Epstein Secrets

detail below.” (Together with NCB and Abdulrahman bin Mahfouz, Khaled bin Mahfouz and Yassin al Kadi are referred to here is ahe “NCB Defendants.”) Al Rajhi Bank played an analogous and equally important role in al-Qaeda’s financial infrastructure, by also providing financial services to al-Qaeda charity front

rtising these accounts, Al Rajhi Bank “provid[ed] a mechanism to allow al Qaida’s supporters to deposit funds directly into those accounts.” JA3828. Al Rajhi Bank’s operations are consistent with their support of al-Qaeda front charities. In 1999, Al Rajhi Bank was warned. by United States government officials “t

ed to as “Arnaout Evidentiary Proffer”); R.963, Ex. 1, pp. 4-5, 7-8, 10-11 (1996 CIA Report); R.209, Exs. 1 and 2 (June 2004 Press Releases issued by the U.S. Department of the Treasury regarding the WESTLAW HOUSE_OVERSIGHT_023409 --- PAGE BREAK --- In re: TERRORIST ATTACKS ON SEPTEMBER 11, 2001., 2012 WL 257568 (2012) 20 21 2

5-25 -23~—s -20 -19 25-26 Other assets -4 “1-11-10 11-1 -11 -11— 11 memo: Identified Saudi Arabian and Middle Eastern holdings in the US Saudi Arabia US Treasury (UST) holdings 51 46 8 69 68 £76 80 91 109 Long-term securities 50 45 82 68 67 74 78 88 107 Short-term securities 1 1 1 1 1 2 2 3 2 Saudi Arabia hold

e + weight in MSCI weight in MSCI ADTVactive buying active days buying passive days passive days passive days Saudi EM buying US$m buyi buying buying AL RAJHI BANK 9.5% 0.1% 37.2 546.5 14.7 477.7 12.8 1,024 27.5 ALINMA BANK 2.0% 0.0% 223.0 116.9 0.5 102.2 0.5 219 1.0 ALMARAI 44% 0.1% ip. 255.8 33.1 223.6 28.9 47

of September 11, 2001 attacks stated cause of action against bank chairman under Antiterrorism Act (ATA), in that allegations and his designation by Department of Treasury as Specially Des- ignated Global Terrorist were sufficient to HOUSE_OVERSIGHT_017843 --- PAGE BREAK --- IN RE TERRORIST ATTACKS ON SEPTEMBER 11, 2

, check clear- ing services, or any other routine banking service.” Jd. In light of the liberal plead- ing standards, however, Judge Robertson denied Al Rajhi Bank’s motion to dismiss and permitted it to request a more defini- tive statement under Rule 12(e). Jd. at 110. The Burnett Plaintiffs provided an 89-parag

rrorist,’ frozen his assets, and named him “one of the founders of al Qaeda.” (Ashton Compl. J 304; Burnett Compl. § 255; Federal Compl. Ff 117, 91.) The Treasury Department “characterized [him] as having ‘directed organizations that have provided financial and logistical support to al-Qa-ida, [he] is the logistics chief

es assured of its subject matter and personal jurisdiction over NCB, Plaintiffs’ claims are doomed because the Court dismissed similar claims against Al Rajhi Bank, Saudi American Bank, and Arab Bank. NCB contends that Center for Reproductive Law & Policy v. Bush, 304 F.3d 183, 194-95 (2d Cir.2002), supports its