UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA ‘Criminal No.
. Violation: 18 US.C. § 1001 False
Statements)
MICHAEL T, FLYNN,
STATEMENT OF THE OFFENSE
Pursuant o Federal Rule of Criminal Procedue 1, the United Stes of America and he
defendant, MICHAEL T, FLYNN, stipulate and agree tat he following face ae true and
accurate, These facts 6 at consis al ofthe fects known othe parties concerning the
charged offense; they are being submited to demonstrat tht stent fc exist thatthe
{efendant commie the offense to which hei pleading guy.
1, ‘The defendant, MICHAEL T, FLYNN, who served as surogste and nations
security advisor forthe presen campaign of Donald. Trump (Campa), 2s a senior
somber of President-Elect Trump's Transition Team (‘Presidential Transition Team”), and ae
the National Security Advisor o President ‘Trump, made mall fale statements and
oistons cing an interview with he Federal Burau of Investigation (BU on January 24,
2017, in Washington, D.C. At the time ofthe interview, the FBI had an ope investigation ano
the Government of Russa’ ("Russia ofors to intr in the 2016 presidental eostion,
‘nclding the nature of any links between nvidualsasoiated wit the Campaign and Russa,
and whether there was any coordination between the Camyaign and Rusia’ efforts
2. FLYNN’s fle statements and omissions impeded and otecwse hada terial
{impact ont FBI's ongoing invesigtion into the existence of any links or coordination‘between individuals assoeited with the Campalgn and Russia's efforts to interfere with the 2016
residential election
alse Statements Regarding FLYWN’'s Request tothe Russian Ambassador that Russia
Refrain from Escalating the Situation In Response fo U.S. Sanctions agains Russia
4. Onorabou January 24,2017, FLYNN agreed to be interviewed by agent frm
the FBI January 24 voluntary interview”). Daring the interview, FLYNN falsely stated that he
Aid no. ask Russia's Ambessador to the United States Russan Ambassador”) trefain om
cecalatng te situation in esponse to saetions that the United States had imposed gaint
Rusia, FLYNN als fale stated tht he did not remember follow-up convesation in which
the Russian Ambassador sated tat Russa hed chosen to moder its response thse
sanctions as a result of FLYNN's request. In rth and in fet, however, FLYNN then and there
‘knw that the following had occured
4. Onorabout December 28,2016, then-President Barack Oba signed
‘Executive Order 13757, which was to take effect the fllowing day. The
‘executive order announced sentions against Russian reponse to that
governments action intended to interfere withthe 2016 presidential
cleation (U.S Sanctions".
. Onor about December 28,2016, the Russian Ambassador contacted
FLYNN,
Ono about December 29,2016, FLYNN called a snioroM
Presidential Transition Team (PTT official", wh was wth other senior
‘member ofthe Presidential Transition Team atthe Mar-Lagoresr in
Pain Besch, Hori, to discuss what, if anything, communicate to the
Russian Ambassador about the U.S. Sanctions. On that cll, FLYNN andImpact of those sanetions onthe incoming administration’ foreign policy
goals, The PIT official and FLYNN alo discussed tht the members of
the Presdenal Transition Team at Mar-a-Lago did net want Russa to
escalate the situation
FLYNN called the
Immediately after his phone ell with the PTT off
Russian Ambassador and requested that Russia no exalt the sustion
snd only respond to the U.S. Sanction ina reciproesl manne.
Shorty after his phone cll withthe Russian Ambassaor, FLYNN s
With the PT official to report on the substance of his ll with the
Russian Ambassador, including ther discussion ofthe U.S. Sanctions.
(On or about December 30,2016, Ruslan President Vidimir Putin
released a slement indicating that Rusia would no take retaliatory
measures in sponse to the U.S. Sanctions at that time
(nor sbout December 31,2016, the Russian Ambassador called FLYNN
and infomet him that Rusia had chosen not o retaliate in response to
FLYNN's request
After his phone eal with he Rusian Ambassador, FLYNN spoke with
senior membs ofthe Presidential Transition Team about FLYNN's
conversations withthe Russian Ambessodor regarding the U.S, Sanctions
_and Russias devsion not to escalate the situationFate Slatements Regarding FLYNN's Request that Foreign Oficial Vote Against or
Delay a United Nations Security Council Resolion
4. During the January 24 voluntary interview, FLYNN made adtional false
statements bout calls he mad to Rusia and several other countries regarding resolution
submited by Egypt to the United Nations Security Couneil on December 21,2016, Specifically
[FLYNN falsely stated that he only asked the countries’ positions on the vote, and that he didnot
request that any ofthe countries take any particular action on the resolution, FLYNN also
{alsly stated thatthe Russian Ambassador never described to him Russia's response to
FLYNN’ request regarding the resolution, in rath and in fact, however, FLYNN then and there
knew thatthe following had occurred:
(0p or about December 21,2016, Egypt submited e eslution othe
‘United Nations Security Coun on he issu of Ie setements
(Cresoltion”), The United Nations Security Council ws scheduled 0
‘vote on the resolution the following day
‘On or about December 22,2016, very senor member of the Presidential
“Transition Tem directed FLYNN to contac official from foreign
goverment including Russia, to eam wher each goverment stood on
te resolusion ano influnce those goverment to delay the vote or
defeat the reslution.
(On orabout Decernber 22,2016, FLYNN contacted the Rusian
“Ambessador about the pending vote, FLYNN informed the Ressian
“Ambassador sbout the incoming administration's opposition tothe
resolution, and requested that Russia vote against or delay the resolution.@. On orabout December23,2016, FLYNN again spoke with the Russian
Ambassador, who informed FLYNN tht iit came toa vote Rusia would
not Ye against the resolution,
(ther False Statements Regarding FLYNN's Contacts with Foreign Governments
5. OnMarch 7,2017, FLYNN filed muliple documents withthe Deparment of
Justice pursuant othe Foreign Agents Registration Act (FARA) pertaining to project
performed by him and his company the Fly Intl Group, lc. FIG") forthe principal bent
ofthe Republi of Turkey (“Turkey pee). Inthe FARA flings, FLYNN rade matvally
false statements and omissions, including by falsely tating that) FIG didnot know whetheror
the extent to which the Republic of Turkey was involved inthe Tukey project, () the Turkey
project was focused on improving US. business organizations confidence regarding dong
‘ousiness in Tukey, and () an op-ed by FLYNN published in The Hil on November 8, 2016,
‘as writen ahs own iniatve and by omiting tht oficial from the Republi of Tukey
provided supervision and direction over the Turkey project.
ROBERT 8. MUELLER, IIL
Jal Coupeel
jon! Van Grace
Zainab N. Abmad
‘Senior Assistant Special Counsels
‘The Special Counse's Office
By:(DANT'S ACCEPTAN(
“The preceding statement isa summary, made forthe purpose of providing the Court with
«factual bass for my guilty plea to the charge against me. Tt does not include all ofthe facts
Known to me regarding this offense, I make this statement knowingly and voluntarily and
‘because | am, infect, gully ofthe etme charged. No threats have been made to me nor am
‘nderthe influence of anything thet could impede my ability to understand this Statement ofthe
Offense fully.
‘have read every word ofthis Statement ofthe Offense, or have ha it ead to me.
Pursuant to Federal Rule of Criminal Procedure 1 after consulting with my atoms, agree
fd stipulate otis Statement of the Offense, and declare unde penalty of perjury that itis trac
and correct.
ates) 3)
ATTORNEYS" ACKNOWLEDGMENT.
1 havo read this Statement of the Offense, and have reviewed it with my client fully. 1
‘concur in my clients desire to adopt and stipulate to ths Statement ofthe Offense as true and
‘curate.
pate: 11132
Raber Kelner
“Astomey for Defendant
“Avtomey for Defendant