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Categories of Documents Relevant to Responsibility for the Events of

1 Documents pertaining to the involvement of Saudi religious institutions
sponsored by the Saudi government in supporting al Qaeda. The 9/11
Commission acknowledged in its Report the likelihood that charities
with significant Saudi government sponsorship diverted funds to al
Qaeda. The 9/11 Commission Staff Monograph on Terrorist Financing
stated that al Qaeda was funded to the tune of $30 million a year by
diversions from such Islamic charities and well-placed financial
facilitators in the Gulf. Various US agencies have elsewhere confirmed
the critical role of Saudi charities with significant ties to the Saudi
government in providing funding and various forms of other assistance
to al Qaeda. In view of these findings, the United States should
release, to the fullest extent possible, records relating to the
involvement of Saudi-based Islamic charities and their branch offices in
the financing and sponsorship of al Qaeda in the years prior to
September 11, 2001, and records describing the relationships between
such institutions and the Saudi government. The declassification
review should encompass records pertaining to the Muslim World
League, International Islamic Relief Organization, Al Haramain Islamic
Foundation, World Assembly of Muslim Youth, Saudi High Commission
for Relief of Bosnia & Herzegovina, Saudi Joint Relief Committee for
Kosovo & Chechnya, Saudi Red Crescent Society, Al Haramain al Masjid
al Aqsa, Muwafaq Foundation, and Benevolence International
The relevance and significance of these records is illustrated by the
limited publicly available information concerning Al Haramain Islamic
Foundation, a Wahhabi proselytizing organization described by the
United States as one of the principal Islamic [organizations] providing
support for the al Qaida network and promoting militant Islamic
doctrine worldwide. Echoing those statements, a senior Saudi official
recently said that al Haramain was notoriously tied to Osama bin
Laden, the Taliban and Al Qaedas terror campaigns.
There is, meanwhile, compelling evidence that the Saudi government
and Saudi officials were directly involved in al Haramains terrorist
activities, an issue central to the claims we have brought against the
Saudi Kingdom. In fact, al Haramain itself asserted in an affidavit filed
in our lawsuit that it operates under the supervision of the Saudi
Minister of Islamic Affairs, who appoints its Board of Directors and
senior management personnel. The 9/11 Commission Staff Monograph
on Terrorist Financing, in turn, explained that al Haramain has
considerable ties to the Saudi government. Two government ministers
have supervisory roles (nominal or otherwise) over al Haramain, and

there is some evidence that low-level Saudi officials had substantial

influence over various [al Haramain] offices outside of Saudi Arabia.
The Saudi government has also historically provided financial support
to al Haramain.
As part of our case against the Kingdom, we sought to develop further
evidence about al Haramains ties to the Saudi government and al
Qaeda through FOIA requests to relevant federal agencies, including
the Treasury Department, which had formally designated all of al
Haramains offices between 2002 and 2004. Despite al Haramains
formal designation and the fact that it was no longer operating,
Treasury withheld 632 out of 681 responsive pages in full, and broadly
redacted 45 of the remaining pages. The 4 pages that were produced
without redactions consisted of the Treasury Department press release
announcing al Haramains designation. The other federal agencies
from which we sought information about al Haramain took the same
approach, leaving us (and the public) without the benefit of any of the
evidence in the possession of the United States.
2 Documents concerning further investigations of the transactions,
relationships, and issues discussed in the so-called 28 pages of the
Joint Inquiry Report. Various Administration officials have indicated in
recent statements that all of the subjects discussed in the classified
pages of the Joint Inquiry Report were the subject of further
investigations by the 9/11 Commission and various executive branch
and law enforcement agencies. Some Administration officials have
suggested without reference to any details that those further
investigations cast doubt on aspects of the so-called 28 pages. For
obvious reasons, the 9/11 families and American public should not be
left to debate the content and import of the 28 pages without the
benefit of the records pertaining to these additional investigations.
3 Other Records of the 9/11 Commission. In an August 20, 2004 letter to
the National Archivist, the 9/11 Commission urged that all of its records
be made publicly available, to the greatest extent possible, by January
2, 2009. More than seven years after that target date, the bulk of the
Commissions records have not been processed for declassification at
all, and the limited records that have been released are in many cases
so heavily-redacted as to be of little use to the American public. This
over-redaction problem is especially prevalent in records relating to
sources of funding and support for al Qaeda. Any meaningful effort to
promote transparency as to the root causes of the tragic events of
September 11, 2001 must address these problems, and provide for the
prompt review and declassification of all of the 9/11 Commissions
records, to include reconsideration of the scope of redactions of
previously released documents. Records pertaining to al Qaedas

sources of support and possible sources of assistance to the 9/11

hijackers and plotters are appropriate candidates for prioritization.
4 Documents relating to the activities, interactions, relationships,
contacts, and financial transactions of the 9/11 hijackers in the United
States. The 9/11 hijackers traveled throughout the United States and
spent time in a variety of locations prior to the September 11th attacks,
including California, Oklahoma, Virginia, Florida and elsewhere. Much
attention has focused on the investigations of the activities of two of
the hijackers, Khalid al Mihdhar and Nawaf al Hazmi, in California, and
some (but certainly not all) of the records pertaining to those
investigations have been released, in part. However, very little
information has been provided concerning the activities of the
hijackers in other locations. There can be no doubt that law
enforcement agencies thoroughly investigated in painstaking detail the
activities of the hijackers in every location they visited, as part of their
efforts to protect the homeland and identify other potential threats
within the United States following the attacks. Indeed, a federal judge
in Florida is currently reviewing 80,000 pages of FBI records relating
investigations of 9/11 hijackers in Florida, which were never provided
to the 9/11 Commission or Congressional Joint Inquiry and were
disclosed by the FBI only as a result of a Freedom of Information Act
lawsuit. The full spectrum of records pertaining to investigations of the
hijackers activities in the United States, and any persons with whom
they may have interacted, should be slated for prompt declassification.
5 Documents pertaining to al Qaedas wealthy Gulf donors. The United
States has in various settings confirmed that contributions from
wealthy Gulf donors sympathetic to bin Ladens cause enabled bin
Laden to build and sustain his terrorist organization and carry out the
9/11 attacks. In this regard, one heavily redacted CIA Report entitled
Saudi-Based Financial Support For Terrorist Organizations, dated
November 14, 2002, confirms that Saudi Arabia is a key base of
financial support for al-Qaida and that Most of the money comes
from wealthy individuals, fundraisers who solicit smaller donations, and
diversions from [alleged] non-governmental organizations. However,
in that report and others detailing Saudi sources of support for al
Qaeda, the identities of the wealthy financiers and businesses that
supported al Qaeda have been redacted wholesale, immunizing parties
culpable for the murder of thousands of American citizens on 9/11 from
accountability for their actions. The protection of the identities of
these al Qaeda financiers persists despite the consistent claims by the
United States in federal court and elsewhere that holding terrorist
supporters accountable for their actions through civil litigation serves
our national security by depriving terrorists of funds and deterring the
sponsorship of terrorism. Indeed, deputy Secretary of State Tony

Blinken affirmed just last year in an affidavit filed in federal court that
Imposing civil liability on those who commit or sponsor acts of
terrorism is an important means of deterring and defeating terrorist
activity. Of course, civil liability cannot be imposed on such terror
sponsors if the United States itself shrouds their identities and
classifies all records pertaining to their conduct.
6 Documents concerning support for al Qaeda by Islamic banks and
financial institutions. U.S. officials and independent experts have also
indicated that al Qaeda had knowing benefactors in the financial
industry. For instance, the Wall Street Journal published a lengthy
report in 2007, titled U.S. Tracks Saudi Bank Favored by Extremists,
concerning U.S. investigations of the Saudi-based Al Rajhi Bank. The
report cited U.S. intelligence reports and included excerpts from those
reports, and indicated that U.S. officials debated the possibility of
formally designating the bank. Although the Wall Street Journal had
been afforded access to the intelligence reports, the CIA asserted in
response to the 9/11 families subsequent FOIA request for those
precise records that the CIA can neither confirm nor deny the
existence or nonexistence of records responsive to your request. It is
hard to imagine the legitimacy of this response given that the records
in issue had previously been shared with the Wall Street Journal. In any
case, records pertaining to investigations of the involvement of Saudi
or Gulf based Islamic banks or financial institutions in providing
support to al Qaeda should be designated for expedited
declassification review, including any such records concerning Al Rajhi
Bank, National Commercial Banks, Saudi American Bank, Dubai Islamic
Bank, al Shamal Islamic Bank, Faisal Finance, and Al Baraka.
7 Documents Relating to the Kingdom of Saudi Arabias Efforts to
Promote Wahhabi Islam and Relationship Between Those Efforts and
Terrorist Activity, Fundraising, and Recruitment. It is undisputed that
the Kingdom of Saudi Arabia has spent enormous sums to propagate
the Wahhabi variant of Islam globally. Much of this proselytizing
activity has been undertaken under the auspices of the Kingdoms
Ministry of Islamic Affairs and Islamic charities sponsored and
supported by the Kingdom. The 9/11 Commission and numerous U.S.
officials have confirmed the nexus between the Kingdoms vast efforts
to propagate the Wahhabi variant of Islam and rise of terrorist
organizations like al Qaeda, and confirmed that al Qaeda and other
terrorist organizations have benefitted in myriad ways from the
Kingdoms efforts to promote Wahhabism.
Records discussing the nexus between the Kingdoms proselytizing
activities and the emergence of terrorist groups like al Qaeda and ISIS
are of vital importance to understanding the events of 9/11 and many

of the terrorist threats we are confronting today, and should be

released. These should include records pertaining to the involvement
of any persons associated with the Kingdoms Ministry of Islamic Affairs
in terrorist activities. Such records are especially pertinent, given that
individuals employed by the Islamic Affairs offices of the Saudi
embassies and consulates in the United States were implicated as
possibly having provided support to the 9/11 hijackers. The 9/11
families and American public cannot fairly evaluate the evidence
concerning the possible involvement of those individuals in providing
support for the hijackers without the benefit of the broader body of
evidence concerning ties between al Qaeda and elements of the
Ministry of Islamic Affairs generally. For obvious reasons, evidence of
broader collaborations between elements of the Ministry of Islamic
Affairs and al Qaeda will provide critical context for evaluating any
evidence of linkages between Islamic Affairs employees in the United
States and al Qaeda.
8 The Removal of Individuals Associated With the Islamic Affairs Offices
of the Kingdoms Embassies and Consulates in the United States. In
the aftermath of the September 11th attacks, the United States revoked
the diplomatic credentials individuals associated with the Islamic
Affairs offices of the Kingdoms embassies and consulates, as part of
what a U.S. law enforcement official said at the time was part of an
ongoing effort to protect the homeland. Reports indicate that as
many as 70 individuals with Saudi diplomatic credentials were sent
home via this process, including 16 individuals associated with the
Fairfax, Virginia based Institute for Islamic and Arabic Sciences in
America. It is believed that these individuals held credentials with the
Saudi embassy in Washington, D.C., employees of which have been
implicated in reports as possibly having provided support to the 9/11
hijackers. Documents relating to the investigations of these
individuals, and decision to revoke their diplomatic credentials and
remove them from the United States, should be declassified as soon as
9 Other Investigations of al Qaeda Attacks and Operations. The United
States has conducted investigations of numerous al Qaeda attacks and
plots, such as the so-called Bojinka Plot, the 1998 African Embassy
Bombings, and the Cole Attack, among others. The United States has
also conducted raids of safehouses of al Qaeda members and fronts,
such as the August, 1997 raid on the home of Wadih el Hage in Nairobi;
the September, 1998 raids on al Qaeda safehouses in London; the
Baku computer seized in Azerbaijan in 1998; the 2001 raid of the
Sarajevo offices of the Saudi High Commission for Relief of Bosnia &
Herzegovina (a Saudi government charity); and the raid on Osama bin

Ladens Abbottabad compound. The release of many of these records

also is long overdue.