مقتطفات من الدعوى المقامة في المحاكم الامريكية ضد المصالح السعودية

المؤشر · 19-08-2002, 01:17 PM

http://news.findlaw.com/cnn/docs/ter...ba81502cmp.pdf

قائمة المدعى عليهم :

-37-
AL BARAKA INVESTMENT AND
DEVELOPMENT CORPORATION, a/k/a AL
BARAKA BANK, a/k/a DALLAH ALBARAKA
GROUP, LLC
NATIONAL COMMERCIAL BANK
FAISAL ISLAMIC BANK
AL RAJHI BANKING AND INVESTMENT,
a/k/a AL RAJHI BANK
AL BARAKAAT EXCHANGE LLC, a/k/a AL-
BARAKAAT BANK
DAR AL MAAL AL ISLAMI
AL SHAMAL ISLAMIC BANK, a/k/a SHAMEL
BANK, a/k/a BANK EL SHAMAR
INTERNATIONAL ISLAMIC RELIEF
ORGANIZATION, a/k/a ISLAMIC RELIEF
ORGANIZATION, a/k/a INTERNATIONAL
RELIEF ORGANIZATION, a/k/a SUCCESS
FOUNDATION
SUCCESS FOUNDATION, INC.
MOHAMED S. OMEISH
ABDURAHMAN ALAMOUDI
KHALED NOURI
SULAIMAN AL-ALI
ABDULLAH M. AL-MAHDI
TAREQ M. AL-SWAIDAN
ABDUL AL-MOSLAH
SALAH BADAHDH
ABDULLAH BIN SALEH AL OBAID
HASSAN A.A. BAHFZALLAH
M. YAQUB MIRZA
SANABEL AL KHEER, INC., a/k/a THE SANABELL,
INC., a/k/a SANABEL AL KHAIR, a/k/a
SANABIL AL-KHAIR
MUSLIM WORLD LEAGUE, a/k/a RABITA ALALAM
AL-ISLAMI, a/k/a ISLAMIC WORLD
LEAGUE
MUSLIM WORLD LEAGUE OFFICES
ABDULLAH BIN SALEH AL-OBAID
HASSAN A.A. BAHAFZALLAH
YAQUB M. MIRZA
SAAR FOUNDATION, a/k/a SAAR NETWORK
ABU SULAYMAN
AHMED TOTONJI
HISHAM AL-TALIB
IQBAL YUNUS
JAMAL BARZINJI
M. OMAR ASHRAF
MOHAMMED JAGHLIT
MUHAMMAD ASHRAF
TAHA JABER AL-ALWANI
TARIK HAMDI
YAQUB MIRZA
SHERIF SEDKY
AFRICAN MUSLIM AGENCY
ARADI, INC.
GROVE CORPORATE, INC.
HERITAGE EDUCATION TRUST
INTERNATIONAL INSTITUTE OF
ISLAMIC THOUGHT
MAR-JAC INVESTMENTS, INC.
MAR-JAC POULTRY, INC.
MENA CORPORATION
RESTON INVESTMENTS, INC.
SAAR INTERNATIONAL
SAFA TRUST
STERLING CHARITABLE GIFT FUND
STERLING MANAGEMENT GROUP, INC.
YORK FOUNDATION
RABITA TRUST
AL-HARAMAIN ISLAMIC FOUNDATION,
INC., A/K/A AL-HARAMAIN ISLAMIC
FOUNDATION, a/k/a ISLAMIC AL-HARAMAIN
AL HARAMAIN FOUNDATION
AL HARAMAIN ISLAMIC FOUNDATION,
INC.
AQEEL ABDUL-AZEEL AL-AQEEL
MANSOUR AL-KADI
SOLIMAN H.S. AL-BUTHE
PEROUZ SEDA GHATY
BENEVOLENCE INTERNATIONAL
FOUNDATION, a/k/a AL BIR AL DAWALIA,
a/k/a AL BIR SOCIETY ORGANIZATION
BENEVOLENCE INTERNATIONAL
FOUNDATION – USA
BENEVOLENCE INTERNATIONAL
FOUNDATION – CANADA
SYED SULEMAN AHMER
ENAAM MAHMOUD ARNAOUT a/k/a
ABDEL SAMIA a/k/a ABU MAHMOUD
MAZIN M.H. BAHARETH
SHAHIR ABDULRAOOF BATTERJEE
ZAHIR H. KAZMI
MUZAFFAR KHAN
SOLIMAN J. KHUDEIRA
JAMAL NYRABEH
WORLD ASSEMBLY OF MUSLIM YOUTH,
a/k/a WAMY INTERNATIONAL, INC., WORLD
ASSOCIATION FOR MUSLIM YOUTH
WAMY INTERNATIONAL, INC.
ABDULLAH BIN LADEN
IBRAHIM S. ABDULLAH
MOHAMMAD BIN FARIS
DR. MAHMOUD DAKHIL
OSAMA BIN LADEN
SAUDI BIN LADEN GROUP, a/k/a BIN LADEN
CORPORATION
TARIK BIN LADEN
KHALID BIN SALIM BIN MAHFOUZ
ABDULRAHMAN BIN KHALID BIN
MAHFOUZ
SALEH ABDULLAH KAMEL
MOHAMMED AL FAISAL AL SAUD
TURKI AL FAISAL AL SAUD
SULTAN BIN ABDUL AZIZ AL SAUD
SULAIMAN BIN ABDUL AZIZ AL RAJHI
SALEH ABDUL AZIZ AL RAJHI
ABDULLAH SULAIMAN AL-RAJHI
KHALID SULAIMAN AL-RAJHI
YASSIN ABDULLAH AL KADI
MOHAMMAD JAMAL AL KHALIFA
ADEL ABDUL JALIL BATTERJEE
AQUEEL AL-AQUEEL
ABDULLAH BIN SALEH AL OBAID
ABDUL RAHMAN AL SWAILEM
WA’EL HAMZA JALAIDAN
ABDULLAH OMAR NASEEF
THE REPUBLIC OF SUDAN,

يتبع بعد الغداء ان شاء الله

المؤشر · 19-08-2002, 01:34 PM

-199-
Al-Rajhi Banking and Investment Corporation
947. Officially founded in 1987, Defendant al-Rajhi Banking & Investment
Corporation, a/k/a al-Rajhi Bank, has a network of nearly 400 branch offices throughout Saudi
Arabia and manages seventeen subsidiaries across the world. Defendant Sulaiman Abdulaziz al-
Rajhi is the Managing Director of al-Rajhi Banking & Investment Corporation and Defendant
Saleh Abdulaziz al-Rajhi is the Chairman.
948. The al-Rajhi Banking & Investment Corporation is the primary bank for a number
of charities that serve as al Qaeda front groups. Al-Haramain Islamic Foundation, the Muslim
World League, and the International Islamic Relief Organization all funnel terrorism financing
and support through the al-Rajhi banking system. One of the hijackers in the September 11th
attack, Abdulaziz al-Omari who was aboard American Airlines Flight 11, held an account with
al-Rajhi Banking & Investment Corporation.
949. Defendant Sulaiman Abdul Aziz al-Rajhi has a history of financially supporting al
Qaeda terrorists. Sulaiman Abdul Aziz al-Rajhi managed the National Commercial Bank budget
of the Saudi Joint Relief Committee (SJRC). The al-Rajhi family is the primary financier of the
SAAR Foundation Network and, as such, is implicated by the SAAR Network raids for its ties to
terrorism and Osama bin Laden. Saleh al-Rajhi has been closely linked to Osama bin Laden’s
personal secretary, Wadih el-Hage. When the Kenyan house of Osama bin Laden’s personal
secretary, Wadih el-Hage, was raided in 1997, information regarding Saleh al-Rajhi was
discovered. Wadih el-Hage was convicted for the 1998 United States Embassies bombings in
Kenya and Tanzania.
950. Co-conspirators, aiders and abettors of the al-Rajhi family include defendants:
Sulaiman Abdul Aziz al-Rajhi, Saleh al-Rajhi, Abdullah Sulaiman al-Rajhi, and Khalid Sulaiman
al-Rajhi, all of these Defendants do business in and have a significant business presence in the
United States through al-Watania Poultry, one of the World’s largest poultry businesses, and
through Defendants Mar-Jac Poultry, Inc., Mar-Jac Investments, Inc. and Piedmont Poultry in
the United States.

المؤشر · 19-08-2002, 01:37 PM

-200-
National Commercial Bank
951. The Saudi National Commercial Bank (or “NCB”) was founded in 1950 by Salim
bin Mahfouz. The Jeddah based bank is now the first commercial bank of Saudi Arabia, with
profits of $613 million and assets of $26.5 billion in 2001. After Salim’s death in 1986, his son
Khalid bin Mahfouz became President and CEO of the Saudi National Commercial Bank until
1999, and its principal shareholder with control over more than 50% of the bank’s capital. The
NCB has several wholly-owned subsidiaries, including SNCB Corporate Finance Ltd. in
London, SNCB Securities Ltd. in London, and SNCB Securities Ltd. in New York City.
952. The National Commercial Bank was involved between 1986 and 1990 in the
fraudulent schemes and practices of the Bank of Credit and Commerce International (or “BCCI”)
after NCB Chairman Khalid bin Salim bin Mahfouz became Chief Operating Officer and major
shareholder of BCCI. A 1992 United States Senate report on the BCCI affair detailed the role
played by the National Commercial Bank in hiding assets and in the cover-up and obstruction of
the Senate investigation. The National Commercial Bank was used by Osama bin Laden and al
Qaeda as a financial arm. The NCB was operated as a financial conduit for Osama bin Laden’s
operations. As a former CIA counter-terrorism expert explained:
How does the al Qaeda organization fund its worldwide network of cells
and affiliated groups? Several businessmen in Saudi Arabia and in the
Gulf contribute monies. Much of the money is paid as ‘protection’ to
avoid having the enterprises run by these men attacked. There is little
doubt that a financial conduit to Bin Laden was handled through the
National Commercial Bank, until the Saudi government finally arrested a
number of persons and closed down the channel. It was evident that
several wealthy Saudis were funneling contributions to Bin Laden through
this mechanism. Now, it appears, that these wealthy individuals are
-201-
siphoning off funds from their worldwide enterprises in creative and
imaginative ways.
953. Defendant Khalid bin Salim bin Mahfouz was born in Hadramaut, Yemen, on
September 12, 1928, Khalid bin Salim bin Mahfouz is the son of Salim bin Mahfouz, who
emigrated in Saudi Arabia in or about 1930. His father founded in 1950 the first commercial
bank of Saudi Arabia, the National Commercial Bank (NCB), based in Jeddah. The National
Commercial Bank is today kingdom’s largest bank.
954. The bin Mahfouz family businesses are organized through a series of holding
companies, including a conglomerate, Saudi Economic and Development Company LLC
(Sedco), founded in 1976 and based in Jeddah, and a petroleum company, Nimir Petroleum,
chaired by Khalid bin Mahfouz’s son.
955. Between 1986 and 1990, Khalid bin Salim bin Mahfouz was Chief Operating
Officer of the Bank of Credit and Commerce International (BCCI). After several fraudulent
practices were discovered, Khalid bin Salim bin Mahfouz was indicted on July 1, 1992 on
charges of participation in a Scheme to Defraud in the First Degree in violation of New York
Penal Law § 190.65, in connection with certain of defendant's acts and omissions relative to
BCCI Holdings and certain related entities. The indictment alleges a series of misrepresentations,
sham loans, and fraudulent conduct in failing to disclose the status of defendant's interest in
BCCI.
956. Under Khalid bin Salim bin Mahfouz, the BCCI was also implicated in supporting
terrorism, as reported by the United States Senate.
In the course of targeting BCCI for laundering drug money, the CIA
learned of BCCI's involvement in manipulating certain financial markets,
in arms trafficking, and in supporting international terrorism, including
handling the finances of Sabri al-Bannah or Abu Nidal, and his terrorist
organization.
-202-
957. The 1992 Senate investigative Report detailed the initial involvement of the BCCI
in terrorism financial support.
BCCI's support of terrorism and arms trafficking developed out of several
factors. First, as a principal financial institution for a number of Gulf
sheikhdoms, with branches all over the world, it was a logical choice for
terrorist organizations, who received payment at BCCI-London and other
branches directly from Gulf-state patrons, and then transferred those funds
wherever they wished without apparent scrutiny. Secondly, BCCI's
flexibility regarding the falsification of documentation was helpful for
such activities. Finally, to the extent that pragmatic considerations were
not sufficient of themselves to recommend BCCI, the bank's pan-third
world and pro-Islam ideology would have recommended it to Arab
terrorist groups.
958. After Salim bin Mahfouz’s death in 1986, Khalid bin Salim bin Mahfouz became
President and CEO of the Saudi National Commercial Bank until 1999 and its principal
shareholder with control over more than 50% of the bank’s capital.
959. A bank audit of the National Commercial Bank conducted in 1998 revealed that
over a 10 year period $74 million were funneled by its Zakat Committee to the International
Islamic Relief Organization, headed by Osama bin Laden’s brother-in-law.
960. The NCB audit report also stressed various irregularities due to “unreported
expenses and loans.” It states that “without knowledge of the Zakat Committee, NCB Directors
established over the years credit and loans facilities for several charitable organizations, along
with banking facilities that were not reviewed by the Committee.” Direct donations were
“received through those facilities to the Red Crescent Saudi Committee, International Islamic
Relief Organization and Muwafaq Foundation.”
961. The NCB audit report points out a $3 million transfer to Blessed Relief
Foundation, a supporter of Osama bin Laden founded by Khalid bin Salim bin Mahfouz. Khalid
bin Salim bin Mahfouz was dismissed from the NCB in 1999 soon after the bank’s audit report
and placed under arrest in Taif. Former CIA Director James Woolsey testified before the Senate
Judiciary Committee that along with the “financial ties” to Osama bin Laden, Khalid bin Salim
bin Mahfouz was Osama bin Laden’s brother-in-law by his marriage to bin Mahfouz’s sister
Kaleda. Khalid bin Mahfouz set up various charity organizations around the world since 1991.
Every of these foundations was linked to al Qaeda and involved in the financing of Osama bin
Laden operations.

19-08-2002, 01:17 PM	#1
المؤشر محلل اسهم تاريخ التسجيل: May 2002 المشاركات: 802	مقتطفات من الدعوى المقامة في المحاكم الامريكية ضد المصالح السعودية http://news.findlaw.com/cnn/docs/ter...ba81502cmp.pdf قائمة المدعى عليهم : -37- AL BARAKA INVESTMENT AND DEVELOPMENT CORPORATION, a/k/a AL BARAKA BANK, a/k/a DALLAH ALBARAKA GROUP, LLC NATIONAL COMMERCIAL BANK FAISAL ISLAMIC BANK AL RAJHI BANKING AND INVESTMENT, a/k/a AL RAJHI BANK AL BARAKAAT EXCHANGE LLC, a/k/a AL- BARAKAAT BANK DAR AL MAAL AL ISLAMI AL SHAMAL ISLAMIC BANK, a/k/a SHAMEL BANK, a/k/a BANK EL SHAMAR INTERNATIONAL ISLAMIC RELIEF ORGANIZATION, a/k/a ISLAMIC RELIEF ORGANIZATION, a/k/a INTERNATIONAL RELIEF ORGANIZATION, a/k/a SUCCESS FOUNDATION SUCCESS FOUNDATION, INC. MOHAMED S. OMEISH ABDURAHMAN ALAMOUDI KHALED NOURI SULAIMAN AL-ALI ABDULLAH M. AL-MAHDI TAREQ M. AL-SWAIDAN ABDUL AL-MOSLAH SALAH BADAHDH ABDULLAH BIN SALEH AL OBAID HASSAN A.A. BAHFZALLAH M. YAQUB MIRZA SANABEL AL KHEER, INC., a/k/a THE SANABELL, INC., a/k/a SANABEL AL KHAIR, a/k/a SANABIL AL-KHAIR MUSLIM WORLD LEAGUE, a/k/a RABITA ALALAM AL-ISLAMI, a/k/a ISLAMIC WORLD LEAGUE MUSLIM WORLD LEAGUE OFFICES ABDULLAH BIN SALEH AL-OBAID HASSAN A.A. BAHAFZALLAH YAQUB M. MIRZA SAAR FOUNDATION, a/k/a SAAR NETWORK ABU SULAYMAN AHMED TOTONJI HISHAM AL-TALIB IQBAL YUNUS JAMAL BARZINJI M. OMAR ASHRAF MOHAMMED JAGHLIT MUHAMMAD ASHRAF TAHA JABER AL-ALWANI TARIK HAMDI YAQUB MIRZA SHERIF SEDKY AFRICAN MUSLIM AGENCY ARADI, INC. GROVE CORPORATE, INC. HERITAGE EDUCATION TRUST INTERNATIONAL INSTITUTE OF ISLAMIC THOUGHT MAR-JAC INVESTMENTS, INC. MAR-JAC POULTRY, INC. MENA CORPORATION RESTON INVESTMENTS, INC. SAAR INTERNATIONAL SAFA TRUST STERLING CHARITABLE GIFT FUND STERLING MANAGEMENT GROUP, INC. YORK FOUNDATION RABITA TRUST AL-HARAMAIN ISLAMIC FOUNDATION, INC., A/K/A AL-HARAMAIN ISLAMIC FOUNDATION, a/k/a ISLAMIC AL-HARAMAIN AL HARAMAIN FOUNDATION AL HARAMAIN ISLAMIC FOUNDATION, INC. AQEEL ABDUL-AZEEL AL-AQEEL MANSOUR AL-KADI SOLIMAN H.S. AL-BUTHE PEROUZ SEDA GHATY BENEVOLENCE INTERNATIONAL FOUNDATION, a/k/a AL BIR AL DAWALIA, a/k/a AL BIR SOCIETY ORGANIZATION BENEVOLENCE INTERNATIONAL FOUNDATION – USA BENEVOLENCE INTERNATIONAL FOUNDATION – CANADA SYED SULEMAN AHMER ENAAM MAHMOUD ARNAOUT a/k/a ABDEL SAMIA a/k/a ABU MAHMOUD MAZIN M.H. BAHARETH SHAHIR ABDULRAOOF BATTERJEE ZAHIR H. KAZMI MUZAFFAR KHAN SOLIMAN J. KHUDEIRA JAMAL NYRABEH WORLD ASSEMBLY OF MUSLIM YOUTH, a/k/a WAMY INTERNATIONAL, INC., WORLD ASSOCIATION FOR MUSLIM YOUTH WAMY INTERNATIONAL, INC. ABDULLAH BIN LADEN IBRAHIM S. ABDULLAH MOHAMMAD BIN FARIS DR. MAHMOUD DAKHIL OSAMA BIN LADEN SAUDI BIN LADEN GROUP, a/k/a BIN LADEN CORPORATION TARIK BIN LADEN KHALID BIN SALIM BIN MAHFOUZ ABDULRAHMAN BIN KHALID BIN MAHFOUZ SALEH ABDULLAH KAMEL MOHAMMED AL FAISAL AL SAUD TURKI AL FAISAL AL SAUD SULTAN BIN ABDUL AZIZ AL SAUD SULAIMAN BIN ABDUL AZIZ AL RAJHI SALEH ABDUL AZIZ AL RAJHI ABDULLAH SULAIMAN AL-RAJHI KHALID SULAIMAN AL-RAJHI YASSIN ABDULLAH AL KADI MOHAMMAD JAMAL AL KHALIFA ADEL ABDUL JALIL BATTERJEE AQUEEL AL-AQUEEL ABDULLAH BIN SALEH AL OBAID ABDUL RAHMAN AL SWAILEM WA’EL HAMZA JALAIDAN ABDULLAH OMAR NASEEF THE REPUBLIC OF SUDAN, يتبع بعد الغداء ان شاء الله التعديل الأخير تم بواسطة المؤشر ; 19-08-2002 الساعة 01:40 PM

19-08-2002, 01:34 PM	#2
المؤشر محلل اسهم تاريخ التسجيل: May 2002 المشاركات: 802	بنك الراجحي -199- Al-Rajhi Banking and Investment Corporation 947. Officially founded in 1987, Defendant al-Rajhi Banking & Investment Corporation, a/k/a al-Rajhi Bank, has a network of nearly 400 branch offices throughout Saudi Arabia and manages seventeen subsidiaries across the world. Defendant Sulaiman Abdulaziz al- Rajhi is the Managing Director of al-Rajhi Banking & Investment Corporation and Defendant Saleh Abdulaziz al-Rajhi is the Chairman. 948. The al-Rajhi Banking & Investment Corporation is the primary bank for a number of charities that serve as al Qaeda front groups. Al-Haramain Islamic Foundation, the Muslim World League, and the International Islamic Relief Organization all funnel terrorism financing and support through the al-Rajhi banking system. One of the hijackers in the September 11th attack, Abdulaziz al-Omari who was aboard American Airlines Flight 11, held an account with al-Rajhi Banking & Investment Corporation. 949. Defendant Sulaiman Abdul Aziz al-Rajhi has a history of financially supporting al Qaeda terrorists. Sulaiman Abdul Aziz al-Rajhi managed the National Commercial Bank budget of the Saudi Joint Relief Committee (SJRC). The al-Rajhi family is the primary financier of the SAAR Foundation Network and, as such, is implicated by the SAAR Network raids for its ties to terrorism and Osama bin Laden. Saleh al-Rajhi has been closely linked to Osama bin Laden’s personal secretary, Wadih el-Hage. When the Kenyan house of Osama bin Laden’s personal secretary, Wadih el-Hage, was raided in 1997, information regarding Saleh al-Rajhi was discovered. Wadih el-Hage was convicted for the 1998 United States Embassies bombings in Kenya and Tanzania. 950. Co-conspirators, aiders and abettors of the al-Rajhi family include defendants: Sulaiman Abdul Aziz al-Rajhi, Saleh al-Rajhi, Abdullah Sulaiman al-Rajhi, and Khalid Sulaiman al-Rajhi, all of these Defendants do business in and have a significant business presence in the United States through al-Watania Poultry, one of the World’s largest poultry businesses, and through Defendants Mar-Jac Poultry, Inc., Mar-Jac Investments, Inc. and Piedmont Poultry in the United States.

19-08-2002, 01:37 PM	#3
المؤشر محلل اسهم تاريخ التسجيل: May 2002 المشاركات: 802	البنك الاهلى التجارى -200- National Commercial Bank 951. The Saudi National Commercial Bank (or “NCB”) was founded in 1950 by Salim bin Mahfouz. The Jeddah based bank is now the first commercial bank of Saudi Arabia, with profits of $613 million and assets of $26.5 billion in 2001. After Salim’s death in 1986, his son Khalid bin Mahfouz became President and CEO of the Saudi National Commercial Bank until 1999, and its principal shareholder with control over more than 50% of the bank’s capital. The NCB has several wholly-owned subsidiaries, including SNCB Corporate Finance Ltd. in London, SNCB Securities Ltd. in London, and SNCB Securities Ltd. in New York City. 952. The National Commercial Bank was involved between 1986 and 1990 in the fraudulent schemes and practices of the Bank of Credit and Commerce International (or “BCCI”) after NCB Chairman Khalid bin Salim bin Mahfouz became Chief Operating Officer and major shareholder of BCCI. A 1992 United States Senate report on the BCCI affair detailed the role played by the National Commercial Bank in hiding assets and in the cover-up and obstruction of the Senate investigation. The National Commercial Bank was used by Osama bin Laden and al Qaeda as a financial arm. The NCB was operated as a financial conduit for Osama bin Laden’s operations. As a former CIA counter-terrorism expert explained: How does the al Qaeda organization fund its worldwide network of cells and affiliated groups? Several businessmen in Saudi Arabia and in the Gulf contribute monies. Much of the money is paid as ‘protection’ to avoid having the enterprises run by these men attacked. There is little doubt that a financial conduit to Bin Laden was handled through the National Commercial Bank, until the Saudi government finally arrested a number of persons and closed down the channel. It was evident that several wealthy Saudis were funneling contributions to Bin Laden through this mechanism. Now, it appears, that these wealthy individuals are -201- siphoning off funds from their worldwide enterprises in creative and imaginative ways. 953. Defendant Khalid bin Salim bin Mahfouz was born in Hadramaut, Yemen, on September 12, 1928, Khalid bin Salim bin Mahfouz is the son of Salim bin Mahfouz, who emigrated in Saudi Arabia in or about 1930. His father founded in 1950 the first commercial bank of Saudi Arabia, the National Commercial Bank (NCB), based in Jeddah. The National Commercial Bank is today kingdom’s largest bank. 954. The bin Mahfouz family businesses are organized through a series of holding companies, including a conglomerate, Saudi Economic and Development Company LLC (Sedco), founded in 1976 and based in Jeddah, and a petroleum company, Nimir Petroleum, chaired by Khalid bin Mahfouz’s son. 955. Between 1986 and 1990, Khalid bin Salim bin Mahfouz was Chief Operating Officer of the Bank of Credit and Commerce International (BCCI). After several fraudulent practices were discovered, Khalid bin Salim bin Mahfouz was indicted on July 1, 1992 on charges of participation in a Scheme to Defraud in the First Degree in violation of New York Penal Law § 190.65, in connection with certain of defendant's acts and omissions relative to BCCI Holdings and certain related entities. The indictment alleges a series of misrepresentations, sham loans, and fraudulent conduct in failing to disclose the status of defendant's interest in BCCI. 956. Under Khalid bin Salim bin Mahfouz, the BCCI was also implicated in supporting terrorism, as reported by the United States Senate. In the course of targeting BCCI for laundering drug money, the CIA learned of BCCI's involvement in manipulating certain financial markets, in arms trafficking, and in supporting international terrorism, including handling the finances of Sabri al-Bannah or Abu Nidal, and his terrorist organization. -202- 957. The 1992 Senate investigative Report detailed the initial involvement of the BCCI in terrorism financial support. BCCI's support of terrorism and arms trafficking developed out of several factors. First, as a principal financial institution for a number of Gulf sheikhdoms, with branches all over the world, it was a logical choice for terrorist organizations, who received payment at BCCI-London and other branches directly from Gulf-state patrons, and then transferred those funds wherever they wished without apparent scrutiny. Secondly, BCCI's flexibility regarding the falsification of documentation was helpful for such activities. Finally, to the extent that pragmatic considerations were not sufficient of themselves to recommend BCCI, the bank's pan-third world and pro-Islam ideology would have recommended it to Arab terrorist groups. 958. After Salim bin Mahfouz’s death in 1986, Khalid bin Salim bin Mahfouz became President and CEO of the Saudi National Commercial Bank until 1999 and its principal shareholder with control over more than 50% of the bank’s capital. 959. A bank audit of the National Commercial Bank conducted in 1998 revealed that over a 10 year period $74 million were funneled by its Zakat Committee to the International Islamic Relief Organization, headed by Osama bin Laden’s brother-in-law. 960. The NCB audit report also stressed various irregularities due to “unreported expenses and loans.” It states that “without knowledge of the Zakat Committee, NCB Directors established over the years credit and loans facilities for several charitable organizations, along with banking facilities that were not reviewed by the Committee.” Direct donations were “received through those facilities to the Red Crescent Saudi Committee, International Islamic Relief Organization and Muwafaq Foundation.” 961. The NCB audit report points out a $3 million transfer to Blessed Relief Foundation, a supporter of Osama bin Laden founded by Khalid bin Salim bin Mahfouz. Khalid bin Salim bin Mahfouz was dismissed from the NCB in 1999 soon after the bank’s audit report and placed under arrest in Taif. Former CIA Director James Woolsey testified before the Senate Judiciary Committee that along with the “financial ties” to Osama bin Laden, Khalid bin Salim bin Mahfouz was Osama bin Laden’s brother-in-law by his marriage to bin Mahfouz’s sister Kaleda. Khalid bin Mahfouz set up various charity organizations around the world since 1991. Every of these foundations was linked to al Qaeda and involved in the financing of Osama bin Laden operations.