Michael Flynn's failure to disclose to the Justice Department his lobbying on behalf of a Turkish businessman may carry legal consequences for the former national security advisor.
NBC News reported this week that Special Counsel Robert Mueller's team is investigating Flynn for failing to register as a foreign agent in connection with a lucrative lobbying contract with Inovo BV, a Netherlands-based consulting firm owned by a Turkish national.
In August 2016, Flynn's firm, Flynn Intel Group, entered into a contract with Inovo but did not notify DOJ of the agreement until March 2017. Flynn received $530,000 for the work.
The Foreign Agents Registration Act (FARA) requires Americans representing foreign entities to identify their clients to the Department of Justice within ten days of signing a contract and before starting work.
The Center for Responsive Politics collects and stores FARA filings in a searchable database in our Foreign Lobby Watch.
Flynn's lobbying work for Inovo was generally pro-Turkish government in its message.
It included the hiring of a film crew to produce a pro-government documentary, according to The Wall Street Journal.
The film was never published.
Flynn's lawyer maintains that Flynn's work for Inovo was not subject to FARA because Inovo's owner is not a Turkish government official and Flynn submitted the FARA filings voluntarily. Flynn closed his firm in November.
A subcontractor assisting Flynn's firm disclosed in March that its work included preparation for a public relations campaign about charter schools linked to followers of Fethullah Gulen, a Turkish religious and political leader currently exiled in the US.
Turkey's current president, Recep Tayyip Erdogan, considers Gulen to be a political rival and blames Gulen for instigating a failed 2016 coup.
Former CIA director James Woolsey told The Wall Street Journal in March that he had witnessed Flynn and Turkish officials discussing a plan to forcibly return Gulen to Turkey.
Last month, President Donald Trump's former campaign chairman Paul Manafort and Manafort's former business partner Rick Gates pleaded not guilty to federal charges, including failing to register under FARA.
The FARA charge stems from lobbying Manafort and Gates undertook for Viktor Yanukovych, the former president of Ukraine, and his pro-Russian political party. A popular uprising, partly motivated by Yanukovych's alignment with Moscow, ousted him in 2014.
According to anonymous sources familiar with the investigation who spoke with NBC News for their story, Mueller's team has enough evidence to charge Flynn under FARA as well.
In May, the House Oversight Committee's top Democrat, Rep. Elijah Cummings (Md), told reporters that documents indicated Flynn had lied on his national security clearance form regarding a 2015 trip to Russia.