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jahedeen.’ Throughout the Afghan jihad, Maktab al Khidmat worked in concert with a network of purported charities and relief organizations, including the Muslim World League (“‘MWL?”), International Islamic Relief Organization (“IIRO”), Rabita Trust, Al Haramain Islamic Foundation (“Al Haramain”), Muwafaq Foundation *26 (
Page: HOUSE_OVERSIGHT_023377 →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
Page: HOUSE_OVERSIGHT_023381 →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
Page: HOUSE_OVERSIGHT_023389 →{ 430. The specific charities that Prince Sultan donated to include Defendants Internation- al Islamic Relief Organization (“IIRO”),'* Al Haramain,'” Muslim World League (““MWL”)," and the World Assembly of Muslim Youth “WAMY”).! Ashton Com- denied Al Haramain’s motion to dismiss the Burnett action. Burnett I, 274 F.
Page: HOUSE_OVERSIGHT_017849 →, 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
Page: HOUSE_OVERSIGHT_017897 →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
Page: HOUSE_OVERSIGHT_017931 →omplaints. 4 The French Interior Minister named one charity, the World Islamic League, during his meeting. Plaintiffs claim this is another name for the Muslim World League. 5 Plaintiffs bring the Court’s attention to Mwani v. bin Laden, 417 F.3d 1 (D.C.Cir.2005), in which the D.C. Circuit found that Osama bin Laden and
Page: HOUSE_OVERSIGHT_017933 →Entities connected to both the Muslim World League and Al Rajhi Bank

Sudan
LOCATION
New York
LOCATION
United States
LOCATION
Arabia
LOCATION
National Commercial Bank
ORGANIZATION
U.S. Treasury
ORGANIZATION
Saudi Arabia
LOCATIONAl Qaeda Islamic Army
ORGANIZATION
James P. Kreindler
PERSON
Kenya
LOCATION
Bill Clinton
PERSONUngar
PERSONCozen O’Connor
PERSON
al Rajhi
PERSONal Haramain Foundation
ORGANIZATION
Supreme Court
ORGANIZATIONLaden
PERSONAshton
PERSON
Khalifa
PERSON
Batterjee
PERSON