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Washington – A business associate of a key figure in the investigation into former Trump campaign chairman Paul Manafort pleaded guilty Friday to failing to register as a foreign agent.

W. Samuel Patten entered his plea in federal court in Washington, shortly after prosecutors released a four-page charging document that accused him of performing lobbying and consulting work in the United States and Ukraine but failing to register as a foreign agent as required by the Justice Department.

Patten was a business associate of Konstantin Kilimnik, a man U.S. authorities have said has ties to Russian intelligence.

Kilimnik worked closely with Manafort, who was found guilty this month of eight financial counts. Kilimnik also is a co-defendant in a pending case against Manafort in Washington, brought by special counsel Robert Mueller’s team, that accuses them both of witness tampering.

The Patten case was referred by Mueller’s team to the United States attorney’s office in Washington, which is handling it. Andrew Weissmann, one of the lead Mueller team attorneys in the Manafort prosecution, was seen at court Friday ahead of Patten’s appearance

Court papers don’t refer to Kilimnik by name, but say Patten worked with a Russian national on lobbying and political consulting services.

Prosecutors say Patten, who formed a consulting company with a person identified only as “Foreigner A,” worked to set up meetings with members of Congress and also drafted talking points for Capitol Hill meetings.

The goal, prosecutors say, was to influence U.S. policy, but they say Patten never filed under the Foreign Agents Registration Act. The law is aimed at promoting transparency about lobbying efforts in the United States.

U.S. District Judge Amy Berman Jackson told Patten that she couldn’t provide any estimate of Patten’s potential sentence because U.S. sentencing guidelines don’t have a section for violations of the Foreign Agents Registration Act. Prosecutions of the offense are rare, but in recent years the Justice Department’s national security division has taken a tougher stance on enforcement of the law.

Patten’s plea agreement requires him to cooperate with the government. He was released on his own recognizance Friday without a sentencing date.

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