JOHNSON, CLIFTON DC PAGE 02

12/21/2001 13:« 2023373462

JOHNSON a CLIFTON. L.L.P.

ATTORNEYS AT LAW

THE WATCBCATC OFFICE BUILDING! ainMlMKHAj,; OFFICE

SUJTI aoa SUITE IOS

Z*OO VIRGINIA, AVEHUtt N.W, 738 SHADES CHEEK rnnnv*M.t

^ROBERT W. JOHNSON II
WA9H1N&TON. D.C. IOO37-IB0S DINMINCHAM, AL3B1QO-4<I33
TEL; {2OI1 317-CUaa THU (*OC> /)70-9»0fl
F»XI [Znai M 7 J J » I F**! 11O9) mO-VJno

December 21,2001
fit.1 - /re ^ 5
JBV EAHG5 PELWEHLY

1L KicSwtd Newccsnb
Pcfi
Director
Office of Fcsriga Assets Control
Department of the Treasury
Treastiry Annex
Pennsylvania Avenue and Madison Place, N.W.
Washington, DC 20220

Re: Yaasin Abdullah Kadi

D ear Mr. Newcamb:

I am writing on behalf of Yassin Abdullah. Kadi to provide the Office of Foreign

A3sct3 Control (OFAC) with certain information to demonstrate that Mr. Radi has DO
connection whatsoever to terrorist activities,11

Enclosed, is Mr. Kadi's Witness Statement of 17 December 2001 with accompanying

exhibits. These materials were; submitted to HM Treasury on 18 December 2001 in
cormcctioD with legal proceedings initiated by Mr, Kadi in the United Kingdom against HM
Treasury.2 The Witness Statement was also submitted in support of Mr. Kadi's Application
in the European Court of Justice under Article 230 of the EC Treatyfora declaration that
Commission Regulation (EC) No. 20622001 of 19 October 2001 and Council Regulation
(EC) No. 467/2001 of 6 March 2001, are, inso&r as they relate to the Applicant void.

For completeness also enclosed is a copy of the Statement of HM Treasury officiaJ

Joseph Halligantowhich Mr. Kadi has replied.

1
On Pectmter 13,2001, OFAC issued a specific license. License No. SDGT-8, {Wroiittfng our firm, inter alia, to
represent Mr. K*di bsforo OFAC and other U.S. government agencies and courts In connection with Mr. KitJi's
efforts ID obtain tha release of assets blacked at the direction of OFAC andtohave his name removed from OFAC's
Hit of Specially Designated Global Tarrrarisu.
:
Yassin Abdullkb Kadi, Claimant and HM Treaamy, Defendant, to Tho High Court Of Justice, Queen's Bsnch
Division, Administrative Court, In The Matter Of Att Application For Judicial fosview And )n The Matter QlAn
Aptiflmiton Under The Tqroriara (United Nations Measures') Order 2001 And In The Mawr of YBBSI'O Abdullah
Kadi. CO/4528A31 andCO/4532/Dl,

003809
 1^.21/2801 13:49 20233/'d^b* JUHNSUN, U L i n u n UL, r A U t H ,

The enclosed video exhibit, "MUWAJFAQ relief lorries in joint operation with
W UNKCRT, is in European format, the original formal in which it was submitted as en exhibit
to Mr. Kadi's Witness Statement A copy in U.S. format will be submitted to OFAC by
separate cover.

Mr. Kadi's Witness Statement is a detailed rebuttal of the allegations made against
him in the United Kingdom, as set out in information provided by the U.S. Treasury
Department to H M Treasury. Its hia Witness Stafcameiffit Mr. Ksdi refutes a!I ftbe
allegations in detail suad demswcsimtes that at 00 time laps be bad nwy Btn!t or caameesJoji
whatsoever wit& Jerrartsts, p o r isas be supported Osama b i s Laden, AKJ&ida, or
ffisiauajj, or any offeer terrorist faadnvMnal, girtsap or orgEEBiEmtffoa in cny way.

Addntmaal SHbaMiaflSoiiaP to Off AC

We must emphasize tills is only our initial submission to OFAC; we intend to

supplement it in due course with additional information developed by counsel and also with
any information feat may be requested by OFAC during the course of these proceedings As
mentioned in our November 29, 2001 Application for a License, we intend to provide OFAC
with detailed information on Mr. Kadi's business and financial activities, and other
information that may be requested. This will include very detailed information on Mr
Kadi's business.ventures, financial holdings, and charitable activities that vrill demonstrate
conclusively that OFAC made an error in blocking Mr, Kadi's assets and designating him as
a Specially Designated Global Terrorist ("SDGT").

Our approach wiH be as open, caudid and forthright as possible. Mr ICfldi has
approved tills approach, and he is willing to provide OFAC, and other agenda and
departments of the U.S. Government with any and all relevant information that may be
requested, subject to confidentiality concerns, as explained below.

Such information is intended to assist OFAC in making a correct determination

regarding Mr. Kadi. The information that may be provided should assist the U S
Government in its mandate to identify actual terrorists and activities that support them, but
not to sancti^ innocent persons or entities. This is essential because the iafommtJoo use<j
by the D A Government to designate Mr. Kadi u a "SBGT" md to itoeze hh u i e t i k
flawed gfld grossry maccairata.

Mr. Kadi (Vrasin Abdullah Aziz Ud Din Kadi) in a resident of jeddah, Saudi Arabia,
who a evolved in number of Internationa] business and financial ventures. He is a gradual
of AJoiandna UniTOity m Cairo, Egypt, wife a degree in architectural engineering After
g r a d u a t e Mr. Kad. tnuned for three years in architectural and e n e W i ^ J I f c c ^ f c

003810
13/21/2001 13:-19 2923373462 JOHNSON, CLIFTON DC PAGE 04

Skidtnortt Owings & Merrill, one of the' largest and most prestigious architectural firms in the
United Slates.3

In 1980 Mr. Kadi began his business career as Vice President of a company, which
represented American Hospital Supplies in Saudi Arabia Over the past 20 years he has
e)rpanded his business and financial operations successfully to a number of countries,
including the United Stales, Great Britain, Canada, Malaysia, Turkey, Pakistan, Jordan,
Lebanon, Bosnia and Albania. To summarize Mr. Kadi's business ventures, he is a respected
businessman and financier, active in banking; construction; real estate development;
manufacturing; technology; mining; food processing and distribution; healthcare and
Pharmaceuticals; media and broadcasting; and international trade, as well as investing in the
stock market He is also involved in various educational and charitable activities.

Im&QBitmn of Sanctions

On October IS, 2001, a. "Notice of Blocking" was sent to Mr. Kadi informing him
that, pursuant to Executive Order No. 13224 (66 Fed Reg. 4-9079) of September 23, 2001,
"the OfSce of foreign Assets Control.. .added your name to the list of persons who commit,
threaten to commit, or support terrorism (Specially Designated Global Terrorist (SDGT))."
The Notice of Blocking also advised Mr. Kadi of the blocking of certain assets; trie need for
licenses) for various transactions; the applicable penalties; and the procedures for
challenging OFAC's determination. *

At or around the same time, similar measures - which Mr. Kadi is challenging - were
taken against him in various other jurisdictions, including the United Kingdom, Switzerland,
and the European Union.

ImipiSHci on M r . Knoll

The purported blocking of Mr. Kadi's assets and his listing as a "global terrorist"
have had a aerioua adverse impact on Mr, Kadi's reputation, business, and his family, as well
as his health. As st&&& in our November 2? Request far a License, it is frankly difficult to
conceive of a more serious allegation against anyone than designation as a "SDGT'.

3
Mr. JCsdi p^orfcsd with the design group developing the master plan and contract dosumentnrlon of the Mecca
Cumpus of tho King Abdul Aziz University.
•• The notice of Blocking wua ua^t to Mr. Kadi in care of Global Diamoad Rcsourco, Inc G3S faocpxt Strict, Ln
JoIIa, CA 92307-4213.
 12/71/20BI 13: « 2023373,62 J m m CLIfJm DQ

Camfiidte^lafiy Cc?EacMeraC|[QBc
'^P'

It is eKtrancly important to recognize that Mr. Kadi's Witness Statement is a direct

response to information provided to his legal representatives in the United Kingdom pursuant
to court order limiting its use. Such information can only be used in submissions for the
purpose of challenging freezing orders made against Mr. Kadi. The exact terms which auplv
pursuant to a Consent Order, dated 7 December 20di, arc, the following:
u
Thc Claimant [Mr. Kadi] has permission to use the First Statement of Joseph
Halligaa dated 16 November 2001 for the purposes of proceedings challenging freezL
orders made against him in the United States, Switzerland, by the European Union or any
other jurisdiction which has made or may make such onfcrs against him, and for purposes of
making r e p r e s s i o n s to the United Nations with a view to removal of the Claimant's [Mr
Kadi's] name from the UN Taliban Sanctions List"

Since all the information in the enclosed Witness Statement and accompanying
exhibits, and other enclosures to tola letter, including thai in Assistant Secretary HaJlican's
Statanenl, * restricted from disclosure by court order, we respectfully request that OFAC
accord the same treatment to such information ^ d prohibit fe. release to kc public W e
further require thai.«/e be given wriUen notice at least 4S hours in advance if OFAC is
contemplate p ubI lC release of this restricted i r u b ^ o n s o w e can seek clarification^
permission orrerfrcss from an appropriate courts). wanncanon/

We may also ask ifaaz certain information in our submissions, not already protected
from disclosure by court order, be regarded as "business confidential" p u J J ^ to
applicable i^giUations, or otherwise regarded as sensitive and confidential tTprotec such
P
fi-om disclosure to Mr. Kadi's business competitors.

^eagateat for Meeting

ffcause of the drastic effects of the Notice of Blocking and "Sf GT designation on
Mr. Kadi's b^iness and the prejudicial impact on his lift, we would like to a x r a t e T S c S i n "
as soon as possible to discuss this matter. At such meeting we hope OFAcZm^l^of
m y ^ of concern and specify what additionaj i n f o n n X i couW be aubmi^d to d £ r * /
Kadi's name and might prove otberwiac beneficial e m i t t e d to cJear Mr.

I will call your office next week to s e c what time would be convenient for a c t i n g .

Sincerely,

Robert W. Johns^ II
For Yassin
Enclosures Afaduliali Kadi

003812
 !N THE HIGH COURT OF JUSTICE CO/ 452??/ f?1
and Cp/45X2)01
QUEEN'S BENCH DIVISION

ADMINISTRATIVE COURT

IN THE MATTER OF AN APPLICATION FOR JUDICIAL REVIEW

AND IN THE MATTER OF AN APPLICATION UNDER THE TERRORISM (UNITED NATIONS

MEASURES) ORDER 2001

ORDERED TO BE LISTED TOGETHER BY ORDER OF THE HONOURABLE MR JUSTICE

SCOTT BAKER DATED 12 NOVEMBER 2001

AMD IN THE MATTER OF YASSIN ABDULLAH KADJ

YASSIN ABDULLAH KADI

Claimant

-and -

HM TREASURY
Defendant

WITNESS STATEMENT OF YASSIN ABDULLAH KADI DATED 17 DECEMBER 2001

PLUS EXHIBITS

PCR1-160472.1

003813
 IN THE HIGH COURT OF JUSTICE CO/ 4528/ 01
and CO/4532/01
QUEEN'S BENCH DIVISION

ADMINISTRATIVE COURT

. IN THE MATTER OF AM APPLICATION FOR JUDICIAL REVIEW

AND IN THE MATTER OF AN APPLICATION UNDER THE TERRORISM (UNITED NATIONS

MEASURES) ORDER 2001

ORDERED TO BE LISTED TOGETHER BY ORDER OF THE HONOURABLE MR JUSTICE

SCOTT BAKER DATED 12 NOVEMBER 2001

AND IN THE MATTER OF YASSIN ABDULLAH KADI

YASSJN ABDULLAH KADI

Claimant
- and -

HM TREASURY
Defendant

WITNESS STATEMENT OF YASSIN ABDULLAH KADf

i, YASSIN ABDULLAH KADI of Farsi Center, West Tower, 11 th Fioor, Suite 1103. Waly

Af-Ahd Street, Ruwais District, Jeddah 21411, Saudi Arab/a, SAY AS FOLLOWS:-

1. I make this witness statement in support of my application to the High Court for

an order setting aside any direction made by HM Treasury against me on or

about 12 October 2001 and/or In support of my claim for Judicial Review seeking

a Quashing Order In respect of the decision of HM Treasury to direct all UK

financial institutions to freeze my assets. As stated in the Claim Form and Notice

PCR1-159363.3 . -]

003814
 of Application, it is not clear whether HM Treasury has Issued a direction against

me under the relevant legislation and I have been advised to make both of the

applications.

2. There is exhibited to this statement marked "YAK2" a paginated bundle of

documents to which I refer. Page references in this statement are to the

paginated bundle "YAK2". Save where expressly mentioned below, I confirm that

all the facts In this statement are within my own knowledge and belief.

o
3. I was bom in Cairo, Egypt on 23rd February 1955 and graduated in architectural

engineering frorn Alexandria University in Egypt. I am a citizen of Saudi Arabia

and my place of permanent residence is Jeddah although, by reason of my

international business Interests, I often travel abroad including regular trips to the

United Kingdom. I am married and have seven children.

4. I have substantial business interests in a large number of companies fn various

countries, and I also hold positions as the Chairman and Board member of a

number of companies. These companies undertake business in a very wide

range of industries Including international financial services, high-tech hardware

production and development, software development, real estate, construction,

manufacturing and health care. I am well-known within Saudi Arabia as well as In

other parts of the world where I carry on business, and consider that I am a

respected businessman and financier. I have never provided support for

terrorism, financial or otherwise, and I am personally strongly opposed to terrorist

activity In all forms.

PCR1-159363.3

003815
 5. In these circumstances, both I and my family were deeply shocked and disturbed

HP' when on 12 October 2001, without any form of prior notfce to me, HM Treasury

instructed all financial institutions to freeze my assets held in the United Kingdom

(together with the assets of other named persons and organisations). The first

that I heard of this decision was the publication on that day of Press Releases by

HM Treasury and the US Treasury Department (see pages 1-7). The effect of the

UK Press Release is to freeze all my assets and prevent me from doing any form

of business in the UK. To make matters worse, both Press Releases also brand
1
me, in no uncertain terms, as a terrorist or supporter of terrorism. On 15 October

2001 (see pages 8-9), my Solicitors wrote to Sir Andrew Turnbull, Permanent

Secretary to HM Treasury, complaining about the seriously defamatory content of

the UK Press Release and asking that my name be removed from the list, and

that HM Treasury provide to them the information and evidence upon which f was

__ included on the list.

6. On 19 October 2001 (pages 10-11), the Treasury Solicitor responded to this letter

on behalf of HM Treasury and stated (hat I was included on the list "on the basis

of Intelligence information provided to [HM Treasury] that [I had] been involved in

funding terrorism". The letter declined to provide the intelligence information

provided to HM Treasury by the US Treasury Department on the grounds that

such information had been provided In confidence.

7, Against this background, it was only as a result of the Order of Mr Justice Scott

Baker dated 12 November 2001 (page 12) ordering HM Treasury to serve its

evidence by 16 November 2001 that HM Treasury has provided any information

at a(( about the basis for HM Treasury's decision to include me on its list dated 12

October 2001 and why HM Treasury alleges that I have been involved in funding

v PCR1-159383.3 3

003816
 terrorism. That information was supplied in the form of a statement by Joseph

Halligan, assistant secretary at HM Treasury, dated 16 November 2001. In this

statement I shall respond in detail to the allegations made against me in Mr

Halligan's statement.

8. In paragraph 7 of his statement Mr Halligan states that on the morning of 12

October 2001 (the date of publication of HM Treasury's list) Mr Halligan had

passed to him a fax from the US Treasury Department dated 11 October 2001

(which I shall refer to as "the US Treasury Department's fax"), which included

details about me. A copy of this fax appears at pages 13-14. I now respond in

detail to the allegations In the US Treasury Department's fax.

ALLEGATION

"Information on AI-QadI from our long list:

- Aka Shaykh Yassln Abdullah Kadj

• Located In Jeddah, Saudi Arabia

o Heads Saudi-based Muwafaq Foundation

Muwafaq Is a Al-Qaeda front that receives funding from wealthy Saudi

• "* businessmen"

FtESPONSE; '

9. I am Shaykh Yassln Abdullah Kadi, if the Arabic letters or phonetics are

transliterated in this manner. My name has never been spelt Kadj. I am also

located in Jeddah, Saudi Arabia. 1 am a Trustee of the Muwafaq Charitable

Foundation (which I shall refer to In this statement as "Muwafaq"). Contrary to

the allegations in the US Treasury Department's fax, Muwafaq is not, and never

has been, based in Saudi Arabia. It is also totally untrue that "Muwafaq fs an Al-

PCR1-159363.3 4

003817
 Qaeda front that receives funding from wealthy Saudf businessmen*. Muwafaq

has never had any connection to_AI-Qaeda or to any other terrorist individual,

group or organisation whatsoever.

10. it is appropriate that I should now explain some of the background circumstances

to why I and my five fellow Trustees of Muwafaq decided to form Muwafaq.

11. ' Philanthropy is a central tenet of religious practice for devout Muslims, like most

I other faiths. Muwafaq was founded by me and my fellow Trustees as a result of

our concerns at famine, poverty, lack of education and under-development

amongst Muslims in the world. We determined to give some effect to our

concerns by providing relief, education and the means to acquire basic skills to

foster economic development. In this regard Muwafaq was similar to many other

major international charity organisations.

12. It was against this background that Muwafaq was established by Constitution and

Declaration of Trust dated 31 May 1992, copies of which are at pages 15-27. All

) of my fellow Trustees and I were thereby appointed as original members of the

Foundation Council and Trustees of its assets.

13. As will be seen from pages 21-22 the principal objectives and purposes of

Muwafaq are in summary to provide relief to and for any individual suffering as a

result of natural disaster, wars, revolutions, civil unrest of any description and

famine; to provide financial assistance to organisations, institutions, hospitals, •

research centres to improve the standards of education of heafth of the needy; to

provide guidance and education by compiling, printing and distributing books,

PCR1-159383.3 5

003818
 tapes, video tapes, newspapers, magazines and other publications; and other

charitable purposes.

ALLEGATION:

"Blessed Relief Is the English translation"

RESPONSE:

14. Blessed Relief Is the name which has been given to Muwafaq in various

• newspaper articles. Muwafaq has never, however, adopted the name Blessed

Relief as the English transfatlon of its name,

ALLEGATION:

"Chaflq Ayadl claims that Yasln Qadi was his partner In Muwafaq, Germany
and that ha recerved 286,000 Deutsche Mark In a Muwafaq bank account
from Yassln AA Kadi Sarmny Ltd., Istanbul"

RESPONSE:

15. Contrary to the allegations In the US Treasury's Department's fax. Chaflq Ayadi

was never a partner" of mine In Muwafaq, Germany. It is not at all clear to me

' what the US Treasury Department mean when they describe Chaflq Ayadl as my

"partner". He was in fact an employee of Muwafaq, employed as director in

charge of Muwafaq's European activities from 1992 to 1995. During this time, I

transferred substantial sums of money to the account of Muwafaq in Bosnia,

through European correspondent banks, for the charitable objectives of

Muwafaq, specifically to further Muwafaq's charitable objectives and purposes in

Bosnia and Croatia.' Fora limited transitional period while Muwafaq was awaiting

registration in Germany I also transferred sums of money to Chaflq Ayadi's

personal account. I made ail of the foregoing payments which in total probably far

PCRM59363.3 • fi

003819
 exceeded DM286,000, for the sole purpose of the charitable objectives of

Muwafaq, in particular to assist Muslim refugees in and from Croatia or Bosnia

and to provide them with relief and education. Many of these activities were

carried out by Muwafaq in co-operation with the United Nations High Commission

for Refugees (UNHCR) as is evidenced by the video marked "YAK3" to which I

refer showing Muwafaq relief lorries in a joint operation with UNHCR. I also refer

to the still photographs at pages 28-29 of "YAK2" showing the emblems of

UNHCR and Muwafaq appearing side by side on a Muwafaq lorry. All the

• ) foregoing sums were applied exclusively for MuwaFaq's charitable purposes.'At

no time have I or Muwafaq ever provided any material or financial support for any

terrorist Dr similar activities or purposes. Moreover, Muwafag's standing

instructions to all Muwafaq's employees were that they were strictly to adhere to

the laws and regulations of all countries where Muwafaq worked and not to

^- engage Muwafaq In any activities outside the strict charitable purposes laid down

"" in Muwafaq's Constitution and Declaration of Trust.

ALLEGATION:

•[ 1 "Directly tied io bin Laden. In an Interview, bin Laden said, ."The bin-Laden
Establishment's aid covers 13 countries.... This aid comes In particular
from the Human Concern International Society". Bin Laden goes on to list
a number of HCI's branch organisations and Includes iWuwaffaq Society In
Zagreb."

RESPONSE:

16. There is a footnote to the US Treasury Department's fax (page 13) which refers

to an article in "FBIS" dated 31 July 1995 entitled "Islamic Financier Bin Ladfn
5
Interviewed on Sudan, Iran Ties". I shall refer to this as the "FBIS Article", A ^ * * * * ^

PCR1-159363.3

003820
 copy of the FBIS Article appears at pages 30-33 . I believe the initials FBIS stand

for Foreign Broadcast Information Service.

17. Contrary to the allegations in the US Treasury Department's fax:-

17.1 Muwafaq has at no time been a member or branch organisation of Human

Concern International Society.

17.2 The "Muwaffaq Society in Zagreb" referred to in the US Treasury Department's

fax (page 13) is not the name of the Muwafaq Foundation founded by me and

my fellow Trustees. At pages 34-40 are documents relating to Muwafaq's

operation in Bosnia and Croatia in which Muwafaq is referred to as Muwafaq

Foundation or.Fondacjja and nowhere is It referred to as Muwaffaq Society.

Additionally, for the reasons explained below, I have grave doubts as to whether

the so-called interview with bin Laden ever took place.

18. It is clear on the face of the FBIS Article that the alleged interview with bin Laden

lacks any degree of credibility at all. As would be apparent to any critical reader

the so-called interview with bin Laden must be of highly doubtful authenticity for

the following reasons:-

16.1 The "source date" of the FBIS Article is stated as 31 July 1995 and yet it purports

to be based on ah interview with Usamah bin Ladfn published in the Egyptiai

Arabic language publication Rose Al -Yusuf nearly a year later, on 17 June 1996.

PCR1-159363.3

003821
 18 2 T h e FBIS Article alleges that the interviewer Fayizah Sa'd interviewed bin Laden <i j

Vv_iX in London at a "luxury villa in Wembley, North London."

18 3 B y February 1994 bin Laden had already been stripped of his Saudi nationality

a n d w a s a well-known supporter of Islamic terrorist causes. It is highly unlikely

that such a high profile terrorist would have been granted an entry visa a n d

actually visited (he UK. In this regard, HM Treasury has not provided any

information as to the steps it took before Including my name on Its list to

) investigate the authenticity or veracity of this alleged interview and whether, for

e x a m p l e , it made enquiries of the Home Office as to whether any visas were

issued either to bin Laden or the alleged interviewer, Fayizah Sa'd and whether

b i n Laden had actually visited the UK. It appears from the US Treasury

Department's fax that the FBIS is used by the U K and U S Governments as a

source of intelligence information. Any responsible Government Department

+-»>* woufd have assessed the veracity or authenticity of this alleged interview at the

time the FBIS Article first came to their attention.

- i 19. Quite apart from the above, the FBIS Article is inherently Implausible in several

important respects. Bin Ladln Is quoted as saying he was bom In Mecca, Saudi

Arabia and is 44 years old. However according to the Interpol website

(www.intetpal.int) at page 41 bin Laden was bom In Jeddah on 10 March 1957,

and so would have been 38 or at most 39 if the interview took place in 1996 and

• even younger if it had taken place any earlier.

/
20. In the FBIS Artide the interviewer alleges (on page 32) that bin Laden was one of *" c " *

the founders of the Human Concern International Society "with the help of Iranian

LJ PCR1-159363.3

003822
 government and the CIA". The interviewer also quotes bin Laden as saying he is

"on a mission for the US Embassy in London", The notfon that bin Laden has

ever acted for or on behalf of the US Embassy in London is frankly preposterous.

21. In addition to this, if bin Laden had visited London and been interviewed in the

1990s, as has been alleged in the FBIS Article, I would expect-this to have been U

reported by one or more of the leading London-based Arabic language

newspapers. They have not reported on any such visit or interview by Bin Laden.

ALLEGATION:

"Saudi businessman have been transferring millions of doffars to Bin

Laden through Blessed Relief. Saudi businessmen deposited $3 million
from the National Commercial Bank, which was run by Khalid Bin Mahfouz,
Into the accounts of the Blessed Relief and other charftles that served as a
front for bin Laden."

" RESPONSE:

22. According to the footnote to the US Treasury Department's fax (page 13) the

document relied on by the US Treasury Department In relation to these

allegations consists of a newspaper article published In USA Today dated 29

October 1999 entitled "Saudi Money aiding bin Laden" (pages 42-43). Once

again the allegations are totally untrue. Contrary to the allegations in the USA

Today article:-

22.1 Muwafaq has never had any account with the National Commercial Bank (NCB).

In any event, as appears from articles published in the UK and US press (the

Guardian dated 26 September 2001 and the Chicago Tribune dated 28 October

2001 pages 44-51) NCB senior officials have vehemently denied the existence of

I
PCR1-159363.3 10

003823
 any Saudi government audit showing that money had been diverted to Muwafaq

and transferred to Bin Laden and described the allegations as "incorrect, false

and frivolous".

22.2 At no time have either I or Muwafaq ever contributed any funds or otherwise

supported bin Laden or al Qaida. At no time have either I or Muwafaq ever acted

as a conduit or channel for funds being passed to bin Laden or al-Qaida.

22.3 It is totally untrue that Muwafaq was involved In the attempt to assassinate

President Mubarak of Egypt. In this regard the USA Today article repeats

allegations made in 1995 In the newsletter Africa Confidential linking Muwafaq to

the attempted assassination in 1995 of President Mubarak of Egypt J and my

feliow Trustees of Muwafaq were completely vindicated of these allegations In

proceedings for libel which we commenced in 1995 in the High Court in London

against the editor and publisher of Africa Confidential. Those proceedings (which

I shall refer to as "the Africa Confidential Libel Proceedings") were settled by

means of a Consent Order dated 30 May 2001 (pages 52-53) under which Africa

Confidential agreed to pay a substantial sum to me and my fellow Trustees,

undertook never to repeat the allegations complained of and agreed to

participate in an agreed Statement In Open Court (pages 54-56) retracting the

allegation concerning the attempted assassination of President Mubarak of Eqypt

and apologising to me and my fellow Trustees. To reinforce how totally baseless

this allegation is, I would add that earlier in the Africa Confidential Libel

Proceedings, Mr Justice Moses by Order dated 30 June 1997 struck out that part

of Africa Confldential's Defence which sought to contend that Muwafaq was

. linked to the 1995 assassination attempt upon President Mubarak. Moreover in

PCR1-159363.3 ' -] •]

003824
 striking out this part of the Defence Mr Justice Moses refused Africa Confidential

permission to appeal.

ALLEGATION:

"Al-Qadl has a vast financial empire linked to funding terrorist activity:"

Implicated In Hamas funding network.

- Kadi International channelled $820,000 to QLI to acquire a property in

Woodridge, Illinois in 1S91. The complex series of transactions ware
structured In a manner that obscured Kadi's connections with QLI.

._ • Q U provided funding for Hamaa via Mohamad Salah from 1991 through
1993. Salah has residence Fn Chicago and was arrested In February
1993."

RESPONSE:

23. I completely deny that any part of my personal or business Interests anywhere in

the world is linked to "funding terrorist activity". It Is also totally untrue that I am

connected in any manner to any Hamas funding network. In regard to the

property In Woodridge, Illinois there was no "complex series of transactions"

undertaken to "obscure" my connection to QLI (the Quranic Literary Institute).

The- true position is quite the reverse as appears from the background to this
r
' transaction as follows:

24. Between 1979 and 1981 I workBd as a trainee for Skidmore Owings &• Merrill, the

international architectural firm based in Chicago, USA. Whilst living in Chicago I

met Dr Ahmad Zaki Hammad (whom I will refer to as "Dr Zakf) in about 1979. Dr

Zaki was introduced to me by my brother-in-law, who knew Dr Zaki's family. Dr

Zaki is, thus, an old friend of my family.

PCR1-159363.3 -|2

003825
 25. Dr Zaki is an eminent scholar with two postgraduate degrees including a Ph. D in

Islamic Studies from the University of Chicago. He has written numerous books

and papers on the Islamic Faith. From my long association with Dr Zakl I can say

that, to the best of my knowledge, he is not an extremist and he is against all

forms of terrorism. So far as I am aware, Dr Zaki abhors terrorism and violence.

26. In the early 1990's whilst I was visiting Chicago, I visited Dr Zaki. Dr Zaki invited

me to participate financially as a supporter of the QLI, a major charitabfe project

c which he was then establishing. Dr Zaki explained to me that the objects of the

QLi were the translation and interpretation of the meaning of the Quran for

Americans, the English speaking community'generally, and others so that they

could understand Islam. The idea was to make Islam understandable to persons

of other faiths in order to try and bridge the gap of knowledge between Islam and

""X " . other faiths. This would be achieved by presenting the meanfng of Islam's Holy

Book, the Holy Quran, in a cleariy understandable English document, thus

explaining it to English speaking people and furthering understanding between

religions. By way of example QLI has published books entitled "the Opening of

the Quran" and "One God The Everlasting Refuge". For the latter title I wrote a

review which appears on the back cover. Copies of the front and back covers of \fi

these books are at pages 57-60.

27. I agreed to support these charitable purposes of the QLI by extending to the QLI „ „

a loan of $820,000 by way of a "Qard Hassan", which is an Islamic concept ^

essentially equivalent to an interest-free loan in favour of a charitable cause. I

agreed with Dr Zaki and his fellow board members of QLI that the sum of

$820,000 would be applied to the purchase of land and its development as an

PCR1 -159363.3 13

003826
 investment. We agreed that a!! profit and proceeds of the transaction would

accrue for the benefit of QLI's Holy Quran Project. The idea was to make QLI a

self-financing institution as soon as practicable.

28. Pursuant to the "Qard Hassan" I transferred the sum of 3820,000 in July 1991.

Dr Zaki and his fellow board members of QLI gave me the details of the

destination account where this sum was to be sent. The transfer of this sum was

carried out with the utmost transparency from my account at Faisal Finance In

" Geneva, Switzerland into the destination bank account In the USA. Falsa!

Finance is a well-known financial Institution in Switzerland.

29. I also agreed to the request of Dr Zaki and his fellow board members of QLI to

transfer some sums of money to .the account of an individual named Mohamed

Salah who was involved with QLI. They explained that QLI, as a nascent

institution, could not at that time undertake any financial burden resulting from

employing any editors, computer operators or other employees. It needed

money, amongst other things, to pay editors, computer operators and other

personnel to work on the Quranic Project and to purchase equipment for this

project. I agreed to the transfer of certain monies to Mohamed Salah for those

purposes.

30. During my visits to QLI to see Dr Zaki and his fellow QLI board members I met

Mohamed Salah on at the most 2 or 3 occasions. Mohamed Salah In fact

occupied the same building as QLI and I understood that he was involved with

helping QLI, especially Dr Zaki, on the Quran Project. I set out below the money

transfers I mada to Mohamed Salah. Once again these were made from my

PCR1-159363.3 14

003827
 account at Faisal Finance in Geneva, Switzerland. Aside from this, I have never

had any link or connection to Mohamed Salah. Also, until I heard about

Mohamed Saiah's arrest, I was not aware, directly or indirectly, of any activity

that Mohamed Salah had outside the sphere of Islamic Charity in the USA. I

made the following transfers to Mohamed Saiah's account at the express request

of Dr Zaki and his fellow board members of QLI exclusively for the purposes of

QLI's Holy Quran Project:

From Faisal Finance: 3 March 1992 $27,000

Uune 1992 • $30,000

14 Sept 1992 $50,000

31. After Mohamed Salah was arrested In Israel in January 1993 Dr Zakl contacted

me expressing the total shock, disbelief and bewilderment of him and his fe(low_

board members of QLI at the news of the arrest. I too was horrified upon hearing

the news. Until then neither I nor so far as I am aware any of the QLI board had

the slightest Idea that Mohamed Salah was engaged In any such alleged terrorist

activities. On 25 February 1993, immediately upon learning of the news of

Mohamed Safari's arrest, i naturally gave instructions to my bank to stop a wire

transfer to Mohamed Saiah's First Chicago account In the sum of $60,000. Once

again, this transfer was expressly requested by Dr Zaki and the QU board

members for the purposes stated in paragraph 29 above. A copy of my fax

instruction and translation appears at pages 61-62.

PCR1-159363.3 -jg

003828
32. All these transfers and the $820,000 transfer in July 1991 were made with the

utmost transparency to US bank accounts from my account(s) at Faisal Finance

in Geneva, Switzerland. It is highly unlikely that anybody who intended to make

payments supporting Hamas or any other terrorist group would have transferred

them to a person in the USA via the US banking system with such openness and

transparency. It would appear to me that if I had wanted to support Hamas or any

other terrorist group (which I repeat I never have) there are numerous other ways

that goal could have been achieved mare effectively and secretly.

33. I should add for completeness that, In addition to the above, in 1992, at the

express request of Dr Zaki, I transferred sums totalling In the region of $250,000

- $300,000 to Dr Zaki for the charitable purposes of QLI and for his own personal

account.

34. Contrary to the allegations In the US Treasury Department's'fax. my transactions

with QLI were never 'structured in a manner that obscured [my] connection to

QLI". I refer to the Mortgage document dated 31 December 1991 (pages 63-67),

executed by Midland Federal Savings and Loan Association as Trustee

expressly in favour of "Kadi International Corp." (defined as "Lender"), a company

associated with me. This Mortgage document relates to the Woodridge, Illinois

property. The document provides by Clause a (headed "Notices") on page 65 for

any Notice to Midland Federal Savings and Loan Association to be copied to the

QLI.

35. Moreover, attached to the Mortgage document is a Loan Note dated 31

December 1991 (pages 68 to 70) in which Midland Federal Savings and Loan

PCR1-159363.3 ' 16

003829
 Association, as Trustee, promised to pay to the order of Kadi International Corp.

the principal sum of $820,000. This document reflected the "Qard Hassan'. The

Loan Note expressly provided in the first paragraph that no interest shall be

payab/e on the principal amount of $820,000. The Loan Note also expressly

provided (in clause 4, page 69) that any Notices to Midland Federal Savings and

Loan Association were to be copied to QLI.

36. Finally, for completeness, the connection between my company Kadi

International and QLI Is also clearly apparent from the Guarantee (pages 71-72}

attached to the Mortgage. By this document QLI guaranteed tha obligations of

Midland Federal Savings and Loan Association under the terms of the Loan

Note.

37. Thus, contrary to the allegations in the US Treasury Department's fax, the

connection between QLI and Kadi International Corp. Is plainly apparent on the

face of the documents. 1 believe all these documents were prepared by QLfs

legal representatives and J took It for granted that they would deal with all

necessary formalities connected with the transaction including appropriate filing

and registration.

38. Thus, far from "obscuring" [my] connection to QLI, the transaction was structured

openly and transparently, making clear the relationship between the parties and

the involvement of myself, as provider of the funds, and my company Kadi

international Corp as beneficiary of the Loan Note.

O PCR1-159363.3 -J7

003830
 39. HM Treasury rely on an Affidavit of Mr Robert Wright dated 9 June 1998 in

forfeiture proceedings in US v One 1997 E;35 Ford Van et al, US District Court,

Northern District. !llinols98 C 3548. I will refer to this as the "Robert Wright

Affidavit" and the proceedings as "the forfeiture proceedings". In paragraph 34 of

the Robert Wright Affidavit. Mr Wright criticises the fact that the Mortgage

document was not executed until some months after the loan was made. As a

general point I would state that transactions and dealings that would, in the West,

generate a very significant amount of documentation are frequently effected by

Arab parties with a minimum amount of paperwork, particularly where, as was the

case here, the parties are well-known to each other, the whole arrangement is

based on trust and for relfgious charitable purposes. There is nothing mysterious

or sinister in this. It merely reflects a different culture and an alternative tradition

of business practice. From the outset the "Qard Hassan* or loan of $620,000

was made on the basis of trust and good faith between me and Dr Zaki for the

charitable purposes of the QLI which I believed, and still believe, to be a noble

project. There was therefore nothing unusual about my advancing the $820,000

Qard "Hassan without any contemporaneous documentation reflecting this.

40. in 1994, the Woodridge property was sold generating a profit for QLI. Shortly

after this Dr Zak! asked me to turn my charitable loan (the "Qard Hassan") into

what is known in Arabic as a "Waqf" which is another Islamic concept, the closest

analogy to which in Western culture is a religious charitable trust This "Waqf

was to be used for the purchase of premises for QLI. I verbally agreed to this.

41. According to the Robert Wright Affidavit, for the next 4 years, the proceeds of

sale of the Woodridge property remained largely undisturbed in a simple interest

PCR1-159363.3 -\Q

003831
 bearing account of QLI. This is hardly consistent with the notion that the funds

were intended, or needed, to support a terrorist organisation. Moreover, since

QLI had tax exempt status, it was subject to increased scrutiny and detaited

disclosure requirements under Federal and State law in the United States. In

view of this, the proceeds of sale, held for 4 years in QLI's account, would hardly

be suitable for financing terrorism. During this 4 year period, QLI were engaged

in finding suitable premises. Indeed, they had found suitable premises, which

they were preparing to purchase, at the time the forfeiture proceedings started In
N
1998.

42. In 1998. I was told by Dr Zaki of the forfeiture action taken in respect of the

assets of QLI. Without waiving privilege, I obtained advice from Jones, Day,

Reavis & Pogue, a prominent US law firm, on the situation. It must be noted that

I never received formal service of the forfeiture proceedings. Indeed, I

understand the case docket for the forfeiture proceedings has no record of the

US Government formally serving either me or Kadi international Corp. with the

forfeiture proceedings. I now regret that at the time I did not take any steps to

intervene in the forfeiture proceedings, or to have the assets unfrozen and

especially that ] did not challenge at the time the false assertions made in the

Robert Wright Affidavit. '

43. Apart from the specific sums I have mentioned above I made no other payments

to QLI, Dr Zaki or Mohamed Sala'h or to any of the other parties referred to In the

Robert Wright Affidavit, ail of whom are unknown to rne. .

PCR1-159363.3 -]Q

003832
 44. I do not know who Mr Wright is referring to when, in paragraph 35 of tha Robert

Wright Affidavit, he claims that "Kadi International" has "disavowed any

relationship with QLI". Quite clearly, Kadf Internationa! Corp. had a relationship

with QLI, as 1 have outlined above and that relationship was clearly apparent

from the governing documents.. If Mr Wright is relying here on a statement made

by a representative of BMI Inc. then they had no authority to speak on behalf of

Kadi International Corp. Regrettably, the US authorities, and Mr Wright in

particular, did not take any steps towards contacting me before Mr Wright made

the assertions in the Robert Wright Affidavit. Had they done so, I would have

corrected the many false assertions and allegations he has made.

™&&&
45. Finally, I would add, in relation to Mr Wright, that according to his own legal

Complaint, Mr Wright was Investigated for misconduct (sexual harassment),

subjected to disciplinary proceedings, and removed from his position on the FBI's

International Terrorist Squad. I refer to the documents appearing at pages 75-92.

ALLEGATION:

"Mailing address found In Kadl/QLJ transaction documents:

Kadi International Corp

C/o BMI Inc.
1 Harmon Plaza
Sacaucus, New Jersey

Attention: Gamal Ahmed r

RESPONSE:

46. ft is not dear to me from the US Treasury Department's fax what, If any,

wrongdoing BMI Inc or Gamal Ahmed are meant to have carried out BMI Inc.

PCR1-159363.3 20

003833
 was a company which at the time was working as managing agents in the USA

for some of my investments In a real estate fund and a leasing fund. BMI Inc.

has since become insolvent and I and other investors lost our money invested

with them. I believe that Gamal Ahmed was an employee of BMI. His name was

given as a contact name for which payments to Kadi Intemationai Corp. should

be addressed. This accords with entirely usual business practice and there is

nothing unusual or sinister about it.

ALLEGATION:

"Director, Global Diamond Resources, an American company. Yassln AJ-

Kadl sits on the Board as a representative of one of two forefgn,
anonymous, Investor groups that have a controlling Interest In Gfobal
Diamond."

RESPONSE:

47. It is completely unclear to. me what, if any, wrongdoing Global Diamond

Resources is meant to have carried out. The allegation that I sit on the Board of

Global Diamond Resources as a representative of one of two "foreign,

anonymous, investor groups" is calculated to create the most mysterious and

j sinister of impressions about me. The allegation is totally untrue. I refer to US

Securities and Exchange Commission Form 1Q-KS8 for the Fiscal year ended 31

December 2000 at pages 93-127 which is a publicly available document. As is

perfectly clear from pages 121-124. I serve on the Board of Directors of Globa)

Diamond Resources as a nominee of New Diamond Holdings Limited, which is a

family company owned by me and my wife, on behalf of our children. This Is

expressiy stated in Form 10-KSB, as US Treasury Department could easily have

ascertained had they made the most cursory of checks by reviewing documents

filed with the Securities and Exchange Commission.

PCRt-159363.3 ' 21

003834
 ALLEGATION:

"Director, Shifa International Hospitals In Pakistan"

RESPONSE:

48. !t is completely unclear to me what, if any, wrongdoing Shlfa International

Hospitals is meant to have carried out. It is true that I am a director of Shifa

International Hospitafs Limited, which is a public limited company based In

Pakistan. Documents relating to this are at pages 128-153. It is not clear to me

on what basis this Is claimed to be a separate ground by US Treasury

Department of criticism against me. Shjfa International Hospital in Islamabad,

Pakistan, is a multlspecfallty healthcare Institution which provides the highest

quality medical care to patients in a caring and compassionate manner by an

outstanding team of healthcare professionals. It is one of the leading hospitals In

Pakistan with state of the art equipment and medical facilities.

ALLEGATION:

"Vice President MM Badkook Co. for Catering and Trading."

RESPONSE:

49. It Is completely unclear to me what, if any, wrongdoing MM Badkook Co. is meant

to have carried out It Is true that 13 years ago I was Vice President of MM

Badkook Co: for catering and trading. Documents relating to this are at pages

154-159. Once again, I do not understand on what basis this is claimed by US

Treasury Department to be a separate ground of criticism against me.

PCR1-159353.3 22

003835
 ALLEGATION:

"Owns Al-Abrar Group International, Dr Wan Muhamad Hasn! Wan

Sufafman Is the Founder, President and Chief Executive Officer of Abrar
Group international." .

RESPONSE:

50. • !t is completely unclear to me what, if any, wrongdoing Al-Abrar Group

International is meant to have carried out. It is true that 1 do own part of Abrar

Group International of Kuala Lumpur, Malaysia. The document relating to this is

at page 160. Dr Wan Muhamad Hasnl Wan Sulalman is the founder of Abrar

Group International. Once again, it is not clear to me on what ground this is

claimed as a separate basis for criticism against me.

51. Global Diamond Resources, Shlfa International Hospitals, MM Badkook Co for

Catering and Trading and Al-Abrar Group International are all completely

- legitimate and lawful businesses with which 1 am now or have in the past been

associated. I am at a loss to understand how my association with these

businesses can be used as evidence that I am somehow involved In providing

support for terrorism.

ALLEGATION:

"His brothsr Omar Al-Qadf is the Director of Mercy International - USA."

RESPONSE:

52. I do not have any brother at all. As is very weff known in Saudi Arabia I am the

only son of my parents and have 6 sisters. It frankly beggars belief that the US

PCRt-159363.3 23

003836
 Treasury Department followed by HM Treasury in the UK have apparently based

their allegations against me in part on my having a so-called brother who is a

director of Mercy International, an allegation which had they made the most basic

of inquiries before publishing their list they would have found to be false. The

statement regarding the relationship between someone called Omar Al-Qadi and

me is completely untrue. Since the case against me Is based, in so easily

verifiable a matter, on a factual error, I am very concerned that, the other

allegations, which are even more vague and subjective, should equally be

understood as based essentially on errors and a lack of proper analysis.

53. Finally, as a loyal Saudi citizen, and a devout Muslim, any act of support of bin

Laden or al-Qalda would constitute extreme disloyalty to my own country and

faith. This is because bin Laden's acts were very harmful and damaging to my

country and the Saudi people long before the 11 September 2001, let alone after

that date. In this regard I am pleased to note, and with gratitude, that the Saudi

Government believes my Inclusion fn the list was a miscarriage of Justice. I refer

to a press conference on 30 September 2001 whfch was widely reported in the

Saudi media on 1 October 2001 (see pages 161 to 162) where the Saudi Interior

Minister, His Royal Highness Prince Naief Bin Abdul Aziz declared;

"This ffassin Kadi] is one of the citizens of Saudi Arabia who has suffered

injustice. The man has spoken for himself and he will pursue his rights

even in the United States of America. He is a businessman with his own

commercial establishment. Now we have nothing in any way or manner

PCR1-159363.3 24

003837
IN THE HIGH COURT OF JUSTICE CO/ 4528/ 01
and CO/ A532I 01
QUEEN'S BENCH DIVISION

ADMINISTRATIVE COURT

IN THE MATTER OF AN APPLICATION FOR JUDICIAL REVIEW

AND IN THE MATTER OF AN APPLICATION UNDER THE TERRORISM (UNJTED NATIONS

MEASURES) ORDER 2001

ORDERED TO BE LISTED TOGETHER BY ORDER OF THE HONOURABLE MR JUSTICE

SCOTT BAKER DATED 12 NOVEMBER 2001

AND IN THE MATTER OF YASSIN ABDULLAH KADI

YASSIN ABDULLAH KADI

Claimant
-and -

HM TREASURY
Defendant

THIS IS THE EXHIBIT MARKED "YAK2" REFERRED TO IN THE WITNESS

STATEMENT OF YASSJN ABDULLAH KADI DATED 17 DECEMBER 2001

Eaa&s
1. Press Releases dated 12 October 2001 from HM Treasury 1-7
and US Department of the Treasury.

2. Copy letter from Claimant's Solicitors to HM Treasury's Solicitors 8-9

dated 15 October 2 0 0 1 .

3. Copy letter from HM's Treasury Solicitors to Claimant's Solicitors 1O>11

dated 19 October 2 0 0 1 .

4. Order of Mr Justice Scatt Baker datBd 12 November 2001 12

5. Copy U S Treasury Department fax dated 11 October 2001 13-14

6. Copy Muwafaq Constitution and Declaration of Trust

dated 31 May 2992 15-27

7. Still photographs of Muwafaq relief lorries in joint operation with UNHCR 28-2S

8. Article in "FBIS" dated 31 July 1995 entitled

"Islamic Financier Bin Ladin Interviewed on Sudan, Iran Ties" 30-33

PCR1-160410.1

003838
 9. Copy documents relating to Muwafaq's work in Bosnia and Croaita 34-40

10. Copy document downloaded from www.interpol.int on Usamah bin Laden 41

11. Copy article in USA Today dated 29 October 1999 entitled 42-43
"Saudi Money aiding bin Laden"

12. Copy article in The Guardian dated 26 September 2001 44-45

entitled "Unlang/ing the financial web*

13. Copy article in The Chicago Tribune dated 28 October 2001 46-51
entitled "Money trail leads to Saudi. US says. Financier denies sending
funds to. bin Laden"

14. Copy Consent Order dated 30 May 2001 52-53

15. Copy Statement in Open Court 54-58

16. Copy front and back covers of The Opening of the Quran" and 57-60
"One God The Everlasting Refuge" published by the Quranic Literary
Institute

17. Copy fax (and English translation) from Claimant to Claimant's 61-62
Bank stopping transfer of money to Mohamed Salah's account

18. Copy Mortgage dated 31 December 1991 executed fay Midland 63-67
Federal Savings and Loan

19. Copy Loan Note dated 31 December 1991 68-70

20. Copy Guaranty dated 31 December 1991 between Kadi International 71-72
and the Quranic Literary Trust

21. Copy documents relating to Robert Wright -v- Karen Medemach

US District Court for Northern District of Illinois. Eastern Division
Cage 01C 5J52 75-92

22. Copy US Securities and Exchange Commission Form 10-KSB for 93-127
Fiscal Year ended 31 December 2000

23. Copy documents relating to Shifa International Hospital in Islamabad 128-153

24. Copy documents relating to MM Badkook Co. 154-159

25. Copy document relating to Abrar Group International 160 .

26. Copy article from Al Riyadh (number 12152) dated 1 October 1992 161

27. Copy translation of extract from Al Riyadh article dated 1 October 1992 162

PCR1-160410.1

003839
 "•i»i. i tvi^A J Uiv i

home | news | site index

110/01

12Octobor2001

TAKES STEPS TO FREEZE MORE TERRORIST ASSETS

HM Treasury, in liaison wrth US Government, today instructed financial institutions to freeze the
assets.of a further 38 individuals and organisations. Those on today's list are believerf to have
committed or pose a significant risk of committing or providing material support for acts of
terrorism.

Chancellor of the Exchequer Gordon Brown said:

r ^\
"if any of those named today hold assets in the UK they will be frozen immediately. Just as there
^ can be no safe haven for terrorists we are taking decisive action to ensure there is no safe hiding
ptaca for their assets. .

"Today's list is a result of intelligence sharing and coordination between UK and US. Wa wiil
continue to work with our allies, and take a leading role internationally, to cut off the ready supply
of finance which is the lifebiood of modern terrorism.

"These measures are part of detailed proposals being formulated to expose, isolate and
incapacitate funds being used for terrorist activities."

Notes to Editors.

The list of people and organisations whose assets should be frozen is:

Entltiaa

AL-HAMATI SWEETS BAKERIES, Al-Mukallah, Hadhnamawt Govemorata. Yemen.

V'^ AL-NUR HONEY PRESS SHOPS (a.k.a. AL-NUR HONEY CENTER), Sanaa, Yemen,

AL-SH1FA' HONEY PRESS FOR INDUSTRY AND COMMERCE, PO Box 8089, Ai-Hasabah,
Sanaa, Yemen; By the Shrine Next to the Gas Station, Jamat Street, TaTz, Yemen; AI-Anjdh
Square, Khur Maksar. Aden, Yemen; Al-Nasr Street, Doha, Qatar.

JAISH-I-MOHAMBflED (a.k.a. ARfefY OF MOHAMMED), Pakistan. "

JAM'YAH TA'AWUN AL-ISLAMIA (a.k.a. SOCIETY OF ISLAMIC COOP£RATIONXa.k.a.

JAMTYAT A L T A ' A W U N A L ISLABSrYYAXa.k.a. JIT), Qsndahar City, Afghanistan.

RABFTA TRUST, Room 9A, 2nd ROOT, Wahdat Road, Education Town, Lahore, Pakistan; Wares
CoJony, Lahore, Pakistan.

Individuals

AGHA, Hajl A b d u l Manan (a.k.a. SATY1D, Abd AI-MarTarn); Pakistan.

AL-HAWATI, Muhammad {a.k.a. A L T A H D A L , Mohammad Hamdi 5Bd}q)(a.k.a. AL-MAKKf,

Abu AslrrO.YBmen.

*AL-HAQ, A m l n {a.k.a. AMEN, Muhammad; a.k.a AH HAQ, Dr Amln;

UL-HAQ. Dr A m i n ) ; DOB: 1960; POB; Nangahar Provinco, Afghanistan.

003840
 • tt.M. (..K-EAdUKY

AL-QADl, Yasin (a.k.a. KADI, Shaykh Yassin Abdu(lah)(a.k.a. KAHDI, Yasln). Jeddah, Saudi
Arabia.

t**f\ *AL-JADAWI, Saqan DOB:1965

•AL-KADR, Ahmad Said {a.k.a AL-KANADI, Abu Abd Al-Rahman);

DOB: 01 March 1948; POB: Cairo, Egypt.

'AL-SHARIF, Sa'd; DOB: 1969; POB: Saudi Arabia •

•BIN MARWAN, Bllal; DOB: 1947

BIN MUHAMMAD, Ayadl Chafiq (a.k.a. AYADI SHAFFQ, Ban Muhammad) (a.lea. AYADI
CHAF1K, Ben Muhammad) (a.k.a. A1AD1, Ben Muhammad) (a.k.a. AiADY, Bon Muhammad),
Helena Meyer Ring 10-1415^80809, Munich, Germany; 129 Park Road, London, NW8, London,
England; 28 Chausse Dl Lille, Moscron, Belgium; Darvingasse 1/2/58-60. Vienna, Austria;
Tunisia: DOB: 21 January 1963; POB: Safals (Sfax), Tunisia.

DARKAZANLIr Mamoun, UNenhorster Weg 34, Hamburg, 22085. Germany; DOB: 4 August
1958; POB: Aleppo. Syria; Passport No: 1310636282 (Germany).
C
iK ) HUA21, Rlad (a.k.a. HUAZi, Raod M.) (a.k.a. AL-HAWEN, Abu^Ahmad) (a.k.a. AL-MAGHRIBI,
-s Rnshid [The Moroccan!) (a.ka AL-AMRiKl, Abu-Ahmad [TriB American]) (a.K.a. AL-
SHAH1D, Abu-Ahmad). Jordan; DOB: 1968; POB: California. USA; SSN: 548-91-5411.
LADEHfYANOY, Mufti Rashld Ahmad (a.k.a. LUDHiANVl, Mufti Rashld Ahmad) (a.k.a.
AHMAD, MufO Rashood) (a.k.a. WADEHYANOY, Muf« Rashld Ahmad); Karachi, Pakistan.

UTHMAN, Omar Mnhmaud (a.k^ Othmaa, Omar Mahmoud) (a.k.a. AL-FULJSTINK Abu
Qatada) (a.k.a. TAKFIR!, Abu 'Umr) (a.k.a. ABU UMAR, Abu Omar) (a.k.a. UTHMAN, A3-
Samman) (a.k-a. UMAR, Abu Umar) (a.lca. UTHMAN, Umar) ( a.k.a. ABU ISMAIL), London.
England; DOB: 30 December 196Q or 22 December 1960'or 13 December 1960. National
insurance Number PW581303D.

YULDASHEV,Tohlr (a.k.a. YULDASHEV, Takhir). Uzbekistan.

ZiA, Mohammad (a.k.a. ZIA, Ahmad); c/o Ahmed Shah s/o Painda Mohammad
al-Karfrn Set, Peshawar, Pakistan; c/o Alam General Store Shop 17, Awatni Market, Peshawar,
Pakistan; do Zahir Shah s/o Murad Khan Ander Sher, Peshawar, Pakistan.

/.- \ YASIN, Abdul Rahman

' ) MOHAIWMED, Khalld Shaikh

AL MUGHASSIL, Ahmed"

AL-HOURI, All

AL-YACOU5, Ibrahim

AL NASSER, Abdel Karim

MOHAMMED, Fazul Abdullah

FADH1L, Mustafa Mohamad

GHAILANi, Ahmed Khalfan

MSALAM, Fahid Mohammed Ally

SWEDAN, Shotkh Ahmed Sailm

2
003841
 «5D _f ui J

ABDULLAH, Abdullah Ahmad

AL1, Ahmed Mohammed Hamed.

ATWAH, Mushin Musa MatwalU

MUGNIYAH, Imad

IZZ-AL-DiN, Hassan

ATWA, AH

* These names have already been published In the UN consolidated list datBd 8 March 2001

The list has been circulated to financial institutions by the Bank Of England.

Enquiries should be addressed to Simon Moyse at the Treasury Press Office on 020 7270 5238.
or from the Treasury Website.

_•")

HM Treasury, Parliament Street, London SW1P 3AG UK

Switchboard: +44 (0)20 7270 5000
Public Enquiry Unit: +44 (0) 20 7270 4558
© Crown Copyright | home

003842
 TREASURY DEPARTMENT RELEASES LIST OF 39 ADDITIONAL.. Page 1 of 4

¥
" ^ TREASURY NEWS

FROM THE OFFICE OF PUBLIC AFFAIRS

FOR IMMEDIATE RELEASE
October 12,2001
PO-689
TREASURY DEPARTMENT RELEASES LIST OF 39 ADDITIONAL
SPECIALLY DESIGNATED GLOBAL TERRORISTS
( \ Treasury Office of Foreign Asset Control (OFAC) has added the names of 39
terrorists to its list of Specially Designated Global Terrorists (SDGT). Their assets
must be blocked immediately.

ABDULLAH, Abdullah Ahmed (a.k.a. ABU MARIAM; a.k.a. AL-MASRI, Abu

Mohamed; a.k.a. SALEH), Afghanistan (DOB 1963; POB Egypt; citizen Egypt)
(individual) [SDGT]
AGHA, Haji Abdul Manan (a.k.a. SAIYID, Abd Al-Man'am), Pakistan (individual)
[SDGT]
AL-HAMATI SWEETS BAKERIES, Al-Mukallah, Hadhramawt Governorate,
Yemen [SDGT]
AL-HAMATI, Muhammad (a,k.a. AL-AHDAL, Mohammad Hamdi Sadiq; a.k.a.
AL-MAKKI, Abu Asim), Yemen (individual) [SDGT]
AL-HAQ, Amin (a.k.a. AH HAQ, Dr. Amin; a.k.a. AMIN, Muhammad; a.k.a. UL-
HAQ, Dr. Arnin) (DOB 1960; POB Nangahar Province, Afghanistan) (individual)
[SDGT]

AL-JADAWI, Saqar (DOB 1965) (individual) [SDGT]

AL-KADR, Ahmad Sa'id (a.k.a. AL-KANADI, Abu Abd Al-Rahman) (DOB 01
Mar 1948; POB Cairo, Egypt) (individual) [SDGT]
AL-LIBY, Anas (a.k.a. AL-LIBI, Anas; a.lca. AL-RAGHIE, Nazih; a.kla. AL-
RAGHIE, Nazih Abdul Hamed; a.k.a. AL-SABAI, Anas), Afghanistan (DOB 30
Mar 1964, Alt. DOB 14 May 1964; POB Tripoli, Libya; citizen Libya) (individual)
[SDGT]

AL-MUGHASSTL, Ahmad Ibrahim (a:k.a. ABU OMRAN; a.k.a. AL-

003843 ^*
TREASURY UtSFAKTMHNT KbLiiASfct> Lib L Ut j y AJJD11IUIN AL.. Page 2 ot 4

MUGHASSIL, Ahmed Ibrahim) (DOB 26 Jun 1967; POB Qatif-Bab al Shamai,

Saudi Arabia; citizen Saudi Arabia) (individual) [SDGT]

AL-NASSER, Abdelkarim Hussein Mohamed (POB Al Ihsa, Saudi Arabia; citizen

Saudi Arabia) (individual) [SDGT]
AL-NUR HONEY PRESS SHOPS (a.k.a. AL-NUR HONEY CENTER), Sanaa,
Yemen. [SDGT]
AL-QADI, Yasin (a.k.a. KADI, Shaykh Yassin Abdullah; a.k.a. KAHDI, Yasin),
Jeddah, Saudi Arabia (individual) [SDGT]
AL-SHARIF, Sa'd (DOB 1969; POB Saudi Arabia) (individual) [SDGT]
AL-SHIFA1 HONEY PRESS FOR INDUSTRY AND COMMERCE, Al-Nasr
Street, Doha, Qatar; By the Shrine Next to the Gas Station, Jamal Street, Ta'iz,
Yemen; Al-'Arudh Square, Khur Maksar, Aden, Yemen; P.O. Box 8089, Al-
Hasabah, Sanaa, Yemen [SDGT]
AL-YACOUB, Ibrahim Salih Mohammed (DOB 16 Oct 1966; POB Tarut, Saudi
Arabia; citizen Saudi Arabia) (individual) [SDGT]
ALI, Ahmed Mohammed Hamed (a.k.a. ABDUREHMAN, Ahmed Mohammed;
a.k.a. ABUFATIMA; a.k.a. ABU TSLAM; a.k.a. ABUKHADIUAH; a.k.a.
AHMED HAMED; a.k.a. Ahmed The Egyptian; a.k.a. AHMED, Ahmed; a.k.a..
AL-MASRI, Ahmad; a.k.a. AL-SURIR, Abu Islam; a.k.a. ALI, Ahmed
Mohammed; a.k.a. ALI, Hamed; a.k.a. HEMED, Ahmed; a.k.a. SHTEB, Ahmed;
a.k.a. SHUAIB), Afghanistan (DOB 1965; POB Egypt; citizen Egypt) (individual)
[SDGT]

ATWA, Ali (a.k.a. BOUSLIM, Ammar Mansour; a.k.a. SALIM, Hassan Rostom),
Lebanon (DOB 1960; POB Lebanon; citizen Lebanon) (individual) [SDGT1]
ATWAH, Muhsin Musa Matwalli (a.k.a. ABDEL RAHMAN; a.k.a. ABDUL
RAHMAN; a.k.a. AL-MUHAJIR, Abdul Rahman; a.k.a. AL-NAMER, Mohammed
K.A.), Afghanistan (DOB 19 Jun 1964; POB Egypt; citizen Egypt) (individual)
[SDGT]

BIN MARWAN, Bilal (DOB 1947) (individual) [SDGT]

BIN MUHAMMAD, Ayadi Chafiq (a.La. AIADI, Ben Muhammad; a.k.a. AIADY,
Ben Muhammad; a.k.a, AYADI CHAFDC, Ben Muhammad; a.La, AYADI
SHAFIQ, Ben Muhammad), Darvingasse 1/2/58-60, Vienna, Austria; 28 Chaussee
de Lille, Mouscron, Belgium; 129 Park Road, NW8, London, England; Helene
Meyer Ring 10-1415-80809, Munich, Germany; Tunisia (DOB 21 Jan 1963; POB
Safais (Sfax), Tunisia) (individual) [SDGT]

DARKAZANLI, Mamoun, Uhlenhorsterweg 34 11, 22085, Hamburg, Germany

(DOB 4 Aug 1958; POB Aleppo, Syria; Passport No: 1310636262 <Germany>)
(individual) [SDGT]

EL-HOORIE, Ali Saed Bin Ali (a.ka. AL-HOURI, Ali Saed Bin Ali; a.k.a. EL-
003844
 TREASURY DEPARTMENT RELEASES LIST OF 39 ADDITIONAL.. Page 3 of 4

HOURI, AH Saed Bin All) (DOB 10 Jul 1965, alt. DOB 11 Jul 1965; POB El
Dibabiya, Saudi Arabia; citizen Saudi Arabia) (individual) [SDGT]

FADHIL, Mustafa Mohamed (a.k.a. AL MASRI, Abd Al Wakil; a.k.a. AL-NUBI,

Abu; a.k.a. ALI, Hassan; a.k.a. ANIS, Abu; a.k.a. ELBISHY, Moustafa Ali; a.k.a.
FADIL, Mustafa Muhamad; a.k.a. FAZUL, Mustafa; a.k.a. HUSSEIN; a.k.a.
JTHAD, Abu; a.k.a. KHALID; a.k.a. MAN, Nu; a.k.a. MOHAMMED, Mustafa;
a.k.a. YUSSRR, Abu) (DOB 23 Jun 1976; POB Cairo, Egypt; citizen Egypt, alt.
citizen Kenya; Kenyan ID No. 12773667; Serial No. 201735161) (individual)
[SDGT]
GHAILANI, Ahmed Khalfan (a.k.a. "AHMED THE TANZANIAN"; a.k.a.
"FOOPIE"; a.k.a. "FUPI"; a.k.a. AHMAD, Abu Bakr; a.k.a. AHMED, A.; a.k.a.
AHMED, Abubakar; a.k.a. AHMED, Abubakar K.; a.k.a. AHMED, Abubakar
Khalfan; a.k.a. AHMED, Abubakary K.; a.k.a. AHMED, Ahmed Khalfan; a.k.a.
AL TANZANI, Ahmad; a.k.a. ALI, Ahmed Khalfan; a.k.a. BAKR, Abu; a.k.a.
GHAILANI, Abubakary Khalfan Ahmed; a.k.a. GHAILANI, Ahmed; a.k.a.
GHILANI, Ahmad Khalafan; a.k.a. HUSSEIN, Maharudh Abubakar Ahmed
O Abdallah; a.k.a. KHABAR, Abu; a.k.a. KHALFAN, Ahmed; a.k.a. MOHAMMED,
Shariff Omar) (DOB 14 Mar 1974, alt. DOB 13 Apr 1974, alt. DOB 14 Apr 1974,
alt. DOB 1 Aug 1970; POB Zanzibar, Tanzania; citizen Tanzania) (individual)
[SDGT]

HIJAZI, Riad (a.k.a. AL-AMRIKI, Abu-Ahmad; a.k.a. AL-HAWEN, Abu-Ahmad;

a.k.a. AL-MAGHRJBI, Rashid; a.La. AL-SHAHID, Abu-Ahmad; a.k.a. HIJAZI,
Raed M), Jordan (DOB 1968; POB California, U.S.A.; SSN: 548-91-5411
<U.S.A.>) (individual) [SDGT]
IZZ-AL-DIN, Hasan (a.k.a. GARBAYA, AHMED; a.k.a. SA-ID; a.k.a.
SALWWAN, Samir), Lebanon (DOB 1963; POB Lebanon; citizen Lebanon)
(individual) [SDGT1]
JAISH-I-MOHAMMED (a.k.a. ARMY OF MOHAMMED), Pakistan [SDGT]
- ' JAMYAHTA'AWUNAL-ISLAMTA(a.k.a.JAM'IYATALTAlAWUNAL
ISLAMIYYA; a.k.a. JIT; a.k.a. SOCIETY OF ISLAMIC COOPERATION),
Qandahar City, Afghanistan [SDGT]
LADEHYANOY, Mufti Rashid Ahmad (a.k.a. AHMAD, Mufti Rasheed; a.k.a.
LUDHIANVI, Mufti Rashid Ahmad; a.k.a. WADEHYANOY, Mufti Rashid
Ahmad), Karachi, Pakistan (individual) [SDGT]
MOHAMMED, Fazul Abdullah (a.k.a. ABDALLA, Fazul; a.k.a. ADBALLAH,
Fazul; a.k.a. AISHA, Abu; a.k.a. AL SUDANI, Abu Seif; a.k.a. ALI, Fadel
Abdallah Mohammed; a.k.a. FAZUL, Abdalla; a.k.a. FAZUL, Abdallah; a.k.a.
FAZUL, Abdallah Mohammed; a.k.a. FAZUL, Haroon; a.k.a. FAZUL, Harun;
a.k.a. HAROON; a.k.a. HAROUN, Fadhil; a.k.a. HARUN; a.k.a. LUQMAN, Abu;
a.lca. MOHAMMED, Fazul; a.k.a. MOHAMMED, Fazul Abdilahi; a.k.a.
MOHAMMED, Fouad; a.k.a. MUHAMAD, Fadil Abdallah) (DOB 25 Aug 1972,
alt. DOB 25 Dec 1974, alt. DOB 25 Feb 1974; POB Moroni, Comoros Islands;
citizen Comoros, alt. citizen Kenya) (individual) [SDGT]

003845
 TREASURY DEPARTMENT RELEASES LIST OF 39 ADDITIONAL.. Page 4 of 4

MOHAMMED, Khalid Shaikh (a.k.a. ALI, Salem; a.k.a. BIN KHALID, Fahd Bin
AdbalJah; a.k.a. HENIN, Ashraf RefaatNabith; a.k.a. WADOOD, Khalid Adbul)
(DOB 14 Apr 1965, alt. DOB 1 Mar 1964; POB Kuwait; citizen Kuwait)
(individual) [SDGT] •

MSALAM, Fahid Mohammed Ally (a.k.a. AL-KINI, Usama; a.k.a. ALLY, Fahid
Mohammed; a.k.a. MSALAM, Fahad Ally; a.k.a. MSALAM, Fahid Mohammed
AH; a.k.a. MSALAM, Mohammed Ally; a.k.a. MUSALAAM, Fahid Mohammed
AH; a.k.a. SALEM, Fahid Muhamad Ali) (DOB 19 Feb 1976; POB Mombasa,
Kenya; citizen Kenya) (individual) [SDGT]

RABITA TRUST, Room 9A, 2nd Floor, Wahdat Road, Education Town, Lahore,
• Pakistan; Wares Colony, Lahore, Pakistan [SDGT]
SWEDAN, Sheikh Ahmed Salim (a.k.a. Ahmed the Tall; a.k.a. ALLY, Ahmed;
a.k.a. BAHAMAD; a.k.a. BAHAMAD, Sheik; a.k.a. BAHAMADI, Sheikh; a.k.a.
x SUWEIDAN, Sheikh AJimad Salem; a.k.a. SWEDAN, Sheikh; a.k.a. SWEDAN,
K
-J Sheikh Ahmed Salem) (DOB 9 Apr 1969, alt. DOB 9 Apr 1960; POB Mombasa,
Kenya; citizen Kenya) (individual) [SDGT]
UTHMAN, Omar Mahmoud (a.k.a. ABU ISMAIL; a.k.a. ABU UMAR, Abu Omar,
a.k.a. AL-FILISTINI, Abu Qatada; a.k.a. TAKFIRI, Abu Vmr; a.k.a. UMAR, Abu
Umar; a.k.a. UTHMAN, Al-Samman; a.k.a. UTHMAN, Umar), London, England
(DOB 30 Dec I960, alt. DOB 13 Dec 1960) (individual) [SDGT]
YASIN, Abdul Rahman (a.k.a. TAHA, Abdul Rahman S.; a.k.a. TAHER, Abdul
Rahman S.; a.k.a. YASIN, Abdul Rahman Said; a.k.a. YASIN, Aboud) (DOB 10
Apr I960; POB Bloomington, Indiana U.S.A.; SSN 156-92-9858 <U.S.A.>;
Passport No. 27082171 <U.S.A. - issued 21 Jun 1992 in Amman, Jordan>, alt.
Passport No. M0887925 <Iraq>; citizen U.S.A.) (individual) [SDGT]
YULDASHEV, Tohir (a.k.a. YULDASHEV, Takhir), Uzbekistan (individual)
[SDGT]
ZIA, Mohammad (a.k.a. ZIA, Ahmad), c/o Ahmed Shah s/o Painda Mohammad al-
Karim Set, Peshawar, Pakistan; c/o Alam General Store Shop 17, Awarni Market,
Peshawar, Pakistan; c/o Zahir Shah s/o Murad Khan Ander Sher, Peshawar,
Pakistan (individual) [SDGT]

MUGHNTYAH, Imad Fa'iz (a.k.a. MUGHNTYAH, Imad Fayiz), Senior

Intelligence Officer of HIZBALLAH (DOB 07 Dec 1962, POB Tayr Dibba,
Lebanon, Passport No. 432298 <Lebanon>) (individual) [SDT] (Already on SDN
List)

Search | Email | Treasury Home Page

003846
Direct Email: [email protected]
Direct Fax- 020 7353 5553

Our Ref. GM/MRS/74 96.3

filir
Dale 15 October 2001
Carter-Rue
and P u U i r i

Solicit
By Fax: 0207 270 4834
Intirnallonal P n n Cei
TSSho.L
London EC<A:

Tel 020 7353 5

Sir Andrew Turnbull
Fan 020 7353 5
Permanent Secretary
H M Treasury OX 333 Chancary L
Parliament Street
Email lawyors^canar-njcVr
London SW1P 3AG
Web silfl www.cartw-rucfc.c

BY FAX
MOST URGENT Andrew Slaphon
Dear Sir Aiasdair Pop
Guy Ms
NiQcl
Mr Yassin Kadi Charfotrn Wat
Ruth Cot
Cameron D(
We have been consulted by Mr Yassin Kadi, the prominent Saudi Arabian Claim
businessman, with reference to the release issued by H M Treasury dated 12
October 2001 headed "H M TREASURY TAKES STEPS TO FREEZE MORE
TERRORIST ASSETS ".
Consults
Martin Sr
Our client is horrified and shocked that his name has been included on this list
and at your allegation that he supports or is in any way connected with terrorism. PaulWhei

Your allegations are completely untrue: Mr Kadi has never been involved with,
supported or provided funds for any terrorist or extremist activities. Pirtimnhlp 5»cr»t
Mchaal Cm**

The allegations that Mr Kadi funds and/or supports Osama Bin Laden, or any
terrorist organisation, are of the utmost gravity and seriousness. It Is difficult to A J I O C I I U Fl
Bannatyrm Kkkwood Franca &
conceive at the present time of a more seriously defamatory allegation to make. EncfranQS H «
It is quite conceivable that as a result of your publication at the present time, Mr 16 Royal Exchange Squi
Kadi could be subject to death threats, his ability to travel and conduct his GlugowGi 3.

business could be severely curtailed or stopped altogether. TfllOUl 221 BC

Fax OH I 221 51
We are particularly concerned that you have seen fit to publish these highly
defamatory allegations of our client without first giving him notice of your intention
to do so and, most importantly, thereby depriving him of any opportunity, prior to
publication, to respond. As we have stated, Mr Kadi Is a prominent Saudi Arabian
businessman; it would accordingly have been a simple matter for your
department to contact him for his response before publishing these outrageous
allegations.

Furthermore, had your department taken the trouble to make even the most
cursory of inquiries it would have discovered that we acted for Mr Kadi, and his
fellow Trustees of the Muwafag Foundation, in libel proceedings in the High Court
against the Editor and publishers of Africa Confidential; and upon settlement of
Ihose proceedings, less than 4 months ago, on 22 June 2001, a Statement in

PCRU156524.1
8
003847
 Page 2
Our Ref: GM/MRS'7496.3

Open Court, was read out before the Honourable Mr Justice Eady in which Africa Confidential
apologised to our clients for allegations they had published in 1995. That settlement was
announced in a press release on 22 June 2001. A copy of the Statement in Open Court is
enclosed.

We assume, but must insist on your confirmation of this, that as a responsible Government
department HM Treasury will have seen and examined any available evidence of alleged links
between our client and terrorism and that in publishing these allegations you did not simply act on
the "say so" of the United States authorities. In any event our client requires immediate sight of
whatever information or evidence you acted on before publishing the list.

For the avoidance of doubt our client is more than willing to make himself and his business records
available to the appropriate authorities towards having his name removed from the list and clearing
his good name of your allegations.

The purpose of our writing to you now is to place you specifically on notice as to the matters set
out above. We also require your immediate undertaking that pending a proper investigation into
this matter by your department or other appropriate authority you will forthwith remove our client's
name from the list.

Our client is determined to pursue all legal remedies available to him to protect his good name and
reputation. Jn light of your failure to make any proper inquiries we have advised our client that any
further publication of these allegations by you will be with malice towards our client.

We await hearing from you as a matter of extreme urgency and in any event by close of business
this Wednesday 17 October. In the meantime it must be clearly understood that all our client's legal
rights are fully reserved.

Yours faithfully

Peter Carter-Ruck and Partners

PCR1-156524.1

003848
 THE TREASURY SOLICITOR
Queen Anne's Chambers, 28 Broadway, London 5 W I H 9JS
DX 123242 St James's Park. Switchboard 020 7210 3000 (GTN 210).
Direct Line: 020 7210 3100 Direct Fax: 020 7210 3257 E-mail: PBennettStreasuryHiolIctor.gsl.gov.uk
TEAM LEADER • EMPLOYMENT UTICAT1ON TEAM A3

Peter Carter-Ruck and Partners Please quote LT1/7955&PXB.A3

DX 333 Chancery Lane
AND BY FAX 0207 353 5553 teferenoe GM/MRS7496.3

19 October 2001

KJ

Dear Sirs

YASSIN KADI v HM TREASURY

I refer to my tetter of 17 October and now write In substantive response to your letter to Sir
Andrew Tumbull of 15 October 2001.
¥
Your client has with others been made the subject of measures designed to prevent his use
of any assets he has In. this Jurisdiction on the basis of intelligence information provided to
my clients by the US Treasury that he has been Involved in funding terrorism. My client's
Press Release was designed to give the widest possible publicity to these measures with a
view to maximising their effectiveness. Your client was simultaneously publicly Identified by
the US Treasury as subject to like measures In the USA for like reasons.

Your suggestion that those sucti as your client who are subject to these measures shoufci be
givan advance notice of them would of course defeat the object of the measures by enabling
the removal of any assets from the Jurisdiction before the measures took effect

The fact that the Newsletter 'Africa Confidential' decided to settle your client's dalm for libel
does not amount to evidence that your client Is not Involved In supporting terrorism.

The US Treasury provided Its Intelligence Information to my client In confidence and has
confirmed to my client that my dlent Is not authorised to provide it to your client

003849
ioi
 It is understood that your client has made similar representations to'thB US authorities by his
US representatives. The US Treasury have apparently drawn your client's representatives'
attention to a procedure which enables those subject to such financial measures in the US to
make representations to the Office of Foreign Assets Control of the US Treasury with a view
to having the measures terminated. My client suggests that your client should follow that
procedure and, fn the event that the US Treasury accepted your client's representations and
terminated Its measures, ft Is very likely that my client would take action to terminate the
measures imposed in relation to your client in this jurisdiction.

I can accordingly confirm that my client will not terminate the measures taken against your
client at this time but is very likely to do so if your client successfully pursues the procedure
avallab/e to him In the USA to which I refer above.

As you appear to anticipate, any claim for libel by your client against mine will be defended
on the ground that In present circumstances the publication was and remains privileged.

Any proceedings should be served on me.

Yours Faithfully

Peter Bennett

"V

-2-
11
003850
 l
<£

14 NOV 2001
In the High Court of Justice ADMINISTRATIVE * * ? Ref: CO/4528/2001
^ CaURTOFRCE.^
Queen's Bench Division
Administrative Court

In the matter of a claim for Judicial Review

The Queen on the application of Yassin Abdullah Kadi

versus Her Majesty's Treasury

Application for permission to apply for Judicial Revjew

NOTIFICATION of the decision following oral submissions In open court by Mr D

Pannlck Q.C. with Mr P Salnl of Counsel on behalf of the Claimant and Mr J
Crow of Counsel on behalf of the Defendant.

BEFORE THE HONOURABLE MR JUSTICE SCOTT BAKER

IT IS ORDERED that:-
1) Permission be granted
2) Filing and service of the Acknowledgement of Service be dispensed with
3) The Defendant's grounds in opposition and evidence be served by 4.15pm on the
16* day of November 2001
4) The Claimant's evidence in reply, if any, be served by 4.15pm on the 21* day of
November 2001
5) The substantive hearing be listed together with CO/4532/2001 on the first open
date after the 26th day of November 2001 but not later than the 21 at day of
December 2001 with a time estimate of one day
6) The hearing be fixed by Counsels' clerks no later than 4.00pm on the 13th day of
November 2001
7) The Claimant's skeleton argument be served no later than four working days
before the date fixed for the substantive hearing
8) The Defendant's skeleton argument be served no later than two working days
before the date fixed for substantive hearing
9) Costs be reserved

(time of the court: 1.57pm to 2,57pm)

,th
Date 12 November 2001

12
003851
 t/Ul

Yasin al-Qadi

Information on al-Qadi from our long list:

» aka Shsykh-Yassin Abdullah Kadj
•, Located in Jcddah, Saudi Arabia
* Heads SaudUbascd Muwafaq Foundation

Muwafaq is an al-Qacda front that receives funding from wealthy Saudi businessmen:
• Blessed Relief is the English translation
* Chaiiq Ayadi claims that Yasin QBdi was his partner In Muwafaq, Germany and
that be received 286,000 Deutsche Mark in a Muwafaq bank account from Yassin
A.A. Kadi Sammy Ltd., Istanbul,
» Directly tied to bin Laden.
• In an interview, bia Laden said, "The bin-Ladin Establishment's aid
covers 13 countries... this aid comes in particular from the Human
Concern International Sociery." Bin Laden goes on to list a number of
HCI's branch organizations and includes Muwaffkq Society in Zagreb.77
---' • • Saudi businessmen have been transferring millions of dollars to Bin Laden
through. Blessed Relief.71 •
• Saudi businessmen deposited S3 million from the National Commercial
Bank, which was run by KhaJid bin Mahjbuz, into the accounts of the
Blessed Relief and odier charities thai serve a5 a front for bin Laden.75

AJ-Qadi has a vast financial empire linked to funding terrorist activity:

• Implicated in Hamas funding network.
• Kadi International channeled $820,000 to QLI to acquire a property in
Woodridgc, Illinois, in 1991.- The complex scries of transactions was
structured in a manner that obscured Kadi's connection to QLI.
• QLI provided funding for Hamas via Mohamad SaJlaii from 1991 through
1993. SaJlah has residence in Chicago and was arrested in February
1993.11
• Mailing Address found in Kadi/QLJ transaction documents:
• Kadi International Corp., c/o BMI, Inc.
One Harmon Plaza
Sccaucus," New Jersey
Attn: Gamal Ahmed
• Director, Global Diamond Resources, an American Company. Yassin al Kadi sits
on the board as a representative of one of two foreign, anonymous, investor
groups that have a controlling interest in Global Diamond.
» Director, Shifa International Hospitals in Pakistan."
77
"Islamic Ftnincier bin Ladin IniervUwsd on Sudan, Iran Ties."* FBIS. July 31.1995
n
"SstidJ Money Aiding bin Laden/ USA Today. October 29,1S99
"'Ibid.
** Affidavit of Rofaen Wn'ftht, FBI. June 6, 1998.
11
"U.S. Sehes SJ.4 MUJiou In Cub $nd Property Intended to Tund Himu Terrorist -A cdvftfe* in the
Middle EaC" U.S. Department of Justice. June 9,1991.
a
"Diamonds fire M Arab's Beit Friend." Middle Eui-Economic Dig«rt. January 15t 19P9

16

13
003852
 ,-ut

Vice President, MJM. Badkook Co. for Catering & Trading."

Owns a]-Abrar Group International."
• Dr Wan Muhamad Haani Wan Sulaiman, is the Founder, President and
Chief Executive Officer of Abrar Group International.0
11
Has its origins in the United States with the establishment of Abrar
Investments, Inc. in 1990. The Group's incorporation in Malaysia wag
initiated in early 1992. Later in 1993, Abrar Group International was
for^ned as the investment and management company of the Group.16.
His brother, Omar aJ-Qadi is the Director of Mercy International - USA

a
"Brief Recordings About Shift International Hospital* Ltd," Bualneu Recorder. July 14,2000
H
M.M. Badkcfcik Co. btqjrfwvvw.»audur>b{i.neiAa.in.bAdkDok/
" "Won of B Kind." Malaysian Tines. September 1,1995
u
MusLcaTradtKctwork. http^/www.inusllintndcjicc/iiirectory/Fliianclal/Servlccj

17

u
(?) 003853
 THIS DECLARATION OF TRUST Is made the- 7; day of
itJ tt
" ".—TT7T7T—~—~ •.. " y
1992 by YhSSIU QUADl" ' " ' : '
o£ PO Box 214 Jeddati 21411" '" Saudi" Arabxa "(hereinafter ca

'The Founder')."' ' •' "

H a E R E A S:-

The Founder has resolved "ca constitute a Foundation for

charitable purposes hereafter declared.

MOW THIS DEED WITNESSETH hUO IT IS HEREBY DECLAJtED as follow

1. The Foundation herebv constituted shall be known a s

i

Muwaffaq Foundation (hereinafter called 'The Foundation')

2. The o r i g i n a l fund o£ the Foundation shall be the sum

TWELVE TROOSftND POUNDS (£12,000) sterling (The FaundatJ

Fund).

3. The terras c)£ the Foundation are contained' i n the Foundati

Constitution.

r%-» - * oa
4. The Foundation s h a l l be s i t e d - i n the- Island'of Jersey oxr
r' J -
such other place or places as the Foundation. Council sha

from time to time determine.

- 1 -

15
003854
 >*T

5. Pursuant to- Article 7 of the Constitution the Founder

appoints the persons who are named in the Schedule hereto as

the original members oc the Foundation Council (hereinaftar

called the Council).

6. The Council shall hold the Foundation Fund and all monies
{ }
which may be added to the Foundation Fund for the objects
declared in the Constitution and the~ investments and-
prooacty from einie to time representing the same UPON' TRUST
eitner to retain or sell and invest the proceeds in_or upon
any investments authorised by the Constitution with power
from time to time to cnange such investments for others of a
like nature; that both the capital and income thereof shall
be applied at the discretion of the Council but exclusively
in pursuance oE the said objects.

I. In furtherance of its objects the Council s h a l l nave the

fallowing powers in addition to those conferred by- r.ne

Constitution.

(i) To employ and pay any person, or persons (not being

a member a£ the Council); to supervise organise and carry

an the work authorised by the Council and as employers of

staff to make a l l reasonable and necessary provision Ear the

- 2 -

003855
16
 payment of pensions and superannuation to or on behalf of

employees and their widows and other dependants.

I (ii) To pay travelling and other reasonable out of

packet expenses whether incurred by A member of the Council

or others.

(iii) To pay and provide for the expenses of acquiring

and running an office far che coordination anc

administration of th"e Foundation.

(iv) To undertake and execute any Trusc which may be

lawfully undertaken by the Foundation.

(v) To establish and support or a s s i s t in establisning

a.nd supporting any charitable association or institution and

to subscribe or guarantee money for charitable purposes.

LvL) To cooperate and collaborate with voluntary bodies

and statutory authorities in operations in similar

charitable fields and to exchange information and to advise.

(vii.) To take such lawful 3tepa by personal or written

appeals, public meetings or otherwise as may from time to

time or at any time become necessary for the purpose of

— j _
WSF

\7
003856
 procuring money property or rights of any kind [by loan

donation subscription or otherwise) and applying the same

for the purpose of the Foundation provided that the Council

shall not undertake any permanent, trading activities in

r a i s i n g funds far the said purpose.

' (viii) To take or receive any gift or mane1/ or" octiec

property whether subject to any 3pecial trust or not which

is not in the opinion of the Council calculated to impede

the -objects of the Foundation.

(ix) To .jiafce regulations for the management of any

property which may be acquired. "~

i

(x) To receive aid from any association wnether

charitable or not society or corporation or individual

whether formed by or in connection with the Foundation or

othezrwise and to subscribe to or cooperate with any such

charitable bodies with a view to a s s i s t i n g such bodies or to .

obtaining anys advantage or benefits for or promoting the •

objects of t h i s Foundation.
A

(xi) To establish and operate both current accounts and ]

deposit accounts with Banicers in the name of the Foundation *

provided that cheques drawn on such accounts shall not be (j

- 4

003857
 /

signed by less than two members of the Council who shall

have power to i n s t r u c t Bankers to accspt signatures of such

persons as raay be nominated hy them even- if those persons

are not members of the Council.

>
(xii) To do all such, other Tawful things as are

necessary for the attainment of the objects of the

Foundation.

8. In the execution of the objects and purposes of the

Foundation no member of the Council 3h,all be l i a b l e for any

loss ca ttie property of the Foundation a r i s i n g by reason of

any improper investment made in good faith so long as he

shall have sought professional advice before making such

investment: or for the negligence or fraud of any agenc

smpLoyed by him or by any other member oc the Council herein

r-4'
in good faith (provided reasonable supervision shall have

Seen exercised) although, the employment of such agenc was

not strictly necessary or by reason of any mistake or

omission made in good faith by any member of the Council

hereof or by reason of any othar wilful and individual fraud

wrong doing or wrongful omission on the part of a member of

the Council who i s sought to.be made l i a b l e .

9. Every new member of the Council s h a l l before acting sign a

A - 5 -

19
003858
 . i .••...laSrnA.r/ir'CT.a^.YrtfiyflC

declaration to be annexed: hereto of acceptance and of

willingness to ace in accordance with the terras of tne

Constitution and of t h i s Deed.

. I N W I T N E S S whereof the Founder has hereunto set" h i s

hand,as h i s Deed, t h e day and year f i r s t before written.

THE SCHEDULE
v_

O r i g i n a l members of t h e Foundation Council

1. Y a s s i n Quadi, PO Box 214, Jeddah 21411, Saudi Arabia.

2. T a l a l M- HadJcook, PO Box 221, Jeddah 21411, Saudi Arabia.

- 3. Rayeis Sin Mahfooz, PO Box 40030, Jeddah 21499, Saudi

Arabia.

4. Abdur Rahman Bin Mahfooz, PO Box 4QQ3O, Jeddah, 21499, Saudi

Arabia.

5.' Dr.' Mohamad Ali El-Gari Sin Eid, PO Box 214 Jeddah, 21411
Saudi A r a b i a .

6. Abdul Gani Al-Khariji, PQ Box 2388 Jeddah, 21451 Saudi

_ Arabia.

SIGNED a s h i s Deed by
YASSIN QOADIia t h e
presence o f : -

•si
003859 a
'tH> f y /2 V
 STATUTES OF MUWRFFAQ FOUNDATION

Article 1

Name

The nams of tha Foundation i s MCJUAFFAG FOUNDATION.

Article 2

Duration

The Foundation i s permanently established.

Article 3

Domicile
',
The domicile of the Foundation i s J a r s a y .

The Foundation Council may at any tiaie by means of a simple

majority r e s o l u t i o n , under observe of the legal and statutory
p r e v i s i o n s , t r a n s f e r ths domicile to ancchar place a t home and
abroad.

Article 4

Applicable Law

All l e g a l r e l a t i o n s h i p s of the Foundation a r s gcvarned solely hy

J e r s e y Law.

Rrticle 5

Objects, Purposes

The o b j e c t s and purposes cor which the Foundation i s created ara

to manage i t s property and to maJcs expenditures and d i s t r i b u t i o n s
for performing s e r v i c e s and providing a s s i s t a n c e Cor the public
benefit anywhere ..in tho world in p a r t i c u l a r in the field nf
c h a r i t y and by e s t a b l i s h i n g , maintaining, a s s i s t i n g and generally
operating foundations, i n s t i t u t i o n s or o t h e r organisations c r
t r u s t s for such purposes, and by making c o n t r i b u t i o n s , gifts or
othar transfers for tha public benefit to thesa i n s t i t u t i o n s .
The Foundation'3 p r i n c i p a l a c t i v i t i e s in p a r t i c u l a r shall be bun
not licnitad t o :

to provide r e l i e f t o and for any individual suffering

as a jreault of... natura.l " d i s a s t e r , wars, revolutions,
c i v i l unrest af..any description and famine;

to provide financial assistance to organisations,

i n s t i t u t i o n s ' , hospitals', research centras to improve
t h e standards of education or h e a l t h of the needy;

21
003860
 to provide guidance and education by comoila ting
p r i n t i n g and d i s t r i b u t i n g of books, tapes, video tapes,
newspapers magazines and other p u b l i c a t i o n s ;

such other charitable purposes as the Foundation

Council may cram time to time by revocable or
i r r e v o c a b l e instrument in writing appoint.

Within tne scope of the administration of i t s assets the

Foundation i s a u t h o r i s e d to conduct a l l legal transactions which
serve the pursuance and r e a l i s a t i o n of i t s o b j e c t s .

Trade according to commercial principles i s not conducted.

* Article 6

Foundation Fund, Situs

The o r i g i n a l fund of tne Foundation snail be TWELVE THOUSAND

POUNDS STEP.IIKG (£l2,COC).

The Foundation's a s s e t s may at any time be increased unlitnitedly

by donations fr;.-n the Founders or tnird . p a r t i e s wherecy sucn
donations s h a l l be a l l o c a t e d to the Foundation Fund or reserve.

The Foundation'a a s s e t s s i t u s s n a i l a t a l l times be locetsd =nd

Hi have i t s l e g a l s i t u s for a l l ourpcsas in sucn" jurisdiction or
W? j u r i s d i c t i o n s , within cr outside the j u r i s d i c t i o n at Jersey as
tne Foundation Council may from time to time determine.

Article 7

Foundation Council
"J
(a) The sole and supreme authority of the Foundation is the
Foundation Council (herein called the "Foundation
Council"). I t consists of at l a a s t two members. The
original me'ftvbers of the Foundation Council of the
Foundation are appointed by the Founders in ^ the
Formation Deed.
Tha term of office of the original Ksmaers of the
Foundation Council is unlimited.

The Foundation Council has the right of co-opting

further members; tnis requires unanimity of tha
members in office. Such subsequent memcers shall only
be acpointed for a pence of 5 years.

member of ths Foundation Council may resign office at

3ny
y time and with immediate effect withouc giving
reason
ac.in

fb) Tha e l e c t i o n of the Presidanc snail be by a majority cc

22
003861
 the whole Foundation Council. The tsrm "Whole
Foundation Council" shall .mean a l l of the members of
the Foundation Council who airs duly qualified at the
particular tints the tsrm s h a l l be a p c l i e d . The
President may ba the a d m i n i s t r a t i v e ' o f f i c e r of tha
Foundation i f the Foundation Council so provides.

The P r e s i d e n t s h a l l bs Chairman a t a l l meetings of the

Foundation Council a t which such person shall be
present. In the absence c£ the President, the
Chairman s h a l l be the Vice P r e s i d e n t or in his absence,
t h e a g e - e l d e s t member af the Foundation Council.

(c) The Foundation Council a d m i n i s t e r s the Foundation and

represents i t vis-a-vis third parties.

if The Foundation Council may d e l e g a t a under i t s own

x
S responsibility and supervision c e r t a i n of i t s dutiss to
third parties and appoint proxies.

Each and every member of ths Council shall, as long aa

he exercises such offics,, be e n t i r e l y independent from
a l l bank3 and cthsr financial i n s t i t u t i o n s entrusted
with the management of the assets ox the Foundation.
Each and every member of the Council irrevocably
undertakes to immediately resign from such ofties,
should this rsauirament caasa to be fully inst for
whatever reason.

(d) Meetings of the Foundation Council may be held sither

within or without the jurisdiction of Jersey.

The Foundation. Council meats as often as necessary or

purposeful upon invitation of a member, provided that a
President has been appointed, by him. The President
(• s h a l l • convene a meeting, when a member of the
Foundation Council requests such with notification of
tne agenda. . A-ny member may summon a meeting should
the President not fulfil t h i s obligation."

(e) Except only where expressly provided in these Statutes

vesting powers and authority in the Founders, a l l
powers and authority o* the Foundation shall be vested
in and may be exercised only by the Foundation Council.

<f) The l i a b i l i t y of the Foundation Council, i t s members

and t h e i r substitutes • shall be limited to intsntional
malfeasance and gross negligence.

(g) A majority of the whole Foundation Council shall

constitute a quorum of the Foundation Council.
Members may be present and vote in person or by proxy,
provided however that the person acting as sucn proxy
is a member of the Foundation Cauncil and represents by

"23
A%
003862 *
 proxy cnly 'one o-char msm'oar of the Foundation Council.

o Should a- quorum not be achieved, upon demand of a

member a nsw meeting with the same agenda shall be
convened not sarlier than five and no lacer than ten
days calculated from the first meeting. A quorum is
given at chis second meeting, without consideration of
the number of members present and represented-

(h) The Foundation Council passes all resolutions with a

simple majority of all Foundation Council members cc
substitutes without axcspcion, -unless otherwise
especially determined in these Statutes.

(i) THe Foundation Council may also pass resolutions in

writing on proposals. Such circular letter
resolutions require unanimity of the members oc the"
Foundation Council. Substitution is not admissible.

(i) The "original .-nsmoars" cf -the Foundation Council, as

defined in lit. (a) above of tha present article, shall
have a right af vetc as ta any resolution passed by tha
Foundation Council.

Article B

Powers
In {furcnsrancs oc tha . "ocegoip.g csjeccs and purposes, ths
Foundation" shall have, .in 'addici.cn co and not in licnititicn of
the powers canfarrsd upon it new or nereafter under cne
provisions of thsse Statutes or tha laws oc Jersey or aay ocner:
applicable j u r i s d i c t i o n in fcrca from time co time, the powsr to
recsive properby by deed of g i f t , l/ill or otherwise; to snfcer
into any lawful transactions which are conducive ta the
.: ) management of i t s property; " to maintain and increase the sarne;
( {•-.• to purchase or otherwise acquire any property, r a a l , personal or
mixsd. to own, hold, mortgage, pladga. s e l l or otherwise dispose
of SUM craoerty,- to invest and re-invast i t s property, to
borrow money, to guarantee the obligations of companies in which
the Foundation has a, d i r e c t or indirect i n t e r e s t , and to make,
execute and deliver promissory notes and other obligations of the
Foundation, for monies- borrowed or otherwise, and to securs the
payment of any such obligations and, in general/ to exercise such
powers 3nd perform sucn act3 is the Foundation Council now or
"hereafter may deem to be necessary, proper or advisable to
effsctuata the foregoing cr incidental to tna powers of the
Foundatcn or conducive to tha 'attainment of the objects and
purposes cf tha Foundation, and. to exercise such other and
furcber powers as may from time to""'time bs provided for in tne By-
Statuces.

In particular the Foundation Council shall have the power tc take

the necessary steps and invest in wnatsver ways cne Foundation

24
003863
 Council Einds necessary .to ensure that the initial capital
crouidss sufficient income for the activities of the Foundation
while at the same time counteracts inflation and remains
relatively secure.

Article 9

Persons entitled to sign. Manner of signing

The Foundation Council determines the persons authorised to sign

on behalf of the Foundation. The initial rules in this respect
are set by the Founders in the Deed of Formation.

Lawful signing on behalf of the Foundation occurs in such manner

that the signatory or signatories affix the signature to the
Foundation wording.

Article 1C
Of f.icers
Except as hersin expressly provided with respect: tc the President
and certain other officers, the officers, employees, agents and
other representatives of the Foundation and their tar.ns , powers,
duties, metircd of selection, remuneration and other relevant
provisions, shall bs as :nay be_£rom time t2 time provided by the
Foundation Council's resolutions or in Ey-S'ta tutas -
Article 11
Susiness VSJC

The Eusiness Year coincides with the Calendar fear. The first
Business Ye»r shall however begin on tha date of formation of the
Foundation and end on December 31st 1992.

Article 12
Auditors _
The Foundation Council may acpcint an acknowledged auditing
agency. The auditors shal submit to the Foundation Council a
written report concerning their examination and proposals. In
addition, tha auditcrs shall supervise the compliance of all
involved persons with tha statutory provisions and any contingent
By-Statutes of the Foundation.

Article-13
Supervisory Body
The Foundation Council may appoint a Supervisory Body composed of
at least two members who shall be in charge cf controlling the
management =nd investment policy of the assets of the Foundation.

25
003864
 The Supervisory Ecciy shall have the right: to request the calling
of meetings of the Foundation Council whenever necessary.

Article 14
Obligation to qiva information. Secrecy

Upon the written request of a Esneciciary, the Foundation Council

may give him information relating tc the Foundation, inasmuch
that i t concerns his awn r i g h t s .

Should, however, the Foundation Council be of the opinion that

such information tniy be used with an abusive or unlawful intent
or be detrimental to the Foundation or tc other Beneficiariss,
the Foundation Council .-nay, at its.own discretion, refuse to give
such information.
clothing whatsoever concern-inc the Foundation, its legal
relation-ships, Including these sCatutsa and/cr contingent By-
Statutas may be drawn to the -attention of outside parties,
especially foreign authorities, unless tha Foundation Council
considers such information tc be in the interest of the
Foundation or i t s Beneficiaries.

Article 15

Forfeiture of the Riahts of the Beneficiaries

hncsvar challenges or contests this Foundation 35 SUCH, i t s

fcrnia con or i t s sxistsnce, Statutes or'Dy-Statutas, donations as
well as resolutions duly adopted in iecorclance with tns law.
Statutes- or By-Statutss• of ths Foundation, wholly cr pertly,
d i r e c t l y or indirectly, shall lase a l l beneficial interest for
himselP and his successors, and this retrospectively.
The bringing of 2 law s u i t , the filing of a Writ before a
-^ domestic or foreign authority, shall be considered the beginning
of such proceedings to challenge the Foundation.

The Foundation Council may uphold the beneficial interest, when

such p e t i t i o n is_withdrawn : r action i s discontinued absolutely.
"\ Article IS

Amendment to the Statutes.

Issuing and Amendment of By-Sta.tutes

(a) Tha Foundation Council shall be entitled to amend

and/or supplement the Foundation's statutes with the
exception c: the Objects "Clause (unless the amendments
or supplementation oc the Cbjects Clause only refers to
the conduct of 3 commercial or non-cc:nmercial
activitv).

26
003865
 (b) Upon formation of ths Foundation, the Founder anc
thereafter the Foundation Council shall be entitled tc
issue By-Statutes. By-Statutes to be issusd by the
Foundation Council may not contradict the Statutes or
ths By-Statutes issued by the Founder. Ey-Statutes
require in order to be valid the written norm and shall
be signed by the Founder respectively by all members of
the Foundation Council. Such By-Statutes have the
same legal affect as the S t a t u t e s .

(c) The resolutions mentionad under ( a ) and (b) require

unanimity.

Article 17

Validity a t Law
/ j
I n v a l i d i t y of any provision of the Statutes and contingent By-
Statutes s h a l l not affect the validity of tha Foundation as such,
nor shall invalidate ether provisions.

Article Ifl

•Revocation and Dissolution of tha Foundation

Ths revocation of the Foundation is not permitted.

(b) Inasmuch as tha circumstances under wnicn t.~e

Foundation was fcrmed so change that tha Foundation
ebjeecs may no longer be sensibly achieved, the
Foundation Council shall be authorised to whclly or
p a r t l y dissolve the Foundation.

Such resolution by the Foundation Council requires the

<:O censent of all i t s members.

(c) Upon dissolution of the Foundation the Foundation

a s s e t s shall be transferred cr caused to be transferred
to an organisation having the same or similar purposes
as this^ Foundation. Such organisation .then in
existence 1 or which the Foundation shall form or causa
to be formed may be in any form and in any jurisdiction
in the world.

Article 19

Legal Representatives

The legal representatives ahall-.be appointed by the Foundation

Council. The i n i t i a l appointment i s made by tha Founder in the
Deed of Formation.

27
003866
 MUWAFAQ relief iorries in joint operation with UNHCR

*^i
K*

ik
s.
r...
-V: __•-._!*.'-^^-{..V ^ ^ - ^ . . ' , , :l^.Ji.:

X1
003867
MUWAFA.Q relief lorries in joint operation with UNHCR

v •

003868
1
 TOo TO Beat Hit!
Unclassifi&d

m Document ID: KTS19970522002331

Eatr/Date: 05/22/1997
Version Number; 01
SLegloni Near East/South Aaia
Sub-Region; South Asia
Catmfcrgr: Iran

Topic; Terrorism
Somrxs-Xhifca: 07/33/1995 ' _•
Islaaaic-Ffaiaaaciffir Sia-l^adla I&tarricrred on Sudaa, ixan'Ties
u NC24062QX99tfUNKNOWN
\BBJS Heport] CasfoSjQSB AL-YUaUFitt AaWcaa n Juae 1996 aapagas 25-2? cocoas a3,300-
wori report on aafaitcr«Tflw-!<a&tJ*amah.Bie-Ladia, -pdio was tecBofly nxpattedfixcmSudan. Doe
interview, v/trioh-waA cxyadad&d'by Fayizah Sa'd, illcgctOy tonkplacaiaLnndoai. Tha. dxta da not
apedfiai • f»
Ictixoducxng ths in£stvlew, Sa'il dijg^rihjs Bisi-Lftdia. is "fte aiaia,ficaacaerof Ike filaidaiBfintalist
.terrorist oprortliona* b.tiia-Aralf^^^ind tiw ^woddriloxgft. S ^ ' B ^ S iterr^Bia-Laxllnsr aloxtiry
villa.in "Wembley in Jttocrfii Laadao. I t e ylHs-la goiis&t£\rt tlax^ mm^ o£gm^ m^ o£&em
"Afgksnt AraJbs" soil fbxs3gnaa£. Sha oaattoaw tot ^rmnbtng- hlm^recjuSxed pussJug throtigh several
seer etaries befhra reaching fta last harrier> hh pchraie safasfctty KhalLL11
AcGQxding to Sa'd, Bai-LadiatootHia iitlilativeaod started talking about himself Bb said, ^ cany a
Sudanese dipicutiatlc paaapan; ustng a pseudonym/ "&$y sjttce ia UaajoaB. Bia-L&dln, I am 44-yeats
I-wmaiasld^iflTnttey.havtBgl^tterhigdombco^^
mocilaQ n£rv?. I w ^ <vrais±^ la 1zadi^ Duxi^
> m^chaats "wha Jiad csc^psd-fiom. &*n attiw otr&rcak of •flw Jiaqjiau.^wst, Dtalng thst tim^-Axab
Tyn^Mh^in stasted'guing to AEgbanistan "Wtft.fiiahfi^? of ti»^7.S. GlA. •eifijlcJi ^ t trp atacarftcansp ia
IstanlmL Vohictoera staped la tbc catnj> and -«ti»fijjrad£s3»altii^to A ^ ^ n i s t ^ T
Bin-Ladin conttones ttat *i _ ^ _ So Itnd. q^rmercljairfs
Das tn tiw sjjtet» af our work, ]
a a i n i y IraniaaitGBida decided to travel to Bad to riay.jw A'fgTi«yJ,«-ea». fa tk» tinHglw^^rt^ -mfe mtppllctl

actpiaiated'wifiiiteoe $uds3a©8ali*iho were xosstnixa oftbsNatlanBrSlaauc Front fNIF] & by

Haiaa al-Turaia, NIF "=«« notfammraar ia Si«Jaa5^C^Qf ^ihssBSwdaaase-wMayomigmaiL

, [email protected]^C^SE0effaN_^ I y4^

o 003869
 was very bright aud polite. Ho convinced DM to Javest my funds In Sudanese projects, l b s al-BaqWr
al-Turabi coup then took place in 1989,"

B i j-adin camitrues; "At thai fane, I becama 'Wall^novtei among tfcfi xrmjaliidja, especially tta Arab
and Muslim ones. 'AbdaEah. 'Azzssi and two of Us SOM were HQfcd ia s. c«r tomb emloaoa in
hawg-in October 1989.1 feftmr life was mdanfer. Wiftthe btttatotf bf fca S ^ v ^ a a w j
limn Afghanisian, wa urujaHdin. felt tfcust thexo w a s attempts to liqmdais the symbols of "Islamic
Jihad,' especially as the informaiim available to os iudicsiediliaithii Mossd wasfcahindthe
assassination, of Shaykk 'Abdallah 'Azzam, swim -was & Palesoiriaa."

At this point, tha ini^riEWer picks up tf» story u fellows v*Bcfera Kabol feu to Uls Afgfaflu
rnxgaiidin, tJaamaij Bi»-I,adia visited Sudaiin April 1992. This was nothla first trip to Sudan. He
also vbitadifein. Oatobcr 1990. HB wsnfctn SudanwltiiHs feres Sodaaott fileada. Fromliaitoam
Aiiport tSusy took n. taxi to A s Green"VELase HoteL Oflft weeK lajB^ Tfeamali Bla-Ladin rentsd a
feenkbed apartment st IS Hayy al-'Amarai Street He and Ida Sudanese friends hagm. to study
projects iQTvfaidh ha ctraldL icvestMs ownay. He visitedtbtministdea ofiidafitrica, agdcutane, eaid
Trartft. l i e Qsneiral Bivaannisai Orgaoizailon was BOX estahUshcd yet."

The interviewer adds: TTaamah Bin-LJidin. says ILB posaeaaes a 'bachfilar's dagiea in pngfa wiring- Hs
smd Ssis Sudanese ftiead al-TaMf estailiiiiBd a. cunstnictLon coEMSsy 'fcdi esigagfid 3bi btSdisa xa&6%
htidgaSj and boaata. A meeting -waa arranged bttweeolmn andHassa al-Ttaabt -wk) fem^biben far
Imsch stMa Hotisa. A ^ S E hmcL al-TaraH told htm: We baw&agrwiito gi-ve you aE&a help you nfied.
Accorcijiialy, wefaa?mBccepfedytror membersh^ ia the NIF. Bin-Ladin paid al-TuraW S5.D0Q as a
tr>ftmivrrtimn fee,
\

q onsLstwi of-two floors. Ho n w i cms ilo or oa •. prfvafe o£Soe and the otius floor as bisfiviogqriJartsas.
He inspected tracks snd iractaca firota Germany Jn.» deal "wesfii SIS jnillf wx. On. &« teoMprqftndaticiH,
. of Hasan al-Turabi, the Stuiansse Government exempted Bin.-Ladin jfrom customs dnty cm t k a e
tfuciEaaaid-traEtais.11 " ,«._
Xhs intaroiewer contnmet: "BjtMioaa betwsMiBJn-Ladm and Haaan al-Turabi booarae strong. Mmy
Afghaa Arahs started arming in Sndaa ftomPe^war. Ai-Ttobatoldhimii^tolraiditt
govcEnroen£l3adeint333giftd"tiiiEi Sodcnesa regime trfSi these Afghans. Afiacprmowias •frnafiwai aid to
tile Sudanese Govcrnroentto spsnd on fiicss Afehaaa, ftelramauGovcmnjcnticnagsd an hs
•prpfn^w- *niwfiTn4grpgfr«tffQoveTOmeUt conldnot footthftbnifrccihieseisccyahjdiiii but si&a Bamfitimfl
tt cmild not expel tfrn"- Bta-Ladia tmdcjstocd fr^ he wis iBqun^d-to p«y'a snm"ftfinatifiy. He give

The intescvlewecesays: 'Tlia camsrfoicSifl&cQa^aoy setup 1^Bta-!^^

SOCWon al-TSialdl [defiaoce>road ff^Wp^ Khaitoum 'with Sfcandl sad 'Afbarah. Tha cost af tiip
project 'was BstiajatodaticuaarodsofirullicMaa of dollars ia addJMtm, 1 ^ Bisa-Ladia canmaay
aonsaroJ=biAihjs sl-StjthsjL cadSlanstiab, canals. Bin-LwS»and tha jaesdbanfct of al-TurahT* icooi act
TipilioKaitliBaiik3JiKb3rtoTOXLHaT?ai(it5ita 3iO millionterstsrd.tSyt bsnikf g capital In return, ha
acqcdrBd ane miTTinm fisdrt»Tm iiflsiiiOn.SiKdufeD.aiui'westasa Sudan'wfaick ho usfidfer agriraittDrs
aad to naxta aa.tiic.''

HiEi-tmerviBWES aAda: "Iil 1993, tiw al-Baahlr gavomnieitticqttfisttd a. loaafioa tTjaniaii Stn~Ls,di&,
•who ga"WB Hi an £8 miTHm, enf^-term lrw\ fft jtviy{yt+'«»i?wgT fa »" '"Tg1^' rift^rtnn ^f»^r fta gflfyg tupy*
eamjjty. At tha qpaaiB^f af the Part Sudan aewfttcport;UBwaah Bln-LadlaflonaiEd$2 £ m^inn » SLc
goes on. to say: ^a^nBhiiaBMtasaj^T^Ai^IslfflnicPoptilar CmifeiBaco, widch Is k M

,../(a«v3Ta.i=rTv?C:O SESSION KEY-=(XXFHQWWZPWL1V<3&CC^Qf0IRY-^J^DLE'-L2VIS5 11/4/5)

31
003870 ,. .
 annually and
ndfctteadedby all the symbols of the Islamic Rcatrtancs, even though t e has" raid £1' '
million rn cantrtbuticnis to"ftfi cao&nsica. UgaJnaH Bto-Ladlu lias more ihm one residues fa "

ys B t o - L a t o pnvate doctor « Ays*a il-Zmbxr!, *ba worted W t i i l a m k i a i i j ^ h S ^ S

jiassinaticm attempt agaiast Brsmdcnt Mufcarak in Addis Ababa, ia a "dose Msodata" of Bia-Ladin.
rianmh. waked inBin-Ladia's office in Cairo before IIB escaped to-Sudan. MuLanunwi Sliswd. al-
IslcobaiU this Vtrtkcr ofKhalid al-Iskmbuli, tlxc assassin ofEgaijrtka hcttsHsat Ajccwaf al-Sadat. la
also a. cloaa ajsoaiats ofBinrLadia. -^^n

Cotitinnins, fim ijdErdswar 3 ^ : ^ Y c m ^ to Yemenis coiuidcT B ^

IsLarmstmovKnieutB. Ha JiasbmLt seven piiv^reli^ousriaiditmMSal^^.alrDaii' Abvan sad
Aden. He has ecprsssed readmsss to troud with Bi» o«afimdaiSaa Idjmxic UnlvBrslEf la Tatzz 5a
Yaanru Biii-LacHn lias tiw with Taaq al-Fadli, the leadar ofroctremlstIsiamists Ja yaatan. Ha also
has strong tiea -wMi Shag^ck'Abci-^l-M^id. d-ZaaAsaL H® isftccus«iof opening ssvsmd Isismist
eaanaoiat camps in Sa'daL Hit reialiojia witfa.flia Yttmad Govwnmcatlum bemxeoaa situsi fe
acouscd Mm and Dtfaer Arah mmaMdin offcebfliBspoiuBalefiarialowing vji ottfauaallgiians ami
snaridngabotelinAdaiiin 1S9Z Hdcc, Bin-Ladin bas moved the Arab mgsHdfci.£ais Yemen, ta
Somalia to. a. move thai cost hhn S3 milliDBx."
l i efcrtervistwsEmismz ^fa^jLadiadfKatu^bldghtarelatlonsbfe^wttfaTJmgBg^
whomlae got to know through. apersaaeaflfldNldal AbU'rHgaa&j'^who Is also known as Alrawd-
E-Ua.'- Muhammad is a SyriaaitflliisiaL HB always aceampames Bftt-Ladla, hss lived x&hk him m.
StLdan, asuiis cam af&s leaders of tba Mtrdta Bpatiwaiood. !a Sjria-iifoeScaprfjaraiiHataHlL after
ikoL9ai evasjts. Sba nHda t h ^ Bli^Lai£a l a o ^ M Ii»plgy8 with !fe1akckbmdL and aha qnotaaHm
as sayisis ffaat 'lie "sviio tas fiaida cwas tilfi raqJBbidM!
The JHtsarTieTwec aa&a Bte-Ladis: "The PbiKppiao QovemmKttbas aaasacl you affhwadng ftc Abu-
Siyah organizsiioa and erf aettiuff up cdicttttSCcalia'diatwetatiiico'VKrBdiastysfflCi Xiitsresuhsdiniite
arrest of several Arab aaticnak, rn^W^ng ShafurRamaJ Yastt^ wto k juwnaod odfhlcnwlag' vp tha
World Trade Cealsr in New Ycuk in lS93lrt BfarLadin mxamtsi "To pet it sixBgtr, tbuo Bia-Laziia \
gsoiilisljmcixt's aid cav&cs 13 ennntdes. frylf1^^"! Albania, Malaysia, Pakistan, feNefearfsoda, \
Britain, Romania, Buaala, Tudttqr, Lebftuoo. hm, and scaaja Gulf coanfeiM wMc&iiians h sa need to
xa£niiaa.'*'WIi3i&viciouL3amilB oa bxff Upa, IJB adds tfesct "this aldj camea in parrfsolarfiomthe Btiman
Concern Izdamaticarul Sociely, -wiiick wa* ffaanded in. A^uumrtaa in U?SZ"

Tlia interviewer foea saystiiatBin-JLadtn wm ona of thefeundegaof fftaf, ^gety-wiAtfip^plp of t^

MQ^a, aoaa LAfdJ ff°?fny ^ •ogga*. ta* ^yaoBa^^iwciM aooiKy at neqra, maiai

Ladin says, "ysa, in otdsr ta ran icy tmataiag/1 AJfcsd If H» gresenea inLosdon ia cdrmecteamfethB
laughs mud MWS9 *»o, I smcaiamij^cciftECt^U.S.EmbawiaExHsioa.11 Sbs asks him. "exa't yon.
afadd-Qiai al-Ttrrafelxsill tend you over, ts ha did to Cxdnsr* Ha says: "It is possfbla, but t db not
ljva in Stadan rum. I toep mining aadl do not stay jppnn?mwat1yiK any country.1' Headdg; l a
g"C0Etai, Stuian n&ads ZQ&ntDrc&m Inesdit. I can aunts you thst my tLB^agcture £cdcu Sudaa ~wlH
ineviiaHy lead to tfaua adHspsa of fee gadaaoaa ecccoaigy.^ Coonlnifa^ hia jgtarvisw, ho aay? riiAC

tuha* <g Tiaprpemfng fri Sr^wn fa "s rrttTtiTr^ nf ptUjprrq and nrjptniimA ertTnu."

c&ottOrtatxan wte% octa* JXA Gitterrsfismt ca^pmams.

[email protected]^CCI_SESSIC»^S3Y«XOHqWW2I;^ 1 U4/$>i

• 003871 .
 *ur CONTAIN capYXlGHJXD WTZKUL carmc Am z>JS3E«»tt new is psotfmnzD
SXONOFTJmCOPTRIGHTOWmAS.

^@rv«tmv7CQ_aBaalONJ^«^XnJQ;WWZF^ 1.1/4/

003872
cn:al
 B'ANl'ONALTJI dUD U SAiOiJ^VU
BufJj : t l - I H - p * / 9 8 i a veaa H-IV- 27/95
d a r a j t v o , ol.o4.19"96 s godine ,

A-nntoaalui sud u dsrajevu. i t o s u d i j a oadovic " c i r a rjaaav-ajuii

van parn.icn.om postupku po zaJtitjevu *~umanltarne Qi^cnizacije
'•"'• •'•"••' ^mrT.nTnvii _ a 5 j e d i s t e t a u o a r a j s v u u l . Hadojke -L-akic i
d o a i o ^e s l i j s l d e u e

K J a 6 Bt UC

3 r i a e SB i z x-e^istra uumaiiitarna o r ^ a n i e a c l j a " WUIVAFA; FCUTTDA1

aa s j e d i s t a m u sariijevxi , koja j e b i l a r e ^ i a t r o v s t i a pod b r . R - i
93 , od 2g.-.J.o.1993. e»odine, k n j i g a 6 e t v r t a r e g i s t r a .
^

O b r l a z l o z e n j e

Dana 2 2 . 1 0 . 1 9 ^ ^ . god, u r e g i a t r u humanitnrnih organlaacija o p i s

Je medjunarod.no udruSenje MUO/iFAQ FCUT-ID.iTICK " sa GJediotaE u u
Kadojko Jjaki -. b r . b b . . -

Hana 2 ^ . o ^ . l 9 9 ^ « go-dine, ' " i r e k t o r jiBvedane Runsanitarne o r g a n i z a

CEAFIiC A TAD I d<j>stavio j e ovom sudu odluku o prebtank-d rada Huraa
itarne or^anizacije tre je batraaeno da se i s t i brisu iz r e g i s t r

OvaJ sud jeizvr§io uvid u odlaku pa Je utvrdjeno aa Ja doaeaeria

odluka o prestanku rad-e humanltarna orgsnizacije i da se sva
prays i obava ze vezane aa djelotok ovog gduruzenja ustupaju prei
uzecu lilSALA, d^o.o. SarsjBvo u l . Kemala apetaiiovica br. 4.p.

lz taSke 3 pomEJnute odluke ovaj sud je utvrdio da je ugovor o

preuziiuEiGju obdyeza. aafiinjen 03.09,1997. god'iae .

vr1 eud Je bez daljeg raspravljanja udovoljio zaiitjemi za bris-

anje i z r e g i s t r a , pa je doneseno rjesenje kao u izrecii
a
» » •

IOUKA ; j ^ r o b i v ovog x j a u e n j a dozvol^epjf i>' >?' ' ^ v ,

S U D 1, J A
j e zalba PBiH u roJcu od 8 dana V-i' J fc'^ ^ \ x . ~ ' p
a i a t a se podnosi putem o.vM^ajiii a. •',,•; :-V\ r nr ,,r/- > • TI

y* ' • / . ;

003873 3^
Vlbl SU3 If :^!...J-_VU|
Sarajevo, 22.lo.19v>. ^oiin-j

VIi-1 ilUJ; U o.^{C-»J:iVi;, u vijacu suufc^vljenom ad -iu-iij^Sa^S^SalJcu i

predsjednika v i j ? c « , suciijn Bcibic Sulje t Dodik I^n^ficn kiiO clano'
v i j e c u , u.llucujucl u vfcnparniunoic posuupfcu po z o h t ^ v u uauJUHiinOOt
UDSOiiiMJA tsUSARtK FOUNDATION za Ui'io u rii^iati-r kod ovorfQ aude, di
2 2 . l o . 1 9 9 i . jiDdiaa,; donio jo alijcdcfie

It .1 E Li Jti ZIJ i5
1. BPISUJii St, u ro g i s t or jaod.junuroclnih udru^Qndo ^od ovoga auclB i£l
Hadojke Lakl6.
Upls t1e l a v r s e n u xtjeiHtur aed t iunarodnih uflrviSeiiJa j;od reg.bro;
R-IV-Z?,^, knjiG6 £ e t v r t a , dana 2 2 . l o . 193.5- godinu.
2. Clldevl 1 suducl EiSDJUZI«W)DlTOa UUliXJi^HJA iiU>VAF/»B. FOUKDATIOII SU ;
- o b o z b ^ ^ l v ^ n j e iljokova, tii'ane, wbu^B, odjece i oa.taliia iiumoni-
t e r n i h a t t i k o l B irtvoaiB r ^ t a , jetimimn, izneaoiilim licimn 1 on-
tollm gr-acijaniiaa HQj-"ubllko Bo»Jno I HBrcsgovlDQ,
- cbazbdad^ivaaj'.' &xvedBfova zu yieenje, ufebjnpBnJe, izaav/mjy i bo*
platnu d i o b r l b u d i j u lEVjeets^aj daaopirjo, Kujigfi,. Drooura i drv
eog, i
- duvnnjo novcanili sr^dotteVtj,
v oatvarivanjo i osfeolih kulturnih, nsufculh, vjorskih i drugih ci
l j e v a i BUdrza^a u skladu GO Utftuvosi' Raiubllke BoGa« i Hercego-
vine,
- izgraduja uXolaklh objokwta, akola, b o l n i e a , kiinika, prBduteca
i s i . , .fctto I oatol& djelotooati ko^ioa sa neiJOBr^diio i l i poorad
zsdovoljavaju potrabaj slroiaaDnih, i e b j e g l i c a , stunovnititvu, ko
I Srfcavu prirod^ih naurafca,
- organtEOVJindQ» ^njogucuvunje i l i uSostvovan^e u pryBniBuci,"Ji SBQ
tanaka, triblnn^ pradavanjfl* l z l o i b i kno ± vrfcenjtt drugib Javnl
manifasfcacljn xi^akladu UA aakonom,
*- EsposIJavaajo neophodnih sluibeniko 1 poBoftnug ouoblja, koja xa
hti^BVQ priroda ponlB,
- poduainanjo i iavrfiuvatijo nvih dobrdtvoi-nlh diiimucfci u ekladu s

5.' MEDJUKJLRGDNU UflRUZiSNJii; UUttAfAK ITOUJJAglOH u e i l j u uticanja srt'd-

stava zu vrl-enje avoje oktivnoHti obtivljace djolatnont prodvi-
djanu avojio Statutom B. u j^Jcladu oa ZtOconoFi.

4 . UfflHUNAUuDMO aflHUZKNJi MDITAFAK. FOWDAIIOJI djoluje na t i r l t o r i j l

Republlka Boona i Hercof5oviaaf a danon uplao u rctjiatBr kod ovo-
Bud a s t i p e svujstvo grad^nnnkog provnog l i e a.

5« HSD.TUNivuUDlIu Ui)HUi,£f?Ji; MUflTAFAK FUHDA2I0N dulno je u ro^u od 15

dana p r i ^ n v i t i uvone nuau svaku pronjenu S t o t u t c i Frograoa radj
Irojje naStRou naJ:on donouenja ovaga r j e ^ e d j a , ' o^cosno duino j e
posfeuiiiti u ekludu aa ciauoa 15 utav 5 Zakona o udi'uiea^u grades

003874
 b.' L-lca t j v l a a t o n a ! zo za£ituponjf i ]>reasi;nvljanje UJOJUlUIiCDNuG Ui)l-ll-

- AYAD1 CHA.17IK, a i r a k t o r - i
Ft? - Dlpl i n g U.:.,V.\D WOV1»'., i.rediijounik Udruienjn.

C B B A Z L C J i HJ b
HbDJUSAKoDHu UDRU2'LjJJ.". WkA?A& FUSDATIUH podaijelo je UVOEB eudu.
dana I b . l o . l 9 ' i j . feodine zahtjav sa r«{ji3tracii)u 1 upic u. r t £ i e t n r
madjuuiirodrilh udruicnja kod ovosa suaa» TJz zohtjev je prilozenc do-
hruaeat>uctjo /.radvidjexict Zalconom o udruzivflnju Brad Jans i Xravilni-
kon: o Jedinntvanvia regi^tru udruionjo. . i

i:uo u i a r u c i ovoga rjKoenja.

PCUEAj ipodnosllnc ua'htjeva i Viuo Javno tuailaotv9t*TO3gGTisjBvlti

£albu Vrhovnoo nvAu R Bill, u roku od 15 clono, D iratu BB pod-
noui ovome sudu u t r l prlnjurlca.

003675
 J
/3A».

On the baaiB of this Statute regulations of the International

humanitarian organization HUVATAQ FOUNDATION,and in accordance wifh
Law regulations on humanitarian Activity and humanitarian organizatior
RBiH (Official gazzette No 12/95,and with the aim of the aucceBBful
work in the region of the Sebublic Bosnia and Horcegovina, i bring:

D E C I S O N
on establishing of the Head Office Muwafaq Foundation for Hereegovin*

Article 1.

The Head Office Muwafaq foundation is established for Hercegovlr

with residence in Konjic, in the atreet Vinka Boraaa No 3l.(Localit3
SIPAD). . J
The Head Office Muwafaq Foundation fo ^ercegovina develops itE
activity in the areas of communities:Konjic,Had£i6i, Jablanica ,Prozox
and Moatar,
The Hoa.d. Office Muwafaq foundation for Hercegovina has ita
offices (Sub-offices) in Konjic,Pa&aric ,Jablanica and HOstar.

Article 2.

The aims and tasks of the Head Office Huwafaq Foundation for
Hercegovina are: I
- Providing medicines,food,shoes and clothea and ather humani-
tarian a r t i c l e s for the war affected people, orphans,aick and handi-
capped people and other oitirons in HBiH.
- Construction or financing of tha construction f equipping and
guiding institutions for rendering services of the social ,children
and health protection education, schooling and training,science ,
culture and sports *nd aothers.
- Starting and carrying out production or other activities on
the base of humanitarian investments for humanitarian purposes.
- Help and oupport in a l l forma of oommunication, transport and
other aervicee for humanitarian purpose ,for needs of individuals or
organizations which carry out humanitarian activity respectively.
- Giving direct psycho-B'ocial and material help and support to
tha self-supporting mothere,children without parents'car© .sick person
with chronical diseases and the wounded, invalids, elderly people and
children.
- Supplying stationery m«ana,print ing and publishing and free
of charge ditributing reports,magazines ,books ,brochures and othera.
- Giving pecuniary aid,
- Healiasation of anther cultural,scientific .religiouB and other
alma and contacts in accordance with the Constitution of RBiH.
- Organisation, enabling or participating in organizatdon of
meetings,apeak'a platforms ,lecturoB,exhibitions as well ae carrying
out the other public manifestations in complianca with, tho Law.
- Undertaking and accomplishing a l l charitable duties in
accordance with the Law.

003876
 Article 3»

The authorized person for representing of the Head Office Muwafaq

Foundation for Hercegayina is Hr» Heyri Karim,the director of tha
Head Office iMuwafaq Foundation for Hercegovina.

Article k.

The director of the Head. Office Huwafaq Foundation for Haroe-

govina will organise and develop activity in Hefaegovina region ,in
the Republic Bosnia and Hercogovina,in accordance vith the Statute ,
programmoa and other aota of the Huwafaq Foundaiion,then every month,
he iB to deliver report to the General director'1 of the Huwafaq Founds

Article 5.

The D i r e c t o r ' o f t h e Head Office Huwafaq Foundatioa for Hercego-

^. v i n a , H r . Meyri Kerim i s obliged to hand over t h e requeBt immediately
••.v/— t o : Higher Law Court i n Sarajevo r e g i s t r a t i o n i n the r e g i s t e r Huwafa
Foundation-Head ^ f f i e a f o r Hercogovina, and t o a u t h o r i z e d H i n i s t a r y
RBiH f o r i s s u i n g the p e r n i i t i o n for c a r r y i n g out [humanitarian a c t i v i t i

Article 6.

Thia Decision cones into forca with the day of bringing i t .

i
o Delivered:
1 I MrMeyri Karira GENERAL DIBECTOR
1 x Higher Law Court,Sarajevo,RBiH MTJWAFAQ FOUNDATION
1 x The authorized Hiniotry in R BiH ± chaflG
J
1 x a/a

003877
 T E H N T
OF THE AUTHORIZED PERSON ON TAKING OVER HIS OBLIGATIONS
I
I,Moyri Karim,pHQaport number-identical card:
authorized parson for representing Huwafaq Foundation -Head Office for
Hercegovina.,in RBiH, declare that I willact in my work according to the
Statute regulations- and other acta of the Muwafaq Foundation,as well as
written or oral orders from the General director of the Huwafaq. Found&t
and a l l in accordance with the Law and in connection with'this I take o-
a l obligations and duties and righta which ariae:| from tha decision o;
establishing of tho Head Office Muwafaq Foundation for Hercogovina am
the nomination of the director.

r--
STATEMEMT QlVEN BY

H r . H e y r i Karim

i..

003878
 . . ' • P o r n No 5

"NAME AND RESIDENCE OF THE FOREIGN HUMANITARIAN. ORGAN 1ZATION -.

HUWAFAQ FOUNDATION -HEAD OFFICE FOR HEHCEGOVINA

M K0 NJ I C . 1
1

No'j 106 / 9 5 . . '

Datum: 1 2 . 0 7 . 1 9 9 5

REPUBLIC BOSNIA ANDHERCEGOVINA .

THE MINISTARY FOR. RETUaEJES AND ' I • ' ' " '
:
SOCIAL AFFAIRS • • ••

B E Q U E S T
for iseueing the permission for perfoming the humanitarian activities
on t e r r i t o r y of the Republic Bosnia and Harcegovina
t
HUMANITARIAN ORGANIZATION: MUWAFAQ FOUNDATION -HEAD OFFICE FOR
(v-' HERCEGOVINA
PROJECT: HUVAFAQ FOUNDATION-HEAD OFFICE FOR HERCEGOVINA IN 1 9 9 5 .
NAHE OF THE PROJECT: SOCHI. AND HEALTH,EDUCATIONAL!,SOCIAL-DEBELOPING
PRODUCTION PROJECT: j
|
( Summary); a ) E x t o i l d : L n g o f t h o h u m a n i t a r i a n a i d \.o t h e c o c i a l a f f l i o t a d
c i t i z e n a o f thB RBiH.in t h e a r e a of Hercegovinasrisfugaea,
orphans,educational and upbringing inBtitutiona 9 health
^ ^ and a o a i a l i n s t i t u t i o n s , l o c a l communitieo,public organiza-
Wm tions and citizens'associations, Islamic aesooia-tions and
others.
b)Organization -giving coutaes MF:Engliflh,Arebic,French and
German language ,then courses for typing,sewing,draaamaicixig
information, the coarse for wood-o^.rving and tin-Bmiths,
then the coutso for training of the adminiatratiTe aacreta;
for givin the firat aid and the course for nuraea.
c) Organization for producing health food for humanitarian
needs*
0 • ,•
-' Responsible for 1
realization: Diraotor HF for Hei&egovina ,executive of the projeat,
instructors and OffiGe staff.
Local planned
personnel: According to the sistematization of the Office HF for " e r -
cegovina in 1995were defined the following work places!
Executive of tha projecta MF, Secretary ,parson for in-
formatics' -interpreter(translator) tcaBhier|WrtLrehouaeiaan,
1
driver and and office hostess.
Categorization
of beneficiaries: Refugeea,ophana ,social afflicted citizeas,patients in
hospitals,pupila an* teachors at echools.ratired' and.
other citizena in HBiH.
Number of the • j
wort executera: Tan workers are employed indefinitely and one number perd-
odiclly ,depending on needs. j
Araa. of a c t i v i t y ; Republic BiH-rogion Hsrcegovina :(Connnunities:Konjic,
Jablanica ,grozor 1 Hadzici).
The planned finan- 1.570.000 DM
cial means of the
projoat:
^ ! ?la^ed.!XpS^itUr<!a . / „ . „ « , . lease,business travel0??79 /o
BIN LADEN, USAMA

Home | Search | Contact |

I
Wanted by Interpo! \
BIN LADEN, Usama l
11 December 2001 I

News
Interpol
mm 0. .-*•!?
' 't
Terrorism
Wanted
Search
Recant HH&^.REEHS'*]
mm
Children and Human
Trafficking
Works of Art Legal Status
Drugs Present family BIN LADEN
Financial crime name:
Forename: USAMA
Corruption MALE
Forensic
Sex:
Date of birth: 10 March 1957 (44 years oid)
Vehicle crime
Place of birth: JEDDAH, SAUDI ARABIA
Regional activities
Language ARABIC
Information
Technology Crime
spoken:
Weapons/Explosives Physical description
Criminal Height: 1.95 meter <-> 77 inches
Intelligence
Analysis Weight: • 65 kg <-> 143 pounds
Colour of eyes: BROWN
Colour of hair: BLACK
Distinguishing
FULL BEARD, MOUSTACHE, MAY WALK WIT
marks and
CANE
characteristics:

Offences
Person may be dangerous.
Offences: FIREARMS AMMUNITIONS , MURDER,
TERRORISM , TERRORISM CONSPIRACY
Arrest Warrant SOUTHERN DI5TRICT OF NEW YORK, NEW
Issued by: YORK / UNITED STATES , TRIPOLI / LIBYA
ARAB REPUBLIC

Linked with
H Name:AL Name:SWED
SHEIK
CHALABI
AHME
FARAJ
SAUM
003880
 Page 1 of2

Saudi money aiding bin Laden Businessmen are financing front

groups
USA Today; Arlington; Oct 29, 1999; JackKelley;
Abstract:
More than a year after the U.S. embassy bombings in East Africa, prominent
businessmen in Saudf^Arabia continue to transfer tens of millions of dollars to
bank accounts finked to indicted terrorist Osama bin Laden, senior U.S.
intelligence officials told USA TODAY.
Secretary of State Madeleine Albright is expected to raise the issue with Prince
Sultan, the Saudi defense minister, during his visit to Washington next week.
Saudi Arabia, the main U.S. ally in the Persian Gulf, has pledged to fight
terrorism.

*-_ According to a Saudi government audit acquired by U.S. intelligence, five of

Saudi Arabia's top businessmen ordered the National Commercial Bank (NCB),
the kingdom's largest, to transfer personal funds, along with $3 million
diverted from a Saudi pension fund, to New York and London banks.
Full Text:
Copyright USA Today Information Network Oct 29, 1999
WASHINGTON ~ More than a year after the U.S. embassy bombings in East
Africa, prominent businessmen in Saudi Arabia continue to transfer tens of millions
of dollars to bank accounts linked to indicted terrorist Osama bin Laden, senior U.S.
intelligence officials told USA TODAY.
The money transfers, which began, more than five years ago, have been used to
finance several terrorist acts by bin Laden, including the attempted assassination in
1995 of Egyptian President Hosni Mubarak in Ethiopia, the officials said.

Secretary of State Madeleine Albright is expected to raise the issue with Prince
Sultan, the Saudi defense minister, during his visit to Washington next week. Saudi
Arabia, the main U.S. ally in the Persian Gulf, has pledged to fight terrorism.

According to a Saudi government audit acquired by U.S. intelligence, five of Saudi

Arabia's top businessmen ordered the National Commercial Bank (NCB), the
kingdom's largest, to transfer personal funds, along with $3 million diverted from a
Saudi pension fund, to New York and London banks.

The money was deposited into the accounts of Islamic charities, including Islamic
Relief and Blessed Relief, that serve as fronts for bin Laden.
The businessmen, who are worth more than $5 billion, are paying bin Laden
"protection money" to stave off attacks on their businesses in Saudi Arabia,
intelligence officials said. Bin Laden, whose family runs the largest Saudi
construction firm, has called for the overthrow of the Saudi government.

003881
 Page 2 of 2

The money transfers were discovered in April after the royal family ordered an audit
of NCB and its founder and former chairman, Khalidbin Mahfouz, U.S. officials
say. Mahfouz is now under "house arrest" at a military hospital in the Saudi city of
Taif, intelligence officials said.
His successor, Mohammad Hussein al-Amoudi, also heads the Capitol Trust Bank in
New York and London, which U.S. and British officials are investigating for
allegedly transferring money to bin Laden. Amoudi's Washington lawyer, Vernon
Jordan, could not be reached for comment.
Mahfouz's son, Abdul Rahman Mahfouz, is on the board of Blessed Relief in Sudan.
Suspects in the Mubarak attack are linked to the charity.
Bin Laden faces U.S. criminal charges for allegedly masterminding the 1998
bombings of U.S. embassies in Kenya and Tanzania that killed 224 people. Bin
Laden, who is in Afghanistan, denies the charges.
Saudi Ambassador Prince Bandar bin Sultan declined to comment on the reports.

Sub TitFe: ' " " L™AL kclitionf "T " """"'
Start Page: 01A
ISSN: 07347456
Sub j ect Terras: Terrorism
Finance
International relations-US
Geographic Names: Saudi Arabia
Personal Names: Bia Laden, Osama
Mahfouz, Abdul Rahman

Reproduced with permission of the copyright owner. Further reproduction or distribution is

prohibited without permission.

003882
 f/r.

maintain snf public record erf tha

The Guardian
Raising money Muwafad.ftrandltion.OSICIBJJ there My
Jr ittriu itrufiuured u afinancialmist, it
woukl not require to b«regfstsredu all.
Wednesday September 26, 2001 Muslim relief Th« Mmraikq Bwudstfott said its otjjsc-
tlvaa lnduded tha pruvtrion of cashfarei-
groups caught ucatioa end pobllsbkutbocskiiiid video*.
In February 1S93. document* *hffw e.
.Uuwafaq Foundation office In Somalia,
m crossfire whew uM-Aia<rlcaa bbunl«t fighters
wora irrtvingfrctn adsfabouiins Sudan.
David Falligtcr and Jamie Wilson But thli limn Its heiufaju«xt£« were
rwxirosd is befog In Delaware, a. US sfcsie
|vro worldwide IiUmlc relief with on a of tfac cnuntzy's most relued
orpLnlttUon* — Mnwaiiui and corporals dbelosurs taquirtensatg. It
Mercy Intenutlonid - i n f t s •hat IB September 1998.
focu" of repiktad dalnu that
lomc of tbrix supporters hava Ubalatrft
llnij whh Oconui bin r,^"i Another Htrsrafuj touch, w u net up in
Bat a Gtisxdlan invezUgidon Into thtlr Ethiopia. Curing lbs 1890s, branches
orijdni «sd the controversy thst h u ror- appeartohirre been wtupJaihuBaJkana
roonded them ibowi her? difficult tt li to where iiddr tasaafindphens numbs nt are
dltentiuislD Lnnocsnt chirity otsnnlsa- recorded for the Muwaf&q Fbnd&cUc In
v _ ^ lions trom local sroupt which hxn besm ZajjnJj, Croatia, and also In Split, "Ursa*
Inflltrarfil by Bin Laden alpnartenj. Prss- In Albania, SknjicfaB«raiii,Zeaica,ind
likntBuah nuyluTa dlfflcilltylnniiklnff SsjBJirTD — as well si in Vienna, Aiutrls,
BtlcibJsaisartlonatliathacaiiwBsatrir tnd Slejcn in'Gemuny-
QQ tsrrorLrt BnMCB by proscribing or- The complex ind dfieentrsIUed itruc-
STLoJaailcmf sot]frctrinfibank accounts. tura n t u u out*Ida Invustljation of tho
The ors&niialloni collect money from. clurityU difficult.
MualLn supportar* around the wnrld, la July 1SME, bowena; &e organlsalloa'g
including wwithy Saudi buaiaesameB. nimtinsnrEd In Africa CoufldcnUajBrhnn
OIHI sycJj grenp •**» let np la tho Itle of the masaaioe publlshtd an wtlclo abort
Man andirubiequanOrtoJen«y— bo(h the attempt to ussislnato FruidnDt
fivonntd ottibor* btuHow efferfjij Wubartk of E^ypt u be droretotha air-
leertcyto companies. Tbolr accounts urt. sort. Tla Sudaness sarerozneot and
not avoilabls for inspection, making isLaralit orssnkfttlonj were aurpfcted,
acrutiny 0 / theirfinancesdifficult. wid the DttJflasiiiB mcntlcin©d tiuU one trf '
In June TPS1 Muwtffiq. (ilo) Lid waa s ei the suspecta dsimsd to bavs worked far
up In the Iclf of Mm, a. Oxhsvea whtra MuvrafiLqinEtMopts.
"non-reaidEnt"finnscaa crcld paytes bsat This daira, wtikb tamtil oot to ba £tl»e,
tnd rerulinf flaanda] tnfeirmiHon. Its dngj-ly putJocaJMurarjiMl rtsif In Mma
backer* wsra n«ned u * group of Saudi tiansffir. [All Sudaneai chuiilca, Including
InvestorsfiwcaJeddfth, Mirwg&q, v u i inbeuquentl? crpoilbd
According to documenta dl*clcacd in from Ethiopia]
Itsaiprocjidlngj, oparotlont Utd already AprntaissdiIbeliultbcsjmlntoDdoji'
br tim orgaoiiallon'j 3audl tnisteas,
SUTsmmenthid taken power In 1968 sad ifhidh tmatoaiif ended lix years lutsr
Sudan had becoma a bs^a for Intern*- idth a statement of apolocr by i f r l a
rfodai WimLrt Dptirstiaaa. la 1W1 O*>nsa. Confidential rddaui In the high court
Ua I^deo aiorad then from 9 u d l Ar»- AJte tha atitattalSSSrf RjUitdlfausrf
Wa. By iflflS ha n i reporwd to h»Te Mt for (hefirstWorld "Crade Ccnirobambtns
up fi netvark of durltabUi trrftnlutlosa. inNtWfoA, tho PaW«binJ poll es raided
Habrotdenad'hU ambitloniifromehlp- thalocalciBi^ofMuTTBfwjtaWamabad,
plngfttudi tad tapplleatonujahedln la and tiuisa of B second chtrifj, Jfary In-
Afghanlitsn sad yniistan, to backiag tarn&tloaA]; rtjijtartd in Svitzeriaiul
emiiaitlEd Uluniits, partitalitiy la TbelKad h«ad oCMOTntfiui Aadr Mcfaifi.
Boucia, Zoatrro andAIbtnla. w held In pducmforsararal moatiw
bc&ra halna reUfcarad Trftboul dwrs*. *o-
Bkmrmi " (VT'ltog ' 1 f!1» TffitniTmTmrt tmayar Ihrhntfi
But did UuTrafaq b*TC anylbLas to da organiut&xuL FarruHj Sirlm QurastiL
with this? Its Saudi tnittei* Esy not Tiwy Mr Qureahi aaJd the besd pf Mercy
ay their object} ara ilmphy to relieve IntmuttlasslZahki Shaftli, k»dtoldJiha
ftmlna and w tuSering. the polka Lrw&rtisstloa w u ipsifcad
Tha charity^formalBtractortfii vsrj because TfaoaeCitad tsade » phona csJI to
totored:toH«yl99aftdescribedIbalf in the Unxcy.offlcss. THers Is no tvideaee
docaitiKiti-wtth inr»r «tnjctura u the •Matey hadBay.ktvol'wuigat In tha grlroaa.
Mnw*£*qFocBd*tlaD based in Jersey but MuiTaJaq'e plaaa to build two 93m
focused on PaJciiLan, with officAi In (£am) hostelstatm Itkmic uniTetsity In
III amahad and Pcihxvrar! Jdainabad had to ba aborted, h e UX&.
Jersey does not have a cnarlcles com- The naxi nota of controveruy csune In
mission, m the US. mainland dota, Febra.ai? 1S&8 wiisn a Ptria-biaed Arsi
riqtlirtnf chariueD to ng^tWiai submit ncwipipcr, Al-Wntm kl-Arftbi, (nibllshcd
ICCOUEU. The »df-tpTtnHDf offihoro wliat tt add wss aa Lntmisw wiUi Bis
WJUWJ, WIJOSB company aecracy l m and Laden, w!io by now iuui bean ocpalled
tai hpren jutua hiro attracted growing frtjm Sodaa aaa was ewEntailly ta«ylup
Interaatloiuil concern, iota not appear to jn Af£hJinlstan vM. Iha 'W!btH.UJ00J
 rr\«A

Tha offtUicro anUtlaa

Jaw1BB1 Muwnlaq LtdformedIn tte
loisofMao
; May IBM Bw Muwateq Foundation
(SQUtemdfriJen»ay
Feb 1B83 Uuve&q Chart V FotmSrton
In Bonw&a cfesra a hsadqusrt*re Sr\

Sranchss sat up in ksiamlo

fundamentalist trcuHoofieta
batwtMtn 1BBB «ndi8ua
ScalAMeen
Khartoum. Sodan
MOQBdSaNi, tkxndte
Addta/toeiM. EthJopta
Asmara, ErttrM

Centra* Asia
A/pTiantstsn
P w l w v , Pakistan <
Islamabad, Pa&Btam

Zftgrab end BpSl, CnMia

"Dnmn. ASbnria
8a«Jovo, Kor^c end ZBWJO,

Vienna. Austria
Slegem Qarmany

Bin Luien tkted the Muwof«q Society Arabia, to finance chaxitlu. Tliese
In Zagreb u p u t <rf * nttwork of huin«n- Induded Muwafiuj. The present truwago-
BlnLad@3i Itaiian orjaoijetloEi which he mpport- mcat of the bank My Use report* were i n -
ed_ But there « u no evidence th*.t Ihli correct, &1«> and frtvttiou^".
claim- w u correct, ar UuU snjr of Lail y t i r Mercy IntertiitJomJ tgsin
tofmrnsHsit Muwsife}1* offldil* worldwide were entered the limelight. It win alleged dur-
•witre of his nuppo rt. tng Jbiiyeart trial of thfi IBM bombera of
ofcharfifes. Dorins 1997 Hniwi&q'i offica la Sudan,
for example, continued its charity work.
the' Nairobi find Dar es SaJaaxn US
embassies thafieviral of the bombers
Skit did In i UN report It w u described u hnple- had uied thit chwity as cover. Ho oyi-
m«il±D^ project! in heshh. educadon and dencc emerged to Implicate the charity'In
KgricoUure. ?ny wrongdoing.
hmm In Juaa199S,liawiStq became AUrjcet But clalmi that the charltiea have had
of Inquiry by ttioJFBI, ilthoujil there [a no links to Osams. bin Laden dearly need de-
do with IMs? evidence that thb led to any Sttspldonbfr; tailed Investigation — not least because
Ins conSnned. An affidavit filed by tgent the public needs to be reassured.
Its Saudi Robert Wright Df tbp Fpi durinf pro- Tha foundation's lawyers la London,
trust aaa ceedlusi to &dzs the uaeti of A impected Peter Carter-Ruck, iald last night It la
say not monevlHundererftirldamlitextremlsta,
revtsietl that a man linked to Mirnifaq-
totally untrue thai the Muwafaq fund sup-
ports Osama bin Laden. Our clients
hulb«eu nunaduatsrrbrUtitipporbir. strongly condemn the atrocity committed
Shortly ofterwirdc mona reports In New York and consider that such act!
Appeared In the US, laying t h a i a Saudi are totally Lrnmoral." They said rlielr
businessman, KhaHd bin MaWouz, had dlcnti did not collect money from the
003884
ftinneQed money through a bank In Saudi public
 Ocl-JHJI IO;!Saa Fra«-CHJCACO TRIBLWE T-381 c UUJ/UUB

Chicago Tribune ^ •: ».5.

Copyright 2001 Chicago Tribune

Date: Sunday. October 23,2001

Editiofl: Chicagoland Final
Section: News Page: 1 Zone: C
Source: By David Jackson, Laurie Cohen and Robert Manor, Tribune
staff reporters. Tribune staff reporters Paul Salopcfc ba. Jiddah, Saudi
Atabis; Stephen X Hedges in London; and Karen Brandon in San Diego
contributed to this report.
Money trail leads to Saudi, U.S. says

Financier dccie3 sending funds to bin Ladca

From a white-carpeted JLddah office, 11 stories above the snn-spsngled
Red Sea, Yassin Kadi ovcrscca a portfolio of business ventures and
charitable projects that span the globe. . v

'Dae Saudi's days are punctuated five times by prayer, and by racquetbaH
V ۥ matches with mfTinryKn) fricnrR

But over die past decade, U.S. officials sxyln court filings and Treasury
Department reports, the tall, soft-spoken inillioxiaiie has patLenily financed
a. web of terrotiai organizations.

cell of Hamas operatives recruited "martyrs" for tiicir campaign against

Israel.

This month the Treasury Department froze Kadi's assets, along with those
of 38 other people, charities and firms said to support terrorism. As
evidence, EL'U.S. government official cites a 1998 Saudi "bank audit that
allegedly shows Kadi's Blessed Relief charity tunneled S3 snlUan to bin
Laden, drawing the cash from, SOTQC of Thar oil-rich country's wealthiest
capitalists,

The bank and ihe inflceatial MaJrfoiE&mily timf founded k say no snch
t- audit exists, and JCcuB said no transfer of nsoney to bin Laden took place.
Kadi has arid he "will take legal action to strike his name from the
Treasury Hat, hut he had not done so by Friday. In a Letter to British
treasury officials, Kadi's lawyers demanded proof of hia links to terrorism
after his sccmrazs were frozen there.

Kadi's busness partaera include samo of his county's most prorninerit

business and civic leaders, and his standoff with Treastcry has exacerbated
American scrams with Smidi Arabia, a vital component in. the Bush
admiriirtradoa's coalition against terrorism. Of the 29 hijackers who
carried out the Sept. 11 »tfa°frft, U.S. officiats say they have Identified 14
&s Sandi cidsens.

By freezing Kadi's assets, and tbc assets of a Saudi based charity, U.S.
intelligence is suggesting that bin Ladea WHS backed not only by certain

003885
 %] !fl:ISifl Prosr-CHICAGO TBlBUtE T-3!B r IIW/UUB

Saudi nationals, but also by Saudi wealth, a charge thai angers residents
there.

Kevin Taecker, a former fmarntial attache to the U.S. Embassy in Riyadh

who now consults for Saudi companies, said. Kadi's incbisiaii on the list
•withour a disclosure of evidence will drive Muslim entrepreneurs .away
from the United Stares. "Everybody dsc is suddenly afraid their names are
going to pop up now," Taccker said.

"If a citizen in your country was accused of a crime and your govemmtot
said, "Sorry, we cannot tell you the "basis of the charges because that is
classified,' you would not accept h," said Jamai Kbashoggi, deputy editor
in chief of tb.$ Jiddah-based Arab News. "This ia undemocratic and. un-
American."

' Finances under scrutiny

Kadi denies any connection TO bin Laden. Buffdurinjjf the pasi decade, as
inielligence agencies worked to choice off the frnftncrpg oiterroiism,
Kadi's finances repeatedly have come under scrutiny.

Vl..' His extensive investment portfolio has ranged from a La Jolla, Calif.-
bascd diamond company mat runs three South. African mines to a Saudi
trading company that shipped medical equipment from HvAnston, KttiS has
endowed Pakistan's largest public hospital and a pathbreaking Saudi
women's college.

. He has advised some of the world's wealthiest dealmakera on the Islamic

propriety of their fax-flung; veainirc3, according to a. banker for one of
Kadi's business partners. And he ha3 helped £ c National Commcrcjai
Bank, Saudi Arabia's largest, develop Islamic financial instruments,

"We devised systems of leasing and ways to borrow maocy* mat could be
used by pious Muslims, who ara not allowed TO charge interest, Kadi told
the Tribune.
Bom to a successful Jlddah merchant family, Yassin jAMnHw AT^y^m
Jtradl~samei5xnR3 spelled Yasin Abdulla Azizuridin Al-Qadl—eamed a
• ' bachelor's degree in engineerine. He lived oa Lake Shore: Drive from July
1979 to February 19S1 when he worked as a 3tudeni trainee for Slodmore,,
Owings & Memll, the international architectural firm.

During the 19803, Kadi returned to the city often as vice president of a
fiimily company, Janrjoom, that represcmcdEvanston's American Hospital
Supply in Saudi Arabia, among other clients. Kadi, 45, will noi calk in
detail about the marry businesses he directed over the past two decades, a
rime when lie widened the circle of international cities where he feit at •
borno and cemented partnerships with Saudi Arabia's influential business
houses.-

Johann de Villiers, tj\™r*n*n of Global Diamond Resources, was struck by

Kadi's self-assurance and intelligence. '•

De VtlHers was introduced to Kadi in 1998 by a ranking executive of the

003886
4;
 fl lOtltu FrorCHlUffl TRIBIHE MM P.ltSAtt hsn
,/
Saudi bin Laden Group, a multinational consortium, of cosinesses owned
by the bin Laden family, which haa cut its de3 with. Osama bin Laden.

Wearing subdued business suits in meetings in London and Dubai, KaM

spoke Pngi{«;h with, only a slight accent. He never mentioned, polities, his
charitable work or his time in the United Siaiea, de Villiers said, His-focus
v/aa on business.
"Whenever ha agreed to do anything, he did it," dc VQlitrs said. "He was a
man. of his word."
"Through. New Diamond Coip. Limited, an offshore investment company
he controls, Xadi took stakes in Gfobal Diamond and another
multinational gem company, but both have struggledfinancially.Kadi's
S3 million stake in Global Diamond has shrunk in value to just S750,000
as the company's stock is trading at 8 cenrs a share.
Met bin Laden in. 1980s . ; '

r
Kadi said he met Osama bin. Laden at religious gatherings during the
t I 9803, But ha said the encatmiers were •unremarkable at a tima when hin
t>' Laden's battle against the Soviets in Afghanistan attracted tLS.
government support and donations from mosques around the United
. States. Kadi described Jamseif as a man of peace whose business conduct
and charitable donations bear out his support of values shared by
Americans.
But the chaxiiy Kadi ran from 1992 to roughly 1997, drawing soroe &\5
million to S20 million from hisfortuneand contributions from H3 wealthy
colleagues, wotdd be linked with bin Laden's Al Qaeda terrorist
orgsnizBlion by U.S. inviesTigators and overseas news reports.
With, branch o£5ce3 in central Europe, Pakistan, Sudan, Somalia and
Ethiopia, among other places, Kadis Blessed Relief charity aaid rr
dlstribuced food, clothing and medical equipment to those suffering from
famine or war.

A Treasury Department dtatbn. issued when Kadi's accounts were frozen

r, cariior this month called Blessed Relief a bin Laden "front that receives
L fimding Scorn wealthy Saudi busiBeasmcri-"
Blessed Relief, called Muwsfeq in Arabic, has a puzzling history.'.
the eariy 1990s, it ostensibly was headquartered in the Channel Island 1
Jersey, in the offices ofa IgcaJ trust adrainistratioa firm.

But Blessed Relief did no bosrinessfromthe island, according to Detective

Inspector Bsvid Mrnty of the Island of Jersey Police, and tba island-based
trustee for the charity resigned two years after Blessed Rcliftf WES
founded

Kadi and several wealthy Saudi business partnersjdso formed a for-predxt

investment company with the sane name in. tba tot haven of the Isle of
Man, according to records from the General Registry of that island.

003887
 ! 10:17a* Froa-CHICAGO TRIBUNE T-3S8 r.MMl F-H

The charity worked in caimiriea and battlegrounds where bin Laden HISO
was active, although it is unclear what relationship, if any, existed
between Blessed Relief and Al Qaedain those places.

In 1995, press reports circulated from Bosnia-Herzegovina that Blessed

Relief was being used to fhnd the Muslim-led Bosnia fighters in their
battle against Serbs and Croats.

Ayzdi Chaflq bin Muhaminad, the former head of Blessed Relief & mission
in.Zaereb, Croatia, also was placed on. the Treasury list of bin Luden-
finVrn people and firms released this mooch. Bom in Tunisia* bin
Muhammad, 38, "was known under four aliases and had addresses in.
Germany, Belgium and Austria. He is believed to have lafi Britain shortly
after tha Sept 11 attacks, and his whereabouts are unknown.

Raid at Pakistani office

Investigating possible links between Blessed Relief and terrorism,

vPakistani police reportedly raided the charity's Islamabad office in 1995,
r aitcrfloearrest of Ramzi Youscffor the 1993 World Trade Centex
c
- . ' bombing in New" York. According to press reports from Pakistan, the
police held the charity's chief local officer in prison for several months
before releasing him without charges. Blessed Relief closed soon after.
The charity's Pakistan lawyer, Farrukh Karim Qureshi, declined to
comment on the case.

In 1998, according to a senior H.S. official, the Saudi government aadilcd

the Jicfcfah-based-National .Commercial Bank and /bond that S3 iwiiiym in
tmnfc jRmds was frameled improperly to Blessed Reiic^ which, allegedly
transferred the money to bin Laden. •

After the alleged audit, Saudi government agencies bought out Chairman
Khalid bin Mahfouz's 50 percent ownership of the bank.

National Commercial Bank senior officials vehemcnliyg denied the

existence of a gcrverninent audit showing diat money h ^ l>cen diverted to
the charity and transferred to bin Laden.
~"\
. J, "I can tell you absolutely, categorically there was no such audit," one- bank
executive said. T h a t never took place."

Mahfbuz family spokesman Cherif Sedky said in a •written stateroeni that

the family never had supported terrorism m any way, and was "shocked
ami angered hy the suggestion11 that it hyj.

Kadi claimed he never heard of the «ff?»r until earlier tjyi month, when
asked about rt by the Tribune.

"There is no S3 million going to Osama bin Laden, never," Kadi said. "It
isn^ possible. Pve never neard of This. Never."

Loan linked to Mamas

003888 49
 :p-i) I(kl7u Frw-CHICACO TRIBtHE j.m PMlm M j

Unlike thai of any other person on. the Treasury Department list, an earlier
part of Kadi's story spilled from classified reports into the public record of
a 1998 federal lawsuit

In 1991, Kadi loaned SS20.000 to the Quranic Literacy Institute, an Oak

Lawn-based group formed TO disseminate the Koran and Muslim texts.
Kadi said lie made the loan because of his friendship with, tha literacy
institute's president, whom fie met ai a Sunday lecture in the Chicago area.
t
Kadi gair| the money was intended to allow the instzcutc to make a land
investment, 'which, would yield profits that would support its charitable
work.
The loan "was to open a peaceful dialogue between civilizations," he said.
"The books we helped publish helped Americana understand Islam more."

. But in a 199,8 affidavit, the FBI alleges thai Kadi's money was laundered
through a DuPagc County real estate deal to yield 5107,000 that went to a
small band of U.S.-based Hamas activists.
x_
Hamas, a 14-year-old rmlfraTit Palestinian organization, funds West Bank
medical clinics and Gaza Strip meal programs, while its Web site ukea
credit for a "glory record" of 85 arracks against Israeli citizens and
soldiers.

Bridgeview connection

The map wno allegedly distributed die Hamas money in the West Bank
was Muhammad Salah, a Jerusalem-born used-car deaLer and grocery
clerk who had settled in Bridgeview.

In January 1993, Israeli police arrested Salah as he tried to cross a Gaza.

Strip checkpoiar and hc!d him for questioning for two months, then
charged Salah with passing out more than £100,000 to Hamas military
cells in several Wesrt Bank and Gaza cities. Israeli authorities confiscaied
S96t4Q0 more from Salah's East Jerusalem YMCA hotel room.

. Salah told Israel he knew nothing about HBHIBIE military activity and was
k distributing cash, as a hurnanjrarian activity.

But La 1995, Salah pleaded guilty in an Israeli military court to aiding

Hamas, and the U.S. Treasury Department added him to a list of specially
designated terrorists. Three years later, after Salah returned to Bridgeview,
the U.S. government filed an unprecedented civil fbrfiatura corrtplamt IO
confiscate SI A rm'IUoa xhst belonged to Sakh aad the Quranic literacy
Institute. Included in that tvas money generaied by Kadrs S820.000 loan
to the organization, court records show.

Saya conviction tainted

"~:
Through his attorney, Salah. says his airninal conviction in Israel should
'be disregarded, claiming it was based on fabricated evidence. Despite the
forfeiture proceedings against hfrn. he points out thai he has not been

003889 -*"
 -VWI 11:1 l u Fro.-C«IUO) TSISOBE ,.„, r.,mug,

: /
charged with a crime in the United States. The Quranic Literacy Institute
also denies all tics to Terrorism.

Sakh's aJlcged Hamas handler, Musa Abu Marzook, was arrested by U.S.
authorities ia 1995 to face extradition for allegedly overseeing 10 Hamas
Terrorist strikes from 1990 to 1994.

la extraditing Marzaok, who ended up in. Syria, U.S. District Court Judge
Kevin Thomas Ehifry cited a piece of evidence he found "especially
damning"—a lengthy handwritten report Salah gave to Israeli agents he
mistook for Hamas comrades while he was in jaiL
I
From a pool of Palestinian applicants, Salah wrote, he culled 27 promising
fighters and sorted, them according io their expertise in chemical materials,
toxins, physics, military education and knowledga of computers. Dropouts
and misfits reduced his cadre to two mm.
o This small band met at Sakh's Bridgeview home and accepted Jiia plane
tickets to Syria, where holy warriors hardened in. AishaaQistan taught them
(o make car bombs and throw grenades, according to Salah's sraiemeat and
^ court papers filed by U.S. prosecutors.
A *
To fund their activities, Salnh used wire transfers totaling more Than
5700,000 from Europe and the l&lddie East
Loan's path murky

But while some of that money can dearly be traced to weapons purchases
and assaults an Israeli*!, the course taken by Kadi's S 820,000 loan b harder
to discern from the FBI affidavit and other court files. The real estate deal
was marked by subterfuge and misleadingrecords—nopublic documenia
indicate Kadi's role in financing the land deal, for example.

Kadi never made an effort xo recover his money, leading prosecutors to

ecpres3 doubts that it was a charitable loan.

"Curiously, despite a manifestly large stake in the- mattex," neither Kadi

nor his representatives ever filed a claim for the money, prosecutors 3aid
in court documents.

Kadi said he did not seejfc the return offcdsmlncy because the insrlrute
subsequently asked to use it for a separate real estate deal, a church and
school

"It was for a holy project, a beiter place," Kadi said.

He said he has a written agreement with the institute on trie project but
declined to provide it.

• Memo: WAS. ON TERROR. THE INVESTIGATION.

Tag; 0110280293

Keywords:

003890 51
 IN THE HIGH COURT OF JUSTICE 1995 Q. No. 1Q67

QUEEN'S BENCH DIVISION

MASTER ROSE

B E T W E EN

(I)YASSINQUADI
(2) TALAL BADKOOK
\. (3) RAYEIS BIN MAHFOOZ
(4) ABDUR RAHMAN BIN MAHFOOZ
; (5) MOHAMAD ALI EL-GARl BiN EID
ftr (B) ABDUR GANI EL-KHARIJI
Claimants
p 30 w
and
(1) BLACKWELL PUBLISHERS LIMITED
[2) PATRICK SMITH
Defendants

m TOMUN ORDER

LTPQN THE PARTIES agreeing the terms set out In the schedule hereto in full and final

settlement of ali claims made in, and arising In the course of, these proceedings

AND UPON THE FIRST DEFENDANT UNDERTAKING not to publish, whether by

himself, his servante or agents or otherwise .howsoever AND THE. SECOND

DEFENDANT UNDERTAKING not to publish, whether by its directors, officers, servants

or agents or otherwise howsoever, the words complained of in the Statement of Claim

herein or any other words bearing either of the meanings set out In paragraph B thereof.

IT IS BY CO NSENT ORDERED THAT:

PCR1-148573.1

003891
s:
 1. The sum of £241,257.55 paid into Court by the Claimants on 14 February 1996

be paid out forthwith to thB Claimants' solicitors together with all interest that has

accrued thereon.

2. Permission be granted for a statement in open Court in the attached terms to be

read before the Judge in charge of the Jury List if he be willing.

3. All further proceedings In this action be stayed except for the purpose of carrying

J this Order and the said terms Into effect for which purpose the parties are at

liberty to apply.

Dated

SCHEDULE

The Defendants will, within 21 days hereof, pay the Claimants the sum of £135,000 by

way of cheque drawn in favour of, and delivered to, the Claimants' solicitors.

Uk-A-. ['
Peter Carter-Ruck and Partners

;.tkjjf
Beachcroft Wansbroughs

PCR1 -143573. t
003892
*»ji
 IN THE HIGH COURT OF JUST|QR 1995 Q. No. 1062

QUEEN'S BENCH DIVISION

BETWEEN

(I)YASSINQUADI
(2) TALAL BADKOOK
(3) RAYEIS BIN MAHFOOZ
(4) ABDUL RAHMAN BIN MAHFOOZ
(5) MOHAMAD ALI EL-GARI BIN EiD
(6) ABDUR GANI EL-KHARIJf
Claimants

and

(1) BLACKWELL PUBLISHERS LIMITED

(2) PATRICK SMITH
Defendants

STATEMENT IN OPEN COURT

Solicitor for (he Claimants

My Lord, in this libel action, I appear on behalf of the Cialmants. My friend Caroline

Addy appears on behaff of the Defendants.

The Claimants, all of whom are Saudi Arabian nationals, are the Trustees of the

Muwafag Foundation, a charitable body established under the laws of .Jersey and

otherwise known by the Arabic name "Moafak el Hairiya". The principal objects of the

Muwafag Foundation Include the relief of suffering caused by natural disaster, war,

revolution, civil unrest and famine and the provision of humanitarian aid In the form of

food, cfothlng, training, resources, medical treatment and education to the displaced,

homeless and destitute. The Foundation has sought to give effect to these objects in a

PCRM47436.1

003893
»*• A
 number of countries since its establishment in 1992. Until the latter part of 1996 its

sphere of operations included Sudan.

The First Defendant is the publisher and the Second Defendant the editor of "Africa

Confidential", a fortnightly newsletter concerned with African politics, diplomacy and

finance which has a readership amongst politicians, officials, business people,

academics and others who are interested in African affairs both within the jurisdiction of

this Court and in Africa and other foreign jurisdictions.

On the first and Inside pages of the issue of Africa Confidential for 7 July 1995 the

Defendants published an article entitled "SUDAN/EGYPT - Calling the shots after Addis

Ababa". This concerned an attempt that had been made two weeks previously to

assassinate the Egyptian President, Hosnl Mubarak, during an official visit made by him

to Ethiopia. When referring to the enquiries undertaken by the Ethiopian authorities

into this assassination attempt and the Sudanese links these had apparently revealed,

the Defendants stated that, soan after the attack, a Sudanese named Siraj Mohamed

Hussein had been arrested. The artfde reported a claim that Slraj Mohamed Hussein

worked for Moafak el Hairiya. It then went on to report, at great length, the involvement

of Sudan's ruling National Islamic Front both in International terrorism and in the brutal

oppression of the Sudanese people.

In fact, as the Defendants now accept, no person named Siraj Mohamed Hussein has

ever worked for Moafak el Hairiya or has ever been associated In any way with any part

of the Muwafag Foundation. The Defendants also recognise that there are no grounds

upon which the Claimants can be suspected of any form of involvement in the plot to

assassinate President Mubarak. The Defendants are here publicly to acknowledge

PCR1-U743B.1

003894
55
 these facts, (o retract formally the allegations that appeared in their article of 7 July 1995

and to apologise.

The Defendants have, in addition, undertaken not to republish the allegations in question

at any time in the future. In the circumstances, the Claimants' reputations are

vindicated. Their purpose in bringing these proceedings has thus been achieved and

they are prepared not to pursue (his litigation any further.

Solicitor for the Defendants

My Lord, on behalf of the Defendants I accept everything my friend has- said. The

Defendants recognise that the suggestion that the Claimants' Foundation was implicated

in the attempt to assassinate President Mubarak was unfounded and ought not to have

been published. Through me they retract that allegation and offer their sincere

apologies to the Claimants for the distress and embarrassment that has undoubtedly

been caused to them by their publication of the same.

Solicitor for the Claimants

My Lord, with that the Claimants are content to let the matter rest.

Cameron Doley Caroline Addy

Peter Carter-Ruck and Partners 1 Brick Court
International Press Centre Temple
76 Shoe Lane London
London EC4A 3JB EC4Y9BY

Solicitors for the Claimants Counsel for the Defendants

PCRM47436.1

003895
56
 wm

^v

003897
58
 wmmm.. wgrnm
mm

^MU

r^ vc

g^^s^^ mesgm&Mi

003898
59
\ ,

003899 60
 r\^T/.T/Tl fcijLJU U/ pij j ,, »: fi yJJIj l^JLili SUJ^I ,UJL. fj^iJJ j ^ - ^ i

MOHAMADSALAH : .ijW.wlI ^ 1 - N
l:i
.. ^«-j-l JVJa(n.J...J..)»r JVL'il*t|-t

*J 8080700 i ^xlJ^Xi ^,L^e, fSj~ I

FIRST NATIONAL BANK OF CHICAGO * j j i . i . - t f o l i , ^-J - •
ONE FIRST NATIONAL PLAZA . CHICAGO IL Q0670 i d ^ ' l O'J^* - "v
TEL (312 ) 407 4000
P.O BOX 1467 .BRIDGEGVIEW ,!L 60455 : j ^ u U I ^fjJU - v
U.S.A TEL ( 70B) 43019Q1 FAX ( 708) 430 1992
CROATIA *fEL'/-FAX ( 003341 ) 414417 '. «." .',' *

tjr _Ui>U <Ulo^* Cc " ^

/r'jiiiiivu^-niu_iVrJt3jj^. i..u.y*s»ift iu\nA(J-jak>Li u M v r m i v n i $ ^ 1 * "N

V P.O. Boat a m t d d i h l M M Tal«x 400190 HxMttlQ Ttm4mi/M«»73_y

003900 67
 Yassln A Kadi
25/2/1993

Instruction to Cancel a Dollar Transfer

To The Islamic Investment
Company of the Gulf

Dear Sir.

Would you kindly cancel the following transfer order which we have instructed you on 24/2/1993
and debit the sum to our Account No. 6700029 which we hold with you.

1. Beneficiary's Name : MOHAMAD SALAH

2. Sum : 60.000 US Dollars
3. Sum in letters : Sixty Thousand US Dollar on/y
*J
4. Beneficiary's A/c No : 8060700

5. Beneficiary's Name : First National Bank of Chicago

of the Bank

6. Bank's Address : One First National Plaza

Chicago
IL 60670

Tel. (312) 407 4000

7. Beneficiary's Address : PO Box 1467
Bridgeview
IL 60455
USA

Tei. {708)4301991
Fax. (708)430 1992
Croatia Tel/Fax (00 3841) 414417

We thank you for your co-operation.

With our greetings.

Signed

Yassin Abdullah Kadi

PCRM60291.1
6:
003901
 lB/B6dT~a2 '&i "fas43f5H[1B8ea

THXS m&SGh&E ("Security instruasnfc*) i s given on Daoasfesr j

is>$ 1. Th& sortgeger i s KXDIAMD n o n n i i&viNOi Aim L<
ASSOCIATION as Sruataa und&y th® provisions of & STtmt spread
da.t©d t h « l i t h day of J u l y , ISfl known s s fBwat mistoij? 12CU
("Borrev*r»). This Security Xnstrust&nt l a givaa t o w
IKTSaifArrOHAL ooap. which i » organlB@4 and ^ d a t i n g un&asr t h e l i
of way J o r i s y , andl %?hoaa a
addraaa I s On^ Haraon 1*1^2a, ssoaucrusy 1
U®SS&Y 0700$ ("L*ndsr ). Borxowar owes Lindas? t h a pjfifloi^al e
a£ nZQWS HUKDHSD I'WSmrs ^HOtraJOSD MD HO/100 DOLXJ»J@ (fiSO/ODC
This d s b t i@ @vid©nosd by goxrowor's Hots dated tSva @asua d a t s
t h i a S a a u r i t y Instwrnanfe ("Hots*), whida gjrevidas f e s th® payae
o i n f u l l of s a i d daht, it not paid sarlisif/ oa •ftacenhiir 3 1 , i§s
This S e c u r i t y Iiistrussnt mmcuxmm t o I^cftdsri (ft) thm s&p&vk&nfc.
th& d®jD-c avld<ana©(i by th& Hot a, and a l l sranawals, (SJ^tofislon^ a
s o d i f i o a t i o n s y (&) t h e payssovb of a l l &th@r suaa a4va»o#S und
.. J Paragraph 4 t o p r o t s a t th® s e c u r i t y oi t i l l s ieaiurity ln#tyuM@»
and fo) -hba p@rfermsn«a of Borra^sr^s eevannhts and agreamsa
uud®» t h i s secrarifcy laatnmaflt snd t h s Mot*. For t h i s gusrposi
Borsrovssr do«ia har*by mortgage, grant and aonvay t o l&nd&T t
following dasaribad prepsr&y laaatadl i n DuPag® coajaty^ I l l i n o i s
SSB RIDER »AM AffifACHSD HSSSTO AHD HM!l & SMtT HBKEO?
which has th© addraoa of fcertita 33 »nd Eobsen E&ad, Ho&dridg.
Illinois.
perffl&nant Sjsal x*tata indox Huab^rsi OS 33 aoi OOS
OS 33 301 033
OS 23 301 033
•SoazTBES. VtXTn a l l t h e ispsovasajifcs ae^ o r faarssffiair airaoti
on t h « proftarty, .®n4 &11 aasaasnta, a l l £ii£turas now o r har®aft<
« p a r t af til® prosHMrty; All r®pliQiaa«flitB and a d d i t i o n s s h a l l a l l
ba covarsd fey tlitH1 s«ou'rity Inatsniaant;. A l l <o£ tha foregoing- i
f rtat&xx<&& t o i n tliim Security Inst;ruaatt-b sa tlw> "?rep®rfcy.»
BdSiRCWISL COTlHAKTa t h a t Bairxcr&kx im lawfully ®ais#d of t i
aatat«a h®araby a&nvayad and has th® siglit t o aoiftgas®, grant ai
canvsy th® Pirejs&srty and t h a t th» l»afap#&fey i s uj^xwsua&ar®*!, &xa@.%
tax ancnaibraness o'f eaoord. Bdnrowes? warrants and w i l l dafe*
f a n a r a l l y t h « tifel® !:& tb» Prepasty i g a i n s t n i l o l e i a a and flssanda
s u b j e c t t e any anousbranonB of r©eor^«
*
covaruutta. Serrcwar and L®ndar covenant and agrs© as fellava
1. l»av»e>it..tttf frginoipai^ iQSTewsr e h a l l ©resgatly pay vfaa
du® t h s p r i n a l p a l ® vidVnctad byth© Kota and any p e n a l t y ahargas du
under t h a Mots.
a. gavfosmfc of Tcascaa. Bosrrowar s h a l l s>ay &afer® any g^nalt
a t t e o h ^ s a l l gsn-sral tas&as# a»d s h a l l pay spaoial fc&*@s, ap*oia
aaasaeaent^ and efchiar ohargan against th® l»zx>p©rty.

003902 63
 la/^cTie* ' t f f !16:44rfnaBBB ' P 3 f

.•3

3. X*Unf • Borrower shall £SNbag>tay dinoh&rffii any l£«n «S

h&s p r i o r i t y ova*- this Security Insfcrum&nt unless Soxravari
aoysas in wsritiag to the pnyswmt of fcho obligation safltt£d«f by
l i t n in a Bjannsy acceptable to Lewder; (b) contacts in good £i
feh« li«n by, or defandss against enforcaaant of th* lien i n , 1<
proa®®dings which in tha i^hdsr 1 ^ opinion op«rat# to s>r@v<§nt
aftforcassnt of tha liaJs 6a? fosrfeitufa of any party of tha Prop©}
or (a) s&ausras fires tfa« .holdsr ot tha lian an a§raaa
s a t i a f a a t « r y to Land®? iUbordittating tlw li«h fco this S^OTM
Inafcrtjmant;,
4
' EgHtnqtlftlB Of .Lmdar.'ji Slcrfrfra ^ t^h@ Proparfcy.
Borrower f a i l * to p s r f o » tha oovaaanta ami af^e<a^@«ta cant a j
Jjn t h i s Ssoujrity litatruaant, or tfaar® i s a lagr&l |jiro«s®diii» t
may aigniSTiaafttly afgeot Lsrw3®r»s iright® i« th* property ((suai
a pro&aading in b&nkruptay, psebatsii for condsanation er to Anfo
•-•> lav® esr ragulationa), than Landax say do an4 pay *o* ^Su&tavat
n«aoajssasry t o protaot tha valua eg tha Property ami Z^ndas?*® r i g
in fcli® fregnat-ty. t^ndajr»s actions say include paying any a
s^our&d hy & lian wbioh hsa p r i o r i t y ovar t h i s Security Instiruaia
app&afing in oousrfc, paying raaaonabl® attotmays 8 faaa and a n t s r
on t h * Prop#irty t o aaka irapaira. Althm^Sb. tender aay -fcafea act:
urtd&if t h i s Paragi-aph 4, I^andsr doaa nofe hava to do so.
Any amount di£bu£@sd by X^ndsr UKd^r thi@ Pmragraph. 4 @K
becoM additiostal debt of Borrower Btimacad by this Saour
Instrument.
5. ggndftmnftti^n> S'h® proa&&dm at any award or olsim
/ direct
di) or aonaogu&cfcial, in oormeotion ^Itli i
oond®anation or othar taking ot any p a r t of th& frep^rty, a r :
donvayanc® in li»u of eondaaination, are jiareby assignsd and sfaj
ba paid t o Land®?';
i n - t h e tskvmnt'ht a ' t o t a l taking &S th® Pz-oparty, tb» s«foaa<
siu&ll b^ applied to tha sums ssoussd by t£d.s Ssourity xrustrvm®*
^hathsr os not than dua, yith sny «XCS@II paid to Bavxmm** In 1
event, of a p a r t i a l talcing of the ^ycsp^rty, unl©ss® ©erroy^r a
LsruSar oth^s^ls© a^rss in writift©, th® sums s s o u r ^ by fct
S^ouritv Iitstruadnt axial 1 b@ x^duo^d by th® ameuut of t^a proa©*
iaultigliiid by th® following fractions (a) th® t o t a l aaiMint of t
mxmm a soured isa<adiataly bafora feha takiivg, divided by (b) fchei 3? a
market vtlu® of the Proparty isaadiafeely b^fox:® th® t&Jting, i»
foslanc^ s h a l l &@ paid to Borrs^ss,
'3, Sorgo.w*:r..HBfr Mlmmftl TlftP^fflPfTPf Bv-.Ly^ftr Ma^
Hal3£tK. Sxtitnsion of tha t i a a fosr pays^nt ©s- ®e4ifi<sttian
amefftisation of tha suou saotirai by thi® S®oiw?ity Instarunai
granted by Landar feo any suoctssor in i n t e r e s t G£ lasrtcjwar ©hs
not operata t o r®ls&e& th& l i a b i l i t y of th« origiaal Borrower
Borrotrar's suaeaeaoj?a in intsrsafe. £iS»d#r shall not b® rsquiaf
t o aossmiift©« proa&gdings ©fminst any sueeafsor in jbitartet er r«fu.
to ®srfe@ftd t i a * for payssnt or oth»nris« modify saortiiifcien ef t

003903 6^
 »/«cYMBg 'ar"lI&i45fW«BBBa

suss ssef&rsd by t h i s i s e u r i t y 2nstrua@nt by sfMfioa ef &ay daa

aad@ fey th@ o r i g i n a l Borrower or Borrower'a suaossaocs itt iBt&ri®
Any farbaariyicia hy Jjandajr in ©sesaising any r i g h t or rss&dy ah
not ba a waiver o£ or prealud® th® ®x®rcis« of arty r i g h t or r@aa
7. fimaaasetors &nd frasiana Bo^nd. Tha coVsiasfttB
agreements of! t h i a s a a u r i t y Xnatru*&ttfc s h a l l bind and banesff it:
aucosaaora end assigns of L®ndar and Borrower.
8. ^Qfcj.q^f. Any notica t o Borrower provided for i n ti
S e c u r i t y Infitsuaant s h a l l be givan by d e l i v e r i n g i t 02? by M&±1
I t by firsrt. c l a s s s a i l unless appliaafela l a ^ r^QUiirds us©
a n o t h e r isothad. Thm notioe s h a l l b« d i t s c t e d t o MIDEABB FBDK)
3A7IHGa &HD LOJUf^Xjand fsruBt !>«pwrta«nt, S9S9 South Harlem &van\
Bridg«ivi®w, l l l i n o l B #0435 with a copy t o QttKMflc LXSfSSJ
IHSTXTOTO, ^435 South SSth St3T«#fe, Osklawi, Xllinoie S04BS, t o 1
, a t t s n t : i o » ot Hasmad Aha^d S^ki, A«y rsotiaa t o Lsm&mx s h a l l
V.y giv&n by f i r s t al&mm stall t o Lander's addrssa s t a t e d h®rsin og 1
ethos- address Lsndar desi^nntsfl by n d t i a s t o BorrdHar. Any noti
providsid for itt t h i s Saourity Inatini&ant s h a l l ii® daassd t o JM
beaen g~iv©n t o Borrow®:? or L<gnds? when given as pvevldod i n t l
paragraph.
9i j^Qvernii^y .,Ttfty 1,-gffiyaffl&hj 1 ity« Kbis Sacurity Instiruaa
s h a l l £>® $&vgm&4 by tha laws o£ th© s t a t s of illisiola. xn t
event t h a t any provision e? eiauea of- t h i s iasurity Jnstsrusjont
tha Fata confliots %rith flpplicaiila la^ f such oonfliot 1shall si
atteat, other previsions of this Saourifey rnstxneiant os tha Me
which cmn be givsn effect without th® oenfiieting grovisicrn.
t h l s &n& th® proviaiotua of this SaevLttfcy Xnstrumsnt uui th» tfc
&rm dacslar©(2 to b^ st&varahla.
10. Ajaa^lagafcioni aawadian. Lander shall Sivs notion
Sosrov^r p r i e rfe?»ao^slarstion following lorrowssf^ bK&aoh of a
covenant or agraras^ani Ln this flaourity iaatrii&&»t. >S^a noti
,
;
s h a l l &p®ait$i faj'ths Usfaulti (b) ths aotlan rs^uifsS to our& t
dafauit? (e) a data, not 1MB than 30 gay® from tha d&ba tM noti
i s givan to B«rrow«r/ by whioh. tha default auat ba cmradf and t
t h a t Sailtir® t5 eurs th& default on or hmtara th® date Eip#«rifi
in tha Serbia© @tsy raault in aoosleration and forsolosy^®. If t
default i s not eared on or b«fera tha date epacsifi^Mi in th& siotia
L&nd®sr a t i t s ©ptien »ay raijpair® iaasdiata payaint in full off a,
sums s©our«d lay this flaourity Xnntruasnt without farth&if d4ssand a:
may forselos® thiai security inatMiawit lay judleial proos«ding.
11. MU4M* Upon piya&nt of a l l eusa s®esurisil by thj
Security Instruaant, LaMar shall rslaas® this Ssourity 3C«iitrumjJ
withdttt aiLa.3?Q& to aosrowar* Borro^ar shall pay th® raaordAtiii
GlOStit!

12. fog&payitfflfc^nd, )gArtei^_^almaEa. i^ndar aatoowl®dg@s thj

i t i s &trar« thaft sasMrovay int«nd« tie mil th® ?rep*srty pursuant t
& oentraot whiah may obligate Borrower to oonvay lass than t*
©ntira prop©rty to tho puifahaaar. in th« av«ht that Borrower 1

003904 65
 obiigat&d' t o oonvsy l@p® than th<a antics ^o^^rtv 1 o a ott® ®* so
occasions p r i o r t o the maturity data e>£ th« Met®, th® |>asrtis@ &f*
t h a t a l l sal® proaaada racaivad by Borrmfsr shall bs paid to tmnd
(unless Lmndms skives t h i s obligation) and ehsll c o n s t i t u t e
prepayasnt on the Met®, In th® svsnt og vsuch at conveyance
Borrower of l@ss than £h& ©n^ir* fsrap@rty# th® lender shall pa*ovi
to Serrowss- a Partial Ralaas® D«®d tmicft will tmla&M& a l l
Landar's right© hald and aaijqirs4 §a a vm&ult ot tbia B©cuiri
Instrusisat in t h a t poirtion of th« Property that i s being aold ;
Borrover.

B¥ SIONZITQ SSWW, »orro¥@r aoosptii and ©gr©ss to th® tarn

snd covenants oontained in t h i s sseurity Snstruaeat.
IM WLTmLB® fflWtSOT, HIDIAHD JFBDSRAIi MAVIHas AMD 2^OJ
AasociA5lOMr i t s auocssHor or amcoaasors i s Trust®® imdar tl
y
j provisions of ffruat Agttsaaant dat^i tha lfflth day of July, 19!
kno%m as tfsrust Hussbor 1206-0, not baraonally but as Trust®® 4
&£oir«sgid, h&u a&VM@d th@B® pzm&ani® t o b® aigji®4 39? it@ d
authorised offi,c@r» and i t s corporat® «®el t o b« hereunto affiscs
and at-test&d to" on thm day and yaar f i r s t above written.
HiDiAun FHDaaai, SAVINS xm ijowr MteociAS'ioM, it© suoo^agc
or suaca^sora aa Truatae undsr thm proviaians of Trust Agy^^^er
dated tth® 18t±i day of .July, 1991 known a@ Tru^t 3?uab«r laO^-O, a
Trustee a® a?o?i§3&id and not personally.

AttaSt-J . fiyj
Titl«« K€l«i"

STA0?B OF ELLZNOI® "•'

COOKS^ Of ______

93h© u n d s r s i g n s d , a tfotiary Publio i n S)tKS foir t h a oeuaty a »

St®t@ a^orssaicl^ doas hsraby a s r t i f y t h a t
pex-ssonally Smoira t o aa t o ba th® of MIDIJAKI
F^DSailL aAV2Hal MID LdAK ABSOCIAUSOM, ifld ..
personally known t o BO t o be th® .. thereof, and
P&raenaliy kno%m t o aa t o b# th® mm® p@r@on@ whose naaas ara
s u b s c r i b e d t a t h a foragoing i n s t r u s a n t , app@ar@d btfor© ®a t h i s da^

003905 66
 lB/Ccfffl 'tff l^!4SPFT?80B8 P,6PA!

i n p e r s o n and aoknowladged t h a t t h # y a i g n a d and d e l i v e r e d th@ @a

i n a t s u a a n t a s t h & i r own £j*a& and v o l u n t a r y a c t i and a s th® fr@@ s
v o l u n t a r y a o t of Borrower, f o r t h a ua&m and gniip«s©6i t h e r e i n a
f o r t h ; and th& s a i d . than and thajr® BQknewl@djg
than h@p @@ enato^lan of t h a cairporiat® s e a l af Barso^ar, o^us^d t
gam® t o b© «ffixe<l t o said inatxuasnt 4@ h i s o%m frtaa and volunta
aot. ®rsd a s this fr®& ssid v o l u n t a ^ a©t*of lorrowsr, foe feh* us
and. puscpos@s t h a r ^ i n s a t f o r t h .
. / a i v a n undar ®y hand and Kot&rlal e a s l thin day

HyCffisai©®i.on s^ir@a)
07HIS DOOOHBSW PRSPAfiBD BY» Joal K. Psri^dman^ 83 B*st Jaokao)
Suit® 3000, Chicago, I l l i n o i s 60604.

003906
 ia/qscng ^r-i'SMGrfinaflflB - p M

•.. •• ••• KJ32I

iMPnAQQ.tQQ •' - DATEDi D$'e«ab6£ 3 1 , 29
ATI Chioago, I I l i n o

!• M&CT&j §..EBOMIgg K>.,. PAY i

JTO* vaLUS XECSIV&D, tha undaraignsed, M1DIAND FIDIS&L SAVT
MD LfcAJf ASSOCIATION, not p a r s o n a l l y but s o l e l y as Trua-
p u r s u a n t t o Trust: Agresaant datad J u l y i § , if s i , and known
T r u s t HfUMbar iao«-O ("Hafcas?") herafcy psroaisess t o pay t o -
l
ordate of KABI iMTBRNAfflONAL COS?., a H©^ J a r s s y o e r p c r a t ;
,.y C*P&y&a") t h a p r i n a i p a l aoount o^ g^GSIT EUHDfUD T®%1
THOUSAND MD HO/100 BOLTABS f5830,000) ("PrtnaLp&l toount'
No i n t e r e s t Khali be payable on t h e Prinoip&l Amount.

(a) Tha P r i n c i p a l Aaount, or any regaining balan^a, s 1h a l l bo i

aBd payaiala an D«aaHb»r 31/ 19S3 ("Maturity Dst©* ).
(b) A l l paymmnte raquir«4 hereundsr pursuant t o th^j. p r e v i s i o n s
-this Mot® shall- toa »ade t o Payee a t On© Haraon Plaa
Saaauoua, .Haw Jorssy 07094 o r as otharwisa dSiaraoted by Psji
o» suoh o t h a r -lag&2 holder h®r@o£r
fa) T£ t h e P r i n o i p e i Amount i s not paid whrni ^us, ?&yt^ s h a l l ha
th& r i g h t t o c o l l e c t a penalty c h a r t s . ,p£ giam?¥ AUB N O / I
•;. . .DOLZASS ($po.6Qy pes: day for aiach day iEtttr th®. Maturity Dm
t h a t thsi P r i n a i p * ! Amount r a a a i n s impsid. Pays® &h&ll n o t i
Ksfe»r-4u weitingr'within t e n (10) days a£t®r t h « H a t u r i t y Da
/ i ^ Paysei sl®ot@ t o c o l l e c t en id penalty*

3. M&KgRf.S, RXSpT *gQ PJ^EPRY •

• • ' • ' * • • • • . " • .

(a) isakear sh«ll have the right to saK® gsyaint® of priaoipal .

^ny tin® befor® th»y ara du^i without any prepayment ahar^ra
fb) M®k@r agrsiii! to aaJs® a sikn'datory pr^payiasnt; funlssp am
P2r*pay5a<int i s waived by Fay**), of a^unts. dwing- under th:
He«@ t e th* astant thiai. mkmr £©aaiv®@ any .sals® precsads <
aoqount of tba aala at a portion or a l l ot tlwi r^sl Mtai
^hidh Im aortgafad by Hak®? t o @®our® t h i s Hot*. M oaly
portion of said real astat® i® b«iu« »old by Kaksar, t h i fay;
aats@® fco psfovida Hamas' vith a P a r t i a l Rmlasaa D«^4 waioa wl3
r®l*a*a a l l o£. Payai'e rights hald and sogulr®d a© a rssuJ
of said mortgage in that portion ©£ th» r®el • ®stat®. being sol
by Maker.

003907 68
 . 10/EOCfefe ' 0 1 10!47RM J80B3
P. 8 PA

4. NQTICgg
Unless appliaabl* lay reijuirsi a diffatane method, any noi
that auat ba given undsr this Mott will b©'given by delivsi
it os? by mailing it by First Class .Mail t<? tha pairti@s
follows! - .
IF TO KAJta&i .',./'
MIDLAND FEDERAL ShVXtiQB AND LOAH ._ .
iTu&bar 1206-0 • .
• o . t$as south H&riara A.v«nu6
. • ' Bridgaviaw, Illinois dO4S5 ' ' .
With a aopy tot
o QUmiiriC LITBEACX IKITIKWS
9435 South 6&th Btxmt
'. Oak L*yn, I l l i n o i s €0453
Attention i Hammad Ahiaad s a k i

I F TO PAYBBl
KADX imrSHN^raOKAL CORPORXOTIOK
O/O BM2, ING.
Qns Harmon ^ l a a a
a o c a u e u g , ir@v Jsirsisy 07094
Attentioni a a a a l Ahmad
o r a t audh o t h a r a<3iarass as s i t l t e r p a r t y has d e s i g n a t e d in
wri-fctsn n o ^ i c a psreviously raoaivad by t b a o t h * r p a r t y .

This Wst® •ss&y not bd aaanded, s o d i f i M or ohangsd nor sha

ai^T ^ a i v a r of afty o t h a p r c w i s i o a s h ^ r ^ e f fca ©ffsotiva, ®KC3«
o n l y by aa inetsniafea* i n w r i t i n g , sign&d fay t&a p a r t y a g a i n
whc® snforesBs©nt of any waiver, amandm^int, ohimg
modification er disohajrgs i s nought.

This Hofca ia aeoursd by a ssortgag®, th© p^oviaiens of wftic!

by t h i s leafattiiaa, are adopted in thai» sntiraty as thotu
fully ®®fe £otth har&ih p 4 tJui provisions hlssfaof shall I
geverasd and cdnatrusd in aesosfaknas vit& tii® lave of ti
atat<s «f i l l i n a i a * Whariftvar posaibl®, aftoh pyoviaion of thi
Hots shall ba intarpretad in m\k<± a aasmar as ta b® affaatii
and valid pursuant to spgliesbia la^^ fiowwir, ia tha @vai
t h a t any provision shall be prohlfcit&d or invalid thar&uttdai
tb® sam® shall be ina£facrtiv«i to tha axtant of sue

003908 69
 lfl/8cini2 '0f "L&^arfrwaBB P . 9 PAG

S M S ™ * 1
. ; . * . «(•?.-•.• . ' . ,i'.• *. • • . . • • • _ . . - , • • • • • •
•v:.tf

•• '• I" :•' '. '"• - ^ • • ' • • i : ' . : ••.'•v:v

ffftiX* .; . •'V'"'.' • '.
 lB/E&ffTSS 'df*T£bi4«$PBBBB " P.LGPAG

WHaSm&fi,MXOEAMD fSDSa&L SAVING® AHD LOAJ? ABSOC1ASIOM

Trust©® undsr tha provisions of a o a r t a l a Trust Agrea&snt data* t
lflth day of J u l y , l i » l known as Srust Sfusbfcr 130S-0 has aacscmt
and d®livar«d i t a Bota in tana p r i n c i p a l amount at I1SOT HUMtift
TI^NTY l^OUSMTD AMD UO/100 DO&L&HS (8030,000), datad Bae«sb«r 3
18S1 payable t o tha order of KKD1 UmUH&SXOH&L CORP., and i
aesrfcg&g« of t h a aasa data t o @@©ur® payment thasnsof, conveying
. W&X ZHTsmh'SioxiMi, COSJP, a@ Landmr, th® following Sasorib
pKOpasrtyi
31S RIDSSl "a" A'ffTACUHD B£3tl30 hMD MADS A FAP.T H1IUSOF

KfOlf THEKEPOai, tb« undar signed, for good and vanish;

• _J c o n s i d e r a t i o n , doas unconditionally and irravocably guarantee 1
t h a h o l d s s froa t i a a t o t i ^ a of said STat® or of any intatrisii
th©r<sdn, ^i® prsispt payaent of tha p r i n o l p s l eusount of ©aid #ot<
whan tlu^ aaas b@ao&d« due fsaa tim® t o feima, ^hartinar by laps® <
t i ^ , asc&lexmtien, or otherwifla, ana a t a l l t i s s s t l i s r a a f t o r , EJ
-tha p r o s p t psys4tnt o£ a l l ausa irbiah may no« ba or &&y haraefts
baaos® dua 4md mrfjig under th« t©£%uv of tha mortgage ©souring sad
Mot^, and does unoonditionally ami irrftvoaabl© $uaz-anfea& fch® proms
psrfosrsaiaKoa of a l l of tha other t e r s e , covenants asd conditions c
s a i d n&rtg&g®} an4 the guarantor do«» har*by waiva p r a s a n t a e n t £c
payaajit:, dskand for poysant, notice of taonpay&ant o r dishonot
p r o t a s t aiid aatio® of p r o t e s t , dili^eno# i n a e l l ^ e t i o s , and any su*.
a l l f o x m a l i t i a a which say be l e g a l l y required to charga i t v i t
l i a b i l i t y i &Jftd tha guarantor dea@ further a^rsnsa t h e t i t s l i a l i i l i t
aig gu&rant€£ s h a l l in no &&y b« iapsiredi ©r affaoted by a;n
riuvsi#als or ®3ft©naiona yhioh ©a^ ba aad® froa ti&& t o tia®, v i t
OK- w i t h o u t Its knowlAdga and aons^nt of th© t i a ^ of paymsnt, of an
p o r t i o n of th» pz'inoipftl aaooat/ or ift SJty forbaarsnoa oar d«lay i
anforoing t h a pay^snt thereof, or l a enforcing tha l i a n of ami
J a o r t g a g a , or by &ay failinr* cri? n®gl®et or r s f u s a l t o anforoa a a i
mortgage or t o r@alis« upon any othsr s e c u r i t y which m&y h&va baa
g i v a n ©r s a y h a r a a f t a r b« given Sax tha indabtsdnass e» ®rvidanc&
by s a i d Hot® or vortgag®, i t baaing tilii I n t s n t harsof t h a t t h
g u a r a n t o r r ^ m i n e l i a i l a as prineiipal u n t i l said ITota and any a n
a l l mxma nmr o r hasraAftsr dn» und^r th& t # n u i of said saa^^fags o:
of t h i s gu&riftty hnv* been paid is* f u l l and tha other t e r a s
csvasmnts and aonditiona of a«id aortgag« asd t h i s gu&ra&ty h&v<
baan p&jrfe^si&id, Bdtyithmtanding any a c t or thing aMeh Edgin
oth^rvis® op@r«i%e as & l$$ai equitable disohsr^® of a s u r e t y .
I n th® avant of the fortolesuifa of said aartgag® B M of «
d * f i a i a n o y , t h s guarantor p«oaiff«s a«4 agra#® forthwith t o pay thi
amount at such dafiolftttgy*
S h i s guaranty ahall b@ binding upen th« auxxsaaser^ and aasigni
of tha guarantor.

71
003910
1B/65CY~32 'BY lEuSBPfi" 3BB88 P..ll>flQ

XU'WITNESS RRBHEOF, t h a g u a r a n t o r ham axs&oufesd t h i s guaran 1

t h i s 51at: d a y o f Dsosmbsr, 1 S 9 1 .
QURANIC LI3?ESAC¥ IHSS'imJTE

By i.

003911 72
19/63CfB2 'tit' "lfei50ftH'3BB0S

PARTIAL RBLIASS D1SD

KNOW ALL MSN BY TH2J3S S>BS1SHTS,
TH&2 IADI INTBMIATIOHAii CORP., an corporation of 1
County of and" Stafca of for and
e e n s i d s r a t l o a of on® d o l l a r , and f o r ©this- geo3~ myi v a l u s t
a o n s i d # r ® t i o n s , th® r a o a i p t whssraaf i s hsraby aaknenflsdg&si, dc
horaby snaaai»@, vml&&m, eenv&y sad i g u i t - a l a i a unto MIDt&HD FEDS3
SATiwsa aim I/SAK hssQGik'sim, gsat i«utJi K a r i a s Avanu^, asrid*©vie
I l l i n o i s 60435, £t^ suoceaaor as? auoo«iaQrs 4 us t r u s t ^ i u n a ^ r t
p r e v i s i o n s ©f a t r u s t egraaaant, datwd J u l y l@, 1S®1, kneren
t r u i t MUabar I20fi-0 *11 th® r i g h t , t i t l # , i4itasr®st» a l k i n ,
d&&a2td what;ai*4av©r i t auty hav« aeujulrad i n , through, o r fey s o&rfct
Hortgag®^ ba&ffing data th» day of , iag
and recorded In tha Eaaordor's off loo ©f DuPaga County P in t
st&t® of U l i n a i a in Book of pae® as Booua®nS; Musb
..-, / t e th® prdmiias thiSilh assarlb^d/ situated in th® cours
of DuPsg®, gts^« of I l l i n o i s , stt follovs, t o wit«
@®# s a i i b i t ; WAM Bttaafasd; togsfch@r with a l l feh« appusrfcanano
arwi privil<ig#s tl»®raunto belonging or a&»&rtAining.
WXTNSf® , _ _ ^ hand _ _ _ _ _ _ _ and aaal th
. day of , , 18ft ..

KRDI X H T S S K M R O U L L COHP.

FHBSIDENf
M « » M w «•• « » MM « • «a -M^g ••• *« * « a p B t * * H > w * v > v ^ i w *m ^ *m *+ mm

STATE OF

cauwrt aw
1 , a ttst&sy pasbiie in aacl fos- t&« ®ai
County, in th®
Siorssaidi, State.
IX> BHUn» CSiSISTf tha
t PB®S2D^M^ OF KADI £IROT!t&TIOK§
COBP. p e r s o n a l l y jcnovn t o % » t o b« th<a sans p@?san eh©®# naB® i
(subsaerlb&d t o t h s fsregoing insttm»int f app®ar®d bsfos^ i ^ t h i s ds
in p a r s o a , and Botoio«l»dgad tlsafe h® aignsxl/ s a a l M and d&llv^rs
tfci® ©aid instruatewt aa hia t*** and voliintazy sot f and thm £s&& an
v o l m i t a r y «ot of ^aid oorporatipa for th^ u*<w ifld g»UE« | >®@© t h a r ^ i
®®t f e r t f t .

003912 ' °
 l a / f c t r 02 ' B l 10J50flM 38888 " P . l ^
,'

Givan und#r ay hand and official notarial ssa&l, this

day of n let «

HOTAEV PtJBLfC
Mail t o t Cesai®sionBxpiraa»

• o
THIS IWSraUMgK? MAS PSSPAJRSD BYl J o a l M. fr±&<3&&3\, BE Sat
v J a o k a o n , S u i t a 2000, Chicago, I l l i n o i s 60604.

74
003913
 I r"

\" - IN THE UNITED STATES tMStRIcf COURT §

I FOR THE NORTHEHNDISTMCTOF ILLINOIS ixl
1 EASTERN BIVTSION c3
i ,:,.^..^,.,..,..,,...,:.. . .. ..,,,,., ;,,.,-,,, B
^ . ROBKfeT G. WRIGHT, 3SL, ) ^~
. . )
J .?^ f i B i > CAN
1 "••-..• ;---...- • - ..; } •
i . . - •; T. • )
! • ) ForasriyCg®aNo.01L-W7257,CateadarF
1 KAREN MMDptNACH, ) Ctrcnit Coart of Cook County JUE^£ ZAS3.
Defendant v) MAGISTRATE JUDGE BOBRIO

t . ., . . , NOTICE OF REMOVAL OF A CTVTL ACTION

i To: Ma. Dcralhy Brown, Clerk DavidP.SchiRpcrs.EBq. ^ ^

i| • •- .:..•.•:... CircnitCtJUrt of Cook County, DL 20 N.CIaifcSt," Suite 36C» ' '9 tyn
. Richard J. Daley Ccaifcr Chicago, IL 60602 °1
• 50 W. Waahington, Km. &QI
• Chitaigo.IL 60602

Tte UNITED STATB5, l y its attornqy, DAVID MORGANl^OST, U.S. I^eparimcnt of

• Justice, sulimitBttsisnotice of removal of the sibove-captioned civil action from tha Ciitniit Court

of Cook County, Dlioois, to the United States District Court, Northern District ofIllinois,

!, pramiEnl to 28 U.S.C. J 1442 (&X3) and 28 US.C. § 2679: fa swppoxt, &e United Statea

> reffpeotfiilfy k a r a t s Qa fbEowing:'

! 1. On Juna 18,2001, Robert G. Wng^it, Uw plamii^ ccanmenced uie above civil

action against Ksraa Medsnach, tho defendant, in the CSn^CbartofCookCcnndy, alleging

t mtsoiioEal infliction of emotional distress md inteotioflal interfemxs wilh prospective

} . advantage. Ccpicsofall process and pleadings and onJere ^ r v ^ UJJOT the pendant are
;
attached pursuant to 28 U.S.CL 5 1446(a) as ExMbit A.
{ 2. Thia fetica ofTtcmoyiai] is "filed in accordance with' 2¥ U.S;C. Ifl442 (aX3) and
* ^ _....„. ._ .. . - „ _

\
003914
j 28 U.S.C. § 2679(d) upon certification by the designee of tiie Attorney General of the United
I
States that the defendant waH acting within the scope of her employment as a federal employee al

the time of lbs incident orifc of which the claim arose. Saa Certification attached as JExhibitB.
«
., _ . . 3. 'Noticaofrcmovalm^ be ^ e d without'bond at myfimebefore trial. 28Ij!S.C. §

2679(d){2). Trial has not yd bocsQ had in this action.

i
« r .

1 4. Pnrsuant to the Certification by the Attorney GeberaTa deaignec and thefilingof

this Notice of Removal, this civil action shall be deemed an action against the United States

-j onder 28 U.S.C. § 2679, and the United States shall bo substituted &a the party dfifftndant
r
J WHEREFORE, thia action now pending in the Circuit Court of Cook County, Dlinoia is

~ properly removed to 'tais Unitea'^iatesDistnct Conrt^pursuibi to*2S"U^S.C. 28 U.S.C. §§ 1442

t (a)C3}and2679(d).
i ^ • . . •
i Respectfully Submitted,
| - ' STUART E.SCHEFFER
v Acting Assistant Attorney General
J ' ." *" , " * "* " SOOTTR.LASSAR
( United States Attomey

, - - HELBNEM. GOLDBERG
i - - Director, Tut in Branch

j Scnior^ftial Connsal^ '"

Torts Branch, Civil Division

.K , i
" EJAVB3MORGANFKOST
t " TrialAttomfiy'
! . Torts Branch, Civil Division
' -" '- - U A Department of Justice
P.O. Box 7146 Washington, D.C. 20044-7146
(202)" 6I6-4I76 fee: (202) 616-4314

003915
003916
* 2IZ0- - serr«o 1UJS
J
1U0 ~ NotSontd 1 ? NotStrvftd .
1328 - Served By Mall 21 - SenfftfiByMair
2 « 0 - Ssn-tdByPtiblJcuiioa 7431 - Served Sy Publication
SUMMONS ALIAS -SUMMONS (Ra*.I/3/9l) C<

• IN THE CIRCUIT COttttX OF COOK COUfTTY, ILLINOIS

COtJNTY JXa A&TMENT, L&g DIVISION

(Na me si! p artf ts) No. • H /itnut^

£OBEST G. WEIGHT, J S . .
BEWXTWIWSt
Plaintiff, Server

v. Xarsu Hsds?nach
KASEM HEUERHACH, FBI
DefandanC. 575 K. Psrnnaylvania
Suite 679
Indinnapolia, If 46
SUMMONS
To saicb dcfea^a&n
YOU ARE SUMMONED and required to file an soswar to the cowplaFal ia tbls one, a copy of
hereto attschctJ, or otlaitrwisa tils your appearance, and pay l i e nqakuS Tee, In ibt ofllcc of the CI«rk»f t&b

afchanl J. Dalty Ceo(er, 50 W. Wubmgton, ftostn 8 0 1 _, Chicago, miaofa IJ06D2

Q. District 2-Skokla 0 Bbtrit£3-aotliiigMeadowi D IHitrltf4-Mfli
S«a« OW OrcUril R<L 2111EaeUS 1SQQ MaybrooS
ReiaasMeadow, U, 60003
Q bistiicfS'BtY^ievtett'' Q DistrictJfi-Maifkham
- • 19320 5.76th Avt lfi5OLS.Kcdiie?to*y.
Marfcliam,lL 6XMZ6
You eaust UlewUisLa 3® 4*yj: aftar icWcs of thUrotamoBS,not eouutlag tbc dty »rierriec
IF YOU FAIL TO DO SO. A JUnXJMEPTT BY BEFAULT MAY BE ENTERXD AOAStiSl YOU FOR THE
K£QU£SXEB IH THE COM?LAINT.
Totheonfcsr: .. • • . . - . . ' . . . . - . •
• This 2BMQJJB3 tausi be rctarai<i"bVdi8 eflksr «r otber persoa to w%«m It was gtvo for scrv!
endwitcaeat of service aatf fees, if say, tmatedlatcly aftar Mtvlca. IT service CSBBB? be made, this sumaii
be remrastS st cnddrie^L Tkla SBasmooi may aot be jsrv^d laterfit&a30 days after la date.

Aity.No^ 122Z.2 tfltNteSS."

&ass
f =—Sai±£-E s^Kf r - r *^^
%®&sgaf
Ctev/^ats/25jpr ChAcago. IL 60602
(Ts be ta&sricd by
TakjpbottK ( 3 1 2 ) 263-1200 t OllwT

ferpjcfi byFacstoHi: Traasmbftoa wllj be aect|itcd Att_

(Arta CB4»> f?ac«to0»Td«?A«
• IUL-B5-209I 11 Mg
P.a

1
I
j\ '.V •
u\ . CO
5
^r *
BGBEB.T G. WRIGHT, JR. ,
oi
:\
Plaintiff,

v,

oil MV.v
Sa£@ndant~

NOW COHE5 the Plaintiff, Robert G. Wright, J r . ("Wright") by

and through his Attorney, David P. Schippers, and for his
Complaint in two counts a^airust the Defendant, Karen Medernach
("Xedemach"), states as follows:

• - gjcamss
1. Plaintiff is a cititen and resident of the State of

Indiana and, at all relevant times, was employed as a Special

Agent (" 3/A") of the Fsderal Bureau of Investigation ("FBI").

2. At all relevant times. Plaintiff was stationed in tha
r

Chicago Daatrlct of the fBI in Chicago, Illinois.

3. 0e£«ndant Kedernach is a citizen and resident of the

State of Indiana, and was, at all times, employed as an 5/A of

the FBI.

4. At ail relevant times. Defendant was stationed in the

Milwaukee, Wisconsin Distract office of the FBI.

, . JUHISDICTICJK &HD" VENUE

3. This Court "has Jurisdiction over the subject matter and

003918
 jruL-es-aeai n-'-is ' •' . ' • •"-• •-r<>-' p-^

has personal jurisdiction over the Defendant, pursuant to 735

ILC5 5/2-209 in that the Defendant coiwiutted many of the tortiou«

aces alleged heroin in th« State" at Illinois.

S. Venua is proper in CaoJc County, pursuant to 735 ILCS

5/2-101, in that tha sale Defendant is a non-resident of the
i° State b£ Illinois. ' • .

F&CT3 GIVING R1SS SO THS CAUSE OF K3XCH

COUSX ONE

intentional Infliction
Of Hentat Distress
7. At the time of ths «vent* complained of herein,

1 Piaintiff had bean An agent of'tha'F'BI for nine years. He

I .-• . enjoyed a rHputatian a* a hard working, dedicatad and cosvpetant

') , • . agent, and anjoysd tha respect and admiration of hii fellou

j ' kif&nta';' o'f'hiV supirVisors and of t^hose with whom he came in

i " . • ' • • . • • • • - . .
1
-... contact professionally,

' . S, As a consequence. Plaintiff expected to succeed Ss an

J . FBI Agent, to recoiva pcowotions and avcntually to retire
i . • . ' . • »

j- honorably and wicH" his rdputfatio'n unsullied.

9. "" At "the time, of the evahts complained of her&i.hV bright

was assigned to the FBI International Terrorist Squad, centered

, • in Chicago. Illinois, and had bsen working in that capacity

i . .. since 1993. " • • - -

I 10. i n o r about i"3351"""Wri'5'^t' davitioped and'""impTeroaKted an

i '•
j investigative plan to identify and neutralize foreign Hiddle

I . . . . . . - • . . " • . • .'; 2
 .PXH35-2031 licjg 4 , p

4,
I
I
Eastern t e r r o r i s t organizations operating throughout tha United

States.

11. During the course of his investigation, Wright

identified a resident of tha United States who wss directly

involved in tha terrorist a c t i v i t i e s in thsr Dnlted status and

slsev/hex©. Wright opened & cass and began an intense and in

depth investigation of that individual's financial and other

activities.

12. In or 2bout 1939, Wright becama awsra that Madernach

had also opened a crirainal case in Hilwaukea concarning tha same

individual and his activity-

13. Medernach demanded that her case be given precedence

and that she be zssigned to be the lead agent, with the Chicago

investigation as secondary.

H. In order to avoid confusion and duplication of effort,

the rar decided that the investigation must DB coordinated out of

ona' office.

15. hs a result, in July 1399. a meeting was arranged and

an agreement was reached between Miluaukaa and the Chicago

Spscial Agents la Charge.

2G. on th« morning of July 20, 199S, MedajcnBch was

instructed to close out her cisa and Wright was told to proceed

with his investigation.

17. Medernach became extremely angry. She complained for

003920
. J'JL-G5-20Q1 li:49 * . P.I

two hours and bemoaned that Wright "had won." Site held Wright

responsible for har being instructod to d o s s 3*Jt her case.

18. At all relaxant times there was in effect Title VII of

the Civil Rights Act of 1964, as amended (42 OSC 2Q0QE, et. seq.}

19. Pursuant, to that statute, it was, and is unlawful to

engsgg in discrimination or harassment in ths workplace on the

basis of gander.

20. Pursuant to the provisions of the Civil Rights Act. the

FBI had in place, at all relevant times, a policy, rules and

regulations prohibiting sexual discrimination and harasssent and

providing discipline for any agent engaging In such activity.

21>. As a young, unmarried mala agent, Wright was especially

vulnerable to false and malicious charges of saxual

discrimination and harassment.

22, As a result of the foregoing, Medernach knew that she

possessed power and influence, the exercise which would damage

Wright in his profession, would humiliate him, would cause hiro

public embarrassment, and would result in extreme nvsntal distress

:o him.

23. on July 22, 1999, two days after sh§ vas ordarad to

close her case and defer to the Chicago investigation being

conducted by Wright, Haderruch filed with the FBI Offico of

Professional Responsibility a false arid malicious charge again$t

Wright in which she alleged that he had engaged in a ^pattern of

003921
.JUL-es-aaai '11=50 - . . . . s ^ p ^

sexual harassment."

24. The false and malicious charges were made uith the

specific intent to cause, or in reckless disregard of the

possibility of causing Wright saver® emotional distress because

Medernach knew that "the mare charg® itself woold humiliate

Plaintiff, publicly embarrass him in his work environment, and

would seriously damage his reputation and career in tha FBI.

25. The falsa and malicious charge and tha intentional

infliction of mental distress ware intended to punish ths

Plaintiff for depriving che Defendant of what she considered to

be her caaa. • .

25. The conduct of the Defendant as stated above w«a

extreme and went beyond all bounds of decency. The conduct uaa,

accordingly, outrageous uithin the purview of tha laws"of the

State of Illinois.

2"?. As a direct and proximate result of Defendant's

intentional and outrageous conduct as. alleged, the Plaintiff waa

• - • •.- - .-•• . - I . - , .

humiliated and publicly emb&rrassad. He suffered frraraediable

injury to his personal and professional reputation, was subjected

to a full investigation and disciplinary proceedings by the FBI

ahd'was rilievsd of his caaa3'"in the k'r'&k o£ international"

terrorism. .

28. As a direct and proximate result of Defendant's

intentional and outrageous conduct. Plaintiff has in fact

003922
01 m
 . JU_-05-2801 ii:50 { A • P.L2

1 ' W,' . '. ..- '

suffered sever and permanent mental and emotional distress as was

4 specifically intended by the Defendant when aha engaged in that

outrageous conduct.
* • WHEREFORE, Plaintiff, Robert G. Wright, J r . praya judgment

' against tHs* Defendant, Karen Madarhach., for damage's" in the amount

of brie"Hundred Fifty Thousand dollars {3150,000.00} and such

other r e l i e f as t h i s Court deems just in the premises.

* ' covxtr xwo

Intentional Tntarferenca with
Prospective ftdvantaas
j . . r "

; 29, ?iiintirff realleges paragraph 1 through 7, both

'•. inclusive of Count One as paragraph 29 of Count Two.

) . ^ 0 - Plaintiff realleges piragreph 9 through 17, both

inclusive of Count Cne as paragraph 30 of Count Two.

! " 31. Plaintiff,"'pri'or"' to the' etferit?' coinplained of hareiri/

.. enjoyed an excal'larit reputation for competence/ ability and

T
j profe5siohari*m. He was highly thought of by hia superiors/ his

/. • -.fellow law enforcement agents and those with whom hn -dealt as an

j . rBl agent. He always received highly favorable appraisals.

32. As a result of hi* "•xcaptional* work record and

excellent reputation. Plaintiff reasonably anticipated that he

! uould obtain prospective advantagas us an agent. Specifically.

. he expected to RIOVR upward within the FBI arid obtain both

financial aind professional advantages arid retire honorably wich a

003923
 P.i:

reputation/ was subjected to a full investigation resulting in a

recommendation of disciplinary action against him and was

i relieved of his duties in the field of international terrorism.

••|
7
1
r
38. As a direct and proxi'mate result of the false and
( " -. *
•i
i malicious statement and actions by the Defendant and the ac~iona
t
of t h e FBi caused by auch'statements and actions, Plaintiff's

carsar as a Special Agent of the FBI hasbsen destroyed'- tiei will

never a t t a i n the prospective advantage that"He enjoyed prior to

the Defendant's false and malicious statements anct actions in

t h a t he will no longer advance financially and 'professionally

within the FEI as he had praviously anticipated.

.••• WHEREFORE, Plainciff, Robert~GV'VrightV'Jr., 'prays that

judgment be entered against the Defendant'^' Karen Medernachs for

dajtiagea in the amount of One Hundred Fifty Thousand" Dollars

{5150.000.00} and 'such other' r e l i e f as t h i s Court deems' Just in

che premises. ' • ••• '• • • .

• Respectfully"'i'libiniccad,

ft) ?. SCHlfStWt Atcornoy for

.Plaintiff

= SCHII>?EHS & BA'SLEY

' 20 North C l a r k S t r e e t
S u i t e 3600
C h i c a g o . I l l i n o i s 60602
(312) 2S3-120O
A t t y . Ho. 12222

003924
JUL-e5-2001 11-58 P.li

VS&IFtCATlOH

ROBERT G. WRIGHT, JR./ &«ing duly sworn, on oath deposes ar.d

status that he has read the above and foregoing Two Count

Complaint, that he Is familiar with tha fact* allog«d therein and

that those faces are true and correct to tha bast of his

knowledge and belief.

ROBERT G. WRIGHT, JR.

SUBSCRIBED AND SWORtf TO

befor^?a® this /j^day ^
of LJ/LL-vL* ^ 2001 OFFICIAL SEAL
.tor
*jdTAHY p u a t r c

003925
003926
 IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
i
ROBERT G. WRIGHT, JKL,

Piaintifi; CANo.

v.
Fonneaiy Case No. 01L-007257, Calendar F
KAREN MEDERNACH, Circuh Comrt of Cook County

DefeadsHi.

' • CfiRTJWCATION

I, Helens "M* Goldberg, Director, Torts Branch, United States Department of Justice,

acting pursuant to the provisions of 28 U-S.C. § 2679(d)<2), and by virtue of the authority vested

tn me by the Appendix to 28 CJUL § 15.3, btscby certify that I iurvoreadthe complaint in this

action. On the basis of tfae information now available with respect to the allegations therein, I

find that the individual defendant, Karca Medcmadb, waa acting within the scope of her

employment aa an employee of the United States at the time of the incidents out of which the

plaintiffs claim arose. Specifically, I find that the act of reporting or giving an official rtatement

concerning the plaintirFa misconduct was within fee scope of Ma. Medemach's duties as 8

Special Agent

IM.GOI Date
Director, Torts Branch
Civil Division
U.S. Department of Justice

89
003927
 ^3 44
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tn

-,—;•.,,;. ^ , , , . JUDGEZA6EL

1 IL BAS® OF JUFUSOICTK5H K « « r i i w i ucaowyj

' ' ' - . , ' •"' v " *• '""••'"'•'•"-•';i"j:;"v'.va!:/!'T.»1)i>»1KP5St

CaalBTl D( AnqSra Eteto D I p i sraf PrtiidpeJ f=isoa t

C&tan or
foreign .-" . >-.T • -.v -• :• K» . > » ^ i ^ ~ r - "•'•-j^»j'rb

pLAC?/W5r»c^rEcac!ftaij .• > , •-.:••.;; Af?»sJ

d
OIC^EM. ni^wBd«=" *^?^?^.*^ D«"»™*c*or n»BsS^cSs«fctt Di
Prcesstfeg S s ^ , Court Ap^atoaCou*
%L MA*nHR£ O ? SOfT mACSAfi'Tf MOm-BatONO)

DOB0TCSlSJU^5O«STO>*lKi0WBSl*41B8Dt 1 ffiSmq . ". ' " "

k-¥/

{"I b »i*B&s of cssa tm&m , pwrvtousfy dsauteEil by iix^e

i A

DAH

•j\r£y^:-. : ^ ^ » I k . i ^ ^ .A Mffyi-r . i/l'-f4--h>t^o^.'.-.•'•-• 003928 j ^ /

U.S. District Court for the Northern District of niinois Page 1 of 2

si Alt*'
RACER U.S. District Court Case Search

Docket Sheet for l:01-CV-5529 U.S. District Court for the

Northern District of Illinois - Click here for Caption Page

Proceedings include all events

Doc.
Date Filed Image Description
No.

MINUTE ORDER of 10/2/01 by Hon. James B. Zagcl:

Plaintiffs motion for voluntary dismisssal is granted. [7-1]
Yes: 2 Pagef s): 48
10/02/2001 Case is dismissed with prejudice and without costs pursuant
KB: PDF
to stipulation, terminating case (EnteredOrdcr.) Mailed
notice [Date Entered: 10/03/01, By. tlm]

MOTION by plaintiff for stipulated voluntary dismisssai;

09/27/2001 No Stipulation to dismiss ; Notice. [Date Entered: 10/03/01,
By: tlm]

MINUTE ORDER of 8/21/01 by Hon. James B. Zagel:

Status hearing set to 10:00 a.m. 10/17/01. Enter order
dismissing the claims against individual, Karen Mcdemacb
Yes: 3 Pagers): 56
08/21/2001 with prejudice and without costs. The United States
KB: PDF
ofAmcrica shall be substituted as defendant in this action.
(Entered Order). Mailed notice [Date Entered: 08/22/01,
By: tlm]

MINUTE ORDER of 8/7/01 by Hon. James B. Zagct:

Plaintiff may the answer the motion to dismiss, Qle an
Yes: 1 Pagers): 29 amended complaint, or a combination of the two by
08/07/2001
KB: PDF 08/28/01. Answer brief to motion to dismiss due [4-1]
8/28/01. Reply toanswer brief not ordered. Mailed notice
[Date Entered: 08/22/01, By: thnj

MOTION by USA to dismiss for lack of jurisdiction

07/25/2001 No
(Attachment); Notice. [Date Entered: 08/22/01, By: tlm}

07/25/2001 ATTORNEY APPEARANCE for plaintiff by David P.

No
Schippers. [Date Entered; 07/30/01, By: tlm]

MAILED Rule 77(d) to David Philip Schippers regarding

07/19/2001 notice of removal with appearance form. [Date Entered:
07/19/01, By: hpj

httpiy/racer.iInd.uscourts.gov/wconne...:l-<:v-5529—ALl+Documrats~on~puid=0100768080 12/6/2001

003929 9
U.S. District Court for the Northern District of Illinois Page 2 of 2

NOTICE by USA of substitution in place of defendant

07/17/2001 2 No
Karen Medcmach [Date Entered: 07/19/01, By. hp]

NOTICE OF REMOVAL (Exhibit) by USA from the

Circuit Court of Cook County, E, with copy of summons
07/17/2001 1 YwlGPagcfc); and complaint, case no. O I L 007257 - Civil cover sheet -
468 KB; PDF
(Documents: I-1 through 1-2) [DateEntered:07/19/01,
By:hp}

PACER Service Center

ElrconiaJc C«w M j u p i " 1 - iM Prtmitr Eltcmmfc CW n/t M««<r.'

http://raccr.ilnd.uscouit3.gov/wconnc...: l-cv-5529—AJl+Documents~on~puid=010Q768080 12/6/2001

003930
 i§g?.2..j

U.S. SECURITIES AND-EXCHANGE COMMISSION

jj| Waabibgtoo, D.C 20549

FORM10-KSB --••

PC] ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE

SECURITIES EXCHANGE ACT OF 1934

For the fccal year ended December 31, 2000

OR

[] TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE

SECURITIES EXCHANGE ACT OF 1934

For the transition period from to

.Ji, J Commission file number 0-21635

', i

Global Diamond Resources, -Inc.

(Name of Small Btxriacss lumar ira to charter)

Nevada ". 33-0213535

(Stall or oliwr^BrUdtcilea rf. ~ * . (LJL5. Eapiayxr
[i>csr|»nrli»a or Brgsaisx&Ht) lit«BriBcirti«j No.)

836 Prospect Street, Suite 2B *nfftf

La iolfa, CaliFwnia

ajJKr'lhJrpboiKBB<Bbcr,l»chiifia3«r««cwJ« f?581 459-1 ? 2 8

Secnritita to be registered nader Section I2(b) of tli« Act

-
* • • "~ - '

1
Title irfatictea ^ "•*- N«Ba»fe*rt tniutse pntiikk
ta bt •• nqhtmA ^ . eadb ckat h »<w tej*rt«rcd

SectfrlUea to b« regisJeret! under Sectfoa I2(g) of the Act:

Common Stock, S.0005 par value

•*iM.H

003931
 Indicate by check mark whether the registrant (1] h » filed all reports required to be filed by Section 13 or I5(d) of
the Exchange Act of 193-4 during (lie past 12 motife (or for such shorter period that {he registrant war required to
fife such reports), and (2) has been subject to such-filing requirements for the past 90 days. Yea X No

Check if there \s no disclosure of delinquent filers pursuant to Item 405 of Regulation &-K contained in this form,
and «/i!J net be contained, to the best of registrant's knowledge, m definitive proxy or information statements
incorporated by reference m Pan IU of this Form I0-K58 or ury amendment to this Forra.IO-KSB. [ ]

The market value of the voting stock held by non-afHliate3 of the registrant BS of March 22, 2001 WBS
approximBtery £2,992,81Z

The number of shares of the Common Stock outstanding a of March 22, 20O1 was 53,171,678.

Documents iacorporotcd by reference: None.

'^J

" 003932-- 9^
 Parti

ftem 1- Description of Business.

Business Development

Certain mining and geological terms used below are defined in the section "Glossary, " below. The
Company has entered into certain financial commitments payable in Rand, lla unit of currency oflka Republic of
South Africa. All Rand based amounts are designated by the symbol R. As of March 21, 1001, the Rand-Dollar
exchange rate wai 7.97 Rand to one U.S. Dollar.

Global Diamond Resources, fnaT a Nevada .corporation ("Company"), was formed under the laws of the
Stale of Kevada on January 7, 1937. We arc engaged in diamond mining and exploration through our wholly
owned subsidiary Global Diamond Resources (SA) \?ty) Limited, 1 South African corporation.

On June 16, 1999 the Company increased its authorized Common Stock from 50 million shares af
50.00G5 par value Common Stock to 100 million shares of M.0OO5 par value Common Stock.

&..J Unless the context otherwise requires, ill references to "we™ and "ihc Company" include its wholly owned
subsidiaries:
a Global Diamond Resources Inc., a British Columbia corporation (GDR-BC),
• Global Diamond Resources (SA) (Pty) Limited, a South African corporation (GDR-5AX
B Global Diamond Rasourras International Limited, a British Yirgm (stands corporation (GDR-BV]),
a Nabas Diamonds (Pty) Limited, a South African corporation (Nabw).
B GDR Drilling (Pty} Limited, E Soudi African corporation (GDR Drilling) .

Our executive offices "are located m 136 Prospect S&iet, Suite 2B, La Jolla, California 92037; Telephone (358)-
459-1528. • -

Business of the issuer

General

The Company is engaged in diamond exploration and mining. We have acquired two mining properties
(the Grnsdrif Deposit and the Cacrwirtning Depo»it)j and own »n option to purchase a third mining property (the
Montrosc Kimberlitc Pipe), »fi of which are located in the Republic of South Africa.

Background
ft j

Diamond ia the name attributed to a chemically inert mincrai. which normally occurs as crysiiib formed
when tne element carbon ia sufafectod to extraordinary Ix-sl gnd pressnro. Diamond is believed to have been formed
at a depth of 2fXMO0lan below the surfeca of the carts'and is then transpaied to the earth's surface by the upward
movement of motics rock. Themdtcn rock solidifies as semi-cireul«a" (pipes) or linear bodies (fissures). The
solidified rode is known as JcimberJrte. Pipes and fissures are eroded over time, and the diamonds thus released
from soch formations arc transported and are eventually deposited in undent car existing riverbeds and on beaches.
In these deposits, the diamonds are typically nssodaitd vrilh the coarser (gravel) fraction of the sediments, which
are collectively known as alluviaj deposits. The pnrrfa -oferosion grind* and crushes the poorer quality diamonds
thereby en hanting greatly the average quality of the diamonds eventually deposited.

EHascoad txplorniioa

Diamond expkiratiejn typically begins with acrid photography, surface sampling and magnetic .surveys for
purposes of locating- indicator minerals or geophysics] anomalies, which may indicate the presence of kimberlite or
an alluvial deposit. In the event a pipe ia located, follow-up sampling is conducted to determine if it is

003933
 cj^

disrnondiferous. If the pipe is determined lo be drarnondifcrota, bafk sampling is then conducted lo evaluate the
value of the diamonds present and the grade of the prospect and thereby establishing proven or probab/e reserves.

The expiorarion and evaluation of an alluvial diamond deposit is similar to that of Icimbcrlite but typically
more complex and leas conclusive because of what Js termed the "nuggei-effefct" which' pertains to the scarce and
irregular distriburioo of diamonds in.the gravel. Drilling can only determine (he Ihrcc-dlmensionaf extent of the
gravd while butk sampling is of necessity substantially more complex than for kimberlitc

Diamond mining

Kimbcrlitc pipes are ruined through a combination of trpeos pit excavation snd underground mining. The
raining of a kimbcriite pipe typically commences vrith an open pit mine to a shallow depth, generally 30 metcrx
Initially, a mining zone is designed and then bulHccffira are used to remove the tcpsoH, which a set aside for
rccIamntioD- Hydraulic excavators arc then employed to otcavale «n open pit. As the mining operations expand,
digging benches fntb the pit wall enlarges the open pit. Since kinbcrlite pipes are relatively confined bodies, it
becomes impractical at s certain depth, approximately JO to 100 meters, to continue mining operations through
open pit excavaticn. At this point,'shafts «re sunk sway from and parallel to the ore body, and from these shafts,
adits to the ore body are developed at varioaa levcJs. The lutnberliie ore a hoisted to the surface and hauled to a
recovery plant by truefca, '^i

AJIuvfal deposits are mined by open cast methods generally known a strip raining. Removing any
overburden present exposes the £ravrt. The gravel is then removed by hydraulic excavator, loaded onto trucks and
trfflnspcrred t o the recovery plant wicre it is then screened to remove ill particles larger than 25mm. Tfi« larger
fractioa is discarded while the smaller fraction is then processed by gravity separation (rotary pans) or centrifugal
separation (DMS) to recover the particles with a relative density of larger than 2.9 as concentrate.

HecoTery . ' •

Each recovery plant consists of screens and associated separators thai employ water, agitation, gravity and
centrifugal force u s primary method to separate ihcheavier dfamondiffcrous concentrate from the lighter tailings.
The two methods employwj are rotary pans and dense media, separation (DMS). Both methods sre well
tried, the only difference being that pans ire mud}- cheaper to construct and operate, however a DMS can be
menftored electronkaliy. - ,"

Electronic sorting machines conduct final recovery frwn the concentrate- These machines utilize the
lutn incsceni properties, of diamond when it b irradiaigd with X-rays. Pboto multiplier tubes sense the luminescence
and activate a trap door, which diverts the diamond to a safe boat. This concentrate is then finally sorted by hand.

.£.--•' Marketiag

The Company sells its diamonds directly to private diamond dealers and manu&cnirers through a tender
system. There are no formal rules by which the prices of dlamaods i r e determined. Sale prices are set by the
diamonds' color, clarity, cut and weight which- die prospecdvB buyer expects to obtain through the polishing
process, and the evaluation process is generally subjective. We expect thai thesaJea of diamonds will be transacted
in U.S. dollars on a cash basis.

003934
96
 k..

Glossary

Set forth below are definitions of certain mining and geological terms used in this report.

Adit 5* The main fibrizontal or near-horizonlaJ'underground opening, with single

access to the surface through which a kimberiite pipe is mined and the ore
is excavated!

Alluvial Deposit A mass of gravel, sand or similar material resulting from, the crumbling
and erosion of solid r e d o . In the sense that it Is used hem, it also implied
an asociatitti. with precious minenis such as diamond. A deposit of
alluvium (deposits made by water) is made by a stream where it nan exit
onto a level plain or meets a slower stream.

The solid or weathered rock underlying mineral-bearing grave), sand day,

etc and upon which alluvial deposits rest.
O
Bench. Cut? The excavation of a flat bench or dirt on a slope to stabilize the slope or to
remove material of value in open pit mining.

i\ j Bulk Sampling Acquiring a forge (often several thousand tens} sample of rock obtained by
mining, excavation, digging or drilling large diameter hales. Balk
sampling is-.necessary to determine the grade and value of diamonds
contained in a deposit.

Carat A uniJ of weight used fix- precious stones equal to 200 milligrams Or 0.2
grams.

Concentrate That fraction of the processed ore which contains aJ) or the largest portion
of the economic mineral to be recovered. In the case of alluvial deposits,
approximately 0.5-1.5% of the ore reports as concenirate from the primary
recovery process. Of tha a further Q.l-Oy/i reports as concentrate from the
electronic sorters.

Diamondifa-ous Containing diamonds.

GcoohYsicai Survey? Manuring and recording any geophysical properties over s specific area,
eg-, gravity^magnetics, electrical coaductmry, acoustical velocities
(seismics), etc^'htilizrng instrument! on land, water or airborpc.

£_, The number of carats (weight) in a physical unit of ore, normally in carats
per 100 tonnes.

A comprehensive term applied to the watcr-wsn mass of broken down

r o d u making up an alluvia! deposit Alluvial gravels are srancfima
arbitrarily described in terms of size as "pebble," "cobble" or "boulder"
gravel.

Unit of measurement of surface area. One hectare approximates 2.47

seres.

Kimberlite Ons of two pn&ory types of diamond-bearing rock and the most common,
often characterized by a more or less vertically orientated carrot-jhaped
structure rdcrrtd to as a kiraberlttc "pipe.™

Magnetic Surveys Measuring the magnetic variations in the earth's magnetic field caused bv
the variations in the magnetic properties of different rocks m the earth's
e n s t with an instrument known 33 a magnetometer cither as ground-based
3

r^y c< r «y 003935 97

*•" L

or mounted within or lowed by an aircraft. Useful m detecting kimfadite

bodies due to the presence of magnetite wd/ssr ilmcnite.

Mineralogy The science dealing "with inorganic, solid, Homogeneous, crystalline,

chemtcaj elements or compounds... (minerals), tha'r crystallography,
physical and chemical properties, classifications and distinguishing
charad eristics.

Mining The activity, occupation, and industry concerned with the large-scale
extraction- at minerals and includes both sur&cs and underground
exawarioni! The making of any excavation for the purpose of recovering
diamonds fri cotnmercisf quantities. Of primary importance in the
Republic oCSouth Africa where mining laws draw « distinction between
"mining** and "prospecting." Sea "Prospecting."

Ore A body of rock or sediment containing a mineral that has sufficfent utility
ind value to be extracted at a profit. See "Reserves."

Overburden A body of rock or sediment that docs not contain a mineral lhaj has
{ sufficfent utility and value to be extracted at s profit (Le. waste).
\.J
The science that deals wfth the origin, history, occurrence, structure,
chemical and mincralogical composition mid classification.

Probable Reserves Reserves for which quantity and grade uncVor quality arc computed from
(Indicated Resource) tnibrmaiion similar to [hat used fcr proven reserves, but the sites For
inspect/on^sampling, and measurement arc farther apart or arc otherwise
less adequately spaced. The degree of assurance, although lower than that
for p'rwar reserves, is high enougK'lo tisuine continuity between'points of
observation.' See "Reserves" and "Proven Reserves."

Prospecting Searching for minerals (including diamond) by any means such as

geophysical, drilling and pilot plant recovery methods, bui does not include
"raining™ {Lt, excavation for purposes of recovering dismoodi in
cottnnerciaJ amounts). See "Minaig."

Proven Rcscryea Rejerva {far which (a) the qwmtfty is computed from dimensions which
(Measured Resource) can be measured from outcrops, trenches, workings or drill holes. Certain
grades end/or qualities computed from die results of detailed sampling, can
be Hllocaicd to tfic quantity thus delineated and (b) the sites for inspection,
sampling j n d measurement are spscsd so doscJy and the geologic
character is4o well defined tbet SIZE, shape, depth and miner*) content of
the reserves arc wsllnssteblished- Sec "Reserves" and "Proven Reserves."

That part of a total camera] deposit (resource) that an bn economically ind

legally processed or produced from at the time of the reserve
determination. Reserves are customarily stated in terms of "ore"

Stripping Ratio The overburden that must ba removed to gain access to an amount of ore.
Expressed as a ratio in meters or tonnes of overburden: one meter or laine
of ore. The standard in this Company u to use a ram ratio. .

TTw washed material that Issues from a recovery plant after the economic
portion of the ore fiw been removed as a. concentrate.

003936 98
 The GntsdrirDeposit , • _

Property Rights. The Company holds a prospecting permit far the Grasdrif Deposit through its wnollv-
owncd subsidiary company, Nabas. The prospecting permit expires on August 4,2003. We will apply fa*a mining
permit when the level of activities warrant such an application, fa terras of the prospecting permit, we are required
to pay to the government a surface rental amounting to R5,20fl ($652 as of March 22, 2001). This amount vras
increased to R10.400 per year, beginning in 2001. Additionally, in agreement was reached in August 2000,
whereby the Company has agreed to pay the Namaqualand District Council a minimum of R50,000 (56,274 is of
March 22, 2001) per year, considered a usage Tee. We are in the process af delineating ore reserves on these
extensive deposits with the view of applying fbr * mining permit in the near future.

Geography. The Grasdrif deposit is an alluvial diamond deposit located on the inner bank of ihc Orange
Rivw in the Northenj Cope Province.

Geology. The Grasdrif Deposit is an alluvfst.gravel deposit situated on a bedrock of shale and greywackc
of the Dwyka formation. The gravels of the GrasdrifDcpcsit have been preserved at three distinct elevations, all of
wfeich seem to have been deposited on the inner bank of the paleo- and present Orange River. The upper terrace
_,••. (elevation 215 meters above sea level) appears to have been deposited as a. point bar of a channel incising in »
V!']1-.-' westerly directicu, while aJl other terraces are associated with t gradual eastward migration of the channels
towards its present position.

JUnrves. Based upon the following, we estimate that the Grasdrif deposit contains approximately SO
million tonnes of duunondiferotci gravel:
a the results derived from a 10,000 meter drilling program completed by the CompBoy in 1997,
H ongoing second phase drilling and bulk sampling, and
is the results of previous exploration programs on the property conducted during die early 1980's.

Mtning Activities. We have completed site establishment at Grasdrifj including roads, power, housing
and water reticulation, erection of a primary end final recovery plant on the tower terrace, and a primary recovery
plant OH the upper terrace. Bulk sampling operations on the lower terrace commenced during the last quarter of
1998 and trial mining oo the upper terrace during the last quarter of 1999.

See "Item 6. Management's Discussion and Analysis or Plan of Operations" fbr a discussion of (he results
of operations and capital requirements of the Grasdrif Deposit.

Tiie Cacnfianinfj Deposit

,£? . Property Rights. The Company has acquired the exclusive rights to conduct mining operations M.
irj v --' Caxwinning, a 2 ^ 3 3 hectare alluvial deposit located in the Northern Cape Province of the Republic of South
Africa. Pursuant to the mineral lease, wa have an initiaJ 10-year right to mine at the Csisrwinning deposit,
expiring March 3 1 , 2008 (with a 10 yew renews] option). In terms of the mineral lease, we arc required to pay KJ
&e government a 5 % royalty of the grow selling price of the monthly production from lhe deposit, with a
minimum payment of R65.000 per year, (58,156 as of March 22^2001), sad ID be increased by R5.000 per year.

Geography, The Caervrinning Deposit is an alluvial gravel deposit situated in the Griqualand area of the
Northern Cape province,- approximately 7t] kilometers wes* of Kimbcrley. ft borders to lhe cast along the Vaal
River, approximately 2 0 WJomeJera. downstream of*the confluence of the VBBI and Hart Riven. Access to the
dsrvnnniag property is available by way of public-paved and gravel rosda. The property b serviced by the state
electric utility.

Geaiogy. The gravd of the Caerwinning deposit is underlain by qusrfcdte and sfule of the Scntakftsdrift
formation of the Transvaal Sequence, as well u ourbeniferoua shale and tfllite of die Ehvyfcs Formation of the
KJTOO Sequence. Rock types of both sequences found on the deposit are horizontally or near horizontally bedded,
and are net cojitjucivo ta pothole formation. Outcrops of rocks of the Tranavaai Sequence occur along the western
mid southern boundaries of the deposit. Rode typo belonging to the Dwyfca formation do not outcrop and were
- only found ax drill holes and excavations. The gravd occurs in three distinct terraces, of which the oldest {a..

003937
 located the furthest from the present riverbed. The terraces are named Tl, T2 and T3 with Tl bemg ihe oldest.
Secondary calcification is extensive in ihc oldest terracar but negligible in the later nnd recent deposits. The grave/
of both terraces mainly consist of cobble and pebble sized clasts in a jandy matrix. Boulder sized particles are
extremely rare except where local•tributBrics have introduced-lwge, slightly angular boulders into the mainstream
deposits.

Reserves. We have completed a drilling program covering the entire Tl terrace cast of the msin road and
T2 terraces. The results af this drilling program indicate that theTI terrace contains 2 1 J million icmnes of grave)
and the area drilled, on the T2 terrace contains 1.2 million tonnes of dismoudifcrous gravel. During 1999, a
drilling program was conducted on the Tl terrace to (he. west of the main road. The results of this program still
need to be interpreted iurther but preliminary indications are that the Tl gravel extends into this area. Prior to
incorporation of tho Company, Mr. Pieicr Van Wyfc, currenlJy the Director of Mining and Exploration of the
Company, worked this deposit in his private capacity and extracted 3,685 carats from 344,400 tonnes of OTE for an
average grade of 1.07 carats per hundred tonnes between 1989 and 1994. Diamonds thus produced were sold jbr
an average price of 5458 per carat.

Mining Plan. We commenced production Bt the T2 terrace at Caenvinntng when we'commissioned the
primary and final recovery plant on site in the las* quarter of J998. We commissioned in additional diamond
recovery plant during die last quarter of 1999- The combined capacity of the recovery plants now amounts to 240
tonnes per hour.

Sec "Item fi. Management's Discussion and* Analysis or Plan of Operations" for a discussion of the results
of operations and capita.! requirements of the Cacrwnnirtg Deposit.

The Moatross KlmberlUe Pipe

Property Rights. The Company has the exclusive prospecting righla and an option to purchase s farm in
the Gauteng Province in the Republic of South Africa, which includes a mining prospect known as the Montrosc
ND. 3 (referred to herein as die "Mootrose Pipe"). Pursuant to a Notarial Prospecting Contract between Maria
Anna Gobey and our wholly-owned subsidiary, GDR-SA, WB have extended die exclusive rights to prospect on the
property until October 10, 2001 in consideration of a payment of R60.000 (SS.268 af September 20, 2000 ) and
10% of ifio value of d l diamonds recovered by us during the prospecting period. We also have the exclusive
option until October 10. 2001 to purchase the farm for a purchase price of Stf 00,000. We are in the process of
applying for an exitnsion of the prospecting permit, which includes the preparation of an Environmental
Management Program Report (EMPR) for the submission to the local government. Upon acceptance of tho report,
the prospecting permit will bo Issued.

Gsography. The Monirose Pipe lies 500 rijcters north of Rayton and 30 km east of Preterit in the
Gsulcng Province. Tho area forms part of the temperate eastern plateau and has an average elevation of 1,500
meters, with warm summers and cool winters. Annual rain&il during the summer month* averages 7S5
millimeters and year round 'mining is undertaken ha the vicinity. Tho region is accessible by the N4 Freeway and
the Transnct Railway. Ingress to and egress from the Montrtae property is availaHc by my of public paved and
gravel roads. The property a serviced by the state deefcric utility and wafer for raining purposes is available from
the Bronkhorstspruit Dsm, 20 kilometers to the east

Gealagy. The Montrose Pfpo is intruded into the upper part of the Rayton Formation, Pretoria Group.
The irea is underlain by a north-east ariking succession of quartdte, shale and mbgraywacke of Prtcainbrian agr.
The Pretoria Group has been intruded by* number offeimberUtepipes and to a lesser extent by Idmberiiti! fissures.
the IsUer striking mainly east-west. A toUl qf ten. kfmbcrllte bodies are known to exist around Rsyton. six of
which, the Montrcse No. I, Montross No- 2, Mwkrase No. 3, SchuJIer-Kaallbnlcin, Nutlonnl and Annex, have
been prospected and exploited to s limited wtenJ irr,thp past.

Reserves. The results derived from a geophysical survey, a drilling program, as well ta a large diameter
drifling program completed in April of 1998 indicate tho existence of • kjmberJila pipe with a surface srea of
approximately 1.25 hectares ss w l l u a 12m.wide fissure on the southeastern boundary ofjhe ferro. A sample of
28 mainly gem quality macro diamonds obtained ftpm the drill samples indicate that the diamonds are distributed
throughout the pipes 81 all levels. We estimate the pipe to contain in excess of 9 raiTlion tonnra of Icnnberlite ore to
a depth of 4W) melers.

003938
t An
 See "Ftem 6. Management's Discussion and Analysis or Plan of Operations" For a discussion of !he results
of operations and capita! requirements of ihe Monlrose Pipe.

Competition

The diamond mining industry is intensely competitive. The principal areas of competition arc the
exploration and acquisition of mineral properties. A large number of companies arc engaged in tJic exploration and
development of diamond properties, many of which have substantially greater technical and financial resources
than the Company. Competition among the members of the diamond mining industry also affect the marketing of
the diamonds produced by the members, in eluding,the price of cut and uncut diamonds.

Regulation

The Company's mining and prospecting operations in the Republic of South Africa and elsewhere arc
subject to various government regulations governing the protection of the environment, prospecting, production,
labor standards and mine safety. Failure to campty with applicable laws and regulations may result m operations to
cesso or to be curtailed, require further expenditures or possibly the loss of mining rights. Existing and future
legislation and regulations could aUo cause restrictions and delays in the development of our properties and
additional expense and capital expenditures. We believe we are in subsiantiaJ compliance with all taws and
{ y regulations.

Our mining operations are also subject to governmental regulations regarding environmental
considerations, including regutatioos relating, to aiTjjuality standards, pollution of stream and fresh water sources
and rehabilitation. We cnay be required to prepare and present to governmental authorities data pertaining to the
effect or impact that any proposed exploration or"mining may have upon the environment- As well, we vril! be
responsible for rehabilitation coats. We currently engage in ongoing rehabilitation as well as provide funds, on an
annual basis, for final mine closure rehabilitation. Rehabilitation requirements may vary depending on ihe
location and the nature of the mining operation*. However, they aim to restoro me pre-tnlning landlbnns and
vegetation and control possible deleterious effluents. We do not consider the existing environmental regulations in
the Republic of South Africa to represent a material cost or burden on our proposed raining operations. However,
new environmental legislation has been tabled, and other legislation has been passed which places significantly
more emphasis on Ihe protection of the environment and, as a consequence, more closdy regulates our mining
operations. Such legislation, together with legislation which may be tabled. Tn future, as well as future
interpretation of existing laws, may require substantial increases in equipment and operating costs, and may cause
delays, interruptions or a termination of operalioni, the extent of which, at present, cannot be predicted with
certainty.

Mining rights in the Republic of South Africa are gorverned by the Minerals Act No. 50 of 1991. Pursuant
to the Minerals A d , the right to prospect or mino u dealt vrrth in terms of the common law, which entitles the
v. I holder of the right to prospect for and mine die minerals concerned. This common law right is, however, made
subject to the provisions of the Minerals Act, which state that no common law right to prospect or mine minerals
may be exercised unless the prescribed statutory authorization has been obtained ki Ihe form oft pennrt to prospect
or an authorization to mine. A prerequisite for Ihs granting of tho aiithornatios that the applicant tnusj be the
n
hoidcr of thecottunon taw right to the minerals.

Pursuant to cessions from the holders of the common law mineral rights, we have obtained government
authorization to prospect the Grasdrlf Deposit and mine (he Cserwinnmg Deposit. We have applied for the
necessary authorization to bulk sample the Monlroec KfmberlFte pipe. We believe we will be granted the necessary
authorization to mine the Qrasdrif Deposit and the Montrosc Kimbcrlite Pipe when required.

Ksipfoyitcs *<

As of Dcccmbar 31, 2000, the Company eraployed"i32 persons, including 2 management level employees
in the U.S. and 6 managers and 124 other employees in the Republic of South Africa, None of our anpfoyees ire
unionized or odlcrwiss subject to a co/tecfive bargaining agreement and we believe that our relatioaship with our
employces is excellent. Subsequent to year end, approximately 60 employees were terminated as part of our effort*

.;

003939 101
 to streamline production casts and reduce'urinecasary payroll costs. All tcrminaied employees were given
retrenchment packages as well as assurances that, upon future labor demands, they will be rehircd,

Iteta-Z Description of Property. _ - . •• • _ .

The Company's executive offices arc located in La Jdla, California and consist of appraximaidy J99
square feet of leased premises. Our lease for these premises expires on March 3 1 , 2002 and provides fir monthly
rent of $1,462. We also lease approximately 260 square feet in the SA Diamond Cento crt Johannesburg. South
Africa. The lease provides for monthly rental of R1.660 (S208 as of March 22, 2001) and expires on February 28,
2003. We lease approximately 750 square fc« of office space in Somerset West from a director of the Company for
RJ8Q0 (S226 as of March 22, 2001) per month tri&no expiration. Subsequent to year end, we moved our office
from Somerset Weal to our property Fn Ddfportthojjp, South Africa. We purchased a property in August 199S in
Ddpcrtshoop, Sooth Africa, which is near the Cserwinning Deposit, by issuing 151,171 shares of Common Slock
and an extension of certain warrant terms. The property, which consists of an office and employees and visitors
housing totaling 5,880 square feet, Is used for the Caerwinning Deposit. See "Item I. Business and Properties -
The Caerwinning Deposit; The Montrcsc Kimberlite Pipe; and The Grasdrif Deposit" for a description of the
Company's rniniog properties.

Item 3 . Legs! Proceedings.

A /
In Jury 1999, the Company and its Chairman, Johann de VUliers, were named as defendants in an action
Mr. Abu Bakr Bin Ali AJ-Akhdsr Mood fa-ought in the United States District Court for lhe Southern District of
California. - Mr. Abu Bakr is a former director of the Company- In ihsfoction, Mr. Abu Bakr alleges that he acted
as a finder in connection with the sale of a total vt 56,000,000 of the Company's common stock to rwo private
investors and that ia connection widi that offering, Tie was entitled to a finders' fee equal to approximately 28% of
the gross proceeds. Mr. Aba Bakr allego that the'Cdmpany and Mr. de VillFers fraudulently forced Mr. Abu Bakr
to pBrticipsfte rn a binding arbitration regarding his'finders' fees and that as a residt of this arbitration, he-was
forced to return the finders' fee and resign from his position with his then current employer. Mr. Abu Bakr has
alleged causes of action for breach of contract, unjust enrichment, fraud, misrepresentation and duress. Mr. Abu
Bakr also alleges iatcrftrencc with and breach of his employment contract with his then current employer. Mr.
Aba Bakr -seeks compensatory and punitive damages in an unspecified amount

In August 1999, the Company and Mr. de Villiers filed «n answer to Mr. Abu Btkr's complaint in which
they denied all of the allegations coabsiDcd therein. The Company believes (hat the allegations of Mr. Abu Bain-
are fiivofoiw and, accordingly, the Company intends to vigorously defend this case

Item <• SabmiMion of Matters to a Vote of Security Holders.

} j • There were no matters submitted to the security holders of the Company in 2000.

003940 l ( ) 2
 •: j T •

Fart II

Item 5. Market for Common Eqnlry and Related Shareholder Matters. •-.-.

The Company's Common Stock has been listed on the OTC Bulletin Board under the symbol "GDRS"
since August 12, I99<5. Set forth below are the high and low dosing price* for the Company's Common Stock far
each quarter during 2000 and 1999. The quotatioss represent inter-deaier quotations without retoi! markups,
markdowns or commissions and miy not represent aptaal transactions.

Quarter Ended High Low

December 31,2000 SJ438 S.07S1
September 30.2000 5.5312 SJ25OO
June JO, 2000 t -S750 S.4375
March 31, 2000 S.9375 S.1250

December 3 J, 1999 SJ250O S.0781

September 30. 1999 S3438 S.1250
June 30, 1999 S-2344 S.I 094
March 31, 1999 S.4375 S.I 552
jj
As of March 22, 2001, ihcrc were approximately 154 record holders and 426 benciiciaj holders of the
CompBny*s Common Slock. '"•'

We have not paid any cash dividends and <ip not contemplate paying dividends m ihc foreseeable furore.
It is anticipated that earnings, if any, will be retained for the operatic*} of the Company's business.

During 2000, we had the following transaction! in common stodc:

• During March 2000, we issued 1,711,000 shares of common stock for 5342,200. These shares were
accompanied by [,711,000. common stock warrants exercisable at 5.20 per share and expire in March 2003.
• During April 2000, we issued 335,000 shares of common stock Per S67.D00. These shares were sccornpmied
by 335,000 common stock warrants, excrcissble at SJ20 per share and expire in April 2003.
• During May 2000, we issued 360,000 shares of common stock for services, valued at $90,000.
• During June 2000, AW issued 1,040,000 shares of common stock for £520,000. These shares were
accompanied by tiWO.OOO common stodc warrants, exerctsable at S.50 per share and expire in June 20Q3.
• During August 20OO we issued 100,000 i h n r s of common stock for services, valued at $37,500.
• Daring'November 2000, we issued 25,000 sharta of common stocfc for services, valued it 54,688. In addition,
we issued 100,000 common stock warrants at S-50 per share. 25,000 of these warrants are immediately
w\ J ejcercjsabJc, 25,000 arc exercisablc when the average seven day dosing value of the stock reaches $1.00 pa-
share, and 50,000 are exercfeaMo wfaea the nverjge seven day dosing value of the stock readies SI.50 per
share. The-vrarrmts expire on July 1,2005. • '
• On December 31,2000, we issued 3,500,000 shares of cenunon stock for M37,449.
• On December 31, 2000, -we issued 500,000 shares of common stodc valued at S39.O5O as an Laccntrn; to m
emp Joyce of the Company. Tide to the shares vest at 100,000 per year, due upon completion of cadi year for"
five years. ' .

During 1999, th«re -were no naJea of common stock. We had the following transactions relating to
common stock during 1999:
• August !999, 100,500 common stock options were granted to sn employee of lire Company excrcisable at
SJ25 per share. 75,000 options arc currently exercjsable, with the remaining 25,000 exercisabfe after August
1,2001. The options expire August 1,2009 or 60 days afler tamlnsricn, whichever occurs first-
» In addition, f 67,000 common stock •WTUTBHU tfgis granted to a consultant, immeditttEry exercisable at S.O781
pud expiring December 3 1, 2004.

During 1993, we had the .following transactions in common stock:

9

003941
103
 •y

• During March 1998, we issued 86,143 sfiares of common stock from warrants exercised tt S.75 per share or
£45,896.
» During August 1998, we issued 151,171 shares of common stock, M well as an extension ofcrrtain warrant
- terms, for the purchase of property in Delportshoop, South Airica. The common stock was.vaJued at 561,980.
• During December 1998, we issued 20,706,950 shares of common stock totaling £5,334,230.
» During December 1998, tve issued 666,667 share* of common stock valued at S133.333 (o a shareholder as a
fee for their assistance in Ihe return of a disputed finder's ice.

Item 6. MflMgnmeot'j Dtscmaioo and Analysis

Background
The Company is engaged in diamond exploration and mining. The Company has acquired the rights to
two mining properties, the Grssdrif Deposit and thfi^Caerwinning Deposit, and owns *n option to purchase a third
mining property, the Montrose fcimberlhe pipe, all pKwhicfi are located in the Republic of South Africa.

To dale, our activities have included the investigation and acquisition of mining property interests,
exploratory work, site establishment and the purchase end operation of mining plant and equipment in the process
of dervelopmcnt as Weil as full-scale mining operations at its properties.

.£ \ Results of Operations ' -

Caermmjfag
The Company's principal mining activities arc conducted at its Caerwinning property. The following
chart details production information for the three years ended December 31, 2000, 1999 and 1998:

2000 1999 1998

Number of tons treated 552,000 186,DOO 37,000

Number of carats yiejded 5.017 1,080 . 219
Estimated S Value a£ recovery* .52,000,000 . S457,00Q SS7.000
EstJmatedS Value per Carat at recovery* '.' "• 1399 S423 S39S
Operating Progt/(Loss) (5432^78) (5536,649) (5122,209)
*May not reflect actual sales value due to changing inventory levels.

Norwrtfastacnding sn operating profit of $411,177 for the first nine months of 2000 operations at
Caerwinning resulted m an operating loss of 5432^78 for tha year. In the third quarter of 2000 a calcified
conglomerate was discovered, necessitating the need to add crushers to process the gravel During this time, we
were forced to mine in an area when; the overburden ratio was quite high, resulting in increased production costs
in the fourth quarter. This, coupled with • much lower average value per carat obtained hi this area, caused ihe
losses of the fourth quarter. During the first quarter of 2001, the crushers were fully operational,, thereby allowing
us to process the gravel expedsttously and work in ireas with a lower overburden ratio. The result was an
operating profit for the first two months of 2001. . .

During the quarter ended S«ptonbor 30, 2008 the Company's consulting geologists completed the ground
magnetic survey of the two geomagnetic anomalies on the Caer*rnning property. The survey indicates rwo large
geomagnetic anomalies, both which warrant drilling, and are otpected to be completed in 200 U

Gmsdrlf
Development and triaJ m ID ing activities continued at the Grasdrif Deposit during the year ended
December 31 2000. The fbflcNring chart details the acplaratiob and trial mining taffannaiioa far both the upper and
lower terraces for the three years ended December 31, 2000, 1999 and 1998:

10

003942
1 f\A
. . ^

:Q00 1999 [998

Number-of tons treated 287,000 I.1 7,000 63,000

Number of carats yielded 611 255 54
Estimated 5 Value al recovery* -5577,000 5272,000 524,000
Estimated 5 Value per Carat at recovery* .-" -. 5944 I I ,0(56 5438
Trial Mining Costa Sl.J 09,520 ' S741,032 $632,824
* May not reflect actual sales value due to changing inventory leveli.

Monrrose
During 2000 we applied for a permit to conduct a 5,000 tonne bulk sample widi the purpose of
deterraming the actual grade of lhc. deposit snd the value per carat of the diamonds. This information b required
to complete a feasibility study on the production potential of the Montrose Pipe. The authorities ipproved the
Environmental Management Program Report (EMPR) for the buile simple during the first quarter of 2001. The
prospecting rights as Well as the option to acquire uhyn-operty were extended to October 2001 to allow for (he
completion of the bulk sample.

Financial Results

2000 1999 1998

Diamond Sales £2,564,600 S714,679 536,990
Operating Loss 52,589.137 12,704,959 52^32^552
Net Low 52,536,303 52,192,731 53,595,167
Loss per Share 5.05 50.05 50.15

General aed administrative expeases •, !.

Management is continuing its efforts to streamline overhead costs and genera] and administrative
expenses. General and adminktrative expensa (br-the year ended December 31, 2000 and 1999 were S1,604,592
and 51,680,005, respectively.

Cnrreaey ConsiderstfcHi
Our mining properties, mining properties under development, and mining equipment are all situated in
the Republic af South Africa, where die currency is-the Rand. Under current accounting pronotmcemcots, (he
Company is required to translate die period end assets and liabilities of its South African subsidiary at the current
exchange rate, while maintaining, equity accounts nt the exchange rate in place at die time of the origins)
transaction. The resulting changes in the balance sheet accounts due to exchange r&lc fluctuation muit be
accumulated and accounted for in the equity section as foreign currency translation reserve. The translation of wr
property mi equipment to reflect die Rand/USS exchange rate of $7364 and WJZ485 at December 31,2000 and
1999, respectively, caused moat of the fbrrign currency trsruEsiioo adjustment of S L.090,625 for 2000 and
S350.803 for 1999. This resulted in accumulated foreign currency translation sdjustmentt-of 52,276,409 and
S!,185,754 « December 31, 2000 ind [999 respeectively.

First Quarter 2001

On January 13,2001 Mr. Pieter van Wyk resigned as Director of Exploration and Minnsg and Dn-ector of
the Company and Director ofGlobei Dismood-SA. Mr. Albert de VTUIers, who had been appointed Chief
Operating Officer of South African operations, assumed responsibility for all day-to-day management activities of
the Company in South Africa.

During the first quarter of 2001 management reviewed operations in depth and a program of cost cutting
and a focus on production was implemented. Operations at Caerwinning returned to an operational profit and the
II

003943
ins
 ^y

•S
recovery of a number of large high quality gemstone diamonds at Grasrfrif placed both (he operations at Grzsdrif
and the entire operations of the Company on a profitable basis. These results support our belief that, given the
nature of alluvial deposits, operations on a large scale could be conducted- profitably.

Liquidity and Capital Resources

The Company has financed its activities to dale through revenue derived from diamond sales, the sale of
its equity securities as wdl as shart-icrm loan facilities.

We believe that we require additional working capital of approximately 5500,000 to satisfy our working
capital requirements'forthe next 12 months. Should any of thefollowingevents occur, additional working capital
might be needed during the next 12 months. The events are:

a) that the Cssrwinning Deposit has negative cash-flow from operations;

b) the trial mining at fee Grasdrif property returns nr«n operating loss or negative cash Bow.

Our belief concerning our working capital requirements ana based on certain asuuniptkjns
concerning; among other thinga, the estimated grade of processed ore. average price per carat, vends of
mining operations, Rand-1/.S. dollar exchange rate, and cost of production, If any of these assumptions
prove Incorrect, ths Company may require further additional capital. Any such additional financing
may recruire an additional pledga or mortgage of the Company's properties and/or any production
therefrom. There is, of comae, no assurance that satisfactory financing could be obtained. In addition to
financing individixtd and available projects, (he Company may also borrow funds from tkne to time for
working capital and other general corporate purposes.

AJ staled in the Auditors1 Report to the accompanying financial statements, thefinancialstatements have
been prepared assuming; the Company will continue as a going cutimu. As discussed in Note 2 to the financial
statements, the Company baa suffered recurring losses from operations that raise substantial doubt about its ability
to continue as a going ccticcrtn Management's plans in regards to these matters are also described in Note 2. The
financial statements do not include any adjustments tfi'at might result from the outcome of this uncertainty.

' Forwnrd-LooklBg Statements

This report contains various forward-looting statements that arc bssed on our belief as well as
assumptions made by and information currently available co us. When used in this report, the words 'believe',
'expect*, 'anticipate*, 'estimate*, and similar'expressions are intended to Identify forward-looking-statements.
Such statements are subject to certain risfci, uncertainties ind assumptions, including, without Jinntaticn, that we
only recently commenced mining operations ai the Cacrwinning Property, have not engaged in commercial raining
) operations a£ the Grasdrif Property, mining risks in general, political risks associated with our operations La the
Republic of South Africa, generaJ economic conditions, currencyfluctuations,and estimates of costs of production.
Should one or mere of these risks or uncertainties materialize, or should underlying assumptions prow incorrect,
BcfuaJ results may vary malcrialiy Iran those anticipated, estimated or projected. We caution potential investors
not to place unduo reliance on sny suchforward-Jookfng:statements, all of which speak onry as of the date made.

12

003944
 " -s
s
Item 7. Financial Statements ' "

INDEX TO FINANCIAL STATEMENTS

Independent Audttora* Report

14
Consolidated Balance Sheet at December 31. 2000
15
CtjasoFidated Statements of Operations for the years
ended December 31, 2000 and 1999 A
tt>
Consolidated Statements of Stockholders' Equity
for the years ended December 31,2000 and 1999
17
Consolidated Statements of Cash Flows for the years ended
December 31, 2000 and
1999 18
Notes to Consotidated Financial
Statements '. 19

* )

.-• I

003945 *'
 R E P O R T OFINDEP£NDEWT';CERTtFlED PUBLIC ACCOUNTANTS

The Board of Directors and Shareholders

Global Diamond Resources, Inc.

We have audited ihe accompanying consolidated balance sheet of Global .Diamond Resources, Inc. and subsidiaries
(the "Company") as of December 31, 2000, and the related consolidated statements of operations, stockholders'
equity and cash Sows for each of the two yean in the period ending December 31, 2000. These consolidated
financial statements are the responsibility of the Company's management. Our responsibility is to express an
opinion on these consolidated financial statements based on our audits.

We conducted our audits in accordance with generally accepted auditing standards. Those standards require that
we plan sad p a f m m the audit to obtain rcasonablff^ssunmce about whether the financial statements are free of
material misststement. An audit includes, on a test basis, examination of evidence supporting the amounts and
disclosures in the financial sfaXsncnts. An audit also includes assessing the accounting principles used and
significant estimates made by management, es well as evaluating the overall consoJidaled financmi statement
presentation. We believe that our audits provide a reasonable basis for our opinion.

i )
In our opinion, the consolidated Gnancinl statements referred to above present feirly, in ail material respects, the
financial position of Global Diamond Resources, Inc. and subsidiaries i s of December 31, 2000, and the results of
their operations and their cash flows for each of the tvwo years in the period ending December 31, 2000, in
conformity with generally accepted accounting principles.
The accompanying consolidated financial statement) have been prepared assuming that the Company will continue '
as it going concern. As discussed BT Note 1 to the etaisolidated financial staierrienls, the Company has suffered
recurring losses from operations and it requires additional capital to fund its operations. These conditions raise?
substantial doubt about its ability to continue as a going"concern. Management's plans regarding these matters arc
also described in Note 2. The consolidated financial statements do not include any adjustments that might results
from the outcome of this uncertainty.

Ill CACCIAMATTA ACCOUNTANCY CORPORATION

Irvine, California
March 29,2001
)

« ) ' ' -J 4
108
003946
 GLOBAL DIAMOND RESOURCES, INC. AP(D SUBSrDURIES
Consolidated Balance Shctt

Assets December 31, 2000

Current assets:
Cash and cash equivalents 3S7J8I
Due from related party 2,400
Inventory 92,450
Prepaid expenses 1.510

Total current assets 483,541

Deferred foreign tax asset 1,402,598

• Mining properties and equipment 4,309,605

6,195,744

Liabilities and Stockholder*' Equity

•.U Current liabilities: '. .
Accounts payable 784,03 I
Accrued liabilities:
Accrued interest 225,000
Accrued salaries and related taxes 178431
Accrued professional fees 83,441
Other 134.662
Total accrued liabilities 621,634

Note payable to director 183,765

Total current liabilities U89.O0

Long-term debt \^ 3.DOQ,000

Total liafcnlrtica > ' 4^89.430

Commttmeata and contingencies "

Stockholders" equity:
Prefiarred stock, 50.001 per valne, 10,000,000 shares authorized,
DO shares issusd and outstanding
Common Stock, $0.0005 par value, 100,000,000 shares authorized,
53,171,678 shares issued End outstanding. 26^86
Additional paid-in capital 15,051,321
Unsmortized stock a.vfsrd (33,192)
Accumulated deficit (11,161,992)
Accumulated ortier cotnprehensrya income:
Foreign currency translation adjustment (2,276,409)

Total stockholders' equity },60SJU

6,195,744

Sec accompanying notes to consolidated financial statements.

15

003947
 -r

GLOBAL DIAMOND RESOURCES, INC AND SUBSIDIARIES

Consolidated Statements of Operation*

Year Ended Dreember 31,

zoo® 1999
Diamond Sales s 1,969,847 5 +48,651
Operating expenses:
Production (2^41,133) (936,341)
•»•

Development and exploration • - (1,109420) (741,032)

Less diamonds recovered 594,753 266.028
Kef development and exploration (514,767) (475,004)
Royalty (98,492). (62,060)
Selling, genera) and administrative (1,604,592) (1,631,078)
Total operating expenses (4,558,984) (3J54 t 683)
Operating loss (2489, J37) (2,706,032)
Other income (cxpensa):
Loss en Hale of fixed assets (213,766)
Interest in come • •' 4,530 $4,842
Interest expense, net (485,7 Iff) (452,176)
Interest expense, net (48I,J8<J) (367,334)
Loss before net tax benefit - *" (3,284,089) (3.073J66)
Deferred foreign tax benefit '* 747,786 880.635
/Net loss (2^36303) (2,192,731)
Other comprehensive toss -
Foreign currency translaiion adjustment (1,090,625) (3JO.SO3)
Comprehensive loss s (3,626.928^ S ' (2443,534)

Basic aed diluted leas per share s (.05) S (.OS)

Base and diluted weighted average shares outstanding 48,064438 S 45,600,678
s

Sec accompanying notes to cnnsolidaied financial statements.

16

003948
no
 7
*" ' * '•T'

GLOBAL DIAMOND RESOURCES, INC AND SUBSIDIARIES \

\
Consolidated Statements of Stockholders" Equity V
For the years ended December 31,2000 and 1999

< Foreign
Additional Paid- • Currency UoBraartlzed
Common Stock Accumuiaied Trsasisttoa Stock Total Stockiiolders'
Shores Amount \a Capital Dafldt Adjnatmact Award Eqully

Balance ti December 3 [, 1998 45,600,678 S 22,800 S 13,457,899 S (6,432.958) S (834,981) S -S 6,212,760 •

Foreign currency translation J

ftdjuiUnent _ _ _ (350,803) (350,803)

•Net loss • ' " —

_ \V p; 192,731) ' _ (2.192,731)

Balance *t December 31, 1999 . 45.6OO.67B 22,800 13,457,899 (8,625,689) (1.185,784) 3,669,226

Issuance of shtacx for cash <S,586,CK)0 3,293 1,363,356 1.366,645

Issuance of thorn for services 485,000 243 131,945 132,188

Slock award 500,000 250 38,800 (39,050)

Amortization of itock awsrd - - 5.8J8 . 5,858

Valuo of options luuod for

services 59,321 59,321

Foreign ourrency trentUtion

ndjiurtinent ~ — (1,090,625) (1,090,625)

Net lots — '(2.536,303) (2,536.303)

i
Balance »t December 3 I, 2000 53,171.678 $ 26,586 S IS,Q5U21 S (11,161,992)5 (2,276,409) S (33,192) S 1,606,314

Sec accompmying notes to consolidated financial statements

003949
 GLOBAL DIAMOND RESOURCES, INC AND SUBSIDIARIES
Consolidated Statements of Cash Flows •
Year End December 31,
2000 1999
Cashflowsfromoperating Bctfvities:
Net loss (2,536,303) 5 (2,192,731
Adjustments to reconcile net loss to net
cash used in operatingjictivitles:
Depreciation and amortization 490,037 44-2,46;
Net loss cm sale affixed assets 213.766
Shares issued for services 132,188
Value of options issued for services 59,321
Amortized stock award 5,858
Increase in deferred foreign tax asset (747,786) (866,455!
Decrease in prepaid expenses CUtO) -
Decrease in accountsreceivable-
Trade 6,734 15,855
Officer — 25,000
Decrease (increase) in inventory (58,700) 10,366
U Increase (decrease) in accounts payable
Increase (decrease) in accrued liabilities^
591,441
500,597
(352,520)
(205,972)
Net cash used in operating; activities U44.357 (3,124,015)

Cashflowsprovided byfinancingactivities:
Net proceeds from issuance of common shares 1J66M9
Proceeds from note payable to Director 222,453

Nd cash providedfayfinancingactivities 1,366,649 222.45J

Cash flows used in investing activities:

Proceeds from saJe of assets 244377
Additions to raining properties and equipment • (37,31*)-

Net casfi used in investing activities 209,061 (2,359,264)

Effects of exchange rates can cash (26,272) (13,309)

Net increase (decrease) in czsh awj

205,081 (5,279,135)
:• r cash equivalents
Cash and .cash equivalents, beginning of year 182,100 5,461^35

Cosh and cash equivalents, cod of year 3S7.I8I S 182,100

Other HipplesTjentaJ disdcBinras:

Interest paid $ 260,7)6 I 452,176

Income taxes paid S 300 S 800

Sec accompanying noos to consolidated finnucitl statements.

18

003950 1U
 GLOBAL DIAMOND RESOURCES, INC AND SUBSIDIARIES
Notes to Consolidated Financial Statements

""• ' • December 3 ["^2000

(I) Sommsry of Significant Acconntf ng Policies; and Practices

Description of Basis ess

Global Diamond Resources, Inc. (the "Company") was incorporated in the stale of Nevada m January 7,
1987 and commenced significant mining operations in South Africa during 1994'.

' Principles of ConsollcUilon

The consolidated financial statements include the financial statements of the Company and its wholly-
owned subsidiaries, GiobaJ Diamond Resources Inc., a Canadian corporation ("Global BC), Global Diamond
Resources International Limited, a British Virgin Islands corporation ("Oiobai BV1"), Global BVI's vmolly-
owned subsidiary. Global Diamond Resources (SA) £Pty) Limited ("Globs! 5A"), a South African corporation
and Global SA's wholly owned subsidiaries, Nates Diamonds (Pty) Limited ("Nates"), a South African
j\ corporation and GDR Drilling CPty). a South Africap corporation. A I! amounts are in U.S. dollars unless
.'.- - otherwise indicated AJI significant in terrain pirry. -balances and transactioni have been eliminated in
consolidation.

Casfa Equivalents

Cash equivalents include all highly liquid investments'with an original maturity of three months or Jess.

Foreign Exchange Translation

Tbe Ruanda! position and results of operations of the Company's foreign subsidiaries are measured using
focaj currency as the functional currency. Assets and liabilities of the subsidiaries ire translated at the exchange
rale in effect it each year-end. Statement of Operations are translated at the average rate of exchange prevailing
during the year. Translation ndjusfenentt arising frocn differences in exchange rates from period to period arc
. • included in the foreign currency translation adjustmenNiccaunt in stockholders' equity.- '

Inventory

Inventory consists of diamonds ready for sale valued at the lower of cost or estimated net realizable vsJue.
Diamonds ana ready fbr sale when they have been separated from the alluviab or broken ore, have been
processed and arc in a deliverable form, rjo value is ascribed to diamonds m the alluviak or in the broken ore.
_ Also included En inventory is fuel, spare parts and rations of 539,500.

Mining Properties and Eqalpenoat

Mining properties and equipment consisting of mineral rights, mining properties under dcvtJopraent,
mining equipment and ofSce equipment (primarily computers) ans recorded at cost Depredation b provided
fbr mineral rights, mining equipment and office equipment using the straight-line method over the estimated
useful lives of 10 years, 3-10 years and 3 years,, respectively, of such assets. Mining properties under
development are depreciated over Jfvo life of tfte -mine using the straight-line method once commerriaJ
production a reached. Value of diamonds recovered from bulk sampling and drilling activities WTJ offset
against mine development costs.

Minted Operatioaa

Initial exploration and evaluation costs are expensed ss-maarred. The decision to develop or mine a
property is based on an assessment of the viability of the property and the availability of financing.

The Company's method of accounting for exploration and related costs on unproven reserves is to expense
all costs, other than acquisition costs, prior to the completion of * definitive feasibility study which establishes
proven and probable reserves.-
, . . . 19

113
003951
 RxkabflltHfJon Casts

. Estimated site restoration .and post closure rehabilitation cosu are- charged against earnings over ihe
expected economic useful life of each mine. Accrued rehabilitation costs arc subject to review by management
on a regular basis and are revised when appropriate for changes in future estimated costs and/or regulatory
requirements. At December 31, 2000, 559,492 of rchabilftalion reserve is included in accrued liabilities.

Stock Options s a d Warrants

The Company has elected to adopt the disclosure provisions only of SEAS 123 and continues to measure
compensation cost related lo stock and stock options issued lo employees using the intrinsic method of
accounting prescribed by Accounting Princtplcs Board Opinion No. 25 ("APB25"), "Accounting for Stock lamed
lo Employees.** and related, interpretations. - .

Income Taaes • •

Income taxes are accounted for under the asset and liability method. Deferred tax assets and liabilities are
recognized for the future tsx consequence attributable to differences between the financial statement carrying
amounts of existing assets and liabilities and their respective tax bases and operating losses. Deferred tsx assets
and 1 labilities are measured using enacted tax rates expected to apply to taxable income in the yean in which
\j those temporary differences are expected to be recovered or settled. The effect on deferred tax assets and
' —' liabilities ofa change in tax rates b recognized in income in the period that includes the enactment date.

Fair,Via las of Financial Inrtrssments sad Coacentrotioa of Credit Rink

The carrying amounts of cash and cash equivalents, inventory, accounts payable and accrued liabilities
approximate &ir value* due to the short-term nature of these instruments. The carrying amount of the long term
debt approximates fair value because the terms are comparable to the current markei.

Financial instruments thai potentially subjecfrtHc Company to concentrations of credit risk, consist of cash.
The Company's policy is to maintain cash at high credit quality financial institutions to minimize risk, but from
lime to time account balances may exceed FederalIy"insured limits.

Loss P e r Common Share

Basic EPS ij calculated using income availaWe to common stockholders divided by the weighted avenge
of common shares outstanding during the year. Diluted EPS is similar to Baste EPS eaccpt that the weighted
average of common shares outstanding is increased to include the number of additional common shares (hat
WTjuld. havo been outstanding if the dilutivc potential common shares, such as options, had been kmed. The
treasury stock mcjfaod is used to calculate dilutivc shares which reduces the gross number of dilutiws shares by
the number of shares purchasable from the proceeds of tile options assumed to be exercised. Diluted earnings
pa- sharu is the same as basic earnings par share in both 2000 and 1999 duo lo net losses in both yean.
i

Net loss per share &r 2000 and 1999 is computed based on the weighted-average number of common
shares outstanding of 48,064,532 and 45,600,678, respectivdy. Common equivalent shares from stock options
and warrants exduded from the computation because their effect is anti-difutivc for 2000 and 1999 were
12,£22,374 and 10,866,980, respectively.

Uec of Estimates

Management has mndo a number of estimates and assumptions relating to tbo reporting of assets snd
Ifnbifitics and disclosure of contingent assets and liabilities at Ihe date of (be consolidated Qnsncifll stotcmeab
and the reported amounts of revenue and expenses.to prepsro thesis consolidaled financial statements in
conformity with generally accepted Bccounting prfria'plo. Ac"'*' "—•'* Fnstn those eatnnaiei.

Impairment of Long- T

Long-lived asaets and nnent whenever events or

changes in circumstances ind; rYcrablc. Recoverability of
assets to be held and used h n assot to future net cash
flows expected to be generaiis red, the impairment to be

003952 114
 recognized is measured by the amount by'tiKich the carrying amount of the assets exceed the fair value of the
assets. Assets Co be disposed of are reported at the lower of the carrying amount or fair value less costs to sell.
Long lived assets are reviewed aimuaJly fix impairment whenever events or changes in circumstances indicate
that the carrying amount of the asset may not be recoverable.

Comprehensive Income

The Company has adopted SFAS No. 130, "Reporting Comprehensive Income." This statement requires
that certain items of comprehensive income other than net earnings or loss be reported in the financial
statements. For the two years in the period ended December 31. 2000 and 1999. the Company's comprehensive
income (loss) relates to foreign currency Cnnslatioaadjustmenti.

Segment Reporting

The Company has adopted SFAS N a 131, "Disclosures about Segments of an Enterprise and Related
InfonnEtion," which establishes annual and interim reporting standards far sn enterprise's operating segments
and related disclosures sboui Hs products, service!, geographic areas and major customers. An operating
0 segment is defined as a component of an enterprise that engages m business activities tram which it may earn
revenues and incur expenses, and about which separate financial information is regularly evaluated by the chief
operating decision maker in deciding how to allocate resources. AJI of (he Company's operations are aggregated
into one reportable segment given the similarities of economic cfaarecteristics between the operations represented
by the various m ines. The Company's administrative headquarters- is located in Southern California.
)
(2) Going Concern

The*Company believes that ft requires additional working capital of approximately 5500,000 (o satisfy rb
working capital requirementjf for the next 12 montftS. Shoufd either of the following events occur, additional
working capital may be needed during the next 12 months. The cvcnb ore:
1. the Cacrwinning Deposit has negative caih flow front operations;
2. the trial mining on the Upper Terrace at the Grssdrif property results in an operating loss or negative auh
flow. ":

The Company intends to raise additional working capital through diamond safes and private placement of
- common stock as well as using available lines of credit

The Company's belief concerning its working capital requirements are based on certain assumptions
concerning, among other things, the estimated grade of its processed ore, average price per carat, commencement
and scale of mining operations, Rsnd-U.S. dollar exchange rate, and cart of production. If wy of these
assumptions prove incorrect, the Company may require further additional capital Any such additional financing
may require an additional pledge or mortgage of-the Company*! properties and/of any production therefrom.
There is, of course, no assurance thai satisfactory financing, if necessary, could be obtained. In addition to
) financing individual and available projects, the Company may also borrow funds from time to time for wotting
capital and other general corporate purposes.

There a no assurance that the Company will be-able to raise the additional capita] it requires through the
equipment refinancing or otherwise ID the event that'the Company is unable to raise the working capital it needs,
it will focua its efforts aa the profitable activities that Its resources can support at that time:

The financial statements have been prepared assuming tfae Company will continue as a going concern.
The Company has suflerod recurring leases from operations that rab«'substantial doubt about fts ability ta continue
as a going concern. The financwf statements do not include any adjustments that might result fora the outcome aC
ih'a uncertainty.

•21

115
003953
 (3) Mining Propertfes sad Equipment

December 31,
2WMJ

Mining property.
Caerwinning deposit, at cost 436,022
Less accumulated amortization (85J68)

350,654

Mining properties nncfcr development:

Grasdrif deposit 972, !00

Mining equipment, at cost 3.853,110

Less accumulated depreciation U (873,437)
: ;
" ' 2,979.673
•-<D
Office equipment, at cost 51,862
Less accumulated depreciation (44,684)

7.178

S 4,309,605

Depredation expense For 2000 and 1999, respectively, amounted to $490,037 and £442,468. During
2000, the Company sold assets with "a book value oFW(SO,]43 for 5246,377, resulting in a loess on sale of
I Rxcd assets arS2J3,76<S.

(«) Long^tenri Debt

The 53,000,000 secured note payable has a prepayment requirement that ir on December 31, 2000 or
2001, the Company has in excess of £2,000,000 in cash and cash equivalents on hand, that excess must be paid
on the Dote. The note does not contain any penalties far prepayment. The note is doc on December 5, 2002 tad
carries interest at 15%, payable every six months in. arrears. The note a secured by the pledge of!0O% of the
stock of Global SA, which holds all of tiic Ccsnpanj^S. mining properties, plant and equipment. The agreement
rriaied to the note restricts the payment of dividends by the Company. During 2000, the option to convert
/\ principal imd interest into a masfrnuni of !,807,81fi common share* expired. As of December 3 J, 2000, the
Company was in arrears oq its semi-annual intertsr payment of 5223,000. The Company has obtained a waiver
and an extension to June30,2001,

(5) Antiorized S&are Capital

On June 16, J 999 the Company mcrcssed its authorized common suxk from 50,000,000 shares of S.0005
par value common stock to 100,000,000 shares of $0.0005 par value common stock.

{«) Income Taxes

The Company has no significant taxable temporary differences wftich would require recognition of
deferred tax liabilities. Utilization of the deferred^foreign tax xutt of SI,402,591 from nei operating loss
carryforwards in SouUi Africa is dependent oo fitfiire'taxaWc profits in excess of profits arising from editing
taxable Uraporary diffirencea. Although there was a reported less 6 r the year aided December 31, 2000 said
1999, the asset has been recognfeed became forecasts Sot (he rninfug operation indicated the carryforwards will
be rrafewl Additionally,, federaf deferred tax assets of spproxlinstdy $2T£22,G0d end stale deferred tax assets of
approximately 5384,000 were not recognized dus lo the uncertainty of firture realFrsbilify snd B 100% valuation
aUovnincB was wJ up to reduce the asset to zrro.

' 22

003954
116
 A£ December 3 ! , 20OO. the Company had available net operating loss carryforwards of approximately
SS.300,000 for federal income tax reporting purposes which begin to expire in 201Q. The net operating toss
carryforwards for state purposes arc approximately 54,000,000 and begin to expire in 2000. The net operating
loss nrrryforwards.arc subject to certain limitations under Section 382 of the Internal Revenue Code

(7) Foreign Operation*

The Company"» wholly-owned subsidiary, Global SA, operates m the Republic of South Africa. During
2000 and 1999, Global SA's sales represented 100% or consolidated sales, while Global SA's expenses
represented 39% and 36%, respectively, of consolidated non-production expenses. All production occurs En the
Republic of South Africa and thus Global SA represents 100% of the production, development and exploration
expenses fear 2000 nnd 1999. At DecembcrJl, 2000 and 1999, Global SA'i lota] assets (primarily ash, mming
properties and equipment) represented 9TA snd.96"ft, respectively, of consolidated total isicts. !n the past, tho
Republic of Sooth Africa, experienced polhical'^nd economic fnsiflblliry. While current indications are that it
appears to be becoming mere stable, there can- be no assurance that the Company's business or interests in
mining properties and relmed options will not be materially adversely aSTccted by local political or economic
developments.

(S) Related Party Traasacdoas

At December 31, 1999, the Company granted 2,000,000 common stock warrants to Weir Intemationai
$'J'Jo Limited ("Weir") in consideration for the tenmination of a marketing agreement whereby Weir would be paid 5%
' "-^f of all diamonds sold. The warrants are- exercisable at $.40 and -will only vest once the Company's publicly traded
stock reaches a minimum fries of SL00 and tho Company has earnings of $.05 per share. The warrants will
expire threa years after vesting. Weir is • stockholder of the Company and ihc Company's Chairman and Chief
Executive'oeicer has a beneficial interest in Weir. Total commissions paid during 1999 were S25.000 and arc
included in Royalty expense for the year ended Deccmber3I, 1999.

As of December 31, 1999,. tho Company-entered into an agreement with Elite Diamond Cutters ("Elite")
to market and sell its diamonds. A director of the Company is a partial owner of Elite. The Company believes thut
the terms of its trxnssctiona with Elite are no lessfavoTobhs than could be obtained from on unaffiitatcd party.
Aa of December 31,2000, the Company owed RJ,390,000 (SI 83,765 it December 31, 2000) to a director
of the company. The note bears interest at I7%upcr annum, payable monthly, and is due on demand. Interest
expense on this note was S31,900 and59IS for 2000 and 1999, respectively.

* ' * •

(9) Stock Optiocs aad Warrants

All issuances of options tnd warrants were it prices at or above marled nt the time, of issuance.

In August 1999, the Company granted 100,000 common stock optfcms to an employee ofithe Company.
The options BTB exercisable at S.25 per share wilh 25,000 exerdsable at any time, 25,000 after February l, 20OO,
• 25,000 after Augusi I, 2000 md 23,000 after August 1,2001. The options expire Augusi 1,2009 or 60 days after
• J termination of service, whichever occurs first.

In December 1999, the Company granted 167,000 common stock warrants to a consultant, immediately
exaxasablc at $0.0781 per share and expiring on December 31, 2004.

In December 1999. tbe Company granteclJWcir International Limited ("Weir") 2,000,000 common itock
warrants. The warrants are exerrisabfc it S,40-and vrill'onry vest once die Company's publicly traded stock
reaches * minimum price of Sl.00 per share and'the Company has earnings of $.05 per share. The warrants will
expire threa years after vesting.

In January 2000, the Company issued 50,000 common stock warrants to each of nine non-executive
directors immediately exercisa ble st $21 per share and expire bi January 2003.

In March 2000, the Company issued 1,711,000 common stock warrants at SJ20 per share and exercisabie
at wy time until they expire in March 2003.

In April 2000, the Company issued 335,000 common stock warrants at SJ20 per share and exercisaHe at
any timn until they expire in April 2003.

23

117
003955 ' ' '
 !n June 2000, the Company issued l.WQ.OtKTaxnmon stock: WHrrants fit $.50 per share and cxcrcisable at any time
until they expire in June 2OQ3.

In July 2000, the Company issued lOO.OOOtiomraon stock warrants to a consultant for services at S J O pcr
share. "25,000 of these warrants are immediately cxercisable, 25,000 will vest w h a the average seven day dosing
value of the stock reaches Sf.Ofl per share and 50)000 will vest when the average seven day dosing value of the
. stock reaches SI.50 per shore. These warrants expire.on July I, 2005.

In November 2000, the Company issued 100,000 common stock options to an employee of the Company,
exerrisable at S.25 per share with 75,000 immediately exercisable and 25,000 excrdsable at the end of 2001.
These options expire on November 14, 2005 or the date Determination, whichever occurs first

la November 2000, the Company issued 100,000 common stock, options to an employee of the Company,
excrcisabie at $35 par share with 25,000 imniediaiely cxercisable and the remaining 75,000 exercisabie at 25,000
per year. These optiona expire en November 14, 2005 or the date of termination, whichever occurs first.

In December 2000, the Company issued 174,374 common stock warrants to a consultant, immediately
exercisshle at S.O I per share and expiring on December 31,2005.

In July 2000, the Company extended the expiration date of 2,000,000 options held by an officer of the
Company to July 25,200 j . •,- .

The per share weighted-average fctr value of stock options and warrants granted lo directors, officers and
employees during 2000 and 1999 was $0.06 and S0.I6, respectively, on the dale of grunt using the Black Scholea
option-pricing model with the following weighted-average aasurnptkms; 2000 - expected dividend yield 0%, risk-
free interest rate of 5.97%, expected Ufa of 5 years and an expected volatility of the stock ovtr the expected life of
the options and warrants of 75%; 1999 - expected dividend yield 0%, risk-frec interest rate of 5.97%, expected life
of 2.5 years, and an expected volatility of the- stock over the expected life of the options and warrants of 68%.

The Company applies APB Opinion No. 25 in accounting for its stock optiona and'/vrarrantj granted to
directors, officers and employees. No compensation cost baa been recognized for its stock optiona and warrants
issued to employees or directors of the Company in the consolidated financial statements as they were issued at or
above market Had the Company determined compensation cost based on the feir value at the grant date for its
stock options and warrants under SFAS No. 123, the Company's net loss and net loss per share would have been
increased la the pro forma amounts indicated below*^

•- - '" ' 2000 1999

Net loss, as reported 5(2^36,303) 5(2,192,731)

Net lost, pro forma (2,675,475) 5 (234,644)

Basic and diluted net loss per

share, aa reported • (S.05) (S.05)
Basic and diluted loss per
share, pro forma (S.06) (S.05)

24

11Q
003956 ' ' °
 Stock option and warrant activity during the periods indicated is u follows: .

Weigh twi-
Number of Average
Shares Eierdse Price

BalHnceat December 31, 1998 9,863,552 S 0.57

• Granted 2,717,000 0.33

Canceled (1.713.572) 0.47

Balancn at December 31. 1999 10,866,980 0.54 .

Granted 4.010374 0-28
C2,054,980) 0J0
Canceled

Balance at December 31, 2000

I2.SZU74 S <M7
J At December 31, 2000. the range of exercise prices ind the weighted-average remaining contractual life
v J oi outstanding opboas and warrants were S0.01 to S J 5 snd 221 years, respectively.

At December 31, 2000 and 1999, the number of opticos and warrants exerciszble wm 10,622,374 and
8,791,980, respectively.

(10) Commitment* and Contingencies

Lease Agrcemeat
. As of December 31, 2000, the Company had a non-cancelsble operating lease commitment for the
Company's corporate office expiring in March 2002.. The monthly rait payment OT this operating, lease is
51.462. The Company also leases office space from sitiircctor ofthe Company Tor R1S0D (S226 at March 22.
2001) per month, which is cancclable on demand, ^"addition,'Global SA had a non-cancclabie operating (case
commitment for the South African corporate office expiring in March 2003. The monthly rent psyrnent on Urn
operations leas* is RI,660 (S20S-at March 22, 2001): Rmt expense fa- 2000 uid 1999 was $23,148 and
120,356, respectively.

Minimum lease obligations Jbr non-cancclablB leases for each of the next five years are."

2001 520,178
2002 17.020
2D03 S 658
20O4 5 -0-
2005 S -0-

Benefit Plan

The Company sponsors a defined contribution pension plan in both the United States ond South Africa.
Contnbuiiottj to the plans Jbr 2000 and 2999,rcspectivejy,Were S77.873 and S .

Legal Ma tiers

In July 1999, the Company and its Chairman, Johwin de Villien, were named aa deftndanU in an action
Mr. Abu Ekkr Bin Ali A!-Akhdar Mood broi^ht hi lhe United-State Dtsirfcl Court Car the Southern District of
California. Mr. Abu Bair is * former director ofthe Company. In that action. Mr. Abu Bakr alleges that he acted
u a 5nder in connection vnfh the safe of a total of 56,000,000 ofthe Company's common Hock to two private
investors sad that in connection vritk that oSbring. he was entitled to a finders' ft* equal to spproxnnatefy 28% of
the gross proceeds. Nfr. Abu Bakr aileges that lhe Company and Mr. dc VUIim fraudulcnOy forced Mr. Aba Bakr
to partictpate fn a binding arbitration regarding bis finders1 fees and that u a result of this arbitration, he was
forced to return the finders' fee and resign fata bis position with his then current employer. Mr. Abu Bakr has

25 -.'

119
003957
 alleged causes of action for breach of contract, unjust enrichment, fraud, misrepresentation and duress. Mr. Abu
Ba&r also alleges interference witb and breach ofhia employment contract with his then current employer. Mr.
Abu Bakr seeks compensatory and punitive damages in MI unspecified anaonnt.--

In August 1999, (he Company and Mr. de VTUiers filed an answer ta Mr. Abu Bskr's complaint in vrhich
they denied ill of the allegations contained therein. The Compwiy believes thai the allegations of Mr. Abu Bafcr
are frivolous and, accordingly, the Company intends to vigorously defend this case.

-'.^

26

121
003958
 - Part IE - " ' "
Item 9- Directors, Executive Officers, Promoters and Contrw? Persons; Compliance witk Section lfi(a) of the
Eochaage A c t

Directors and Executive Officers

Set forth bekw, effective as of July 1, 1999, are the directors «nd officer* of the Company «nd its South
African subsidiary, Global Diamond Resources (SAVPty) Limited ("Global Dimnond-SA"). Each person holds the
stated positions with the indicated companies. -•• ,
Name Age ". '• Position

Johann de VilHers 48 Chairman of the Board, Director of the Company,

Chief Executive Officer and Chief Financial Officer
Director of Global Diamond-SA

Picter van Wyk 50 Director of Exploration w d Mining and Director of

the Company and Director of Global Diaracnd-SA
•V-)
John Tyson 53 Director of the Company

Charles MacDonnW 47 Director of the Company and Director of Global

Diamond-SA

Said K Ghachem 59 Director of the Company

Ahmed M. Basodan 39 Director of the Company

' Yassiu Abduaalh Kadi 46 Director of the Company

Mattar AbduIIa Al Muhairy 57 Director of the Company

Am in Koudsi '57 Director of the Company

Andries.Janzen 57 Director of the Company and

Managing Director of Global Diamond-SA

Oason S. Al-Shaflch 47
Director of the Company
Paulua Vries 49
Director of Global Diainond-SA
Eugtsje Brill 36
Secretary of the Company
Albert W. de VTJHera 44 Chief Operating Officer of Global Dtamond-SA
(eflectrve October 2000)
Mr. dc ViJlicrs founded the business of thoConpaay in 1993 and has served HS Chairman and Chief
Executive Officer since inception. From 1984 to 1990, Mr. de VlUiers served ss Chief Exeaifi>t: Officer of
Kensington Finance Corp*, an options trading firm ind member of the- American Stock Exchange. Frora 1990 to
1994, Mr. de Vllliers acted as investment advisor tothe Monitrend GoW Mirtua] Ftaid. From 1976 to 1984,
Mr. de "Vlllien was the managing director of the Octlm Group, a South Afiica baaed tntemBtfonal diamond
mining, polishing and trading company, ffe was appointed Chief Finsncwl Officer in Jury 1999. Mr. Johann dc
ViUiers is not related to Mr. Albert de VHliers.

Mr. van Wyk haa gerved as Chief Consulting Geologist of Global Damood-SA from Jury 1994 to
February 1993. In February I99§, Mr. van Wyk was appointed to esrws as Director of Exploration tad Mining of
the Company md as member of the Company's Board ofDirectors. Mr. van Wyk holds a M-Sc (Ocology) and has
lectured in Sednuentoiogy st the University of Pretoria and in Economic Geology at the Rand Afiifauma
University. He was the Senior Field[Geologist for Rand Mines before operating his. own diamond mining snd
exploration concern with interests in southern Namibia (alluviais), south, of Kiniberlcy (kiraberlite fesurcs), «nd
v«
• 27 . . .

121
003959
ID "I. n t rSIK ) • it HI Z0Z1Z3182B US TREASURY DEMRTWaT

Second Tranche of Names

1 Al Stnia. Honey Prcis For industry and Commerce

2 Al-Homati Sweeu Baiccnci
J Al-Nur Honey Press Shops (tlta, Al-Nur Honey Center)
-1 Ayadi Chafjq bin Muhammid
.- I3r .Arain Ah'Haq (Dr Arr.in ul-Haq)
6 Hujt Abdul Min*n Agha
7 larn'yiih Ta'Hwun uMsIamn tboL-icty of Iilamir. Cooperation)
i MohAmmad 2,m
'' Nlufti Rashid Ahmad Ladchyanoy
IU Muhammad al-Homari (aki, Mohammad Hamdi Sadtq al-Ahdal)
J1 Omar Mahjnoud l'thman.(aka. Abu Qauida il-Filijlini
I.' Kiad Hijazi fnk&, Ahu-Alunad al-ha>ven, Rushid al-Maghribi, Abu-Ahrnad al-Amriki, and
Ahu-Ahxnad al-ShahidJ
I ' roh.ii Ytilda,nhe\
U Ydsin al-Qadi uka, Shaylch Yussin Abudullah Kadi)
I* . • U . - J A D A W I . Saqar
lt> Al-kadr, Ahmud Sa'id
1/ AI.-SHARJF. Sa'd
18 FJtNMARWAN, Rilal
I1/ DAK.KA7.AM.I, Manioun
'(• Kabila trust
;t im-=n-I-Moh<irnmcd iJIMI

004006
 l-io-iiMii & §fe ) i Allington Towers
HM Treasury V3MM8 19 Allington Street
r*.Tamrjn London SW1E 5EB
Tel: 020 7270 4750
Fai: 020 7270 5430
[email protected]
www.h m-treasury.gov.u k

David Parr 10 October 2001

Bank ofEngland

2*EW US LIST

Please see the attached letter from the US Treasury, notifying us of their intention to
issue at 8.00 Washington time tomorrow (13.00 UK time) a further list of 21
individuals, groups and entities determined by the US to have committed or to pose a
significant risk of committing or providing material support for acts of terrorism.

The Treasury (i.e UK Treasury) requests you, pursuant to UNSCR 1373 and the Order
in Council applying it within the UK adopted yesterday, to issue a Notice/Press
Release requiring banks and financial institutions to freeze any monies held with them
in these names and to report to you on any accounts they have frozen and the amounts
frozen. The Notice should also remind thebanks and financial institutions of their
reporting requirements under the Terrorism Act 2000. In effect, this Notice would be
very similar to the one you are issuing today in respect of the earlier list of 27 people,
except that their funds are frozen under UNSCR 1333. I have spoken with NCIS
who are content for the matter to be handled this way.

This new Notice should not be issued until we have notified you that the US has
actually publicised this list (see the last paragraph of the letter).

Copy to Martin Comley at NCIS and Wasim Mir (FCO).

Joseph HaJHgan
HM Treasury

004007
utvenox & FtorUL
 i-n-io-03 <B ~jU v ^ Ailington Towers
19 Street
*easury v9&ii*R AM^B*0*1
^tHrajRi London SW1E 5EB
Tel: 020 7270 4750
Fax: 0207270 5430
[email protected]
www.hra-treasury.gov.uk

David Parr ' 11 October 2001

Bank of England

ANOTHER US LIST

Further to my letter of yesterday enclosing a US generated list of 21 individuals or

institutions, we have now received a further letter from the US Treasury concerning a
further list of another 22 individuals who are described as "most wanted terrorists".
(Copy attached — Annex A). This letter states that they may be added to the blocking
order to the extent that they are not already covered by existing executive orders
blocking funds.

We have enquired further into this list: 5 out of the 22 are already subject to UN
sanctions under UNSCR 1333 and no further action is necessary in respect of them.
We shall, however, need to add the remaining 17 to the 22 from the earlier list who
are to be subject to freezing orders under UNSCR 1373.

We have also received another letter from the US Treasury (Annex B) giving more
information about the 22 from the earlier list. This may help the banks in identifying
such accounts. You will see from the. covering letter that the US have moved the
release date of this list to 8.00 Washington (13.00 London) on Friday October 12 and
they request that we keep the list confidential until then.

We therefore need a Notice to be issued along the lines I indicated in my letter of

yesterday but covering 38 names (i.e 21 +17) rather than 21 under UNSCR 1373.
This should be released at 13.00 UK'time tomorrow unless you hear to the contrary
from us beforehand. It is possible that the Treasury may wish to give this latest
action some publicity, either through a Press Notice or a Ministerial interviews.

• O-IO
004008
 Reporting Arrangements

I should also take this opportunity to set out the reporting arrangements for the
various statutory disclosures that I discussed with you and Merlyn Lowther this
morning:
Banks/firiHnciaHnstiniti'ons are required to report to the Bank of England
(Sanctions Unit) on any accounts they have frozen and the amounts frozen
in respect of individuals/institutions named in UN sanctions resolutions.

Reporting of suspicious transactions under the provisions of the Terrorism

Act 2000 should be to NCIS. This will cover both accounts with
individuals/institutions who are not listed in UN Resolutions, and past
transactions with individuals/institutions listed in UN Resolutions before
their accounts were frozen, where suspicions of terrorist financing apply.

In situations where a bank/financial institution makes a suspicious

transaction report to NCIS under the Terrorism Act and also believes that
individuals may be connected to someone on UNSCR 1333, and therefore
liable to have their account frozen, the bank/financial institutions should
also report their suspicions to NCIS. Provided NCIS are content that
' these accounts should be frozen and that this will not prejudice an
investigation, NCIS will pass to the Treasury- information about the
suspected link with someone listed under UNSCR 1333. The Treasury
will then inform the Bank of England, so that arrangements can be made to
freeze the money.

These mechanisms will allow us to give the following clear guidance to

banks/financial institutions about reporting arrangements:

disclosures in respect of individuals/institutions listed in UNSCRs to the

Bank of England;

suspicious transaction reports under the Terrorism Act and reports about
individuals/institutions not named in UNSCRs to NCIS.

I have spoken with NCIS who are content.

Copy to Martin Comley.

Joseph Halligan
HMTreasury

5
004009
 Yasin al-Qadi . • -.^:?

Information on al-Qadi from our long list:

B
aka Shaykb Yassin Abdullah Kadj
•. Located in Jeddah, Saudi Arabia
• Heads Saudi-based Muwafaq Foundation

Muwafaq is an al-Qacda front that receives funding from wealthy Saudi businessmen:
" Blessed Relief is the English translation
H
Chaflq Ayadi claims that Yasin Qadi was Ids partner in Muwafaq, Germany and
that he received 286,000 Deutsche Mark in a Muwafaq bank account from Yassin
A.A. Kadi Sammy Ltd., Istanbul.
• Directly tied to bin Laden.
• In an interview, bin Laden said, "The bin-Ladin Establishment's aid
covers 13 countries... this aid comes in particular from the Human •
Concern International Society." Bin Laden goes on to list a number of
HCl's branch organizations and includes MuwafFaq Society in Zagreb.77
- Saudi businessmen have been transferring millions of dollars to Bin Laden
through Blessed Relief.78 •
• Saudi businessmen deposited S3 million from the National Commercial
Bank, which was run by Khalid bin Mahfouz, into the accounts of the
Blessed Relief and other charities.that serve as a front for bin Laden.79

Al-Qadi has a vast financial empire linked to funding terrorist activity:

• Implicated in Hamas funding network.
• Kfldi International channeled $820,000 to QLI to acquire a property in
. Woodridgc, Illinois in 1991.- The complex scries of transactions was
structured in a manner that obscured Kadi's connection to QLI.10
- QLI provided funding for Hamas via Mohamad Sallah from 1991 through
1993. SaJlah has residence in Chicago and was arrested in February
1993. sl
• Mailing Address found In Kadi/QLI transaction documents:
• Kadi International Corp., c/o BMT, Inc.
One Harmon Plaza
Secaucus.'Ncw Jersey
Atta: Gamal Ahmed
" Director, Global Diamond Resources, an American Company. Yassin al Kadi sits
on the board as a representative of one of two foreign, anonymous, investor
groups that have a controlling interest in Global Diamond.
1
Director, Shifa Internationa] Hospitals in Pakistan.83
77
"Islamic Financier bin Ladia Interviewed on Sudan, Iran Ties." FBIS. July 31, 1995
71
"Saudi Money Aiding bin Laden." USA Today. October 29,1999
"Ibid.
10 .Affidavit of Robert Wright, FBI. June 6, 1998.
1!
"U.S. Seizes SI.4 Million in Cash and Property Intended ID Fund Hamas Terrorist Acrivki« in the
Mjddlc East." U.S. Department of Justice. June 9,1998.
a
"Diamonds are an Arab's Best Friend." Middle East Economic Digest January 15, 1999

16

Cui22-i
004010
 Vice President, MM, BadJcook Co. for Catering & Trading.*4
Owns al-Abrar Group International:
* Dr Wan Muhamad Hasni Wan Sulaiman, is the Founder, President and
Chief Executive Officer of Abiar Group International.85
• Has its origins in the United States "with the establishment of Abrar
Investments, Inc. in 1990. The Group's incorporation in Malaysia was
initiated in early 1992. Later in 1993, Abrar Group International was
formed as the investment and management company of the Group.8*.
His brother, Omar a]-Qadi is the Director of Mercy International - USA

c
"Brief Recordings About Shifa International Hospitals Ltd." Business Recorder. July 14, 2000
u
M.M. Badkdofc Co. brtp^www.saudiarafaia.nrt'm.m.bsdScook/
u
"Wan of 8 Kind." Malaysian rimes. September l,)996
K
Muslim Trade Network. bttp://^A^vw.^n«lurnrade.^cL'directo^>'/Financla[/Scrvjces

17

—j- I 004011
 •Vssr

I2Octob B r2001

TEJR&ORIST FINANCING: U S T OF SUSPECTS

The names on the list attached to this news release are cntides/individuals who arc
suspected of commitcfiig, or posing a significant risk of committing, or providing maierial
support far, acts of terrorism. Financial institutions are requested to check whether Ihsy
maintain any accounts for tha persona listed and, if so, they should freeze the accounts
and report their findings to the Bank of EnglamL

Financial Institutions are reminded of the requirement to file suspicions Transactions

reports TO the National Criminal Intelligence Service (NCIS) in respect of any
persons/entities with, whom they have bad dealings who they suspect may be involved in,
or providing material support for, acts of terrorism.

Any further additions to the list of names of persons/entities •whose accounts must be
frozen, will be notified in due course.

Copies a f this release and attached list are available from the Financial Sanctions Unit at
the Bank af England and arc an the Bank of England's website
hrtp^/nnt^;bara:ofCT^?aiKl-CQ.ttK-

Any queries about this news release should be addressed TO:

The Financial Sanctions Unit
Tel: +44 (0)20 7601 4762/53IIM783/4607
Fax: +44 (0)20 76Q1 4309
Ernail: sanctionsluriiti^bajikofen'gJandco.cOg 'i

ENDS
Gont'd

001223
KCEIVED IZ-NOV-CJ ?0:31AU F«OM-020 7SD! 43D9
TO-Trsasury S o l i c i t o r s PACE 03 004012
 Entities
Air-HAMATI SWEETS BAKERIES, AI-MnkaLlah. Hadbnmawt Govcrnoratc,
Yemen.

AL-miR HONEY PRESS SHOPS (aJca. AL-NUR HONEY CENTER), Sanaa,

Yemen.
AL-SHUA' HONEY PRESS FOR INDUSTRY AND COMMERCE, PO Box
' 8089, Al-Hasabah, Sanaa, Yemen; By the Shrine Next to ihe Gas Station, Jaraal
Street, Ta'iz, Yemen; AI-Arudh Square, IQmr Maksar, Aden, Yemen; AI-NaST Street,
Data, Qatar.

JAISH-I-MOHAMMED (aJca. ARMY OF MOHAMMED), Pakistan.

JAM'YAH TA'AWUN AL-ISLAKIA (aJca. SOCIETY OF ISLAMIC

COO]PEKATION)Ca.k.a. JAMTYAT AJL TA'AWUN AX rSLAMTYYAXaJca.
JXT), Qandahar City, Afghanistan.

HABITA TRUST, Room 9A, 7** Floor, Wahdat RDB4 Education Towx, Lahore,
Pakistan; Wjurs Colony, Lahore, ^Pakistan.
Individuals
AGHA, Haji Abdul Manaa (a-k-t SAIYID, Abd Al-Man'am); PaJdstan.
ALr-HAMATl, Muhammad (aJca. AL-AHDAL, Mohammad Hamdi Sadiq)(aJca.
Al^MAKKI, Abu AJita),YemerL

*AL-HAQ, Amin (a.k-2. AM3N, Mahspunad; a.fc.a AH HAQ, Dr Amin;

UL-HAQ, Br Amin); DOB: 1960; POBt Nangahar Province, Afghanistan.
AL-QABI, Yaain (a.k.a~ KADI, Shaykii Yaala AbduDahXa-ta. KAHDI, Yasln),
Jeddah, Saudi Arabia.
*AL-JA2>AWr, Saqar; DOB: 1965
"AL-KADR, Ahmad Sa'id (a.k.a AL-KANADI, Abu Abd Al-Rahman);
DOB: 01 March 1948; POB: Cairo, Egypt.
*AL-SHARIF, Sa'd; DOB: 1969; POB: Saudi Arabia

*BINMARWAN, Bilal; DOB: 1947

BIN MUHAMMAD, Ayadi Chsfiq (a.k.a. AYADI SHAFIQ, Ben Muhammad)
Ca.k.1. AYADI CHAF1K, Ben Muhammad) (a.Sc.a. AIADI, Ben Muhammad)
(a.k.a. AIADY, Ben Muhammad), Hdeae Meyer Ring 10-1415-S0S09, Munich,
Germany; 129 Park Road, London, NW8, London, England; 28 Chaussc Dt Lille,
Moscron, Belgium; Darvingasse 1/2/58-60. Vienna, Auscria;.Tmusia; DOB: 21
January 1963; FOB: SaJaJs (Sfax), Tunisia.

0 U Ji. C d t

RECEIVED ia-HOV-01 lfl:3IA« rROM-020 7 6 0 1 ^ 3 0 ^ ^ TO-Tr.»Ufy Sol , = , t o r , PACE 04

004013
°{
 DARKAZANLI, MamoUQ, Uhleahorster Weg 34, Hamburg, 22085, Germany;
DOB; 4 August 1958; POB: Aleppo, Syria; Passport No: 1310636262 (Germany).

HUAZ3, Risd (a-k-a. HUAZr, Rsed M.) (aJca. AL-HAWEN, Abu-Ahmad) (aJca.
AL-M^eBDRiBl, Sashid [The Moroccan]) (aJtJL AL-AMRIIO, Abtt-Ahmad
[The American]) (aJLa. AI^SHAHID, Aba- Ahmad). Jordan; DOB: 1968; POB:
California, USA; SSN: 548-91-5411.
LADEBYANOY, Mnfti Rastid Altmad (ai.a. LUDHIANVI, Mufti Rashid
Abmad) (aJfe.s. AHMAD, Muffl RaahcedQ (auk-a. WADEHVANOY, Mufti Kashld
Altmad); Karachi, PaJdstaa.

ITTHMAW, Omar Makmoud (sJca. Othmaxi, Omar MJUnnoxid) (a_k.a. AL-

FILISTINI, Abu Qatada) (ajia. TAKFOU, Abu "Umr] (z.k.1. ABU UMAR, Abu
Omar) (a.k.a- UTBMAN, Al-SEmman) (aJca. UMAX, Aba tlmar) (a.k.s-
tTTHMAN, Umsr) ( a.k^ ABU ISMAIL.), London, England; DOB: 30 December
I960 or 22 December 1950 or 13 December 1960. National Insurance Number
PW5S1303D.

VULBASHEV, Tohir (aJLa. YULDASHEV, Takiiir). Uzbekistan.

Z1A, Mohammad! (aJca. ZIA, Ahmad); c/o Ahmed Shah sfoPainda Mohammad.
al-Karim Set, Pttshawar, Pakistan; c/o Alam General Store Shop 17, Awami Maricci,
Peshawar, Pajdstaiy c/o Zabiv Sliah s/o Murad Khan Andcr Sher, Peshawar, PaJdstan.
YASIN, Abdul Rahman
MOHAMMED, Kbatfd Sbaikli

AL MUGHA5SXL, Ahmed
AL-HOUK1, Ali

AL-YACOUB, Ibrahim
AL NASSER, Abde) ]fiSariin
MOHAMMED, Fazul AbduUah
FADHIL, Mustafa Mohamed
GHA1LANI, Ahmed Khalfati
MSALAJV1, Fahid Mohammed Ally
SWEDAN, Shclkfa AJimcdSalim
ABDULLAH, Abdullah Ahmed

00 ' P'^S
RECEIVED iz-NDU-Di ia.-3MW ?RoW-n2n Ten) Ainu TnT ' ~ *" ^
JMM rROM-020 750! 4 3 f f B ^ ~ s TO-Tr«a S U r y S a i . c l t a r s PAGE 05 004014
 ALI, Ahtatd Muiusmmtd Eanxed

ATWAH, MTEHMB MUSM MawraHl

MUGNIYAH,Imad

12Z-AL-DIN, Hsssauo

ATWAjAli

* Ttfisa rig toes have already been published in the UN consolidated list dated
8 Marcti 2001

c~

DECEIVED IWnv-i,, ,».SIAH MOW-KO NOI 4JIH Tor ,, 0012^9

T
^ < °-TrBijUr)r S o l i c i t o r . PACE OB 004015
 COUNTY OP COOK )
) ss
STATE OF I L L I N O I S )

RPFTDaVTT OF -RrmBRT WRTflHT

I, Robert Wright, being duly sworn, do hereby depose and

state:

1. I am a Special Agent of the Federal Bureau of

Investigation (FBI) aaaigned to the Chicago Division. I have

been a Special Agent with the FBI since 1990. I am currently

assigned to the Chicago Division Counter-Terrorism Task Force

In this capacity, I have become familiar with techniques used by

international terrorist organizations to surreptitiously move and

launder money in and out of the United States, including through

use of domestic financial institutions, in support of

extortionate terrorist and paramilitary activities and operations

in the United States and abroad, including the State of Israel

and elsewhere.

2. The Chicago FBI Terrorist Task Force has been conducting

an investigation into activity dating back to 1989 and

continuing to the present involving the transfer or transmission

of money from Europe and the Middle East to a network of

individuals and organizations in the United States, including, in

the Chicago area, Mohammad Salah, Azita Salah, and the Quranic

Literacy Institute ("QIJI") . There is probable cause to believe

001230
/r"=5:\ 004016
( tO \
 MQHAMMFD SALAH, QLI, AND THKTT? RKr.ATTON.qTTTP

4. On January 25, 1993, Mohammad Salah, a naturalized

American citizen and Chicago area resident, was arrested in

Israel for his membership and participation in the HAMAS

terrorist organization ("HAMAS") .l In January of 1995, Salah

pled, guilty in an Israeli military court to belonging to HAMAS

and illegally channeling funds to the outlawed HAMAS

organization, including funds transferred through one of the

subject accounts he held jointly with his wife Azita, at LaSalle

l
HAMAS is an acronym of the Arabic term for "The Islamic
Resistance Movement."--Harakat al Muqawama al Islamiyya. It is an
independent political organization founded in the Israeli
Occupied Territories in 1987 at the beginning of the Intifada,
the Palestinian-led campaign to resist Israeli political dominion,
over the occupied territories. Organizationally, HAMAS is divided
into two operational branches or bureaus--a political branch and
a military branch. The political branch has among its publicly
stated purposes the establishment of a Palestinian identity and
homeland. To that end, the organization is involved in community
building activities in Israel and abroad. However, acting
through its military branch, which receives instruction and
support from its political branch, HAMAS also has been engaged in
a more than decade-long campaign of subversive and violent
activity--commonly denominated as terrorist activity--undertaken
primarily in Israel, and supported in part by illegal activities
in the United States including, among other thingsr money,
laundering in violation of 18 U.S.C. § 1956, including some that
are the subject of this affidavit. These terrorist activities,
for which HAMAS has repeatedly and publicly claimed credit, have
as their broadly represented purpose the undermining the Israeli-
Palestinian peace process, and, more generally, of forcing the
State and citizens of Israel to cede physical and political
control and dominion over the lands comprising Israel and the
occupied territories, and replacing the Jewish political
authority over these lands with an Islamic government.

s~^ V H>wrfnH ^
 Talman Bank in Chicago. For his crimes, the Israelis sentenced

Salah to five years imprisonment. Salah was released from an

Israeli prison in November of 1997, at which time he was

permitted to return to the United States.

5. On July 27, 1995, while Salah was incarcerated by

Israeli authorities, the United States Treasury Department's

Office of Foreign Assets Control added. Mohammad Salah to the list

of Specially Designated Terrorists, (published at 60 Fed. Reg.

44932, August 29, 1995), because of his facilitation of terrorist

activities in the Middle East.

6. A review of bank records obtained by the FBI

demonstrates that Salah previously has claimed to be an employee

of the Quranic Literacy Institute ("QLI") of Oak Lawn, Illinois.

QLT represents itself to be a not-for-profit research institute

devoted to the translation and publication of sacred Islamic

texts and to scholarly research devoted to such topics. QLI's

principals include its PresidejxL, Ahmad— Za-ki -Hameed"~'(~"ZaKi" ),

Corporate Secretary and Trustee Amer Haleem, and Treasurer

Abraham Abusharif.

7. Bank records obtained by the FBI "include an employment

verification letter issued for Mohammad Salah by QLI to the

Standard Bank & Trust Co of Evergreen Park, Illinois. The

letter, printed on QLI organizational letterhead and signed by

004020
Amer Haleem, states that Salah began working for QLI as a

computer analyst on January 1, 1991, at a salary of $36,000. The

letter was provided to Standard Bank & Trust by QLI in support of

Salah's securing of a mortgage loan in excess of $100,000 for his

residence at 9229 S. Thomas, Bridgeview, Illinois. In making

application for the loan, Salah claimed as his only employment

the purported job with QLI.

8. Bank records further show that Salah also claimed an

employment relationship with QLI when he opened his subject

account with First National Bank of Chicago, (account number

8060700), in late July of 1991. The bank obtained an oral

verification of Salah's employment with QLI from QLI treasurer

Abraham Abusharif.

9. Other information obtained by the FBI indicates that

Salah either was not employed by the QLI in the capacity claimed

or that QLI is seeking to conceal and disguise the relationship

it has with Salah. QLI initially responded to FBI and INS

inquiries by refusing to discuss Salah's employment status. FBI

review of QLI business records did not reflect any type of

regular periodic payments to Mohammad Salah, such as paychecks or

tax withholding records, that would reflect the existence of the

employment relationship claimed in the employment verification

letter submitted to Standard Bank. Additionally, speaking

f~ T • t i l l '
 through its attorney Ralph Brown during a February 6, 1998,

telephone conversation with FBI agents, QLI has expressly denied

having employed Salah at any time. Salah's wife, Azita Salah, in

an interview with FBI agents, denied that her husband was

employed by QLI and stated that he merely performed volunteer

work for the organization.

10. Tax records obtained' in the course of the investigation

indicate that Salah secured a mortgage from Standard Bank & Trust

not only through misrepresenting his employment status and

relationship with QLI, but also through tendering falsified tax

returns for the 1988, 1989 and 1990 tax years which he

represented to be copies of filed returns. IRS tax information

revealed that the Salahs in fact did not file tax returns for the

1988 tax year and that the tax returns they filed for the 1989

and 1990 tax years materially differed from the returns tendered

to Standard Bank & Trust as part of the mortgage application

process-.

RATiAH'S ATJQIIST 1992 TRTP TO ISRAEL FOR HAMAS

11. Salah's statements to Israeli authorities after his

arrest in January 1993 suggests that Salah's claimed employment

with QLI -was likely a cover for his position as a high-level

HAMAS military operative.

12. While in Israeli custody after his arrest on January

r\ -\ • ,•) .-) '~>

25, 1993, Salah made a series of statements to Israeli

authorities in which he admitted hia activities in the United

States and abroad as a HAMAS military operative prior to and

during the period he was claiming to be a computer analyst for

QLI . According to Salah, his involvement with HAMAS began

approximately in 1988 and continued through to the date of his

arrest by Israeli authorities on January 25, 1993. Salah further

divulged that his activities for HAMAS, domestically and

internationally, included recruiting and training new candidates

for membership in HAMAS military cells in the Israeli Occupied

Territories and to perform terrorist acts, primarily in the State

of Israel. Salah told Israeli authorities that his recruitment

activities included, among other things, conducting interviews

and background checks, as well as identifying and sorting

prospective candidates on the basis of expertise and skills

relating to, among other things, knowledge of chemicals,

t

explosives and the construction of terrorist devices that might

be used in HAMAS military operations in Israel and elsewhere.

His training activities for HAMAS, according to Salah, included

mixing poisons, development of chemical weapons, and preparing

remote control explosive devices.

13. Salah also admitted having served as a financial

conduit for HAMAS operations. Relatedly, he admitted to directly

_ CG1237
/|?\ . 004023
 financing domestic and international travel and terrorism

training for new HAMAS members. Airline records obtained by the

FBI show that Salah purchased airlines tickets for travel between

the United States and sites in the Middle East for himself and

other suspected HAMAS terrorists, including Alwan Shareef and

Razick Saleh Abdel Razick, both of whom flew from the United

States to Syria with tickets purchased by Salah in September of

1992. A review of the Salahs' bank records revealed that Salah.

paid -for the airfare by executing a check, dated September 29,

1992, drawn from the subject LaSalle Bank account that Salah

jointly held with his wife Azita-. Additionally, Salah has

acknowledged in statements to Israeli authorities that these

trips were taken for the purpose of receiving training in

preparation for HAMAS military and terrorist operations in

Israel.

14. Bank and airline records obtained by the FBI and

reviewed in conjunction with statements to Israeli authorities by

Salah and other HAMAS operatives indicate that between June 18,

1991 and December 30, 1992, Mohammad Salah expended in excess of

$100,000 in direct support of HAMAS military activities.

15. For example, Salah admitted to Israeli authorities that

in September of 1992, he gave in excess of $4 8,000 to Salah Al-

Arouri {"Al-Arouri"), an admitted HAMAS military operative and

(^0\ 004024
student at Hebron University in the Israeli-occupied West Bank.

According to Salah, the money was to be used to purchase weaponry

to be used to carry out attacks against Israel.

16. Salah's admission is corroborated by a number of

independent sources, including statements of Salah Al-Arouri to

Israeli authorities in early 1993. Al-Arouri has related that he

received approximately $96,000 from Salah during a face to face

meeting at Hebron University late in the summer of 1992.

According to Al-Arouri, Salah gave him the money specifically for

the procurement of weapons and the financing of the activities of

HAMAS military apparatus in Hebron. Al-Arouri further related

that weapons were in fact purchased with the money provided by

Salah.

17. Aa recounted by Al-Arouri, Al-Arouri gave an individual

named Musa Dudin approximately $45,000 of the money he received

from Salah so that Dudin could purchase weapons in September of

1992. Among the weapons Musa Dudin purchased were one short M-16

rifle; two Kalashnikovs, two Uzis, a number of 9 millimeter

pistols, and numerous magazines and hundreds of rounds of

ammunition for the various weapons. Al-Arouri further related

that the weapons purchased with the money from Salah were-

subsequently used in terrorist attacks, including a suicide

attack resulting in the murder of an Israeli soldier in Hebron in

10

004025
 October of 1992. According to Al-Arouri, the attack was carried

out with the short M-16 rifle purchased with the money he

received from Salah. Al-Arouri related that shortly after

purchasing the rifle with the Salah money, he gave it to HAMAS

operatives Baahir Hamada and Talal Salah, who used the. weapon in

their October 1992 murder of an Israeli soldier. Al-Arouri

further related that after the attack., he assisted Hamada and

Talal Salah in evading Israeli authorities who had initiated a

-• massive manhunt for the two HAMAS killers. According to

subsequent published news reports based on Israeli military

Bources, the two men soon thereafter escaped to Egypt by sea in a

rubber dinghy launched from the border town of Rafah in the

occupied territory of Gaza.

18. In statements to Israeli authorities in January and

April of 1993, Musa Dudin confirmed his role in the events

revealed by Al-Arouri as summarized in the previous paragraph.

Additionally, Musa Dudin admitted his involvement in the planning

and execution of a HAMAS terrorist attack in Hebron on December

12, 1992, which resulted in the killing of Israeli soldier Yuval

Tutanji. Musa Dudin stated that one of the weapons used in the

ambush attack was a Kalashnikov rifle from the Hebron military

squad. Al-Arouri indicated in his account of his dealings with

Mohammad Salah that funds given to him by Salah were used to

11

004026
provide the Hebron squad with weapons, which included Kalashnikov

riflea, clips and ammunition, and additional money to support

their terrorist attacks.

19. Salah's transaction of HAMAS business with Al-Arouri is

supported by Israeli border control records which, according to

Israeli police, show that Salah entered Israel's Ben Gurion

Airport from the United States on August 25, 1992, and departed

from Israel Ben Gurion Airport on September 9, 1992.

20. Additionally, bank records from subject LaSalle Bank

account number 02-203453-2, held in the names of Mohammed and

Azita Salah (and one of the subject accounts against which

seizure and forfeiture is sought), corroborate the statements of

Salah and Al-Arouri regarding their dealings. Specifically, the

bank records reveal that from August 12 through September 12,

1992, deposits in an amount exceeding $52,000 were received in

Salah's LaSalle Talman account. Within that same period, on

September 3, 1992, while in Israel, Salah withdrew $50,000 from

his LaSalle Bank account by executing ten (10) $5000.00 checks

made out to "Cash." The reverse side of each check indicates

that it was cleared through the central branch of an Israeli bank

in Tel Aviv on September 8, 1992, and debited against Salah's

LaSalle Bank account in the United States the following day.

QLT-RELATED SQURCES MADK LARGE STRUCirmFJ)

12

001241
004027
 TRANS FF.T?S OF MOTsTFY DIRECTLY TO fiAT.Aff

21. A review of bank records further indicates that QLI and

QLI-related entities or individuals likely were a Bource of funds

for Salah's HAMAS-related expenditures between 1991 and hiB

arrest in January of 1993 and beyond. They also suggest that the

QLI-related transfers of fundB to Salah were, in significant

part, structured in an effort to conceal QLI as the source of

the funds.

22. For example, bank records show that- on each of October

29, 30 and 31, 1991, Salah received a $6,000 check, ($18,000 in

total), executed by Ahmad Zaki Hameed, the President of QLI. The

checks were not drawn on QLI bank accounts, but rather from

Zaki's personal bank account.

23. A review of bank records similarly revealed that on

June 18, 1991, Salah received $40,500.00 in the form of five (5)

cashier's checks, each in the amount of $8,100.00, drawn from an

account held by the George Washington Savings and Loan

Association of Oak Lawn, Illinois with the First National Bank of

Evergreen Park, Illinois. Bank records show that the cashier's

checks were obtained for and given to Salah by Linda Abusharif,

the sister of QLI Treasurer Abraham Abusharif. Bank records

further reflect that the five cashier's checks were counter-

signed by Salah who deposited them into his LaSalle Bank account.

13

CG1242
004028
 QLT '.R SCHEME TO GENFlffATfi TNCOMK FOR HAMAH ACTTVTTTKR

24. Bank records further suggest that the planned source of

the funds that were relayed to Salah by QLI related entities was,

at least in part, the proceeds of a local land deal involving QLI

and Golden Marble Corp, that was financed with funds transferred,

from a Swiss account of a Saudi Arabian entity into the United.

States.

25. In interviews with the FBI, Golden Marble President Dr.

Tamer Al-Rafai ("Al-Rafai") has related that beginning in March

of 1991, he met with QLI President Ahmad Zaki Hameed who

represented himself to be a possible investor in a land

development project Al-Rafai hoped to start. An outcome of the

meetings was that Al-Rafai was instructed to bid on land for the

project and, if the bid was accepted, QLI would arrange to

finance the project,

26. Accordingly, in May of 1991, Al-Rafai made a bid of

$820,000 for a large unimproved lot located at Route 53 and

Hobson Road in Woodridge, Illinois. The bid was accepted, after

which Zaki informed Al-Rafai that he had identified a source for

the funds necessary to close the deal. Zaki further told Al-

Rafai that QLI would handle all business matters regarding the

investment £ST$i*t?n^a!BSK^

14
 27. According to Al-Rafai, on July 19, 19 91, Saudi Arabian

bus i fe.&^fffnianr-?EflB^nJfcftdj^^

jFggSasgs&ki, wire transferred $820,000 to Golden Marble from a

Swiss bank. Bank records corroborate the wire transfer. Shortly

thereafter, on July 2 2 , 1991, Golden Marble used these funds to

purchase the Woodridge, Illinois property. Both the wire

transfer from Kadi to Golden Marble and the land purchase were

consummated without ttte prior execution of any kind of mortgage

or loan note. Indeed, QLI was not signified as a party to, or

otherwise referenced in the papers concerning, these

transactions.

28. However, on July 18, 1991, prior to the closing on the

purchase of the Woodridge property, Zaki, in his capacity as

QLI's president, established a land trust (Trust No. 1206-0) at

the Midland Federal Savings & Loan Association. The bank trust

documents specify the woodridge property as the only asset of the

trust and designate QLI as the sole trust beneficiary. This

specification was nominally false at the time it was made,

because the property had not been purchased yet, (and would not

be until four days later). And when it was purchased, it was

purchased by Golden Marble, not QLI. Moreover,- the documents

establishing the QLI/Midiand Federal Bank trust, which have been

reviewed by the FBI, do not recognize or otherwise reference Al-

15

vnioo
004030
Rafai, Golden Marble, Yassin Kadi, or %fi|,i -lafcaaaaafcLtaaaJI a§£ a

party in interest, or otherwise connected to, the Woodridge

property,

29. On July 23, 1991, the day after Golden Marble closed on

the Woodridge property, QLI and Golden Marble executed a Lease

and Sale Agreement. The agreement, which is signed by Ahmad Zaki

for QLI and Tamer Al-Rafai for Golden Marble, states QLI to be

the owner of the Woodridge property, and provides that Golden

Marble.would lease the property from July 22, 1991 through July

21, 1993 for $164,000. The agreement specified that the rent was

to be paid in a lump gum of $150,000 on July 22, 1991, with the

remaining $14,000 due three months later. The agreement further

specified that Golden Marble was to purchase the property within

two years--i.e. by July 1993--for a price of $970,000.

30. Bank records reflect that the day the lease and sale

agreement was executed--July 23, 1991--Al-Rafai, on behalf of

Golden Marble, executed three checks payable to QLI totaling

$101,000. Each of the three drafts, which according to Al-Rafai

were payments against the $150,000 rent due at the inception of

the lease, were returned for insufficient funds after being

deposited by QLI into its Oak Lawn National Bank account. Zaki

Hameed demanded immediate payment. However, QLI ultimately

granted Al-Rafai forbearance on the payment until September 1991.

16

00I24o
004031
 On September 11, 1991, Al-Rafai, for Golden Marble, wrote a check

for $22,000 to QLI. On the following day, Al-Rafai executed a

check for $88,000 to QLI.2

31. Bank records reviewed by the FBI indicate that QLI did

not cash or deposit the two September 1991 checks from Al-Rafai

totaling $110,000 for six months, until March 11, 1992, when Zaki

'Hameed of QLI endorsed the checks over to a third party.3

Within days after Zaki Hameed'a endorsing of the checks, Mohammad

Salah received the first in a series of three substantial

overseas wire transfers into his First National Bank of Chicago

account that is a subject of this seizure and forfeiture action

totaling just under'$110,000. Specifically, bank records for

Mohammad Salah's First National Bank of Chicago account number

80S0700 show that on March 16, 1992, within five days of Zaki

Hameed'a endorsing of the Golden Marble rent, Salah received an

2
The balance of the $150,000 rent payment was paid on
November 27, 1992, when Al-Rafai wrote QLI a check for $40,000.
3
Tamer Al-Rafai has related that he was told by Zaki
Hameed that the checks were not cashed during this period because
QLI was waiting for the conferral of tax-exempt status from the
IRS. In fact, the delayed endorsement of the checks on March 11,
1992, correlates with QLI's attaining status as a 26 U.S.C. §
501(c)(3) tax-exempt organization in March of 1992. Prior to
that time, and including the summer of 1991, QLI did not have tax
exempt atatua. It therefore should have reported the rental
income from the Woodridge property as a non-tax exempt
organization for the 1991 tax year. A review of tax records
indicates that QLI did not report the rental income, or any other
income, for the 1991 tax year as it was required to do.

17

0J124G
004032
 overseas wire transfer of $27,000 into his First Chicago account

from Faisal Financial of Geneva, Switzerland. That wire was

followed by two additional wire transfers from Faisal Financial

of Geneva of $30,000 on July 3, 1992*, and $50,000 on October 7,

1992.

32. Also on July 23, 1991, Zaki Hameed and Amer Haleem of

QLI brought Al-Rafai to the Midland Federal Bank, at which time

Zaki had Al-Rafai execute a document transferring the Woodridge

property to Midland Land Trust No. 1206-0, of which QLI was the

only beneficiary.

33 . A title search for the Woodridge property obtained by

the FBI does not reflect Golden Marble having ever been recorded

as owner or party in. interest to the Woodridge property at the

time of the land deal in July of 1991. The title search instead

shows ownership of the property as being held by Midland Federal

Land trust 120S-0. This chain of transactions, (which according

to Al-Rafai was directed by Zaki, QLI's President), resulted in

* On July 5, 1992, two days after the July 3, 1992,

$30,000 wire transfer from Faiaal Financial of Geneva Switzerland
was received into his First Chicago account, Mohammad Salah
signed a lease for Standard Bank & Trust Safe Deposit Box Number
4019. On July 9, 1992, Salah drew on the wired funds by
withdrawing $10,000 from the First Chicago account. According to
Standard Bank's Trust personnel, Azita Salah has paid the yearly
rent for Box Number 4019 through to the present, including the 4
year ten month period during which Mohammad Salah was
incarcerated in Israel.

18

00L247
004033
 QLI gaining possession and ownership of the Woodridge property in

a manner that obscured its connection to the overseas transfer of

$820,000 froiff^TF^-ftetMfli^anM fy .Kaflj., Tn^P^P^t-lon.a^^J^b^iakinh the

deal was financed.

34. Indeed, QLI' 3 relationship to the loan extended by Kadi

International for the July 1991 purchase of the Woodridge

property was not reflected in any notes or agreements until

December 1991, five and a half months after the wire transfer and

closing of the land deal. Specifically, on December 17, 1991,

«®^f ! ^^Sou^nZaki, instructed Midland Federal, as Trustee of

Trust No. 1206-0,

On December

31, 1991, Midland Savings did so by executing a note specifying

that $820,000 was due and payable on December 31, 1993, and

providing that "All payments are to be made to Kadi International

corp., **ff7o ss *5tPr aa me?^^

A^^^^B^SSfif^sar^feiB^d." Richard Taylor, Vice President of Midland

Federal, who signed and notarized the document advised the FBI

that he understood the note as signifying that QLI was planning

to borrow $820/000 from Kadi International Corp. and use the Land

Trust #1206-0 as collateral for the loan. The bank officer who

served as trustee related to the FBI that at the time he prepared

19

Q0L2iG
CiS\ 004034
and executed the note, he was not aware that it was referencing

an unsecured loan that occurred five and one half months earlier.

35. N-at^a^lyf Kadi.. In_£sxX)3J^r&sseSr--sccsx3r~ircs°^tel!'afe~cr"gtTC±iry,

representative of BMI, Inc., (specified, as payee in the QLI

"Note"), testified that Kadi International Corp. had no records

or any relation to QLI, its president, Zaki Hameed, or Midland

Trust No. 1206-0. The representative also testified that BMI was

not aware of the note or mortgage executed in favor of Kadi

International. Additionally, a review of title records for the

property indicates that the note or mortgage was never record as

a lien against the property, which had the effect of further

concealing from public notice the relationship between QLI and

the oversees transfer of funds from Kadi in Saudi Arabia. 5

MOTTAMMAn B A T . A H ' f i TT?TP TO TffRART. TN .TANTTARV O P 1993

36. Mohammad Salah has related to Israeli authorities that

in December of 1992, he was ordered by Mousa Mohammad Abu Marzook

("Abu Marzook") to travel to Israel's West Bank in January of

5
A review of tax records reveals that for the tax years
1991 through 1995, QLI never filed the annual IRS Fortn-990
required of tax exempt organizations. This failure acted to
further conceal and obscure QLI's business dealings generally,
its effective receipt of $820,000 internationally transferred
into the United States by Kadi for the purchase of the Woodridge
property, and the income QLI received in the form of rents from
Golden Marble between 1991 and 1994.

20

001243
004035
 1993 to carry out five missions on behalf of HAMAS.

37. Abu Marzook is the leader of the political bureau of

HAMAS. According to records of the United States Customs Service

and the Immigration and Naturalization Service, Abu Marzook is a

native of Rafia, Gaza, who moved to the United States in 1973,

and eventually settled in the Washington, D.C./Northern Virginia

area as a resident alien until 1993. Between 1993 and 1995, he

resided principally in Jordan, which deported him in June of 1995

for his involvement and senior position in HAMAS. In July of

1995, after making trips to Iran and Syria, Abu Marzook attempted

to reenter the United States at which time he was arrested by

Customs and INS officials at the request of the Israeli

government which sought to prosecute Abu Marzook for numerous

crimes in connection with his leadership of HAMAS -

In October of 1995, acting at the request of the Israeli

government, the United States initiated extradition proceedings

against Abu Marzook based on pending Israeli criminal charges

that included, murder, attempted murder and conspiracy stemming

from HAMAS sponsored terrorist acts on civilian targets in Israel

and the Occupied Territories between July of 1990 and October of

1994. These terrorist acts resulted in the killing of over 30

Israeli citizens, the injuring or kidnaping variously of scores

of other innocent civilians, including an American citizen, and

21

0012U0
004036
6a\
 the wounding of scores of Israeli aoldiera.

In the resulting extradition proceedings in the spring of

1996, the United- States District Court for the Southern District

of New York found probable cause to believe that HAMAS was the

perpetrator of numerous of the crimes for which- the Israeli's

sought to prosecute Abu Marzook, including the April 4, 1994,

suicide bombing of a passenger bus in Afula, Israel, which killed

eight civilian passengers and seriously wounded 44 civilians and

two Israeli soldiers, and the April 13, 1994- bombing of another

passenger bus between Afula and Tel Aviv, which killed six

persons, including four civilians and one Israeli soldier, and

wounded an additional 12 civilians and 18 Israeli soldiers. In

the district court proceedings, Abu Marzook expressly

acknowledged his position as the leader of the political branch

of HAMAS. The court found probable cause to believe that Abu

Marzook, in his leadership capacity, had knowledge of these and

other terrorist acts, that he had promoted and defended them

• ' publicly, and that he had directed underlying activities in

support of HAMAS terrorist activities, including the activities

of Salah in both the United States and Israel. The district

court's decision is published in In the Matter of the Extrarfi ti op

of Ahn Marzook- v. Phri Btopher, 924 P. Supp. 555 (S.D.N.Y. 1996).

38. Salah's relationship' with Abu Marzook is independently

22

001251
004037
 corroborated by bank records showing more than $752,800 flowing

from Abu Marzook (or accounts controlled by Abu Marzook) to Salah

between 198 9 and January 1993.6

39. According to Salah, he was first contacted by Abu

Mar2ook about the proposed January 1993 missions through a series

of telephone calls placed by Abu Marzook in December of 1992.

According to Salah, Abu Marzook called him after a succession of

calls by Abu Marzook to Syria, Lebanon and Sudan through which

Abu Marzook received information from, and consulted with, HAMAS

operatives regarding the mass deportations by the Israeli

government of 415 HAMAS operatives in Israel and the Occupied

Territories on December 17, 1992. In public statements, the

Israeli government indicated that the mass deportation was a

direct response to the murder of a number of members of Israeli

military and police units in the previous weeks for which HAMAS

had claimed credit,7 and the last of which was the December 15,

s
\ - Among the transfers, the largest of which are set forth in
the following paragraphs, was a check executed by Abu Marzook for
$5,000 and dated August 8, 1992, just two weeks prior to Salah's
trip to Israel to provide weapons money to HAMAS operative Salah
Al-Arouri. £Lefi %% 15-20. In the extradition proceedings, Abu
Marzook acknowledged this transfer to Mohammad Salah.
7
Among these precipitating incidents was the murder of
Israeli soldier Yuval Tutanji in which Musa Dudin assisted, and
which was undertaken by the Hebron military cell of HAMAS that
was supported with weapons and money provided by Al-Arouri with
funds he received from Salah in September of 1992. See % 18.

23

004038
1992, dumping of the atabbed and mutilated b o d y of a kidnaped

Israeli border police officer in the West Bank o n the main road

between Jerusalem and Jericho. The discovery of the body was the

precipitating event for Israel's immediate arrest and detention

of approximately 1200 Palestinians, followed on December 17, 1992

by the Israeli deportation of approximately 40 0 suspected HAMAS

members.

40. According to Salah, Abu Marzook reported to him in the

immediate wake of these events that HAMAS' situation inside

Israel was serious because the mass deportations and arrests had

decimated the organization within the Occupied Territories. Abu

Marzook characterized the situation as most serious in Ramallah

and Hebron because of the sudden removal of HAMAS leadership

structure in those areas.

41. Salah further related that A b u Marzook instructed that

due to the mass deportation by the Israeli g o v e r n m e n t , it was

necessary that Salah go to Israel to assist in reorganizing and

restaffing the military cells in Hebron, R a m a l l a h , Nablus,

Bethlehem, Jericho and Jerusalem. Salah also stated that Abu

Marzook instructed h i m to distribute $790,000 to HAMAS cells in

support of HAMAS-sponsored military {or terrorist) activities.

According to Salah, A b u Marzook directed that Salah allocate the

funds as follows: $100,000 to Ramallah; $130,000 to Nablus;

24

U U .L d 0 •)
/ "*. 004039
$100,000 to Hebron; $300,000 to Gaza (specifically for military-

activity there); with the remainder to be distributed according

to military and general requirements that would be determined

following Salah's arrival and assessment of HAMAS organizational

needs in Israel and the occupied territories.a

42. Salah told Israeli authorities that Abu Marzook also

identified by name specific contacts and operatives with whom

Salah was to meet to gather further information and make

assessments regarding HAMAS' situation following the mass

deportations and resulting leadership vacuum. Additionally, Abu

Marzook provided Salah with the names of specific individuals who

were to be placed into leadership positions in various mosques

and units to replace those who had been deported.

43. In response to Abu Marzook's various directives, Salah

made arrangements for air travel from the United States to sites

in the Middle East for himself and other HAMAS operatives. The

air travel was booked through Ghada Sharif. Sharif was Salah's

regular travel agent for such purposes, having previously booked

the airline reservations for Salah to fly to Israel to conduct

HAMAS business in August and September of 1992, as well as those

of HAMAS operatives Alwan Shareef and Razick Saleh Abdel Razick

8
Salah indicated to Israeli authorities that the final
designated distribution provided for the remaining $160,000 to be
l
distributed to Nablus.

25

00125*
004040
(tt\
 to fly to Syria in September 1992 for HAMAS military training.

44. Immediately following the organizational crisis

initiated by the December 17, 1992 deportations, and the

communications between Abu Marzook .and Salah, Zaki Hameed and

Amer Haleem of QLI separately made contact with Golden Marble

President Tamar Al-Rafai to pressure him to liquidate the

Woodridge property because, they claimed, the Saudi funds tied up

in the property were needed immediately. According to Al-Rafai,

f— beginning in mid-December of 1992, Zaki Hameed repeatedly

contacted him and pressured him (and Golden Marble) to tender the

money for the purchase of the Woodridge property from QLI. In

these communications, Zaki Hameed repeatedly told Al-Rafai that

the money was needed immediately for "a mission above all else."

QLI Secretary and Trustee Amer Haleem also contacted Al-Rafai

during the same period and similarly told him to do whatever was

necessary to liquidate the Woodridge property and get the money

to QLI. Al-Rafai could not do so because, at the time, Golden

o
Marble lacked the financial resources to take immediate action.

Additionally, according to Al-Rafai, the Lease and Sale agreement

with QLI did not contractually obligate Golden Marble to purchase

the property for another seven months.

45. Bank records reviewed by the FBI reveal that shortly

after these events, close associates of Abu Marzook initiated a

26

OD4041
 series of wire transfers into Salah's La Salle Bank account

totaling $985,0.00.

46. According to Salah, he provided Abu Marzook with the

account number to the LaSalle Talman Savings checking account he

held with his wife so that Abu Marzook could wire him the funds

to be distributed to HAMAS operatives in the Middle East.

47. Bank records reviewed by the FBI reflect that on

December 29, 1992, Ismail Selim Elbarasse ("Elbarasse"), who,

according to Salah is, a HAMAS, operative in the United States,

wire transferred $3 00,000.00 to Salah's LaSalle Bank account.

The Elbarasse wire originated from an account at the First

American Bank of McLean, Virginia, which Elbarasse jointly held

with Abu Marzook.9

.48. In the days just prior to this wire transfer there was

a substantial influx of money principally from international

sources into the First American Bank of Virginia account jointly

held by Elbarasse and Abu Marzook. On December 23, 1992, $99,985

was wire transferred into the account by an individual named Gazi

Abu Satnah from an as yet unspecified source. It was followed

9
A review of bank records indicates that the account was
the same one from which Abu Marzook had drawn from in executing a
$5,000 check to Salah on August 8, 1992 that is discuseed in
footnote 2. It is also the same account from which Abu Marzook
wrote a November 27, 1992 check to Salah in the amount of $2,110
(which Abu Marzook also acknowledged in his extradition
proceedings).

27
with a December 23, 1992 wire transfer of $200,000 from Faisal

Financial of Geneva, Switzerland,10 and a December 29, 1992 wire

transfer of $73,475.77 from Dubai, United Arab Emirates.

49. Bank records indicate that in early January of 1993,

Salah withdrew a significant portion of the $3 00,000.00 placed

into his account by Elbarasse. Specifically, bank records

reviewed by the FBI show that on January 7, 1993, just days prior

to flying to Jerusalem on January 13, 1993, Salah wrote a check

for $3,000 to Amer Haleem of QLI.11 They also show that on

January 12, 1993, the day before his departure, Salah withdrew an

additional $2,000 in cash from his account. The largest

withdrawal, of $200,000, was directed by Salah from Israel.

50. Salah has related to Israeli authorities that he

arrived in Jerusalem on January 14, 19 93 for the purpose of

meeting other HAMAS operatives to coordinate, among other things,

a terrorist attack against Israeli. Salah further related that

on January 19, 1993, subsequent to his initial round of meetings

with various HAMAS operatives, some of whom Salah met with

10
This is the same entity that transmitted a total of
$107,000 directly into Salah'a subject First Chicago account
through a series of three substantial wire transfers from Geneva
Switzerland between March and October of 1992. S_£J£ if 31.
11
Bank records reviewed by the FBI' also reveal that on
January 12, 1993, the day before Salah left Chicago for the
Middle East Zaki Hameed of QL.I executed check for $1,040 to
Salah's travel agent, Ghada Sharif.

28

r> -j » „ • , - ...

004043
 pursuant to Abu Marzook's instructions, he placed an

international call from Israel to his wife Azita in Chicago and

instructed her to wire $200,000.00 from their joint LaSalle Bank

account to First Chicago Bank of Ravenswood account number

678006002654-4 held in the name of Rihbe Abdel Rahman. According

to Salah, Rahman was an unlicensed money changer. Bank records

reviewed by- the FBI indicate that Azita Salah carried out her

husband's instructions on the same day. According to Salah the

t , $200,000.00 was then transferred from the Abdel Rahman account to

the Middle East.

51. According to bank records reviewed by the FBI, the

successful transfer of the $200,000.00 on January 20, 1993 was

closely followed by a succession of large wire transfers from

HAMAS-related sources into Mohammad and Azita's LaSalle Bank

account. Records from the Salahs' LaSalle Bank account and the

First American account of Elbarasse and Abu Marzook show that on

January 20, 1993, Elbarasse wire transferred $135,000 into the

Salahs' La Salle Bank account, and followed it with another wire

transfer of $300,000 on January 25, 1993.

52. Bank records for the First American Bank of Virginia

account held jointly by Abu Marzook and Elbarasse show a further

influx of overseas money just prior to this second round of wire

transfers to the Salahs' LaSalle Bank account. On January 4,

29

0ui256'
004044
 1993, a second $99,985 wire transfer was received into the First

American account from an individual named Gazi Abu Samah. On

January 22, 1993, the First American account was credited another

$665,000 from a wire transfer from Faisal Financial of Geneva

Switzerland.

53. FBI review of bank records alao show that during the

same period, Nasser Al-Khatib (Al-Khatib"), a United States-based

supporter and financial backer of HAMAS and close associate of

i_z. Abu Marzook, wire transferred additional funds into Salah-

controlled accounts in Chicago. In an interview with the FBI in

March of 1994, Al-Khatib acknowledged being a supporter of HAMAS,

and that he donated money to HAMAS causes. Al-Khatib further

related that prior to leaving the United States in June of 1993,

he was an employee of Abu Marzook, serving essentially as Abu

Marzook's personal secretary. In that capacity, Al-Khatib,

explained, he had access to and was a signatory to some of Abu

Marzook's financial accounts, and that he had made financial

transactions on Abu Marzook's behalf.12

54. A review of bank records reveals that on January 21,

12
A1-Khatib had previously written a check to Salah on
August 21, 1992, immediately prior to Salah's trip to Israel
during which he gave money to Salah Al-Arouri for the purchase of
arms for HAMAS military operations See. ^ 15-20. Bank records
indicate that the check was deposited by Salah into the subject
LaSalle Bank account that he jointly held with his wife, Azita.

30

001259
004045
 1993, Al-Khatib wired $50,000 into Salah's La Salle Bank account.

On the same day, he wired an additional $30,000 into Standard

Bank & Trust account number 2393288006-2 held jointly by Salah

and his wife. Standard Trust Bank records reflect that the wire

from Al-Khatib was credited in Azita Salah'a name. Al-Khatib

followed with a $170,000 wire transfer on January 22, 1993 into

the Salah's Standard Trust Bank account number 23 9328006-2.

55. On January 25, 1993, Salah was arrested by Israeli

military authorities. At the time of his arrest, he was found in

possession of $97,4 00. Salah also was in possession of extensive

notes he had compiled from his meetings with over 40 HAMAS

operatives and contacts in Israel and the occupied territories

over the preceding 11 days.

THF? REMAINING MONEY TRAIL

56. .Bank records show that on January 29, 1993 four days

after Mohammad Salah'a arrest by the Israelis, an unidentified

individual attempted to cash a check for $299,950, made payable

to Nasser Al-Khatib, purportedly executed by Salah and drawn from

the LaSalle Talman account he held jointly with his wife. LaSalle

Talman declined to clear the check when the unidentified

individual attempted to cash it. A cursory examination of a copy

of the check obtained from LaSalle Talman bank records indicates

that it was executed in handwriting that substantially differed

31

0012uO
004046
(\x%)
 from Mohammad Salah's handwriting appearing in checks and drafts

known to have been executed by Salah.

57. Bank records reviewed by the FBI further show that of

the $985,000 wire transferred into Salah's account in Between

December 29, 1992 and January 25, 1993, $723,541.18 was.

transferred out through the following•transactions. On February

1, 1993, Azita Salah withdrew $723,541.18 from the Salahs' two

accounts and deposited $717,041.18 into a new savings account,

r Standard Bank & Trust Account No. 56002850-0. Bank records for

the account show that Azita Salah then began to draw substantial

amounts of money

58. Standard Bank & Trust bank records for the account show

the following withdrawal-activity on April 2, 1993, $4,500.00 was

withdrawn from the account. On April 2, 1993, Azita Salah signed

a lease for Standard Bank & Trust safe deposit box No. 207. That

is the only day of any logged transactions for the box.

59. Bank records further reflect that on April 6, 1993,

o
Azita Salah transferred $97,067.93 from the account to pay the

outstanding balance of the Salahs' mortgage on their 9229 S.

Thomas, Bridgeview, Illinois residence.

60. In a subsequent interview with the FBI, Azita Salah,

accompanied by counsel, stated that she believed the money placed

into the joint LaSalle Bank and Standard Bank & Trust accounts
32

001261
. j 004047
 she held with her husband was intended for distribution by her

husband to charitable organizations overseas. However, Azita

Salah stated that she decided to keep the money herself after her

husband was arrested in Israel. Aizita Salah further stated that

she transferred the money into a new account because she feared

the United States Government might attempt to take it.

61. On February 10, 1995, the Office of Foreign Asset

Control, U.S. Department of Treasury, having reason to believe

that Mohammad Salah acted on behalf of an organization (HAMAS)

designated by U.S. President William J. Clinton, in Executive

Order 12947, as a terrorist organisation threatening to disrupt

the Middle East Peace Process, ordered the freeze of all of

Mohammad and Azita Salah's known bank accounts containing

$372,572.39.

62. Among the accounts frozen by the order was Azita

Salah'a Standard Bank & Trust savings account number 56002850-0

which she had opened on February 1, 1993 with $717,041.18 in

- ' funds internationally wire transferred to Mohammad Salah for

HAMAS purposes. Standard Bank & Trust personnel informed the FBI

that after the account was frozen, Standard Bank & Trust

transferred the funds in the account into a new account, Standard

Bank & Trust Account No. 560249500-3. On March 31, 1995, those

funds, totaling $233,973.00, were in turn, transferred to a

33
 Standard Bank & Trust certificate of deposit account, which has

been periodically renewed every six months, the remainder of

which presently is held in Standard Bank & Trust • Account No.

5580349268, Since the transfer to a certificate of deposit

account, the Office of Foreign Asset Control has, on a monthly

basis, licensed withdrawal of a living stipend from the

certificate of deposit account to Azita Salah. On a monthly

basis Azita Salah has deposited the living stipend into Standard

Ci^ Bank & Trust Account No. 23 9328806 for subsequent use.

63. Bank records show that on July 9, 1993, a certified

check debited from Golden Marble's Account Number 60609146 (at

the Midland Federal Savings & Loan Association) was drawn and

made payable to the QLI in the amount of $169, 000." On

September 24, 1993, that check was deposited into the QLI

Building Fund Account, #0010930021133, at the Midland Federal

Savings & Loan Assoc. As of December, 1997, the $169,000 plus

interest of approximately $25,000 was in the account. According

to bank records, the $169,000 deposit is the only transaction to

have taken place in this account.

64. One June 30, 1994, the Woodridge property was sold, by

the QLI, for $1,050,000. The net proceeds of $988,500 were

" According to Tamer Al-Rafai, the $169,000 check was

payment for a one year lease extension on the Woodridge property
negotiated between QLI and Golden Marble.

34

oj«as3
 deposited directly into the QLI General Fund Account #12310153 at

the First National Bank of Chicago. Since the deposit of the

land sale proceeds, the account has been maintained with a

balance at all times in excess of $&20,000, the amount that was

initially transmitted .by Saudi corporation Kadi International in

July of 1991 for the purchase of the Woodridge site. At present,

the account, which is merely a simple interest bearing checking

account, has a balance of approximately $875,3 00.54

r 65. A review of bank records reveals that since the deposit

of the land sale proceeds into the QLI General Fund Account, QLI

has only intermittently transacted business from the account.

66- One of the transactions made from the account was the

execution of a check dated October 21, 1996, by QLI Treasure

Abraham Abusharif, in the amount of $25,112.40 and made payable

to Hawklnson Ford Co. 6100 West 95th Street, Oak Lawn, Illinois,

for the purchase outright of a 1997 Ford Club Wagon XLT, VIN:

1FBJS31LXVHA4 0 60 8. On May 22, 1997, QLI returned the vehicle to

v
" Hawkinson Ford due to mechanical problems covered under warranty,

and was given a replacement vehicle, a grey 1997 Ford Van E35,

VIN: 1FBJS31L3VHB70844, which QLI currently owns and possesses.

67. Shortly after Mohammad Salah's return to the Chicago

area after having served his Israeli-imposed prison term for his

involvement with HAMAS, QLI transferred money from the General

35

ftZS
 Fund Account. Specifically, on February 2, 1998, $50,000 was

withdrawn from the account and transferred into First National

Bank of Evergreen Park Account No. 1412446, held in the name of

The Quranic Literacy Institute, which was opened by Zaki Hammed

and Abusharif.

CONCLUSION

68. Based on the preceding information, there is sufficient

probable cause to believe that the QLI funds in First National

^ Bank of Chicago account number 12310153, QLI funds in First

National Bank of Evergreen Park account number 1412446, and One

1997 E35 Ford Van, VIN: 1FBJS31L3VHB70844, are funds involved in

financial transactions or property traceable to transactions in

violation of the Money Laundering Statute, 18 U.S.C. § 1956.

These assets were derived from an $820,000 wire transfer from

Yasain Kadi in Saudi Arabia to Golden Marble, Inc., for the.

purchase of the Woodridge property, which was subsequently sold

for $1,050,000 with the net proceeds of $988,500 deposited into

" " the subject account. The illegally transferred funds also were

used to generate income (in the form of rent and sales profits)

to facilitate the activities- of Mohammad Salah and others in the

HAMAS conspiracy involving past and continuing violent terrorist

attacks, including the extortion, kidnaping and murder of and

against the citizens and government of the State of Israel, in

36

GJite
fiS)
 furtherance of HAMAS' publicly declared goala of undermining the

Israeli-Palestinian peace process, and forcing the State and

citizens of Israel to cede physical and political control and

dominion over the lands comprising Israel and the occupied

territories.

The foregoing defendant funds and vehicle also represent the

proceeds of monetary transactions in excess of $10,000 with the

illegally transferred funds, in violation of 18 U.S.C. § 1957,

thereby rendering the defendant funds and vehicle forfeitable

pursuant to 18 U.S.C. § 981.

69. Based on the preceding information, there is probable

cause to believe that the QLI-held funds in Midland Federal

Savings & Loan account number 0010 930 02113 are funds involved in

or traceable to financial transactions in violation of the Money

Laundering Statute, 18, U . S . C , § 195 6 (a) (2), and are therefore

subject to civil forfeiture pursuant to Title 18, U.S.C. §

981(a)(1)(A). The' subject funds are rents collected by QLI from

Golden Marble pursuant to the terms of the Lease and Sales

Agreement for the Woodridge property. As such these funds were

derived from the $820,000 wire illegally transferred from- Saudi

Arabia by Yassin Kadi of Kadi International with the intent of

generating income for the use of Mohammad Salah and others in the

HAMAS conspiracy involving past and continuing violent terrorist

37

([&). ° 04052
 attacks, including the extortion, kidnaping and murder of and

against the citizens and government of the State of Israel, in

furtherance of HAMAS' publicly declared goals of undermining the

Israeli-Palestinian peace process and forcing the State and

citizenB of Israel- to cede physical and political control and

dominion over the lands comprising Israel and the occupied

territories.

Additionally, the foregoing defendant funds also represent

s- the proceeds of monetary transactions in excess of $10,000 with,

the illegally transferred funds, in violation of 18 U.S.C. §

1957, thereby rendering the defendant funds and vehicle

forfeitable pursuant to 18 U.S.C. § 9ai.

70. The funds in the Salahs' bank accounts--Standard Bank &

Trust Account Number 5580349268 and Account Number 239328806;

LaSalle Bank, F.S.B. Account Number 022034532; First National

Bank of Chicago Account Number 8060700, (each of which is

currently frozen pursuant to order of the Office of Foreign Asset

Control, U.S. Department of Treasury, as authorized under

Executive Order 12 94 7 and based on reason to believe that

Mohammad Salah acted on behalf of and in concert with the HAMAS

terrorist organization) ; Standard Bank & Trust Safe Deposit Box

Number 207; and Standard Bank & Trust Safe Deposit Box Number

4019, were involved in financial transactions in violation of the

38

_ 0012*7
004053
Q^i)
 Money Laundering Statute, 18 U.S.C. § 1956{a){2). The subject

funds are moneys transferred, or traceable to moneys transferred

from outside the United States, into the United States, with the

intent of supporting HAMAS in the commission of specified

unlawful activity, involving extortion, kidnaping and murder of

and against the citizens and government of the State of Israel,

in furtherance of HAMAS' publicly declared goals of undermining

the Israeli-Palestinian peace process and forcing the State and

.- . citizens of Israel to cede physical and political control and

dominion over the lands comprising Israel and the occupied

territories. The subject funds are therefore subject to civil

forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A). The subject

funds were deposited via wire transfers from Ismail Selim

Elbaraase & Abu Marzook's joint bank account in McLean, Virginia,

and from Nasser Al-Khatib, which, in turn, had been deposited via

wire transfers from Geneva, Switzerland and Dubai, U.A.E. No

other legitimate source of income has been determined to exist

for either Mohammad or Azita Salah to account for their

possession of these funds.

71. There is probable cause to believe that the real

property commonly referred to aa 9229 S. Thomas, Bridgeview,

Illinois with the legal description:

Lot 5 in Mosque Foundation and Center

39

004054
 Area, Subdivision of part of the
Southeast quarter of Section 1, Township
3 7 North, Range 12, East of the Third
Principal Meridian, in Cook County,
Illinois. PIN 23-01-404-012.

was acquired through, and constitutes the proceeds of bank fraud

in violation of 18 U.S.C. § 1014, and therefore is-forfeitable

pursuant to 18, U.S.C. § 981{a)(1)(C). The subject property,

(which is currently frozen pursuant to order of the Office of •

Foreign Asset Control, U.S. Department of Treasury, as authorized

^--, under Executive Order- 12947 and based on reason to believe that

Mohammad Salah acted on behalf of and in concert with the HAMAS

terrorist organization), was acquired by the Salahs through a

residential mortgage loan obtained from Standard Bank. & Trust of

Evergreen Park, Illinois based upon false information provided to

the bank by Mohammad Salah in the form of false claims regarding

his employment relationship with QLI and falsified federal tax

returns.

Additionally, the mortgage loan was paid with funds

transferred into the United States from abroad with the intention

that they be used to support HAMAS domestic and international

• terrorist activities, including the extortion, kidnaping and

murder of and against the citizens and government of the State of

Israel in furtherance of HAMAS' publicly declared goals of

undermining the Israeli-Palestinian peace process, and forcing

40

C Olgp 9
 the State and citizens of Israel to cede physical and political

control and dominion over the lands comprising Israel and the

occupied territories, thus rendering the house property traceable

to moneys transferred in violation of the money laundering

statute, 18 U.S.C. § 1956{a)(2), and therefore forfeitable

pursuant to 18 U.S.C. § 981. Additionally, the purchase of the

property constitutes a monetary transaction valued in excess of

$10,000 with proceeds of a violation of 18 U.S.C. § 1956(a)(2),

e in violation of 18 U.S.C. § 1957, thereby rendering the property

41

(so) Qdfc2'?«i
forfeitable pursuant to 18 U.S.C. § 981.

Special Agent Robert Wright

Federal Bureau of Investigation

SUBSCRIBED and SWORN to before me

this 9th day of JjAmr*T9"9"8-=r--

United States Magistrate Judge

42

004057
 L277/2S

COMMISSION REGULATION (EC) No 2062/2001

of 19 October 2001
amending, for the third time, Council Regulation (EC) No 467/2001 prohibiting the export of
certain goods and services to Afghanistan, strengthening the flight ban and extending the freeze of
funds and other financial resources in respect of the Taliban of Afghanistan and repealing
Regulation (EC) No 337/2000

THE COMMISSION OF THE EUROPEAN COMMUNITIES. RABITA TRUST, Room 9A, Second Floor; Wahdat Road,
Education Town, Lahore, Pakistan. Wares Colony, Lahore, Paki-
Having regard to the Treaty establishing the European stan
Community,
Individuals (25):
Having regard lo Council Regulation (EC) No 467/2001 of 6
March 2001 prohibiting the export of certain goods and AGHA, Haji Abdul Manan (aka SAIYID, Abd Al-Manam), Paki-
services to Afghanistan, strengthening the flight ban and stan
extending the freeze of funds and other financial resources in
respect of the Taliban of Afghanistan and repealing Regulation AL-HAMATi, Muhammad (aka AL-AHDAL, Mohammad
-«s& (EQ No 3 37/2000 ('). as last amended by Commission Reguia- Hamdi Sadiq: aka AL-MAKX1. Abu Asim], Yemen
^ — on (EQ No 1996/2001 (*), and in particular Article 10(1),
second indent, thereof. AL-HAQ, Amin (aka AMIN, Muhammad; aka AH ' \Q, Dr
Amm; aka LJL-HAQ, Dr Amin); bom 1 960, Nangaha- 'rovincc,
Whereas
Afghanistan
(1) Article 10 of Regulation (EQ No 467/2001 empowers
AL-JADAW], Saqarr born 1965
the Commission to amend Annex I on the basis of
determinations by either the United Nations Security
AL-KADR, Ahmad Said (aka AL-KANADI, JU Abd
Council or the Taliban Sanctions Committee.
A1-Rahman), bom 1.3.1948, Cairo, Egypt
(2) Annex I to Regulation (EC) No 467/2001 lays down die
list of persons and entities covered by the freeze of AL-QAD1. Yasm (aka KADI, Shaykh Yassin Ah Jlah. ak
funds under that Regulation KAHDI, Yasin). Jeddah, Saudi Arabia

(3J On 17 October 2001 the Taliban Sanctions Committee AL-SHARJF, Sad, bom 1969. Saudi Arabia
determined to amend the list of persons and entities to
whom the freeze of funds shall apply and therefore BrN MARWAN. Bilal; bom 1947
Annex I should be amended accordingly.
BEN MUHAMMAD, Ayadi Chafiq (aka AYADI SHAF1Q. Ben
Muhammad, aka AYADI CHAFIK. Ben Muhammad. ..ka AIADI,
Ben Muhammad- aka AFADY, Ben Muhammad), He.ene Meyer

c HAS ADOPTED THIS REGULATION Ring 10-1415-80809. Munich, Germany; 129 Park Road,
London NW8. England; 28 Chausse D) Lille, Moscron, Belgium.
Darvingasse 1/2/58-60. Vienna, Austria, Tunisia; bom
Anide 1 21 1 196 3. Safais (SfixJ, Tunisia
The following persons and entities shall be added to Annex !
DARKAZANLI, Mamoun. Uhcnhorser Weg 34, Haburg, 2085
Regulation (EQ No 467/2001
Germany; bom 4.8.1958, Aleppo, Syna Passport No
Entities (6J- 1310636262 (Germany)

AL-HAMATJ SWEETS BAKERJES, Ai-Mukallah, Hadhramawt HIJAZI. Riad (aka HIJAZ1. Raed M aka AL-HAWEN, Abu-
Govcmoraic, Yemen Ahmad, alci ALMAGHRIB1, Rashid (The Moroccan), aka AL-
AL-NUR HONEY PRESS SHOPS (aka AL-NUR HONEY AMRIK1, Abu-Ahmad (The American), aka AL- SHAH1D, Abu-
CENTER) Sanaa. Yemen Ahmad), Jordan, born 1968. California, USA; SSN 548-91-
5417
AL-SHIFA HONEY PRESS FOR INDUSTRY AND COMMERCE,
PO Box S089, Al-Hasabah. Sanaa, Yemen; By the Shnne Next LADEHYANOY. Mufti Rashid Ahmad (aka LUDHIANV1, ML
to the Gas Scation, Jamal Street, Taiz, Yemen, AI-Arudh Square. Rashid Ahmad, aka AHMAD, Mufti Rajiheed; aka WAL*
Khur Maksar, Aden, Yemen, Al-Nasr Street, Doha, Qatar HYANOY. Mufti Rashid Ahmad), Karachi, Pakistan
JAJSH-I-MOHAMMED (aka ARMY OF MOHAMMED), Pakistan
UTHMAN, Omar Mahmoud (aka AL-FILISTINi, Abu Qatai
AMYAH TAAWUN AL-1SLAMIA (aka. SOCIETY OF ISLAMIC aka TAKFIRJ. Abu Umr; aka ABU UMAR, Abu Omar; 3
COOPERATION, aka JAMIYAT AL TAAWUN AL 1SLAMIYYA. UTHMAN, Al-Samman. aka UMAR, Abu Umar; aka UTHMA
ala. JIT), Qandahar City, Afghanistan Umar, aka ABU ISMAIL], London, England, born 30.12 19
or 1312 1960
V) UJ L 6/. S J.ZCJUi p [
ft Oj L 271 12 10 2001 p 21 YULDASHEV, Tohir (aka YULDASHEV, Takhir). Ugfjejjgg
 • juuuidj 01 me European Communities 20.10.2001

ZIA, Mohammad ( a b ZIA, Ahmad); c/o Ahmed Shah i/o FAZUL. Haroon; aka FAZUL. Harun; a b HAROON; a b
Painda Mohammad al-Kanm Set. Peshawar, Pakistan; c/o Alarn HAROUN, Fadhil: aka HARUNr aka LUQMAN. Abu; aka
General Store Shop 17. Awami Market. Peshawar, Pakistan; c/o MOHAMMED, fazul; aka MOHAMMED, Fazul Abdilahi; ska
Zahir Shah j/o Murad Khan Ander Sher, Peshawar, Pakistan MOHAMMED, Fouad; aka MUHAMAD, Fadil Abdallah); bom
Abdullah Ahmed Abdullah (aka ABU MARJAM; aka AL- 25.8.1972 or 25.12.1974 or 25.2.1974. Moroni, Comoros
MASRJ, Abu Mohamed; a b SALEH], Afghanistan: bora 196J, Islands; citizen Comoros or citizen Kenya (individual)
Egypt; citizen Egypt [individual)
Mustafa Mohamed Fadhil (aka AL MASRI, Abd AJ Wakil; aka
Muhsin Musa Marwalh Atwah (aka ABDEL RAHMAN; a b AL-NUBI, Abu; aka ALi. Hassan; a b ANIS, Abu; aka ELBISHY.
ABDUL RAHMAN; aka AL-MUHAJ1R. Abdul Rahman; aka AL- Moustafa Ali; aka FADtL. Mustafa Muhamad; a b FAZUL,
NAMER. Mohammed K.A.), Afghanistan; bora 19.6.1964, Mustafa, aka HUSSEIN; aka JIHAD, Abu; aka KHAUQ; aka
Egypt; citizen Egjpt (individual) MAN. Nu; aka MOHAMMED. Mustafa; aka YUSSRR, Abu);
Anas al-Liby ( a b AL-LIBI. Anas; aka AL-RAGHIE. Nazih; aka bom 23.6.1976, Cairo, Egypt; citizen Egypt or citizen Kenya;
ALRAGHiE. Nazih Abdul Hamed: a b AL-SABAI, Anas). Afgha- Kenyan ID No 12773667; serial No 201735161 (Individual)
nistan; born 30.3.1964 or 14.5 1964, Tripoli, Libya: citizen
Libya (individual) Sheikh Ahmed Salim Swcdaxi {aka Ahmed the Tall: * b ALLY.
Ahmed; aka BAHAMAD; aka BAHAMAD, Sheik; a b BAHA-
Ahmed Khalfan Ghailani ( a b AHMED THE TANZANIAN; aka MADI, Sheikh; a b SUWHDAN, Sheikh Ahmad Salem; aka
FOOP1& a b FUP1; a b AHMAD, Abu Bakr a b AHMED. A; SWEDAN, Sheikh: aka SWEDAN. 5h«kh Ahmed Salem); bora
aka AHMED. Abubabr; a b AHMED, Abubabr K.: slfca 9.4.1969 or 9.4.1960, Mombasa, Kenya; emzen Kenya (indi-
AHMED, Ah ibabr Khalfan; a b AHMED, Abubabry K.: a b vidual)
AHMED, V.r.ned Khajfan; aka AL TANZAN), Ahmad; a b ALf,
Khmed K' i /an: a b BAKR. Abu; a b GHAlLANr. Abubakary Fahid Mohammed Ally Msalam (aka AL-K1NI, Usama, aka
Khalfan , --ied; a b GHAJLANt, Ahmed; a b GH1LANI, ALLY. Fahid Mohammed; ika MSALAM, Fahad AJly; aka
Ahmad Kl 'an; a b HUSSEIN. Mahafudh Abubabr Ahmed MSALAM. Fahid Mohammed Ali: a b MSALAM. Mohammed
Abdallah, KHABAR. Abu; aka KHALFAN, Ahmed; a b Ally; a b MUSALAAM. Fahid Mohammed Ali; aka SALEM.
,V JHAMk ShanfF Omar); born 14.3.1974 or 13.4.1974 or Fahid Muhamad Ali); bom 19.2.1976, Mombasa, Kenya; citizen
•M.I 974 1.8.1970, Zanzibar, Tanzania; citizen Tanzania Kenya (individual)
• individual)
Abdul Rahman Yasin ( a b TAHA. Abdul Rahman S.; aka
\hmed M -nmed Hamcd Ali (aka ABDUREHMAN. Ahmed TAHER. Abdul Rahman S.; aka YASIN, Abdul Rahman Said;
Uohammt va ABU FAT1MA; aka ABU ISLAM: a b ABU aka YASIN, Aboud); bora 10.4.1960, Bloomington, Indiana
KHADIIJA •>d AHMED HAMED; aka Ahmed The Egyptian; USA; SSN 156-92-9858 (USA); passport No 27082171 (USA
aka AHMi .hmed; a b AL-MASR1, Ahmad: a b AL-SUR1R. (issued 21.6 1992 in Amman, Jordan) or passport No
\ b u Islarr - ALI, Ahmed Mohammed; a b ALI. Hamed; a b M0887925 (Iraq); citizen USA (individual)
HEMED, d, a b SHIEB. Ahmed; a b SHUAIB), Afghani-
stan: bon '5, Egypt: citizen Egypt (individual)
Fazuf Ar n Mohammed ( a b ABDALLA, Fazul; a b Ankle 2
•ADBALL j-/.ul; a b A1SHA, Abu: a b AL SUDANI, Abu
Seu .: niel Abdailah Mohammed; a b FAZUL. Abdalla: This Regulation shall enter into force on the day of its publiua-
aka FAi. -Jallah; a b FAZUL. Abdallah Mohammed; aka tion in rhe Official Journal of the European Lommuniucs.

This Regulation shall be binding in its entirety and directly applicable in all Member States
t }
Done ai Brussels. 19 October 2001

For the Commission

Christopher PATTEN
Member of the Commission

b 013*273