Many commentators anticipate that Special Counsel Robert Mueller will likely indict retired lieutenant general Michael Flynn in part for the former National Security Advisor’s previously undisclosed work as a foreign agent of Turkey. Mueller’s team has reportedly obtained enough evidence to indict Flynn and his son, according to an NBC News report earlier this month.

There is no way to tell, based on current reporting, whether that body of indictable evidence, includes the two alleged meetings in Sept. and Dec. 2016 where Flynn may have discussed a plot to forcibly remove U.S.-based cleric Fethullah Gülen, or initiate legal proceedings against him, in exchange for $15 million. But in considering Flynn’s case, it is important to keep track of how he changed from a relatively hardline position against the government of Turkey to public positions in favor of Ankara. Important questions for legal liability and moral responsibility include whether Flynn’s conflict of interest and efforts in favor of Turkey continued past the election and into his time in office.

Engaging in pro-Turkish government dealings was a major change in Flynn’s position on Turkey. In July 2016, Flynn gave a speech supporting the military coup against the Turkish government, specifically citing the country’s “move toward Islamism” under President Recep Tayyip Erdoğan and the military’s secular orientation. And previously, while serving as DIA Director under the Obama administration, Flynn says he alerted White House officials to Turkey’s indifference toward ISIS’ growth in Syria.

What explains why Flynn changed his position on Turkey and why did he persist in pro-Turkish positions after his firm’s contract to work on behalf of the Turkish government purportedly ended?

I. Flynn’s initial anti-Erdoğan, anti-Islamist public positions, and his later The Hill Op-Ed Reversal

War Against “Cunning Radical Islamists” Tweet (Nov. 16, 2015)

Flynn has publicly spoken against what he views as a global threat of radical Islamism, which, according to his view, also implicated Erdoğan’s pro-Islamist government at one point. He tweeted in November 2015:

We are facing violent, but very serious and cunning radical Islamists. We can be war weary when we win. If we lose, we have nothing. — General Flynn (@GenFlynn) November 16, 2015

Flynn Expresses Concerns on Turkey’s Indifference to ISIS to Sy Hersh (January 2016)

Flynn seemed to view Turkey’s pro-Islamist attitudes as leading to the country’s indifference to ISIS growing next door. In January 2016, he told Seymour Hersh in a New Yorker interview:

“If the American public saw the intelligence we were producing daily, at the most sensitive level, they would go ballistic…We understood Isis’s long-term strategy and its campaign plans, and we also discussed the fact that Turkey was looking the other way when it came to the growth of the Islamic State inside Syria.”

He added that the Obama administration gave “enormous pushback” with respect to the DIA’s reporting on ISIS’ growth in Syria, including Turkey’s alleged indifference: “I felt that they did not want to hear the truth.”

Flynn Tweets that Fear of Muslims is Rational (Feb. 27. 2016)

In line with his prior statements, Flynn tweeted in Feb. 2016 that fear of Muslims was “rational:”

Fear of Muslims is RATIONAL: please forward this to others: the truth fears no questions… https://t.co/NLIfKFD9lU — General Flynn (@GenFlynn) February 27, 2016

Flynn Lauds the Anti-Erdogan Coup at ACT! For America Speech (July 15, 2016)

On July 15, 2016, Flynn gave a speech at the Cleveland meeting of ACT! For America. The organization is an advocacy group that opposes what it calls “Islamofascism,” which Brigitte Gabriel, the group’s founder, believes comes from “one source: The Koran.” Flynn began his remarks by expressing support for the military-led coup d’état in Turkey:

“[The Turkish military] has been just excised for many years by what, what really became a secular country, meaning a sort of, regular sort of nation-state, and then began to move toward Islamism. This is Turkey under Erdoğan, who is actually very close to President Obama. So, I’m going to be very fascinated to see what happens, because if they, the military succeeds, then one of the things that came out of the military tonight, they’re about plus eight hours from here, so it’s probably about I don’t know, three-four o’clock in the morning there. One of the things the military immediately said is: “We recognize our responsibilities with NATO, we recognize our responsibilities with the United Nations, we want to make sure that the world knows, we are, we want to be seen as a secular nation. This is the military. [Applause] So, yeah, I think that is worth clapping for.”

New York Times Notes Flynn and Trump Share Islamophobic Outlook and Flynn’s Influence on the Campaign (November 2016)

The New York Times’ post-election profile of Flynn noted his anti-Islamist credentials throughout the campaign:

[Trump and Flynn] have both at times crossed the line into outright Islamophobia. … [Trump and Flynn] both exhibit a loose relationship with facts: General Flynn, for instance, has said that Shariah, or Islamic law, is spreading in the United States (it is not). … As an adviser, General Flynn has already proved to be a powerful influence on Mr. Trump, convincing the president-elect that the United States is in a “world war” with Islamist militants and must work with any willing allies in the fight, including President Vladimir V. Putin of Russia.

Flynn Supports Erdoğan Government’s Goals in the Hill Op-Ed (Nov. 08, 2016)

On Election Day 2016, The Hill published an op-ed by Flynn titled, “Our ally Turkey is in crisis and needs our support.” The op-ed criticized the Obama administration for not being friendly enough toward Erdoğan’s government and portrayed Gülen as a cleric who “portrays himself as a moderate, but he is in fact a radical Islamist.”

It compares Gülen to the founders of the Egyptian Muslim Brotherhood and labels him Turkey’s equivalent of Bin Laden:

“To professionals in the intelligence community, the stamp of terror is all over Mullah Gülen’s statements in the tradition of Qutb and al Bana. Gülen’s vast global network has all the right markings to fit the description of a dangerous sleeper terror network. From Turkey’s point of view, Washington is harboring Turkey’s Osama bin Laden.”

It also ties Gülen to the Clinton Foundation:

[F]unding seems to be no problem for Gülen’s network. Hired attorneys work to keep the lucrative government source of income for Gülen and his network going. Influential charities such as Cosmos Foundation continue their support for Gülen’s charter schools. Incidentally, Cosmos Foundation is a major donor to Clinton Foundation. No wonder Bill Clinton calls Mullah Gülen “his friend.”

And concludes:

“We need to adjust our foreign policy to recognize Turkey as a priority. We need to see the world from Turkey’s perspective. What would we have done if right after 9/11 we heard the news that Osama bin Laden lives in a nice villa at a Turkish resort while running 160 charter schools funded by the Turkish taxpayers? The forces of radical Islam derive their ideology from radical clerics like Gülen, who is running a scam. We should not provide him safe haven. In this crisis, it is imperative that we remember who our real friends are.”

When Flynn’s op-ed came out, Ekim Alptekin, the Turkish businessman who hired Flynn’s firm, told the New York Times: “This is not a guy who would be influenced by a contract. He wrote what he believes.”

Al Monitor’s Turkey columnist Mustafa Akyol also told the paper of the warm reception Flynn’s op-ed had inside the government of Turkey: “You would expect to see [an Islamophobia] concern here, but quite the contrary: Flynn is quite a respected figure now in government circles, just because he wrote that Gülen should be extradited to Turkey.”

He added: “[Flynn’s op-ed] was greeted with great happiness here,” adding that Erdoğan supporters thought: “Finally, somebody in America who understands us.”

In late Nov., Alptekin denied that either Erdoğan or the Turkish government paid for Flynn’s op-ed, telling The Independent that the idea was “preposterous,” noting that the op-ed also criticized the Muslim Brotherhood, a group that Erdogan had sometimes supported. He contended that Inovo’s contract with Flynn Intel Group was “not about representing the position of the Turkish government,” and Alptekin said that he was not affiliated with the Turkish government.

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Flynn has a strong anti-Islamist streak, and yet he went from criticizing Turkey’s relatively pro-Islamist government and supporting the coup against Erdoğan, to publicly advocating for Gülen’s removal to face justice for the coup in Turkey. What changed between these two events—the coup and the op-ed—to cause Flynn to switch positions on Turkey?

II. A likely motive: lucrative lobbying contracts, and how Flynn’s private business activities may have affected his public positions

Flynn Intel Group Signs Contract with Inovo BV (Aug. 2016)

In early August 2016, Flynn Intel Group was approached by Alptekin, the chairman of the Turkish-American Business Council, a Turkish economic relations board run by an appointee of Prs Erdoğan. Alptekin proposed that Flynn work on a project repairing Turkey’s image in the United States with Alptekin’s Netherlands-based firm Inovo BV—work to be performed by Flynn’s firm over 90 days in exchange for $600,000. Flynn agreed.

Though Flynn later conceded in his belated filing that the Inovo work “could be construed to have principally helped the Republic of Turkey,” Flynn opted not to file this work with the Foreign Agent Registration Act (FARA) database until strongly encouraged to do so by the Justice Department. FARA requires lobbyists whose work directly or indirectly benefits a foreign government to file as agents of a foreign power. The Flynn firm would likely assert that because the Inovo work benefitted a business and not a foreign nation, the firm could instead file with Congress under the Lobbying Disclosure Act, and it did so in Sept. 2016.

Flynn Meets with Turkish Ministers Alongside Woolsey in New York (Sept. 21, 2016)

On September 21, Flynn met in New York with the Turkish foreign minister and energy ministers (the latter is also Erdoğan’s son-in-law), alongside former CIA Director James Woolsey and a former FBI agent, according to Woolsey’s account of the deliberations. Woolsey later told the Wall Street Journal that the meeting discussed a plot to remove Turkish cleric Gülen from the United States and take him to Turkey.

According to a report by the Daily Caller, one month after the Sept. 2016 meeting between Flynn and Turkish ministers in New York, Flynn attended an event with Halil Mutlu, former director of the Turken Foundation, a U.S. charity focused on Turkish issues, and President Erdoğan’s cousin. (Readers should note: The Daily Caller generally has a far-right ideological lens, and has been criticized for having a white nationalist problem in recent months.)

Flynn Intel Group Lobbies Congress on Inovo’s Behalf (Sept.–Oct. 2016)

After signing the contract with Inovo BV, Flynn’s Intel Group began lobbying Congress on Inovo’s behalf, though Flynn himself did not participate in the lobbying. Flynn’s Sept. 2016 Lobbying Disclosure Act forms reveal that Robert Kelley, Flynn’s lawyer and a former Chief Counsel to a House subcommittee, managed the lobbying portion of the Inovo contract.

According to the FARA registration, in Oct. 2016, VP Bijan R. Kian met twice with Miles Taylor, National Security Advisor to the House Homeland Security Committee, to discuss Flynn Intel Group’s work for Inovo and research related to Turkey and Gülen. According to a Daily Caller source, at the second meeting, Kian and Inovo representatives discussed Gülen with Taylor, and what they called his “shady” Gülen Movement Schools. The source added that House committee staff were not receptive to Kian’s approach, and that Flynn was not present for the meeting. Beyond this Congressional outreach, the FARA registration also notes that Flynn’s firm oversaw a PR firm SGR LLC’s outreach to an Arkansas state government official with respect to the Inovo work.

The AP reported that as part of the Taylor meeting, Flynn Intel Group staff suggested that Congress hold hearings about Gülen.

At the time of the filing, Alptekin told the AP: “I disagree with the filing…It would be different if I was working for the government of Turkey, but I am not taking directions from anyone in the government.” He said the filings were a response to “political pressure.”

Flynn Group’s VP Meets Alptekin Prior to The Hill Op-Ed (Nov. 2, 2016)

According to an in-depth profile of Flynn by The New Yorker’s Nicholas Schmidle, on November 2, 2016, Alptekin privately met Flynn Intel Group VP Bijan R. Kian and other corporate officers at the firm’s offices in Alexandria, Va. Alptekin, believing that Trump was likely to lose the election, emphasized that, “We have to generate something to show Turkey how successful we can be…What success can we show them now?”

As Schmidle points out, Flynn’s op-ed in The Hill was published a week later.

Flynn and Alptekin Statement to the Wall Street Journal (Nov. 17, 2016)

Flynn told the Wall Street Journal in a Nov. 17 statement that he would end his relationship with his firm if offered to serve in the Trump administration. He said: “If I return to government service, my relationship with my company will be severed in accordance with the policy announced by President-elect Trump.” Turkish businessman Ekim Alptekin tells the Journal that he hired Flynn to advise him on the U.S.-Turkish security relationship, and more generally, to improve U.S.-Turkish relations.

WH Cabinet Secretary’s Post-Election Investigation into Flynn’s The Hill Op-Ed (Nov. 19, 2016)

On Nov. 19, the day after Trump appointed Flynn as his National Security Adviser, lawyer Bill McGinley, who later became White House Cabinet Secretary, called Kian and others to investigate the Flynn op-ed. A source told The New Yorker:

Some people seemed skeptical as to whether Flynn had really woken up the day before the election and felt compelled to write an op-ed defending Erdoğan…McGinley wanted to know if Turkish government dollars touched that op-ed.

Kian reportedly told McGinley that Flynn wrote the op-ed entirely on his own, and that it was unrelated to his work for Alptekin.

However, the Flynn group’s FARA filing noted that in October and early November, Flynn developed the op-ed based partly based on research done for the Inovo work, and that a draft was shared with Inovo before publication. Further, SGR LLC, a public relations firm Flynn Intel Group hired as part of the Inovo contract, helped Flynn place The Hill op-ed.

Second Meeting with Turkish officials on Alleged Gülen Plot in New York (Dec. 2016)

Mueller’s investigation is reportedly looking into whether, during a second alleged meeting between Flynn and Turkish government representatives in mid-Dec. 2016, participants discussed a plan for Flynn and Flynn Jr. to remove Gülen in exchange for up to $15 million dollars. It is also reportedly looking into whether they discussed a separate plan to free Turkish-Iranian gold trader Reza Zarrab. The Wall Street Journal reported that the alleged meeting took place in mid-December at the 21 Club in New York, and the discussion considered forcibly removing Mr. Gülen from the U.S. on a private jet to the Turkish prison island of Imrali.

If the December meeting were to be confirmed, even if the more sensational allegations about the content of the meeting were not established, it could contradict Flynn Intel Group’s filing statements, which state that the Flynn firm’s contract with Inovo terminated in November 2016, and that is when Flynn’s paid work that benefited the Turkish government ended. Intentional false statements on a FARA form are a felony.

Flynn Tells Susan Rice “We’ll Take it From Here” on Raqqa Campaign (Jan. 10, 2017)

On Jan. 10, outgoing National Security Adviser Susan Rice presented Flynn a plan to imminently take over the Islamic State’s capital in Raqqa, Syria, according to the Washington Post. The plan involved arming Kurdish Peshmerga fighters in northern Syria, and Obama administration officials believed they had little time left to move forward with the operation.

The Post noted that Turkey’s Erdoğan had resisted their overtures to fight the Islamic State more robustly, leading in part to the U.S. plan to rely on the Kurds:

In contrast to Obama, Turkish President Recep Tayyip Erdoğan did not see the Islamic State as his country’s No. 1 threat. In private meetings with senior U.S. officials in 2014, Erdoğan said the Kurds were his top concern and that removing Assad ranked second, according to U.S. and Turkish officials.

Erdoğan has long been upset by the U.S. support for Syrian Kurds, which he considers part of a terrorist group that threatens Turkey’s national security.

According to the Post, Flynn responded to Rice:

Don’t approve it…We’ll make the decision.

McClatchy reported that it is not known if Flynn consulted other administration officials before telling Rice to hold off on the decision, or whether Flynn’s decision was approved by a higher-ranking official such as Secretary of Defense nominee James Mattis.

Raqqa Plan is “Dead on Arrival” When Presented to Trump Officials (Jan. 17, 2017)

When the plan was turned over to the Trump administration on Jan. 17, per Flynn’s request, the Post reported that it “was dead on arrival.” According to McClatchy, “Some members of Congress, in private conversations, have even used the word ‘treason’ to describe Flynn’s intervention” with Rice. And while there is no reporting whether Flynn advised Trump to hold off on the Raqqa assault, media outlets have noted that Trump only approved the plan weeks after he had fired Flynn.

Flynn, Turkish FM Meet over Breakfast at Trump Hotel (Jan. 18, 2017)

McClatchy reported that Flynn met Turkish foreign minister Mevlut Cavusoglu over breakfast on Jan. 18 to discuss U.S.-Turkish interests. It was later reported by Business Insider that Republican Rep. Devin Nunes, Chairman of the House Intelligence Committee, was also present at the closed-door meeting at the Trump Hotel in Washington, D.C. Pro-government Turkish newspaper Daily Sabah reported at the time of the breakfast that the meeting was “a first direct reachout between the President Recep Tayyip Erdoğan administration and the incoming Donald Trump administration.” An aide to Cavusoglu told the paper that that “Çavuşoğlu was the only foreign leader at the breakfast and the topics on the U.S.-Turkish agenda were discussed by the attendees.” Cavusoglu would later attend Trump’s inauguration.

Met w/General Flynn,who will assume the position of National Security Advisor, and other officials at a working breakfast in Washington D.C. — Mevlüt Çavuşoğlu (@MevlutCavusoglu) January 18, 2017

President Trump’s Call with Erdogan (Feb. 7, 2017)

On Trump’s first call with Erdoğan, the pair agreed to engage in joint action against ISIS positions in Syria, according to two sources in Erdoğan’s office, Reuters reported. They added that Erdoğan urged Trump not to support the Syrian Kurdish YPG militia. Al-Monitor reported based that a senior Turkish official said that Erdoğan “drew attention to the close ties between the Syrian Kurdish People’s Protection Units (YPG) and the Kurdistan Workers Party,” the Turkish-based Kurdish group. Likewise, Reuters added that CIA Director Mike Pompeo would be in Turkey on Feb. 9 to discuss security issues with Turkish officials.

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Considering the nature of Flynn’s pre- and alleged post-election work on behalf of the Turkish government, it appears that the money paid to him as part of the Inovo contract may have played a decisive role in changing his position on Turkey. The extent of his reversal would have negatively implicated U.S. national security interests if it figured into his response to Susan Rice on the operation to retake Raqqa, the Islamic State’s so-called capital. But why would Flynn remain motivated by pecuniary interests once he was named to be national security advisor and then served in the administration? Perhaps it was not a financial interest at that point. Perhaps it was a case of a person’s judgment being clouded, convincing themselves that they believe in a new policy outlook to reduce the cognitive dissonance that would otherwise persist. Another explanation is a more illicit one. If Flynn and his son were still interested in mid-December in being personally paid $15 million by Turkey, there’s reason to think Flynn would not have dropped such interests going forward on other policies favorable to Turkey. The allegations reported in the Wall Street Journal and NBC News involving the mid-December meeting certainly raise this specter. The available information in the public domain does not provide a sufficient basis to reach any firm conclusion. It will be up to Mueller’s investigation and others to tell.