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trafficking for violations of 18 U.S.C. § 1591, in part due to Epstein's criminal activities in his New York Mansion located at 9 East 71st Street. See United States v. Jeffrey Epstein, Case No. 1:19-cr-00490 (S.D.N.Y.). 123. On July 8, 2019, Epstein was arrested pursuant to the Southern District of New York In
f AML Compliance for Deutsche Bank Americas and the then-General Counsel for Deutsche Bank Americas, who at that time served as chair of the Bank's Americas Reputational Risk Committee ("ARRC")]. Neither suggest [that the Epstein 52 EFTA00162009 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page
lar pattern to what it did for Epstein, Deutsche Bank onboarded and provided accounts to a billionaire who was a relative of one of the founders of Al Rajhi Bank in Saudi Arabia, an entity long suspected of financing terrorists. 294. In a similar pattern to what it did for Epstein, Deutsche Bank onboarded an
es.*! As a result of al Kadi’s deep involvement in sponsoring al-Qaeda, through Muwafaq as well as various businesses under his control or influence, the *41 United States listed him as a Specially Designated Global Terrorist on October 12, 2001.” Read in context and collectively, the allegations concerning the chariti
Page: HOUSE_OVERSIGHT_023380 →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 →fficient con- tacts with the United States as a whole but is not subject to jurisdiction in any particu- lar state, requires contacts with the United States as a whole. U.S.C.A. Const.Amend. 5; Fed.Rules Civ.Proc.Rule 4(k)(2), 28 U.S.C.A. 50. Constitutional Law ¢=305(5) The due process minimum contacts
Page: HOUSE_OVERSIGHT_017837 →has sufficient con- tacts with the United States as a whole but is not subject to jurisdiction in any particu- lar state, requires contacts with the United States as a whole. U.S.C.A. Const.Amend. 5; Fed.Rules Civ.Proc.Rule 4(k)(2), 28 U.S.C.A. 50. Constitutional Law ¢=305(5) The due process minimum co
Page: HOUSE_OVERSIGHT_017837 →t, but in the manner of a private player within it, the foreign sover- eign’s actions are ‘commercial’ within the meaning of the FSIA.” Weltover, 504 U.S. at 614, 112 S.Ct. 2160. Courts must in- quire whether the foreign state’s actions “are the type of actions by which a private party engages in trade a
Page: HOUSE_OVERSIGHT_017858 →Teamsters, 945 F.Supp. at 617. a. Purposefully Directed Activities Theory Personal jurisdiction based on Rule 4(k) requires minimum contacts with the Unit- ed States to satisfy Fifth Amendment due process requirements. Plaintiffs claim these requirements are met because De- fendants purposefully directed their ac
Page: HOUSE_OVERSIGHT_017872 →forum. Cases that cite this headnote Federal Courts @ Terrorism Two officials of Saudi Arabian government did not have such minimum contacts with the United States as to support a finding of general personal jurisdiction, in action alleging their decisions regarding distribution of humanitarian relief funds prov
Page: HOUSE_OVERSIGHT_017907 →n re Terrorist Attacks on September 11, 2001, 392 F.Supp.2d 539 (2005) 10 A.L.R. Fed. 2d 789 purposefully directed his activities toward the United States by making personal contributions to several Saudi-based charities. (Federal Compl. §§ 442-43.) 19! Plaintiffs must make a prima facie showing that P
Page: HOUSE_OVERSIGHT_017922 →--- In re Terrorist Attacks on September 11, 2001, 392 F.Supp.2d 539 (2005) 10 A.L.R. Fed. 2d 789 purposefully directed his activities toward the United States by making personal contributions to several Saudi-based charities. (Federal Compl. §§ 442-43.) 19! Plaintiffs must make a prima facie showing
Page: HOUSE_OVERSIGHT_017922 →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 →Entities connected to both United States and Al Rajhi Bank

New York
LOCATION
Bill Clinton
PERSON
New York City
LOCATION
Barack Obama
PERSON
Michael Cohen
PERSON
Alfredo Rodriguez
PERSON
Supreme Court
ORGANIZATION
United Kingdom
LOCATION
Atlanta
LOCATION
Philadelphia
LOCATION
Eric Holder
PERSON
U.S. Treasury
ORGANIZATION
Lebanon
LOCATION
Houston
LOCATIONSecond Circuit
ORGANIZATION
Yemen
LOCATION
Frankfurt
LOCATIONHaley Robson
PERSON
Philippines
LOCATION
Hosni Mubarak
PERSON