f charities that serve as al Qaeda front groups,” including Al Haramain, MWL, WAMY, SJRC, and IIRO. Burnett Complaint 185; Rule 12(e) Statement 131. “Al Rajhi continues to maintain Al Haramain’s accounts despite Al Haramain’s designation on March 11, 2002 as terrorist organizations by both the United States

¥ 333.) It was incorporated in Virginia in 1983 and dissolved in December 2000. (Burnett Compl. § 261; Ashton Compl. J 333.) Its largest donor is the al Rajhi family of Saudi Arabia. (Burnett Compl. § 261; Ashton Compl. § 333.) The complaints claim that over one hundred “affiliated organizations” are regis

an Khaled bin Mahfouz and Al Rajhi Bank Managing Director Suleiman al Rajhi,*' both of *52 whom have direct ties to bin Laden.** Both bin Mahfouz and al Rajhi are identified as primary al-Qaeda sponsors on the “Golden Chain,” a document discovered during a 2002 raid of the Bosnian offices of Benevolence Int