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

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

, 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

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

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