Flynn’s firm disclosed it was lobbying for Inovo in September but did not register with the Justice Department as a foreign agent. Robert Kelner, a lawyer for Flynn’s firm, wrote in a letter to the Justice Department on Tuesday that the firm believed at the time that the congressional disclosure was sufficient but is now registered retroactively as a foreign agent.

“Nevertheless, because of the subject matter of Flynn Intel Group’s work for Inovo, which focused on Mr. Fethullah Gulen, whose extradition is sought by the Government of Turkey, the engagement could be construed to have principally benefited the Republic of Turkey,” Kelner wrote. “To eliminate any potential doubt, the Flynn Intel Group therefore is electing to file a registration under FARA, in lieu of its prior LDA registration.”

Flynn resigned from the Trump administration in February over calls he made to the Russian ambassador to the U.S. during the transition. Price Floyd, a spokesman for Flynn, said that Flynn had decided to retroactively register with the Justice Department “out of an abundance of caution.”

Of Flynn’s work, Price would say only that “he was hired by Inovo BV to help repair the perception of the business climate in Turkey with key audiences in the U.S. following the attempted coup.”

Flynn’s op-ed, published in The Hill, argued the U.S. shouldn’t provide “safe haven” to Gülen, whom Flynn compared to Iran’s Ayatollah Khomeini. “We need to see the world from Turkey’s perspective,” Flynn wrote. “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 op-ed never disclosed that Flynn was being paid to work against Gülen, describing Flynn only as a “former director of Defense Intelligence Agency and the author of New York Times bestseller ‘The Field of Fight.’” Floyd declined to comment on why Flynn didn’t make the disclosure.

Flynn’s firm continues to maintain his op-ed wasn’t tied to his firm’s work for Inovo. “The op-ed was not written or published at the request of, or under the direction or control of, Inovo, the Republic of Turkey, or any other party,” Flynn’s firm reported in the filing. “No compensation was received for the publication of the op-ed.”

Alptekin, who is also the chairman of the Turkish-American Business Council, an arm of Turkey’s Foreign Economic Relations Board, told POLITICO in a phone interview from Turkey late Wednesday evening that Flynn has written the op-ed of his own accord and that he had misunderstood some of the finer points of Turkish politics. Flynn tried to tarnish Gülen’s supporters by comparing them to “one of the best friends of the Turkish government, the Muslim Brotherhood,” Alptekin said, which he would have advised against.

“I really think that he’s not very politically savvy,” Alptekin said. “He acts on his motivational impulse.”

But Flynn’s firm’s statements repeatedly undermine its assertion that the op-ed wasn’t tied to its work for Inovo. Flynn’s firm acknowledged in a filing that Bijan Rafiekian, another member of Flynn’s firm who also registered as an agent of Inovo, “and an editor, Hank Cox, participated in the drafting” of the op-ed. Cox was paid $300 by Flynn’s firm several weeks later. (Rafiekian was later named to Trump’s transition team working at the Office of the Director of National Intelligence. He did not respond to a request for comment.)

Flynn’s firm also admitted that “the op-ed addresses subject matter related to the research that Flynn Intel Group conducted for Inovo, and a draft of the op-ed was shared with Inovo in advance of publication. No changes, other than technical edits, were made to the op-ed based on feedback from Inovo. To the best of our knowledge, Inovo did not communicate with the Republic of Turkey regarding the op-ed or provide the draft op-ed to the government.” SGR LLC, a Washington firm that Flynn’s firm hired to do public affairs work on the Inovo project, also helped to place the op-ed in The Hill, according to the filing.

Alptekin never spoke with the Turkish government or anyone else about the op-ed, he said.

“If this was a Turkish government attempt and we were trying to hide it — imagine how dumb we all are,” Alptekin said.

Flynn’s firm also disclosed a meeting between “Flynn Intel Group” and the Turkish foreign and energy ministers in New York on Sept. 19. Alptekin confirmed that the meeting had taken place and that Flynn himself had attended it. But he said he’d set up the meeting in his capacity as chairman of the Turkish-American Business Counsel, not as the head of Inovo, and that Flynn had attended a Trump adviser, not as a contractor for Inovo.

Alptekin had to push hard to convince the Turkish foreign minister to take the meeting because he expected a Hillary Clinton victory, Alptekin said.

“In all honesty, the Turkish ministers didn’t realize that Flynn would be an important person,” he said. “Nobody expected Trump would even win.”

Flynn’s firm did more than write op-eds, according to the filings. “Flynn Intel Group was tasked to perform investigative research for a specified scope of work using its laboratory team of senior defense, diplomacy, development, and intelligence professionals over a three-month period,” the firm disclosed. “Flynn Intel Group was to retain an experienced filming and production crew in order to develop a short film piece on the results of its investigation, and a public affairs firm to utilize for public affairs as needed. Flynn Intel group held weekly calls with the client to report engagement progress.”

Flynn’s firm reported spending nearly $250,000 on the project. Flynn himself received $12,000 for “Administrative Support” — including a $4,000 check on Nov. 22, four days after Trump tapped Flynn as national security adviser. The firm spent $40,000 with SGR LLC, a Washington consulting firm, but it doesn’t appear the firm ever produced a video.

SGR “was engaged but the video was not completed or disseminated, to the best of our understanding,” Flynn’s firm reported. “Because this is a retroactive registration prepared after Flynn Intel Group had already begun to close operations, this registration is based on documentation currently available to Flynn Intel Group,” the report continues. “If additional relevant information is later identified, Flynn Intel Group will amend its registration.” SGR never produced a video, according to the firm.

Among other Inovo-related expenses, Flynn’s firm also reported paying $1,200 for an “interview” to Rudi Bakhtiar, a former Fox News reporter who said she was fired after rejecting a colleague’s advances. It was not immediately clear what the payment was for. Bakhtiar didn’t respond to a request for comment.