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Mike Flynn...Part II FARA & Emoluments

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Posted on December 21 2018

As a reminder a few nights ago,  I abruptly ended the Flynn entry at FARA’s front door, full disclosure I was both physically and mentally exhausted. And unfortunately I have extremely limited bandwidth while the General Assemby is in session. Those who know me in real life know what the 6 week push is like and what it does to my availability.  I rarely have a few moments to myself and I’m pretty sure I drop a lot of balls from Thanksgiving to New Years.

The purpose of this follow up entry: drill down on Flynn’s emoluments violations, his lobbying work and his FARA Filings. At all relevant times I will link to the orginal data source. Before we dive head first into a bucket of receipts, it might be best to revisit then Acting Attorney General Sally Q. Yates testimony before the US Senate in May of 2017. 


Flynn FARA #6406

In the March 2017 Flyn Intel Group FARA #6406 registration, the cover letter page 1 paragraph 2 states in part a rather carefully word yet contrived explanation. 


...under FARA, a U.S. firm that represents a foreign corporate client, which is not a foreign government or political party, may register under the LDA rather than FARA, so long as the firm engages in lobbying activities for its client. Flynn Intel Group concluded that because its client was a foreign corporation and the services provided included lobbying activities, it could file under the LDA...



The aforementioned paragraph made me stop and think, where have I heard this argument before? Why yes I’m certain that Paul Manafort AND Sam Patten used these same arguments that they had registered with the House or Senate and therefore they did not know they would be required to also register with the Department of Justice. Generally speaking feigning ignorance of the “law” is not an acceptable defense. You may recall that Manafort attempted to blame shift his FARA issues to his FARA Attorney, see May EDVA Manafort entry and a more fulsome explanation of the “crime fraud exemption”, found here. I also expanded the crime fraud exemption and linked to Melissa Laurenza, a partner at Akin Gump Strauss Hauer & Feld, refused to testify, she was ordered to testify before the DC Grand Jury when Mueller SCORED his 1st win. The tweet below has the embed Court Ruling:


But back to Flynn and his FARA excuse of “but I registered with the Congress under the Lobbying Disclosure Act”, so of course, Flynn’s excuse naturally that made me curious. I then put my eyeglasses on, cracked my knuckles and approached my keyboard with a bit of authority...meanwhile my inner monologue was like: Let’s do this, so me what you got and give it your best shot.

Within 25 seconds I was able to zero in on the Flynn Intel Group’s LDA Filing, which was filed on September 15, 2016. The Flynn Intel Group’s LDA Registration found here. Their Q4 2016 LDA Filing found here.What I do not understand is why no one else ran this search. Because Flynn’s excuse about filing via the LDA does not under even generous circumstances pass the sniff test. Why? Because the Flynn Intel Group only file ONE LDA and disclosed <$5,000 in lobbying fees. Which means it’s reasonable to conclude that Flynn not only lied on his FARA Filings but he also LIED on his LDA filings. The reason I’m making this assertion is the LDA Filing was Q4 2016 the same period of time Flynn was working as a unregistered Foreign Agent.




Perhaps I’m being tough on Flynn by calling into question the fulsome and truthfulness of his Flynn Intel Group LDA Filing. Or maybe I might know where and what Flynn clearly lied about on his FARA “Supplemental” Filing.  I now refer you to page 4, section 13, which Flynn & his Attorney submitted (under penalty of felony)

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 of the op-ed.

What I found absolutely implausible is Mike Flynn all by himself anc on “his own initiative” drafted and submitted the OpEd, which is affirmed later on pages 10 and 11. It’s a twisted word salad that is really just offensive but I’ll give Flynn’s Attorney some credit for the linguistic gymnastics of their supplemental FARA Filing:


What many of you may recall just before Comey was fired he testified before the Senate Judiciary Committee. One Senator asked then FBI Director Comey about the FBI NYC field office and leaks. I would refer you to my previous research, but you know, that work is gone. Notwithstanding some of you who gave followed me on twitter remember the copious threads on Giuliani, Flynn and Brian McCauley. In March of 2017, I was like hmmm why did Flynn pay McCauley tens of thousands and after Trump had named Flynn as his National Security Advisor. In a previous Rudy Giuliani series, I walked you through the various FBI leaks and the oddity McCauley is, you can read more here.


Why yes SGR LLC (note the highlighted email address in the LDA report below, yes it’s Sphere Consulting but that shouldn’t be much of a surprise given on April 30, 2014 Sphere announced the formation of tneir “sister organization” SGR, LLC ) -new- 2017 client :Sberbank CIB USA, Inc.

And yes of course that could be just an extraordinary coincidence but given the incalculable amount of time I’ve researched it’s alawys interesting to see how Mercury & Podesta Group somehow manage to pop up with various Russian Entities that are currently sanctioned.

See section 16, entitled lobbying issues:

Assist in clarifying scope of sanctions imposed by Executive Order 13660, assessing possible ways to address sanctions to relief and monitoring relevant developments applicable to such matters.

Incidentally SGR, LLC FARA # 6379 March 2018 filing, it appears they terminated their relationship with Catalonia but picked up a monthly $60,000 contract with Qatar.


Registrant arranged meetings with media organizations and policymakers to broaden
government outreach with the United States and to facilitate relations Within the scope and
powers of the Government of Catalonia. Registrant also conducted research on issues of
concern to the principal and provided counsel to the principal with regard tP the
aforementioned groups.


Embassy of the State of Qatar
Registrant provides government and public relations services for Qatar with regard to bilateral
issues pertaining to the relationship between Qatar and the United States. Such services
include outreach to the United States Congress, the federal government, and the media.


But the reason I continue to single out Brian McCauley he was the former deputy assistant director for international operations at the FBI and a some point in his career he was assigned to then Secretary of State Clinton. After the horrific murder of our Ambassador Christopher Smith and the burning down of our Embasdy in Benghazi, McCauley became obsessed and fixated with punishing Clinton. 


The Flynn Intel Group, FARA # 6406 Exhibit C, which was filed simultaneously with Flynn’s retroactive FARa Filing, is a bit curious. Exhibit C Flynn Intel Group Articles of Incorporation. 

Whats odd to me is nothing in the Articles of Incorporation discuss DarkShores LLC but in the FARA Filings makes a very brief mention of DarkShores LLC, specifically that this LLC owned 1,000 shares of Flynn Intel Group. I’ve scoured the typical databases and yet the only incontrovertible data I can find is DarkShores,LLC was incorporated the same day as Flynn Intel Group. You can run the same Delaware State Corporation Commission search via this link. I ran multiple queries in various Federal Contract Databases and those searches yielded zero information. I took the next logical step of running a Virginia SCC query, based on their statutory assumption that any Business entity doing business in the State of VA would be required to file as a “foreign corporation” and yet nothing. With that said for now my quest to find any data on DarkShores, LLC must be set aside.



I mean who among us hasn’t had at least two business partners indicted? And who among us hasn’t texted a shady Transport Company, “good to go” while standing on the stage as Trump took his oath of office? Because as painfully detailed the Maryland Trucking/Logistics Company and Flynn’s main point of contact indicted and Flynn’s business partner indicted this week.



Yet even after all of this time, the White House still refuses to answer what took them so long to fire Flynn? While many will argue that the Trump White House needed to get all the facts before firing Flynn that’s not an appropriate explaintion why Flynn remained on staff and had access to our Country’s most sensitive intelligence. 

 And yes it’s easy to judge an administration’s actions after the fact, but in the spirit of transparency the only thing the Trump Administration lies about on an all but 100% of the time, contacts with Russians, during the campaign and during the Transition and “adoptions” aka Sanctions. That’s not my opinion that’s based on a preponderance of verifiable information in the public domain. I still maintain that even if there was nothing nefarious about Flynn reaching out to Ambassador Kislyak, why and who instructed Flynn to lie about it.

Some of you may recall the numerous threads I created, where I took pains to chronologically categorized the numerous Congressional request/letters. I actually never understood why Kaspersky Labs paid Flynn to speak.

Given in March of 2017, the House Democrats sent the following 11 page letter to White House, Secretary of Defense, and FBI Director Comey regarding Flynn’s Emoluments Violation, 


February 2017 letter to Flynn’s Speakers Bureau, requesting invoices, checks and other documentation regarding Flynn’s December 2015 Russia Today visit.

March 2017 production of payments/checks/invoices related to Flynn’s December 2015 Russia Today trip & speech.

My point? Flynn isn’t a Boy Scout. He has a long pattern of lying, withholding material information and apparently thinks Trump will have his back. I won’t discount the Special Counsel’s assertion that Flynn offered “substantial assistance” but I do find it curious that Trump 



And my last point, some have doubted the veracity of my claim that Flynn’s son Flynn Jr was his dad’s chief of Staff and that he also traveled to Russia for the Russia Today “summit” (sidenote I can not properly convey how much I hate Dr Jill Stein, she needs to hop on a plane to Moscow and never ever come back to America, she’s a goddamn disgrace. Full Stop.) notwithstanding here’s some evidence to support my assertion. 100% Flynn Jr was in Russia with his dad. I suppose you’d like to see da tapes? Fine I’m happy to provide it.

What I found interesting about this Russia Today “interview” is it was originally filmed in December of 2015 yet Russia Today only published it on November 20, 2016. What is stunning is in the past I’ve talked about RT, see entry here and the actual weaponization of RT’s disinformation has never been so obvious to me. Once again Russia using Active Measures to alter reality and throw out false flags, it’s what they did with the downing pf MH17 so there’s that awesome nugget of goodness. 


 Again I do not like amplifying any Russian Propaganda but I will say this long forgotten December 2015 Q&A should be scrutinized because in retrospect the interview has a whole new meaning, at least for me it does.


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