tt Complaint 1324. The Mohammed Bin Laden Organization is allegedly a wholly-owned subsidiary of SBG and its board members include defen- dants Bakr, Tariq, and Omar Binladin. Ashton Complaint 1556; Burnett Com- plaint 91325. Khalifa listed the Mo- hammed Bin Laden Organization address on his visa applic

6 Jameel, and Kamel, along with Khalid bin Mahfouiz and Suleiman al Rajhi, are identified as primary al-Qaeda financiers in the Golden Chain.” Bakr, Tariq, Omar, and Yeslam bin Laden are Osama’s half-brothers. Bakr, Tariq, and Omar are alleged to have used their positions within the Saudi Binladin Group