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Received by NSD/FARA Registration Unit 01/25/2017 8-16- 1 AM.

0.MB No. 112^0003;ExpiresApril 30,2017*
y.s. Department of justice Amendment to 'Registration Statement
Washington;D
' C 20530 ' Pursuant to the Foreign Agents Registration Act of
1938, as amended '
INSTRUCTIONS. File this amendment form for any changes to a registration. Compliance is accomplished.by filing an electronic amendment to
registration' statemeht.ana.uploading any supporting doctiinSnts at WmiMSiSLJM&SSM:-

Privacy Act Statement. The filing of this document is required for the Foreign Agents Registration Act of 1938, as amended, 22 U.S.C. §611 & seq.,
for the purposes, of registration under the Act arid public disclosure. Provision ofthe tnfotmation requested is mandatory, and faitere to provide the
:
information is subject to the penalty and enforcementprovisions established in Section 8 ofthe Act. Every registration statement, short form
registration statement, supplemental sttteuteutv exhibit, arnendrneni, copy of informational materials or other document or information filed with the
Attorney General under this Act. isa/publicreedrd open to.public examination, inspection and copying during the posted business hours of the
Registration Unit in Washington, DC Statements are also available online at the Registration Unit's webpage: MteirSsMl4ass:. One copy of
••every.saca-docansenfe-odi^fitan'infon^ is automatically provided to the Secretary of State pursuant, to Section 6fb) of the Act, and •
copies of any and all documents areroutinelymade available to other agencies, departments and Congress pursuant to Section 6(c)'-of the Act. The
Attorney Genera! alsotransittits a semiannual report to Congre,ss on the administration of the. Act which lists the names of all 'agerrts registered under
the Act and the foreign principals they, represent. This-reportis availabie to the public in print and'oaline at;
: l^MMSiMM^.-

Public Reportirjg Burden,. Public reporting burden for this collection'of information is. estimated to average 1.5 hours per response; ihcluding the
time for reviewing instructiotts^searphing existing .data sources, gathering and maintaining thedata needed, .and completing and renewing the
collection of information. Send comments regarding thisibtffden estimate or any other aspect of this collection of information, ihetadingstiggestions
forreducing this rkirdentifr 'iUgjjrtrtttkai' JJmti'Gwpts'ri^oila^ Section, National Security Division, U.S. Department.of Justice, Washington,
;
DC 20530; and to the Office-qf Information and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503.

1. Name of Registrant .2. - Registration No.

Sonoran Policy .Group, LtC 6399:

3. This amendment is filed: to accomplish the. following indicated purpose or purposes:

83 To give a 10-day notice.of change in information as required by Seetion.2(rj)i o f the Act
f § To correct a deficiency i n
O Initial Statement

• ' Supplemental Statement;for fhe period ending

: ;

B:Other.piirpose (svmiM Opdating-officers ' .

O To give.notice dfchangeinan exhiWt.previousiy filed.

4. I f this amendment requires the fijK^^pf »|ocunieritot-do«un^tSj please list:

1. IQ-Bsy notice of paidcontract engagementwith Mew Zealand Embassy following original registration,
2. Notice;of addition'of.new company ofOeer.

5. Each item cheeked above must be explained .below in full detail together with; where.appropriate, specific reference to and identity
;

of the iteTin %-'di«.i«g^r^ion:'staM3^nijt lib. which it pertains. (If space.M insufficient, a fullinsertpage musthe used.)
1 , Letter of engagement sufemttted
executed on January'9 with Embassy for. U.S. government affairs werk dn.bjiaterai:yisa matters.
•2, Addition ofcorporate effice^
interesutheforetgnprincipai, •

FOpi.NSO-5'
Re\iseC03/M

R e v i v e d h v NfsD/FAR A Rpaktratinrt Unit 01./9<;/9A17 C^A-Ti A A I

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Received by NSD/FARA Registration Unit 0 i /25/2017 8:36:21 AM

EXECUTION
In accordance with 28 U:S.C, § 1746, the undersigned swear(s) or affirm(s),under penalty of perjury that he/she has (they have) read
the-information set forth in this registration statement arid the attached exhibits and that he/she is (they are) familiar with the contents
thereof and that such contents are in their entirety true and accurate to the best of his/her (their) knowledge and belief, except that the
undersigned.make(s) ho represeptatiohas to the truth or accuracy ofthe information contained in the attached Short Form Registration.
Statement's), if any., insofar/as such infonriation is not within his/her (their) personal knowledge.

!
(Date of signature) (Print or type name under each signature or provide electronic signature' )

January 19,2017 . /s/Christian Bourge eSigned

1
This s«teraent;siaii te^
fiaictScms, i { - ^ i ^ p s m ^ : k ' m < ^ i ^ t s ^ : p ^ ^ the oiganizatiMs.can, t>y'poiyer of 'wtpt^vi^terke one pi mate ineKvKtuak to-'«t«cate.'ttt» statementon ifeMsjf,
Received by NSD/FARA Registration Unit 0.1/25/2017 8:36:21 AM

Ambassador Caroline Beresford

Deputy Head of Mission
Embassy of New Zealand
37 Observatory Circle, NW
Washington, D.C. 20008

January 11,2017

Madame Ambassador:

SPG, LLC is delighted to confirm that we are representing the New Zealand Embassy in
the United States to provide advisory and counsel in promoting New Zealand gaining
access to the United States Treaty Trader (E-l) and Treaty Investor (E-2) visa program. We
are excited to help facilitate interactions with the U.S Congress and incoming
administration in order to ensure increased investment and trade between our two nations.

In this matter, the Embassy solely is our client, not any other New Zealand government
agency or affiliated entities. Should we engage on other matters, the terms outlined herein
will apply unless agreedto otherwise and stipulated in writing.

Executive Chairman Robert Stryk, will run our engagement operations, but other SPG
personnel will be also be involved as required.

As outlined in our proposal SPG will, in coordination with relevant embassy personnel,
develop and execute a strategy for engagement on this issue. The terms of engagement as
outlined in our contract executed on January 9,2017 is from January 9,2017 to March 9,
2017 with a monthly fee of $25,000 a month to be paid each month by wire transfer by the
dates specified in the document. This fee covers all our services on this matter with the
exception of expenses incurred at the request of the embassy in writing on its behalf should
they occur.

We currently represent ho other client that directly conflicts with you, nor related to U.S.
visa matters. Without your prior informed consent and as long as we remain engaged, we

T>*™»I\«»H hv lsjQTVF AT* A T*pmstraiinn T Tnit 01/25/201 7 8-36-71 AM

Received by NSD/FARA Registration Unit 01/25/2017 .8:36:21 AM

will not undertake any client representation that is substantially related to these matters nor
in conflict with the Embassy.

On matters not substantially related to our defined engagement, SPG will not be
prevented from advocating positions for other clients that are not in accord with the
position of the Embassy .

Subject to the relevant provisions of the District of Columbia's Rules of Professional

Conduct, you consent to our representing you as clients in other matters in which they are
not adverse to you, to parties who are adverse to the Embassy in matters in which we do
represent you, and to our representing clients in business transactions, counseling,
legislation, regulatory, or other matters in which they are adverse to the Embassy provided
that any such matter has no substantial relationship to any matter in which we represent or
have represented you. At the same time, SPG is sensitive to the possibility of conflicts or
other problems that might arise from particular relationships. In such situations, we will
consult with you as appropriate on a case-by-case basis.

SPG and its professionals who are involved in helping execute our engagement will
register with the Department of Justice under the Foreign Agents Registration Act as
required by U.S. law. This registration will disclose certain information concerning our
engagement including this engagement letter. Additional periodic filings are also required
to remain compliant that will disclose additional information.

Both you and ourfirmwill use electronic devices and Internet services to communicate
with each other and forward documents notwithstanding the risk that such communications
may be intercepted by and disclosed to unauthorized parties. You agree that the benefits of
using such technology outweigh the risks of unauthorized disclosure,

Subject to the provisions above relating to registration with the Department of Justice
under the Foreign Agents Registration Act and the use of electronic devices and Internet
services, we agree to treat as confidential and not disclose to any third party, nor use for
our own benefit, any information about you or provided by you in the course of or
executing our contract except: where the disclosure is authorized by you and following
informed consent or necessary for the proper performance of our obligations under this
contract; where the disclosure is required by law, provided that we will give you prompt
notice of the required disclosure if permitted to do so; or where the information is public
knowledge.

If this letter fails to accurately express our mutual understanding or if you have any
questions, please let me know. If acceptable, please sign and return a copy of this letter for
our records.

Thank youforthe honor of serving you and the people of New Zealand.

Christian Bourge, CEO SPG, LLC

Accepi

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