia must be at issue.
Indeed, in December 2015, a delegation from the NRA traveled to Russia at the invitation of
Alexander Torshin and Maria Butina’s purported gun-rights organization known as “The Right
to Bear Arms.” These are the same two individuals who met with high-ranking Obama
administration officials in 2015, the same year as the NRA delegation’s Russia trip. 18 Before
this trip, as with any other trip, logistical details were discussed between NRA officials. The
Minority report takes issue with the fact that NRA professional staff handled trip logistics, like
securing visas and making itineraries, and that senior NRA officials participated in the trip. 19
The Minority report attempts to use this evidence to undermine the NRA’s tax-exempt status but
fails to explain how this activity rises to the level of an improper tax-exempt purpose.
Organizations, including Congress, often participate in these types of trips in order to meet with
government officials to gain first-hand knowledge on issues relevant to their industry or other
area of expertise.
Generally, the Minority concludes that “some members of the NRA delegation traveled to Russia
to cultivate future business opportunities” and that the CEO of the Brownells firearms retailer
and then-future NRA President Pete Brownell “went to Moscow several days ahead of the rest of
the NRA delegation to meet with Russian arms companies.” 20 Based on the documents reviewed
by Majority staff, this generally appears correct, and such activity also appears to be entirely
normal behavior for a CEO of a major firearms retailer, as the facts show Mr. Brownell started
his December 2015 trip to Russia for this personal-professional purpose and then concluded it
with an NRA-focused goodwill purpose. This is reflected in a November 30, 2015 email from
Paul Erickson to Pete Brownell in which Mr. Erickson wrote to Mr. Brownell,

18

Press Release, Sen. Charles E. Grassley, Grassley, Wyden Seek Details on Meetings Between Russian Agents &
U.S. Treasury, Fed (Feb. 15, 2019), https://www.grassley.senate.gov/news/news-releases/grassley-wyden-seekdetails-meetings-between-russian-agents-us-treasury-fed.
19
SFC MINORITY RUSSIA REPORT, supra note 12, at 16-21.
20
Id. at 44-45.

4

 21

This email shows that Mr. Brownell did what probably thousands of business travelers all
throughout the country do every day: combine business travel with personal travel. Even federal
employees are allowed to do this. For example, travel policy for the U.S. Department of Justice
states,
A traveler may choose to combine official and personal travel, and/or travel by a
different mode of transportation from that authorized. All costs in excess of those
incurred for official travel resulting from personal preference must be borne by the
traveler, not the Department. 22
IRS employees are allowed to do the same thing. 23 The fact that Mr. Brownell appears to have
done this on his December 2015 trip to Russia, some of it taken for his own business’ purposes
and some of it for NRA-related goodwill purposes, has no effect whatsoever on the NRA’s taxexempt purpose of promoting firearms safety, education, and training and advocacy on behalf of
safe and responsible gun owners.
The Minority report also makes the same sort of allegation with respect to Outdoor Channel
CEO Joe Liberatore, who supposedly traveled with NRA officials to Russia for “purely
commercial” reasons. 24 By that point in time, the Outdoor Channel and the NRA had entered
into a partnership to “[bring] together the top two brands in the outdoor arena, [spanning] a
variety of platforms including programming, events, advertising, marketing and digital
initiatives.” 25 It would make sense that Mr. Liberatore would want to attend an NRA-related
event in Russia in furtherance of Outdoor Channel’s business interests, as they were directly
related to the partnership with the NRA. Without more, the Majority is curious as to why this
21

Email from Paul Erickson to Pete Brownell (Nov. 30, 2015) (Brownell Production, Bates #00208), attached hereto
as Exhibit 1.
22
U.S. DEP’T OF JUSTICE, POLICY STATEMENT 1400.04, § 301-41 et seq. (effective July 1, 2014),
https://www.justice.gov/sites/default/files/usao/pages/attachments/2015/02/03/combining_official_and_personal_tra
vel.pdf.
23
See INTERNAL REVENUE SERVICE TRAVEL GUIDELINES § 30.5.2.3.3(3) (Feb. 28, 2014),
https://www.irs.gov/irm/part30/irm_30-005-002.
24
SFC MINORITY RUSSIA REPORT, supra note 12, at 54.
25
Outdoor Channel and NRA Broad Strategic Partnership, PR NEWSWIRE (Jan. 6, 2014),
www.prnewswire.com/news-releases/outdoor-channel-and-nra-broaden-strategic-partnership-238865681.html.

5

 sort of activity poses a threat to or is an abuse of the NRA’s tax-exempt purpose. The Minority
report also alleges dual travel purposes for David Keene and Joe Gregory, 26 but nothing in those
allegations call into question an abuse of the NRA’s tax-exempt purpose, and the Minority
report’s inclusion of such allegations appear to be a gratuitous attempt to undermine the
credibility of those individuals.
The Minority report alleges the NRA incurred costs associated with Mr. Liberatore’s travel to
Russia in December 2015, 27 and the documents do seem to reflect this. Specifically, it appears
that after the December 2015 trip to Russia, Mr. Liberatore wrote to Maria Butina expressing
surprise at her requesting reimbursement from him for $6,000 worth of costs related to his travel.
Maria Butina then appeared to turn to Mr. Brownell to ask how she should handle the situation,
and Mr. Brownell then turned to Millie Hallow at the NRA asking if the NRA “president
office’s” budget could pay $4,500 of this expense. 28 Whatever the resolution of this $6,000
payment was, even if the NRA improperly paid this amount, it does not come close to
jeopardizing the tax-exempt status of an organization with over $412 million in revenue.
The reason such a would-be misappropriation, or any similar would-be misappropriation, does
not jeopardize the NRA’s tax-exempt status is because the tax code contains intermediate
sanctions, which is a mechanism to penalize a minor infraction made by a tax-exempt
organization without resorting to the extreme remedy of stripping it of its tax-exempt status.
In 1996, Congress added to the tax code a section that imposes a 25-percent tax on excessbenefit transactions. 29 These excess-benefit transactions are transactions in which certain taxexempt organizations, including the NRA, might provide a benefit to a high-ranking official
within the organization, among others, without the official providing adequate consideration to
the organization in return. 30 This tax is the intermediate sanction, as its purpose is to tax
improper benefits conferred on an organization’s insiders (and certain managers) without going
to the draconian length of revoking the nonprofit organization’s tax-exempt status. 31 Congress’
purpose in creating intermediate sanctions for excess-benefit transactions was to strike this exact
balance. When these intermediate sanctions became law in 1996, the accompanying Committee
Report described their purpose this way:
In general, the intermediate sanctions are the sole sanction imposed in those cases
in which the excess benefit does not rise to a level where it calls into question
whether, on the whole, the organization functions as a charitable or other taxexempt organization. In practice, revocation of tax-exempt status, with or without

26

SFC MINORITY RUSSIA REPORT, supra note 12, at 53-56.
Id. at 23.
28
Email from Pete Brownell to Millie Hallow (Jan. 9, 2015) (Brownell Production, Bates #00377-79), attached
hereto as Exhibit 2.
29
26 U.S.C. § 4958 (2018).
30
Id. § 4958(c)(1)(A).
31
Suzanne Coffman, About Intermediate Sanctions, GUIDESTAR BLOG (Jan. 1, 2003),
https://trust.guidestar.org/about-intermediate-sanctions.
27

6

 the imposition of excise taxes, would occur only when the organization no longer
operates as a charitable organization. 32
Just about everyone knows the NRA takes positions on issues surrounding guns and gun control,
which have been, and will continue to be, passionate issues in our national discourse. Generally,
the NRA opposes gun-control efforts, which millions of Americans support and which millions
of other Americans oppose. Reasonable people can disagree about these very important issues.
However, based on the facts alleged in the Minority report, no reasonable person could think an
organization with the size and the influence of the NRA can be said to have no longer existed by
late 2015 for its non-profit purposes because of a disputed $6,000 expense associated with a
2015 goodwill trip to Russia. That would be an absurd proposition. To be sure, the Minority
report does allege that certain NRA payments may have run afoul of the tax code’s intermediatesanctions tax, 33 but what the Minority report does not discuss is how the intermediate-sanctions
tax is essentially a small penalty for a small infraction. If the NRA did improperly pay $6,000
after-the-fact for Mr. Liberatore’s travel to Russia in December 2015, that could mean the person
who improperly authorized this payment – if it was improper at all – is subject to a $1,500 tax. It
does not come remotely close to causing the NRA to lose its tax-exempt status.
THE MINORITY REPORT CONCLUDES THE NRA DID NOT VIOLATE SANCTIONS
LAW.
The Minority report also discusses how NRA officials having met with certain Russians “raise[s]
significant concerns under U.S. sanctions law.” 34 The Minority report, however, does not allege
that such meetings, to the extent they actually took place, violated U.S. law because the Minority
report itself admits that such meetings would not have violated U.S. law. On page 44, the
Minority states in no uncertain terms, “U.S. sanctions law does not prohibit meeting with SDNs
[sanctioned individuals]….” 35 This clear declaration by the Minority was only mentioned after
the Minority report excruciatingly detailed certain meetings that may have taken place between
Russian entities that may have been sanctioned under U.S. law, or were related to companies that
may have been sanctioned under U.S. law, and NRA officials, including Mr. Brownell. 36 This
discussion appears to simply be an attempt to undermine or embarrass the NRA. The Minority
concludes this portion of its report with a discussion of how personnel at Mr. Brownell’s
company communicated with the U.S. Department of the Treasury’s Office of Foreign Assets
Control (OFAC) to make sure that Mr. Brownell’s anticipated meetings in Russia would not
violate U.S. sanctions law. 37 That communication, already listed in the Minority report, is worth
repeating. On November 25, 2015, Vice President of Strategic Development Rob McAllister at
Brownells, Inc. emailed Mr. Brownell with the following information:

32

H.R. REP. NO. 104-506, at 59 n.15 (1998), https://www.congress.gov/104/crpt/hrpt506/CRPT-104hrpt506.pdf.
SFC MINORITY RUSSIA REPORT, supra note 12, at 6, 74.
34
Id. at 75.
35
Id. at 44, 75 .
36
Id. at 40-42.
37
Id. at 42-43.
33

7

 38

Essentially, the Minority report alleges Mr. Brownell must have done something wrong –
“[t]hese interactions raise significant concerns under U.S. sanctions law” 39 – by meeting with
certain Russians even though the evidence shows he performed his due diligence and was open
with the U.S. government as to who those meetings would be with, and the U.S. government
provided him guidance on how to stay within the law when participating in those meetings.
The Minority report also takes issue with what appears to be an online Russian magazine named
“Kalashnikov” using an NRA logo. The Minority report states, “On January 20, 2016, the
Kalashnikov Magazine website published an article, without attribution about the NRA
delegation’s visit featuring the trademarked NRA logo.” 40 As of this writing, it does appear that
a Russian “Kalashnikov” website footnoted in the Minority report contains what looks like a
version of the NRA logo. 41 But without any factual support, the Minority report takes a leap and
concludes that this trademark publication was actually authorized by the NRA. Nevertheless,
such publication “raises concerns” about U.S. sanctions law, according to the Minority report:
“Further, members of the NRA delegation provided interviews, permitted the use of trademarked
NRA logos, and appeared in promotional material for sanctioned Russian arms manufacturers in
their official capacity as representatives of the NRA.” 42 The Minority does not explain how
possibly giving an interview rises to a level of sanctions concern and gives no factual predicate
for the allegation that NRA personnel “permitted the use of trademarked NRA logos.”
The Minority report also discusses at length various interactions that Mr. Brownell and other
NRA officials may have had with Russians and Russian companies. But again, the Minority
sprinkles its report with the phrase “raises concerns” in editorializing about these interactions.
This is simply a euphemism for saying that a certain factual allegation does not violate the law
but could be embarrassing to the NRA anyway. Nothing in the Minority report’s discussion of
U.S. sanctions law reasonably calls into question the NRA’s tax-exempt status.

38

Email from Rob McAllister to Pete Brownell (Nov. 5, 2015) (Brownell Production, Bates #00798-99), attached
hereto as Exhibit 3.
39
SFC MINORITY RUSSIA REPORT, supra note 12, at 75.
40
Id. at 40.
41
NRA в России [NRA in Russia], KALASHNIKOV (Jan. 20, 2016), https://www.kalashnikov.ru/nra-v-rossii/.
42
SFC MINORITY RUSSIA REPORT, supra note 12, at 44.

8

 CONCLUSION
The U.S. and Russia relationship was vastly different in 2015 than it is today. In hindsight, the
misplaced optimism that the Obama administration had toward Russia was obviously illconceived given what we know today. The Minority report seeks to apply today’s standard, and
what we know now about Russia, to the actions of various board members of the NRA. In that
vein, the report is littered with salacious, unsubstantiated accusations, and reads as if there were
an elaborate conspiracy theory by members of the NRA to aid in the attempted Russianinfiltration of conservative organizations and the Republican Party. Unfortunately, just as the
Obama administration cannot go back to correct its approach with Russia, the Minority cannot
apply today’s standards with the conduct of NRA board members in 2015. But that’s what it
does.
The Minority report finds no facts that give rise to the possibility that personnel associated with
the NRA engaged in any activities that call into question its tax-exempt status. The Minority
report takes hold of the common practice of business travelers, giving multiple purposes to their
business trips, so that ordinary behavior is painted with some supposedly nefarious purpose. To
the extent NRA funds were used improperly in any facts discussed in the Minority report, it
appears to have been minor, hardly a rounding error for an organization with hundreds of
millions of dollars in revenue each year and nothing that cannot be corrected with minor
intermediate sanctions. The Minority report discusses sanctioned individuals and companies in
Russia with the hopes of connecting them to NRA personnel so as to “raise concerns,” but even
the Minority must admit that just meeting with individuals on an OFAC list does not, unto itself,
violate U.S. law. It is fair to analyze the wisdom of traveling to Russia in December 2015 to
meet with high-ranking Russian officials, but it is nowhere close to reasonable to question the
tax-exempt status of the NRA because of it.
In the end, the Minority report contains much conclusory innuendo about an organization, the
NRA, and repeatedly attempts to paint a picture that does not exist. The Minority report uses
terms like “raises concerns” in an attempt to embarrass the NRA while absolving the Minority
from having to assert any serious factual or legal analysis. The Minority report exaggerates
several details while omitting or downplaying mitigating facts. The Minority report states, on
several occasions, that it was unable to establish many assertions that it purports to make. In the
Minority report, statements like these are often inserted at the end of a section, left without any
analysis or elaboration. Glossing over such facts just because they are damning to a narrative
does not mean they do not exist. Despite this, the Minority report seeks to use this report as
justification for a compulsory audit of the NRA in order to conduct yet another fishing
expedition for wrongdoing. Therefore, the Majority finds that the facts do not support the
Minority’s narrative or conclusions.

9

 EXHIBIT 1

To: Pete Browne!!?

From: Paul Erickson
Sent: 2015-11-30T03z142172

importance: Normal
Subject: Take No Grief.
Received: 

Happy Monday, Pete!

JUST 3 private note in case you get any unwanted "mentoring? from your NRA brothers (and one-half
sister married to Keene): You will NOT be ?doing business" during your days with the NRA delegation
in Moscow. Shouid you arrive a few days ahead of the formal delegation, that is YOUR time to he
spent on YOUR purposes with ZERO ?official" contacts ?just an American businessman exploring
business opportunities with companies unrelated to the dipiomatic good will tour that Ms. Butina
has arranged for the "honcho set.?

Don?t be intimidated out of a business trip because you happen to have successfully scheduied TWO
completely different missions on ONE trip to the opposite side of the world.

A final heads-up: Due to NRA protocols, it will be suggested to you that (due to seniority) David
Keene and Joe Gregory are ?leading" the delegation in the wake of the Cars withdrawal. That is
technically correct due to your as?yet?officiai eiection to the office of President. But know with
CERTAINTY that the only reason that Torshin Butina were able to preserve the incredible VIP
meeting schedule they had arranged was because of YOUR about?to-be title. Others may be
introduced with various accolades, but ail Russian eyes and questions will be on you.

I?ll keep you post-ed on any other last minute ore-departure intel. Call or write at any hour with
questions!

Paul

?icell)

00208

EXHIBIT 2

To: Millie Hallowl?

From: Pete Browne"

Sent: 12
Importance: Normal

Subject: Fwd: Liberatores in Moscow
Received: 
im 1.

imag?zp 
Easement:
We

a.
33-33:!

Situational awareness.

There is confusion on a couple of fronts regarding reimbursements around Russian trip. Libitors
did not have a complete understanding on what expenses they were to be responsible for (food).
Maria was lead to believe she was paying for 8 delegates when there were in fact It).

So I have been asked to ?gure out who should hold the bag on this.

The unfortunate situation is all parties were caught by surprise by this.

6000 is at issue to PY For food Russians spent to cover the 2 extra delegates. Keep in mind this

covers 3 dinners and 3 lunches. If the math works that is a total of $500.00 per person per meal
to get up to 36.00000. Which I think is extreme. So this number is more than just food or in it is

in rubles instead of dollars.

0n the advice of past president and co~traveler I have indicated to libators a possibility of a
reduced charge is in the works.

What would the process be if we were to take care ot'45 00 of above charge through the president
of?ce?s budget?

Pete
Sent from my iPhone
Brownelis

Begin forwarded message:

From: Maria Butina 
Date: January 8: 20l6 at 6:04:34 PM EST
To: Pete 
Subject: Liberatores in Moscow

My Dear Pete,

003??

 have a situation that needs your delicate and manly professional advice.

This message is going ONLY to you until i have a better idea of how to proceed (and
only because you are mentioned in the message from Jim below). I saw the
American ?Star Wars? movies last fall . . . ?help me. Pele, you're my only hope!?



When planning the NRA delegation trip to Moscow months ago, I met personally with
David Donna Keene in Washington, DC. We agreed that my organization had
enough money to cover ALL expenses for up to 8 NRA guests in December. If
there were any more, they would have to pay their own way.

When the Liberatores were added to the trip. Donna Keene assured me that the Outdoor
Channel would have no problem with their expenses. Believing this. we found a
way to cover their nearly 56.000 in costs. Donna in Moscow again said not to
worry.

When I quietly asked for reimbursement from Donna after Christmas, I received the
message below from Jim several days later.

I feel terrible. i do NOT want this issue over expenses to affect the strong friendship
between the NRA and The Right to Bear Arms. in the message below, Jim said
that he spoke to you -- what was your 

i know Donna is in a hard place on this issue as coordinator of the trip but it's also
clear that she didn't warn the Liberatores about this possibility before they were
already in Moscow.

1 await your counsel after your winter board meeting ends!

Regards,
Maria Butina

Haliano eoo?meunn:

Omiaamenb: Jim Liberatore

Toma: RE: Attached Image
Rare: 7 nHaapn 2016 11:38:15 GMT-6
l?lonyna'renu: Maria Butina
Kenna: Pete Brownelt

 

Maria-

00378

This will be a little bit of an embarrassing email to write, but 'was told
before the trip that my expenses would he covered and that my air fare
was all I needed to worry about. which is what I told my company to get
the approval to go to Russia. . It is true, Donna did approach me the night
before we left teliing me I was going to get, "my portion of the bill? which
at the time and the place, the lobby of the hotel, I did not want to
challenge and new was going to talk to Pete about the situation, which I
subsequently have.

1With that said, even if now 1 were going to try and submit some expenses
to my company, I would need receipts as I cannot get reimbursed for
expenses without the proper backup. I can at this point attempt to get the
hotel reimbursed, but cannot promise I can even get that done. Also, I will
pay personally for our ballet tickets so let me know what that came too as
well.

If you can send me my itemized hotel bill I will try and get that thru for
reimbursement. lam sorry for the confusion.

Also, I hope you are still interested in Kim's breakfast she is setting up at
SHOT Show. She has sent multiple request to Syetlana which have not

being responded too but we are still working on getting her there as weli.

I will also be sending you this week a response to your questions for the
President and our proposed program.

Thank you, and again, I am sorry for any confusion

. :a-v - World Fishing Neluurk.
Slim-[main 

 

00379

EXHIBIT 3

Rzan Repp

From: Rob McAllister

Sent: Thursday, August 30, 2013 1:3? PM
To: Ryan Rapp

Cc: Teresa Mackewich

Subiect: PW: Russia

FYI below.

Rob McAllister

VP of Strategic Deveiopment

Brawnells, Inc.

ext:-

From: Rob McAiIister
Sent: Wednesday: November 25, 2015 3:21 AM

To: Pete Emwen?

Subject: RE: Russia
Hi Pete,

I followed through with DFAC regarding the peopie on the itinerary. The last two guvs on the list hit the UFAC "Specially
Designated Nationals" list of people to avoid. Especificallv asked OFAC the question of meeting individuals like
these if no business is transacted. Their response was that "the generai ruie of thumb, not necessarily a herd?and-fest
rule? is to avoid a meeting if the SDN could "derive a benefit" from the especially if the meeting could be
described as vou providing a service to the SDN individuai. The advice was to be cautious and be aware that you should
provide no benefit to those SDN persons. If we want we can set up a further call with them to talk details, but I think
we?re on solid ground if the purpose of those SUN persons attending meetings is simplv good wilt i.e. the exchange of
ideas is not between you and these individuals but rather between the NRA and The Right to bear Arms group.

Rob

From: Pete Browne?

Sent: Tuesdav, November 24, 2015 1:20 PM
To: Rob McAllister

Subject: FW: Russia

From: Perrine: Nicholas
Sent: Tuesday. November 24'. 20-15 1:01 PM

monasteries:?
assessmen?

Suhject: Russia

00793

Roxie,

Attached is the latest itinerary for Russia. Please send a scan of Mr. Browneil's passport photo page so we can
get started on the visa.

Thanks,
Nick

Pete Brownell
Chief Executive Officer



Emir:?
Address:?
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