which is why it is called RSA encryption. Any information you
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plaintiffs’ pleadings and supplemental materials allege that support for al-Qaeda’s agenda emanated
*49 siphoned off charitable donations to support al Qaeda
including its material sponsorship of al
” were themselves important al-Qaeda benefactors with direct ties to bin Laden dating from the
and because senior Al Rajhi Bank officials
again by virtue of the public reporting concerning the
Al Rajhi Bank was aware at all relevant times that MWL
Al Rajhi Bank funneled its own zakat contributions to al-Qaeda
Khaled bin Mahfouz and Yassin al Kadi are referred to here is ahe “NCB Defendants.”)
and by virtue of the longstanding ties between senior executives of NCB
by virtue of the extensive public reporting concerning those
with specific awareness that those entities were supporting al-Qaeda.® At all times
typically through their own zakat charitable contributions to al-Qaeda’s
al-Qaeda’s partners in the financial sector operated covertly within its global infrastructure
including an account for bin Laden’s personal bodyguard
partnered with al-Qaeda by mamtaining accounts for al-Qaeda and by embedding
*° Al Shamal maintained accounts for Osama bin Laden and several other al-Qaeda officials
Al Shamal *45 and FIBS are referred to herein as the