a used NCB as "a financial arm, oper- ating as a financial conduit for [their] oper- ations." Ashton Complaint 1564; Burnett Complaint 189. In 1986, Khalid bin Mah- fouz became NCB's President and CEO and remained so until 1999. Ashton Com- plaint 11563; Burnett Complaint 1188. Also in 1986, Khalid bin Mahfouz