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HOUSE_OVERSIGHT_023396

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In re: TERRORIST ATTACKS ON SEPTEMBER 11, 2001., 2012 WL 257568 (2012) office in Washington, DC, and he was reported to have “major investments” in Bank Al-Taqwa, a notorious Specially Designated Global Terrorist. JA3125-26, 3146. Dallah al Baraka “is a shareholder of Aqsa Islamic Bank, a bank that Israel has refused to approve, ‘citing obvious ties with known terrorists.’ ” SPA60 (Terrorist Attacks I). Both Saleh Abdullah Kamel and Al Rajhi Bank’s chairman and managing director, Suleiman Abdel Aziz al Rajhi, are alleged to have been identified in the “Golden Chain” document as one of al-Qaeda’s principal financiers. JA3164, 3866-67, 3869-70; see also supra pp. 56-60. United States intelligence agencies concluded that the seized materials were authentic al-Qaeda documents that chronicle the formation of al-Qaeda, detail its financial and organizational structure, and identify al-Qaeda’s most important financial benefactors and the individuals responsible for coordinating their contributions. See supra at pp. 54-55 nn.85-86. Jamal al *108 Fadl, a senior al-Qaeda official who defected and became a cooperating witness for the United States, has authenticated the Golden Chain document. See supra at 55 n.86. The Treasury Department has used inclusion on that list as a basis for designating individuals as terrorist sponsors and for freezing their assets under Executive Order 13224. Id. The Golden Chain has been relied upon by the United States as an exhibit in multiple criminal cases. See supra at pp. 54-55 nn.85-86. And, the 9/11 Commission’s Final Report also relied upon the Golden Chain. See supra pp. 25-26 &n.8. These allegations, taken together, detail an extensive relationship between the defendants and al-Qaeda, giving rise to a reasonable inference that the defendants’ provision of material support to al-Qaeda was knowing or, at the very least, reckless. The reasonableness of this inference is supported by the D.C. Circuit’s judicial review of habeas petitions bro

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