In June 2015, retired Lt. Gen. Michael Flynn took a little-noticed trip to Egypt and Israel, paid for by a U.S. company he was advising. The company hoped to build more than two dozen nuclear plants in the region, in partnership with Russian interests.
Flynn's quiet involvement in that project — and his failure to disclose his ties to the effort — could complicate the legal issues facing President Trump's former national security adviser, who has signaled that he may be willing to cooperate with special counsel Robert S. Mueller III.
Congressional Democrats say Flynn may have violated federal law by failing to disclose the Middle Eastern trip in his security clearance renewal application in 2016. A top House Republican declined the Democrats' request for a congressional inquiry but referred the allegations to the special counsel.
Last month, Mueller revealed that his wide-ranging investigation into Russian interference in the 2016 election had led to charges against three former Trump campaign officials. One of them, foreign policy adviser George Papadopoulos, has been cooperating, according to court filings.
There are now signs that Flynn — whose international dealings have been the subject of intense interest by the special counsel — may also be willing to share information with prosecutors. Last week, his attorney shut down communications with Trump's legal team, a development many interpreted as suggesting possible cooperation with Mueller.
Investigators for the special counsel have been examining whether Flynn hid foreign business dealings, particularly work he did for Turkish interests during the campaign, according to people familiar with the probe.
The nuclear venture is yet another instance in which Flynn appeared to have a personal stake in an international project while he was advising Trump in 2016, giving prosecutors one more potential avenue to pressure him to cooperate.
A spokesman for Mueller declined to comment. An attorney for Flynn declined to comment.
Flynn remained involved in the Middle Eastern nuclear project from the spring of 2015 to the end of 2016, according to recent financial disclosure filings, a period that partially overlapped with his role as a prominent adviser to Trump's campaign and transition.
"General Flynn's actions are part of a broader pattern of concealing his foreign contacts, payments, travel and work on behalf of foreign interests," said Rep. Elijah E. Cummings (Md.), the ranking Democrat on the House Oversight and Government Reform Committee. "The bigger question is this: What did President Trump know, and why did he disregard all the red flags?"
The White House declined to comment.
Flynn served as an adviser to two Washington-based companies pursuing efforts to build nuclear power plants in the Middle East: ACU Strategic Partners, which proposed a partnership with Russian interests, and IP3/IronBridge, which later launched a separate endeavor that initially proposed working with China to build the infrastructure, according to federal documents and company officials.
In various filings in 2016 and 2017, Flynn did not initially disclose his connection to ACU and foreign contacts he made while advising the firm.
Flynn said he served as an "advisor" to ACU from April 2015 through June 2016, according to an amended financial disclosure he filed this August. But he made no mention of the company in a "Truth in Testimony" form he signed for a congressional appearance in June 2015, shortly before he traveled to the Middle East on the trip paid for by ACU. Flynn wrote that he was representing his company, Flynn Intel Group, at the hearing.
He also did not reveal his ties to ACU on the personal financial disclosure form he completed in February after entering the White House, according to federal filings. It was not until August — six months after he was forced to resign as national security adviser — that he disclosed a relationship with the firm on the amended form.
But perhaps his most serious omission, House Democrats contend, came on his security clearance renewal application in January 2016 and in his interview with background check investigators the following month, according to an Oct. 18 letter signed by Democratic lawmakers on the House Oversight Committee.
"It appears that General Flynn violated federal law by omitting this trip and these foreign contacts from his security clearance renewal application and concealing them from security clearance investigators who interview as part of that background check," according to the letter.
It is a criminal offense to knowingly omit material information requested by federal officials conducting such a review.
An attorney for Flynn's company told the committee that it would not provide documents about the Middle Eastern nuclear project unless it was subpoenaed, according to the letter.
Rep. Trey Gowdy (R-S.C.), chairman of the House Oversight Committee, declined to issue a subpoena and instead referred the Democrats' concerns to Mueller and Deputy Attorney General Rod J. Rosenstein.
"Much of what is sought by my Democratic colleagues — if properly investigated, charged and proven beyond a reasonable doubt — would carry criminal penalties," Gowdy wrote in his Oct. 18 letter, posted by the committee. "Congress does not, and cannot, prosecute crimes."
Gowdy, a former prosecutor, did not offer his opinion on whether the allegations had merit, but he wrote that he did not want to "risk interfering with any ongoing criminal probes."
Flynn, who was fired by President Barack Obama from his post as director of the Defense Intelligence Agency in 2014, became involved in ACU's project in 2015, as part of a group of former top military and diplomatic officials and nuclear experts the company assembled to help push its plan.
The idea: to build several dozen "proliferation-proof" nuclear power plants across Persian Gulf states. The plan relied heavily on Russian interests, which would help build the plants, as well as possibly take possession of spent fuel that could be used to build a nuclear weapon, according to people familiar with the project.
ACU's managing director, Alex Copson, had been promoting variations of building nuclear facilities with Russian help for more than two decades, according to news reports. Copson did not respond to requests for comment, and ACU's counsel, Don Gross, declined to comment.
ACU officials declined to identify its investors. The company said in a statement Monday night that it "has never used or accepted investment funds from any foreign government or any company or individual affiliated with any foreign government."
Around the time he began advising the company, Flynn was warning publicly that America's national security would be at risk if the United States allowed Russia and other countries to spearhead nuclear energy projects in the Middle East.
"I don't want Russia to be talking to Jordan about building nuclear plants," Flynn testified before a House Foreign Affairs subcommittee on June 10, 2015. "I don't want the Chinese or Pakistan to be talking to the Saudis about building potentially 10 to 15 plants. I don't want the Russians to go over to Egypt and talk to them about building nuclear plants."
"I want the United States of America to be in the driver's seat," he added.
Two weeks later, Flynn traveled to the region. There, he urged Egyptian officials not to sign a deal with Russia to build nuclear plants and assured Israeli officials that ACU's plan could prevent Israel's enemies from obtaining material for nuclear weapons, according to people familiar with his conversations. The trip was first reported by Newsweek.
Thomas Cochran, an expert on nuclear nonproliferation issues who worked as ACU's senior scientist, joined Flynn on the Israel portion of the trip. "Because General Flynn firmly believed in the necessity of the project from a US national security perspective, he traveled to Egypt and Israel to explain the ACU project's importance," he wrote in a June letter to congressional investigators.
Flynn did not have a contract with ACU, but the company paid more than $5,000 toward his expenses for the trip, according to the firm and federal filings.
ACU also wrote Flynn a $25,000 check for what it described in a letter to the House Oversight Committee as "the loss of income and business opportunities resulting from this trip." But the company said Flynn never cashed the check, mystifying congressional investigators who have examined the matter.
Around June 2016, according to his financial disclosure, Flynn ended his association with ACU and began advising a company called IP3/IronBridge, co-founded by retired Rear Adm. Michael Hewitt, a former ACU adviser.
IP3 initially proposed partnering with China and other nations, rather than Russia, to build nuclear power plants, according to a company spokesman, who said the China component has since been dropped.
In August 2016, the company produced a PowerPoint presentation that included Flynn's photo and former government title on a page titled "IP3/IronBridge: Formidable US Leadership." The document was labeled as a "Presentation to His Majesty King Salman Bin Abdul Aziz" of Saudi Arabia and displayed the seals of Saudi Arabia and the United States. The presentation was obtained by Democrats on the House Oversight Committee, who made it public.
IP3 officials said in a statement to The Washington Post that the document was never presented to the Saudis. The company also said that while it had offered Flynn a role as "an advisor" in June 2016 with no pay, Flynn responded that he wanted to "hold off." In December, the company said, he sent a letter to IP3 "terminating the offer."
Asked why Flynn reported on various financial disclosure forms that he had been a "consultant," "board member" and "advisor" to IP3, the company said it appeared that Flynn disclosed a "potential" role "out of an abundance of caution."
Cummings said his committee was not informed that Flynn had an offer from IP3 that he deferred until after the election.
Flynn continued to support the idea of the nuclear project during the presidential transition. He encouraged Tom Barrack, one of Trump's closest friends, to pursue a related plan and endorsed a colleague's suggestion that Barrack meet with IP3 officials, according to a person familiar with their conversation.
Barrack was interested in developing a Middle East "Marshall Plan" to provide aid to poor regions of the Persian Gulf as a way to combat terrorism. At Flynn's urging, he had a lunch with IP3 officials but did not know that Flynn had served as an adviser to the firm, according to the person with knowledge of the episode.
Barrack declined to comment.
Both the ACU and IP3 proposals remain in flux and would require numerous governmental approvals to proceed.
Meanwhile, other nations have moved to secure their own nuclear power projects in the Middle East.
In May, two years after Flynn visited Egypt to urge that nation not to sign a deal with Russia and to work with a U.S. firm instead, Egypt finalized a deal with Moscow to build its first nuclear power plant. The arrangement was supported by Russian President Vladimir Putin.
Alice Crites contributed to this report.