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Date:20/12/2022
Respected Attorney General Greetings.
Subject (Complaint and Report of Money Laundering
Crimes)
Complainant: Adnan Abdul Mohsen Ahmed Al-Tayyar for himself
and in his capacity as the owner of the International Business
Center Company for Stationery and Office Supply.
Defendants: Zain Group, Mobile Telecommunications Company
(Zain), Mr. Nabil bin Salama in his capacity as CEO of the
company, the Ministry of Communication, the Ministry of
Commerce and Industry, and the members of the private
telecommunications committees which were formed in 2013
until the date of filing the complaint.
The Facts
- The facts of this complaint and communication are summarized
in the fact that Zain Group and Mobile Telecommunications
Company (Zain) committing money laundering crimes repeatedly
and systematically in complicity basses with the Ministry of
communication and the Ministry of Commerce and Industry
which are criminalized by Law No. 35 of 2002 and Law No. 5 of
2006 Law No. 47 of 2006 and Law No. 106 of 2013, by which
Zain Group and Mobile Telecommunications Company (Zain) are
employing funds within local and foreign commercial
investments and financial investments by using several
currencies including the United States currency (US dollar),
among the most prominent of them were the phased
acquisitions of many telecommunications companies such as
Atheer and African telecommunications companies (document
97), knowing that these funds are obtained from the
committing of the forgery crimes of customary documents
namely the invoices of mobiles service subscribers, and from
the forgery crimes of official documents namely the companies’
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financial reports which are criminalized by the provisions of

Article 257, Article 258, and Article 259 of the Penal Code No. 16
of 1960, and from the committing of fraud crimes which are
criminalized under the provisions of Article 235 and Article 236 of
the Penal Code No. 16 of 1960, moreover, Zain Group and Mobile
Telecommunications Company (Zain) concluded the above-
mentioned committed crimes by selling the acquired companies
in order to falsify the real nature of the invested money which
was used in the acquisition operations by returning back the
money collected from the selling operation back to Kuwait and
showing the money collected from the selling operation in the
companies’ financial reports as an investment income, which
means that The Annual Financial Reports of Zain Group and
Mobile Telecommunications Company (Zain) are false
documents, one of the most prominent funds laundering
operations is the proceeds of the transaction that took place in
the African continent on June 8, 2010 using (US dollars) the
currency of the United States of America referred to in the
financial report of Mobile Telecommunications Company (Zain)
for the financial year ended 31/12/2010 under (Document 72),
which is the sale of Zain Africa for the amount of 10.7 billion US
dollars ((ten billion seven hundred m
illion). US Dollar)).
A detailed explanation of crime elements
First: Documents forgery Crimes.
Second: Commercial and financial investment operations.
Third: Fraud and money laundering crimes resulting from them.
Fourth: The elements of the participation of the Ministry of
communication and the Ministry of Commerce and Industry.
Fifth: Assault on the sanctity of public funds.
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Sixth: Humanitarian violations resulting from the crimes

committed.
Seventh: Literary fraud with fraudulent intent to win local and
international awards.

First: The Forgery Crimes

1- The Mobile Telecommunications Company (Zain) has
committed and is still committing the forgery crimes of the
invoices of mobile-phone service subscribers in Kuwait, by
which material false statements stated therein arise from
inflating the consumptions cost of the international calls as
well as the received roaming calls which are stated in the
invoices, with the intent to defraud the subscribers that the
invoice’s inflated costs are true costs, and collecting the
inflated cost from the subscribers knowingly that the invoices
are false.
The first way of committing the crimes: -
The Mobile Telecommunications Company (Zain) falsifies the
invoices of mobile service subscribers by using different false
calling rates to calculate the false consumption cost of the
international calls to several countries which are stated in the
invoices, by which the value of the false calling rate of any
country becomes more than the true calling rate by a
percentage value of the true calling rate of such country,
moreover, the company follows a well-studied policy in
determining the percentages' values which are used in the
falsification by making their amounts inversely proportional to
the amount of the real calling rate of the country (i.e. the
value of the percentage increases as the value of the true
calling rate decreases), I will give an illustrative example
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explaining the policy that was applied during the period of

validity of the real international calling rates included in the
Ministry of Communications resolution No. 108/2002
(document 1 1) and resolution No. 112/2004 (document 1 2)
as follows:
The Mobile Telecommunications Company (Zain) determined
a percentage value equal to 18% of the true international
calling rate of countries whose true international calling rate
value is equal to 0.500 (K.D per min) in order to falsify the true
international calling rate value of such countries as the calls to
china, therefore the false calling rate to china has become
equal to 0.590 (K.D per min) (doc 34), and the company
determined a percentage value that is equal to 20% of the real
international calling rate of countries whose true international
calling rate value is equal to 0.400 (K.D per min) in order to
falsify the true calling rate of these countries such as the calls
to Taiwan so that the false international calling rate to Taiwan
becomes equal to 0.480 (K.D per min) (doc 74), while the
company determined a percentage value that is equal to
23.33% of the true calling rates of countries whose true calling
rate value is equal to 0.300 (K.D per min) in order to falsify the
true calling rate of these countries such as Spain so that the
false international calling rate to Spain becomes equal to
0.370 (K.D per min) (doc 74), moreover, the company also
determined a percentage value that is equal to 50% of the
true calling rates of countries whose true calling rate value is
equal to 0.100 (K.D per min) in order to falsify the true calling
rates of these countries such as UAE and Saudi Arabia so that
the false international calling rate to these countries becomes
equal to 0.150 (K.D per min) (doc 86, 90).
(a) Table No. 1 (document 27) as well as the clarification of
the data of Table No. 1 within (document 26) clarifies the
crimes of the falsification of international calling rates of
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some countries in the invoices, which were committed

during the validity of the International calling rates
stipulated in the Ministry of Communications Resolution
No. 108/2002 (document 11) and Resolution No.
112/2004 (document 12).
(b) Table No. 2 (document 35) as well as the clarification of
the data of Table No. 2 within (document 36) clarifies the
crimes of the falsification of international calling rates of
some countries in the invoices, which were committed
during the validity of the International calling rates
stipulated in the Ministry of Communications Resolution
No. 505/2008 (Document 8).
(c) Table No. 6 (document 49) as well as the clarification of
the data of Table No. 6 within (document 91) clarifies the
crimes of the falsification of international calling rates of
some countries in the invoices, which were committed
during the validity of the International calling rates
stipulated in the Ministry of Communications Resolution
published in Al-Anba newspaper under edition No. 11404
(document 7) on 3/1/2008.
The second way of committing the crimes: -
The Mobile Telecommunications Company (Zain) falsifies the
false invoices of mobile service subscribers by increasing the
value of the percentage which was used previously to falsify
the international calling rates of countries once the ministry of
communication reduces the international calling rates of
calling world countries, as an example clarify the second way
of falsification that is the action exercised by the company
against the calls to china when the true international calling
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rates to china was equal to 0.500 (K.D per min) the company
was used 18% percent to falsify the true international calling
rates and once the ministry of communication reduced the
true international calling rates by 20%

Criminal intention element 1: The intentional desire to

commit the crimes could be inferred from the company's act
of applying the policy of the inverse relationship to determine
the values of the percentage used to falsify the true values of
the calling rates of the international calls by which the Mobile
Telecommunication Company had avoided the decrease in the
proceeds collected from forgery crimes that would have
arisen if the company had applied a fixed value of the
percentage to falsify all different international calls calling
rates, as such act necessitated the activity of studying
different alternatives to choose from then buying and running
a program which is consistence with the preferred policy.

2- Committed and committed by the Mobile Telecommunications

Company (Zain) CRaM Tzwi Customary those who to the, with
the intention of using them in a way that deludes subscribers
that they are identical to the truth by proving Incorrect billing dues for

both (international calls) (and received roaming calls) as correct

knowing that they are not valid in order to obtain their
money, and the means of changing the fact were by using
fraudulent calling charges to calculate the dues of
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international calls, where Increase the values of counterfeit

fees for countries with low-value international calling
charges from their real values specified in the decisions of the Ministry of
Transport by more than 5-0%, such as the UAE, Bahrain and
Saudi Arabia, and in order to see the details of the crimes of falsifying
invoices that includeeach of the amounts of fraudulent fees
that exceed the real fees by percentages of The real fees of some
countries, as well as the documents containing the forged

international telecommunications receivables and the places of

forgery in them for the same countries, and the amounts of
real fees specified in the decisions of the Ministry of Transport
in force during three different time periods for the countries
Three explanatory stories have been prepared in addition to an
explanatory explanation for each table according to those
time periods shown as follows:-
Knowledge and intent to commit the crime
It is notlimited to the existence of knowledge and intention of the mobile
telecommunications company (Zain) to commit crimes of forgery
of documents during their commission simply because it changed the
reality of international calling receivables with bills by using fees that exceed the amount of the real
international calling charges in the calculation of receivables despite its
the

knowledge of the real international calling rates specified in the

decisions of the Ministry of Transportation, but also Due to the
company's systematic criminal activity before initiating the
commission of crimes of falsification of invoices, the availability of the
elements of surveillance, persistence and the desire to increase the

proceeds of the crimes committed, andthis is evidenced by the

company's use of the leadingpercentages Different from the
value of real international calls to falsify international calling receivables
with invoices to countries by that the amounts of percentages are large
whenever the amount of the real international call fee for the countries subject to
forgery is small, and the smaller the amount of the real
international call fee in the place of forgery , the company uses a
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larger percentage than the previous one, As an illustrative

example, the company uses 18% of the real calling fee of KD 0.500 (KD per minute) such
as the State of China to falsify thosecharges so that the
international calling fee for China after forgery becomes 0.5 90
(KD per minute), while the company uses 23.33% of the real
calling fee of 0, 300 (KD per minute) such as the State of Spain to
falsify that anchorageso that the international connection fee for Spain after its
forgery becomes 0.37 (KD per minute), while the company uses 50% of the
real connection fee of 0.1 00 (KD per minute) ) such as the
countries of the UAE, Bahrain and Saudi Arabia to falsify these fees, so that
the international connection fee for the UAE, Bahrain and Saudi
Arabia after its forgery becomes 0.1 50 (KD per minute), which
confirms the availability of the elements of surveillance andscience with
the holding of The intention to commit traction through such
conduct, which is clearly and in detail demonstrated by comparing
the amounts of percentages used to falsify real international
calling receivables for a number of countries listed in column 4 of (Table 1)
with the real international calling rates of those States with different
international calling values from each other listed in column 3 of
(Table 1), which is This confirms the company's keenness to
increase the revenues obtained from committingforgery
whenever the real international call price of countries is low in
value.
This is also clearly and in detail by comparing the percentages
used to falsify international calling receivables for a number of
countries included in the data of column 4 of (Table 2) with the
real international calling rates of those countries included in the
data of column 3 of (Table 2).
- The availability of knowledge and intention to commit the
crime is also evidenced by the pursuit of another criminal activity by
the mobile telecommunications company (Zain) that reflects the

availability of the element of surveillance, determination and desire

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to increase the proceeds of the crimes committed, through the

company's monitoring of reductions in real international calling
rates on the one hand, As soon as the company becomes aware

that the Ministry of Transportation has issued decisions related to reducing

international calling fees between Kuwait and the countries of the world,

the company is working to change the amounts of percentages

of real international call rates that it used to falsify real international call

dues in bills. This is what happened on 3/1/2008 after the

issuance of the decision of the Ministry of Transport to reduce the international
connection fees between Kuwait and the countries of the world by 20% of the
international calling rates applied in that period (Document 7), and for

example, once the Ministry of Communications reduced the

international calling fee to China From KD 0.500 per minute to KD 0.4 00
per minute The company started the amount of the percentage from
18% to 20% of the real charges, as well as as as once the Ministry of
Transportation Resolution No. 505/2008 (Document 8) was issued,
once the Ministry of Transport reduced the price of international
calling to China from 0.4 KD 00 per minute to KD 0.21 0.0 per minute
The company has once again started increasing the percentage of China's real
international calling fee used to falsify China's international calling

receivables, increasing the percentage amount from 20 % to

31.42% of China's real charges. , as a result of the Company's surveillance
method prior to the commencement of document forgery crimes, the Company was able to

avoid a decrease in the proceeds of document forgery crimes

that it would have earned if it had maintained the use of the
same amount of percentage of real fees that it used for forgery
when the real China international calling rate was KD 0,500 per
minute, and Explanatory documents have been prepared, namely
Table 5 (Document 50) and Chart No. 2 (Document 52) which will
present the behavior of Mobile Telecommunications Company
(Zain) represented in surveillance,persistence and the desire to
continue committing a forgery crime. International call charges
to China and increase its financial revenue.
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It is possible to find more details of the criminal activity practiced by

Mobile Telecommunications Company (Zain) before the commission of
the crimes of falsification of international calling charges for several countries during

different time periods by comparing the amounts of percentages used in the

falsification of international calling receivables for a number of
countries included in the data of column 4 of Table 3 (Doc. 44).
) during the period to which the international call charges listed in the Ministry of Communications

Decision No. 108/2002 (Document 1 1) and Decision No. 112/2004 (Document 12) were applied,

together with the amounts of percentages used in the falsification of international

calling dues to the same countries, during the period after the
issuance of the Ministry of Communications' decision on
reducing international calling rates No. 505/2008 included in
the data of column 3 of Table No. 3 (Document 44).
3- The Mobile Telecommunications Company (Zain) also
committed crimes of forgery of official documents, namely bills of the
participation of mobile phones submitted to the judicial authorities in the
lawsuits filed by the Mobile Telecommunications Company
(Zain) against subscribers who failed to pay the company's bills
with the intention of using them in a way that deludes the
judicial authorities that they are identical to the truth by
proving incorrect dues in the documents for each of ( international
calls). ) (and received roaming calls) as the correct dues knowing that they are not
valid, and the telecommunications company (Zain) was able to
obtain several court rulings thatobligated subscribers to pay amounts to the
company in excess of the real calling dues thatthey owe to the

company.
4- Mobile Telecommunications Company (Zain) has also
repeatedly committed and is committing forgery of several
other graphic documents. The annual financial reports of Mobile
Telecommunications Company (Zain) submitted to the Ministry
of Commerce and Banks and the Kuwait Stock Exchange With
the intention of using them in a way that deludes them to be
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identical to the truth by proving incorrect data in the

documents as true data with knowledge of their incorrectness,
andthese data are each of the following:
First: Call revenues, which are the recurring revenues obtained
from the bills of customers subscribed to the mobile telephone
service, due to the company's inflating the volume of dues of both
(international calls) (and roaming calls received) in the
subscribers' bills, which was indicated by its facts . The
company in its annual financial reports within the paragraphs (call revenue)
including, but not limited to, the call revenue data included in
the company's financial reports within the documents
(13,14,14,15,17,18).
Second: IRAInvestment and Financial Transactions , which are the
revenues of investments and financial transactions obtained by the Company and

the Net Group, the use by Mobile Telecommunications Company

(Zain) of the revenues of fraudulent calls to complete

investment operations and financial transactions, which are
theoperations of the Financial and non-investment referred to
in the company's financial reports in the paragraphs (investments in

securities, loans to an associate, investments in associates

andshares in companies under joint control) as detailed in the
following paragraph. Therefore, the proceeds of investments
and financial transactions such as the sale of Zain Africa
represent the proceeds of money laundering crimes.
Second: Commercial Investment Operations

- The annual financial reports of Mobile Telecommunications

Company (Zain) indicate that the company carried out local and foreign investment
operations, with the company's knowledge that the funds used in these

operations were obtained from committing crimes of falsifying

the dues of both (international calls ) (and roaming calls received)
listed in Mobile phone subscribers' bills in Kuwait,and therefore these
investment operations are considered one of the operations that aim to camouflage
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and hide the real source of funds, which is the proceeds of crimes
of forging international call dues and roaming call dues received
in the bills of mobile subscribers in Kuwait, and we list some of
these operations As outlined under the processes below:-
1. Investment operations in securities, which are the operations referred
to in the annual financial report issuedby Mobile
Telecommunications Company (Zain) in paragraph 8 in (Document No. 63) and
paragraph 8 in (Document No. 64); Note 7 in (Document No.
65).
2. Loan operations to associates, which are referred to in the
annual financial reports issued by Mobile Telecommunications
Company (Zain) in note paragraph 12 (document No. 6 6), note paragraph 10 in (document No.
6 7), and note paragraph 10 in (document No. 6 8).

3. Transactions of stakes in a company under joint control, which are

referred to in the annual financial reports issued by Mobile
Telecommunications Company (Zain) in paragraph 1 (document No. 66), paragraph
11 in (document No. 67), and paragraph 9 in (document No. 68).

4. Investment operations in associates, which are referred to in

the annual financial reports issued by Mobile
Telecommunications Company (Zain) in note paragraph 10 in
(document No. 6 9), paragraph 9 in (document No. 70), and paragraph 8 in
(document No. 71).
Third: Money Laundering Crimes Resulting from Fraud Crimes
The management of Mobile Telecommunications Company (Zain)
committed money laundering crimes as a result of the company

obtaining financial transfers in exchange for the public

subscription to increase the company's capital, which took place on 1-7

August 2008 and closed on September 18, 2008, through which the group

raised an amount of 1.2 One billion Kuwaiti dinars after

approximately 99% of the company's shareholders participated in that
subscription (Document 73), with the members of the Board of Directors knowing
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that the subscription funds were obtained from the subscribed

victims NetJj Committing the management of the Mobile
Telecommunications Company (Zain) Fraud crimes punishable
under Articles 235 and 236 of Law 16/1960 due to the
publication of incorrect data in the company's annual financial reports as
true with knowledge of their incorrectness, and these data are
both the revenues of the calls as well as the revenues of investments and
financial transactions with the aim of achieving the goal of It
consists in getting the public to subscribe to the company's capital increase to
finance future strategic expansion plans (Document 99) with the
company's knowledge that the funds obtained from committing
fraud crimes on the one hand, andon the other hand with the aim of
deluding the members of the company's general assembly that there is
a right for the members of the board of directors The project is
represented in the remuneration of the Board of Directors for
achieving the inflated volume of call revenues and investment revenues
included in the company's annual financial reports, despite the
members' knowledge of the invalidity of these revenues and their
knowledge of their true nature as the proceeds of crimes of
falsifying subscribers' bills and the proceeds of money laundering
crimes resulting from the use of funds revenues Fraudulent calls in
investment operations as indicated above, and in order to clarify
the size of the amounts of board remuneration that they
received during several years and transferred to their accounts in
the banks listed in the company's financial reports from 2002 to
2013, we present (Table No. 4) (Document 28), a timetable
showing the amounts of The amounts of remuneration obtained by the
members of the company's boards of directors, and we also
present (the diagram No. 1) (Document 29) which shows the amounts of
the amounts of the bonuses graphically.

Fourth: Elements of the participation ofthe Ministry of

Transport and the Ministry of Commerce and Industry
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The first element is the act of the Ministry of Communications'

refusal to take measures to report money laundering crimes
committed by the Mobile Telecommunications Company (Zain)
despite the Ministry's knowledge of the company's commission
of these crimes on an annual basis due to the fact that the
Mobile Telecommunications Company is subject to its control
and technical and legal supervision referred to above. Within
Law 26 of 1996 and Ministry of Transportation Resolution No.
273/1996.
The second element: is the act of deliberate disruption of the
legal supervisory role imposed on the company contained in the
articles of Law 26 of 1996, and this was done through the
refusal of the Ministers of Communications to form the
Permanent Committee at the Ministry of Communications,
which has the inspection authority stipulated in Emiri Decree
No. 8 of 1959. whose task is to supervise the application of
telecommunications companies subject to Law 26 of 1996 to all
regulations, standards and specifications of the International
Telecommunication Union and those issued by the Ministry of
Communications, in addition to supervising the extent to which
the company adheres to the tariff of its services determined
by the Ministry of Communications. It is worth mentioning
that the committee was not reconstituted until 2013, in
accordance with Resolution No. 2747/2013 regarding the
reconstitution of the Special Communications Committee, but
this new committee and the committees that followed it violated
the obligations imposed on them referred to within Law 26 of
1996 and the decision of the Ministry of Communications No.
273/1996, by refraining from exercising their supervisory role
over the company despite the knowledge of its members
thatthey have the inspection authority stipulated in Emiri Decree
No. 8 of 1959, which is also considered an element of
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participation of members of the Special Communications

Committee formed in 2013 in all crimes Money laundering
committed by Mobile Telecommunications Company (Zain).
The third element: is the act of refraining from the Ministry of
Commerce and Industry annually during the period of renewal
of the license of the Mobile Telecommunications Company (Zain)
from taking legal action obliging the Mobile Telecommunications
Company (Zain) to provide evidence proving that the company
meets the condition contained in the third paragraph of (Article
4) of the elements of incorporation of the company (Document
14), which It suspended the company's license for the
purposes for which it was established to purchase or lease
telecommunications lines to provide its services on the
condition that this be done in a manner that does not conflict
with the services provided by the State, andsince that was the
Mobile Telecommunications Company (Zain) providing its
services in a manner that conflicts with the services provided by
the State. On the leased communication lines due to their
forgery of international calling receivables that were made on
those lines without the Ministry of Commerce and Industry
obliging them to provide evidence proving that the international
calling charges used by the company to calculate international
calling receivables in subscribers' bills match the international
calling charges specified in the decisions of the Ministry of
Communications. Therefore, the act of refraining from the
Ministry of Commerce and Industry from taking the
aforementioned legal procedures Although the Ministry of
Commerce is aware of the need to do so on an annual basis, the
element of the participation of the Ministry of Commerce and
Industry in all the crimes committed by the aforementioned
company is represented, taking into account that the validity of
the calculation of the receivables of future roaming calls
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depends on the validity of the dues of international calls, and if

the Ministry of Commerce and Industry had applied this
measure, taking it would have prevented the commission of
Mobile Telecommunications Company (Zain) has committed the
aforementioned crimes of forgery and money laundering on an
annual basis due to its inevitable discovery that the prices of
international calls do not match the company's bills with the
prices of international calls specified in the decisions of the
Ministry of Transportation.
Fifth: Assault on the sanctity of public funds
The Mobile Telecommunications Company (Zain) is considered to have
committed repeated attacks on the sanctity of public funds on an annual basis, due

to the fact that many ministries, state institutions and joint stock

companies are exposed to the same crimes of forgery of documents and

the aforementioned crimes of money laundering and statement
as they are among those who have notsubscribed to the mobile
telephone service.
Sixth: Humanitarian violations resulting from the crimes
committed
- Mobile Telecommunications Company (Zain) has committed
consistentpatterns of gross violations of the civil and political
rights of mobilesubscribers under article 17 of the International
Covenant on Civil and Political Rights , which stipulates that no one shall
be subjected arbitrarily or unlawfully to interference with his

correspondence, since all The money laundering crimes

committed by the mobile telecommunications company (Zain) that
are the subject of the complaint and the communication are based on the
violation of that right through the company's illegal interference
with the correspondence of the complainant and the people byfalsifying the cost of the
dues of the complainant and the international people and Roaming
received in subscribers' bills with the company's use of the proceedsof
forgery crimes in investment operations using US dollars.
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Seventh: Literary fraud with the aimof winning local and

international awards
Zain Group and Mobile Telecommunications Company (Zain)
commit many fraud crimes at the global and local levels and
frequently occurring by accepting to win international and local
competition awards in order to achieve an honest commercial
reputation and depend on the availability of transparency in the
company's reports, despite the knowledge of Zain Group and
Mobile Telecommunications Company (Zain) that the real reason
that led to Their superiority over their counterparts from other
global and local mobile telecommunications service providers is
that they received more money than their real revenues due to the

commission by the Mobile Telecommunications Company (Zain) of

the crimes of falsifying international call dues and roaming calls received in
subscribers' bills and falsifying call revenues included in the
company's annual financial reports with the They are the
proceeds of forgery crimes in committing money laundering
crimes previously explained within the complaint and report and
continuously, which led to the superiority of the company and the group and not
because of the subordination of Zain Group and Mobile
Telecommunications Company This is clearly evidenced by the
company's receipt of awards from the Kuwait Transparency
Society of Transparency International, despite the lack of
transparency in the company's reports or invoices , as well as the
company's fraud on the International Islamic Charitable Organization,

where the authority awarded an award to the telecommunications

company because of the company's funding of awareness campaigns that

meet the needs of the needy in the region using funds with the
company's knowledge. The source of the funds used to finance these
campaigns is derived from the company's commission of crimes
of falsification of international calling dues, future roaming dues
and money laundering crimes repeatedly, as indicated in the
complaint.
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To find out many details of global and local literary fraud committed by
Zain Group and Mobile Telecommunications Company (Zain), as well as

evidence related to local and international fraud crimes aimed at

improving the reputation of the company and Zain Group, in
addition to victims who have been exposed to fraud such as
magazines, social organizations, religious bodies, commercial
gatherings, etc. Documenttime summary A with all the evidence
and proofs related to this in document (98).
Since the Mobile Telecommunications Company (Zain) knew that
the act of employing funds in local and foreign commercial investments

was aware that such funds were derived from the commission of
crimes of forgery of customary and official documents in Kuwait
from criminal acts in all countries of the world as a crime of money-
laundering, subject to the provisions of Law No. 35 of 2002, which
establishes a number of articles aimed at preventing the
company from profiting and exploiting its capacity. To gain from
illegal trade through.
Therefore, failure to do so entails criminal liability in accordance
with the provisions of public and special penal laws, as Law No.
47 of 2006 approving the United Nations Convention against
Corruption provides for the criminalization of such acts in
accordance with Articles 14, 21, 23, 24, 31 and 30 thereof, and
the Money Laundering Law No. 35 of 2002 criminalizes another
aspect of it in accordance with Article II thereof, as well as Law
106 of 2013.
Accordingly
We submit our complaint and this communication to you to
investigate these crimes, in line with the provisions of Articles 5 and 6 of the
United Nations Convention against Transnational Organized
Crime, which was approved by Law 5 of 2006 and thus became
part of the legislation of the State of Kuwait. The law mandates
the implementing regulations to specify the measures to be
taken by States within Articles 12 and 13. 14. This is to confiscate
 19

the proceeds, to compensate the victims of the crime and to

return the proceeds of crimes to their rightful owners, in addition
to the ordinary measures provided for in those articles of the
same law.
Introduction: Adnan Abdul Mahsn Ahmed
Al-Tayyar
Signature:
Phone: 99409999
B/M: 254050601824
Complaint Accessories:
First: 98 documents.
Second: a document portfolio consisting of 16 pages.

Nabil Bin Salama, in his capacity as CEO of Mobile

Telecommunications Company (Zain), acquired an equivalent
amount of KD 3.8 million and was calculated on the basis of
operating profits, despite his knowledge that Mobile
Telecommunications Company (Zain) and Zain Group committed crimes
during his tenure of falsification of subscribers' bills, the company's financial reports and money laundering
and in 2010 the company obtained financial returns from
crimes,

committing money laundering crimes equivalent to 445%

compared to the proceeds of the company's commission of
money laundering crimes during 2009. (Document 100) Note
that the acts he was committing are not operational acts but are
crimes punishable by the Penal Code and the laws of money
laundering in Kuwait and in all countries of the world. committing
of the mobile telecommunications company (Zain) for both
crimes of the commission of Crimes of and the commission of
Which will be detailed later, money laundering operations by
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committing crimes of forgery of official documents, which are

the company's financial reports again, by changing the reality of
the investment income included in the company's annual
financial reports, knowing that they are not correct, by
increasing them by including the amounts of money laundering
proceeds. where the company was able to launder the
fraudulent dues for international calls and the fraudulent dues
for the received roaming calls that it obtained from the bills of
subscribers in Kuwait, which it had previously used in the phased
acquisition of African telecommunications companies by
returning them to Kuwait as the investment income of the sale of
Zain Africa with the company's knowledge that they are the
proceeds of money laundering crimes, and therefore all the
annual financial reports of Zain Group and Mobile
Telecommunications Company (Zain) are forged official
documents due to the invalidity of both call revenues and
investment income listed therein.