[Senate Hearing 111-540, Volume 1]
[From the U.S. Government Publishing Office]
S. Hrg. 111-540
KEEPING FOREIGN CORRUPTION OUT OF THE UNITED STATES: FOUR CASE
HISTORIES
=======================================================================
HEARING
before the
PERMANENT SUBCOMMITTEE ON INVESTIGATIONS
of the
COMMITTEE ON
HOMELAND SECURITY AND
GOVERNMENTAL AFFAIRS
UNITED STATES SENATE
ONE HUNDRED ELEVENTH CONGRESS
SECOND SESSION
----------
VOLUME 1 OF 2
----------
FEBRUARY 4, 2010
----------
Available via http://www.gpoaccess.gov/congress/index.html
Printed for the use of the Committee on Homeland Security
and Governmental Affairs
KEEPING FOREIGN CORRUPTION OUT OF THE UNITED STATES:
FOUR CASE HISTORIES --VOLUME 1 OF 2
S. Hrg. 111-540
KEEPING FOREIGN CORRUPTION OUT OF THE UNITED STATES: FOUR CASE
HISTORIES
=======================================================================
HEARING
before the
PERMANENT SUBCOMMITTEE ON INVESTIGATIONS
of the
COMMITTEE ON
HOMELAND SECURITY AND
GOVERNMENTAL AFFAIRS
UNITED STATES SENATE
ONE HUNDRED ELEVENTH CONGRESS
SECOND SESSION
__________
VOLUME 1 OF 2
__________
FEBRUARY 4, 2010
__________
Available via http://www.gpoaccess.gov/congress/index.html
Printed for the use of the Committee on Homeland Security
and Governmental Affairs
U.S. GOVERNMENT PRINTING OFFICE
56-840 WASHINGTON : 2010
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COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS
JOSEPH I. LIEBERMAN, Connecticut, Chairman
CARL LEVIN, Michigan SUSAN M. COLLINS, Maine
DANIEL K. AKAKA, Hawaii TOM COBURN, Oklahoma
THOMAS R. CARPER, Delaware JOHN McCAIN, Arizona
MARK L. PRYOR, Arkansas GEORGE V. VOINOVICH, Ohio
MARY L. LANDRIEU, Louisiana JOHN ENSIGN, Nevada
CLAIRE McCASKILL, Missouri LINDSEY GRAHAM, South Carolina
JON TESTER, Montana ROBERT F. BENNETT, Utah
ROLAND W. BURRIS, Illinois
PAUL G. KIRK, JR., Massachusetts
Michael L. Alexander, Staff Director
Brandon L. Milhorn, Minority Staff Director and Chief Counsel
Trina Driessnack Tyrer, Chief Clerk
Patricia R. Hogan, Publications Clerk and GPO Detailee
PERMANENT SUBCOMMITTEE ON INVESTIGATIONS
CARL LEVIN, Michigan, Chairman
THOMAS R. CARPER, Delaware TOM COBURN, Oklahoma
MARK L. PRYOR, Arkansas SUSAN M. COLLINS, Maine
CLAIRE McCASKILL, Missouri JOHN McCAIN, Arizona
JON TESTER, Montana JOHN ENSIGN, Nevada
PAUL G. KIRK, JR., Massachusetts
Elise J. Bean, Staff Director and Chief Counsel
Robert L. Roach, Counsel and Chief Investigator
Laura E. Stuber, Counsel
Adam K. Parks, ICE Detailee
Jason E. Medica, ICE Detailee
Adam Henderson, Professional Staff Member
Christopher J. Barkley, Minority Staff Director
Justin J. Rood, Senior Investigator to the Minority
Mary D. Robertson, Chief Clerk
C O N T E N T S
------
Opening statements:
Page
Senator Levin................................................ 1
Senator Coburn............................................... 5
Prepared statements:
Senator Levin................................................ 47
Senator Coburn............................................... 51
WITNESSES
Thursday, February 4, 2010
Michael Jay Berger, Attorney for Equatorial Guinea Cabinet
Minister Teodoro Obiang Nguema Mangue.......................... 6
George I. Nagler, Attorney for Equatorial Guinea Cabinet Minister
Teodoro Obiang Nguema Mangue................................... 7
Jeffrey C. Birrell, Registered Agent for the Republic of Gabon,
The Grace Group................................................ 9
Neal Baddin, Realtor for Equatorial Guinea Cabinet Minister
Teodoro Obiang Nguema Mangue................................... 10
Brenda K. Cobb, Vice President, Insured Aircraft Title Service,
Inc............................................................ 11
William J. Fox, Senior Vice President and Global Anti-Money
Laundering and Economic Sanctions Executive, Bank of America... 11
Wiecher H. Mandemaker, Director, General Compliance, Personal
Financial Services, Anti-Money Laundering Compliance, HSBC Bank
USA, N.A....................................................... 14
David T. Johnson, Assistant Secretary, Bureau of International
Narcotics and Law Enforcement Affairs, U.S. Department of State 35
Janice Ayala, Assistant Director, Office of Investigations, U.S.
Immigration and Customs Enforcement, Department of Homeland
Security....................................................... 36
James H. Freis, Jr., Director, Financial Crimes Enforcement
Network, U.S. Department of the Treasury....................... 38
Alphabetical List of Witnesses
Ayala, Janice:
Testimony.................................................... 36
Prepared statement........................................... 87
Baddin, Neal:
Testimony.................................................... 10
Prepared statement........................................... 52
Berger, Michael Jay:
Testimony.................................................... 6
Birrell, Jeffrey C.:
Testimony.................................................... 9
Cobb, Brenda K.:
Testimony.................................................... 11
Prepared statement with an attached letter................... 53
Fox, William J.:
Testimony.................................................... 11
Prepared statement........................................... 58
Freis, James H., Jr.:
Testimony.................................................... 38
Prepared statement........................................... 98
Johnson, David T.:
Testimony.................................................... 35
Prepared statement........................................... 80
Mandemaker, Wiecher H.:
Testimony.................................................... 14
Prepared statement........................................... 66
Nagler, George I.:
Testimony.................................................... 7
APPENDIX
``Keeping Foreign Corruption Out of the United States: Four Case
Histories,'' Majority and Minority Staff Report, Permanent
Subcommittee on Investigations, February 4, 2010............... 119
EXHIBITS
1. GCharts prepared by the U.S. Senate Permanent Subcommittee
on Investigations:
a. GU.S. Bank Accounts Used by Teodoro Obiang, 2004-2008.... 510
b. GU.S. Banks Accounts Used by Jennifer Douglas, 2000-2009. 511
Obiang Case Documents:
2. GUnion Bank of California Case Report, dated June 2007, re:
BERGER, M-Wire Review-High Risk/Terroris; BSA Amount $4,960,734
(Case Closing Notes: Investigation detected suspicious activity
related to the appearance of money laundering on behalf of PEP) 512
3. GMichael Berger correspondence (unsigned) to Teodoro Obiang,
dated July 2006, outlining Berger's services for Obiang........ 518
4. GMichael Berger email to Teodoro Obiang, dated October 2006,
re: Bills that I have not paid yet (All further payments on
your behalf will be made through the Unlimited Horizon
accounts. . . .)............................................... 523
5. GMichael Berger email to Teodoro Obiang, dated October 2006,
re: Acknowledgement of Receipt of $199,931.17 Wire Transfer
(This confirms my receipt of a wire transfer from you in the
amount of $199,941.17. This money was received in my attorney
client trust account at Bank of America on October 20, 2006.
Per our telephone conversation today, I will transfer said
funds to the Unlimited Horizon General Checking Account at
Union Bank on Monday (when Union Bank opens) and use said funds
to pay your bills.)............................................ 524
6. GMichael Berger email to Teodoro Obiang, dated November
2006, re: Time to Wire Additional Funds to Unlimited Horizon,
Inc............................................................ 526
7. GCitibank form, Observations at Place of Business, dated
June 2007, re: tour of Unlimited Horizon, Inc. at same address
as Law offices of Michael Jay Berger........................... 527
8. GCitiBusiness Deposit Account Application, Senior Public
Figure Screening form, dated June 2007, (Check yes if there are
any signer/owners (owning 25% or more) who is a citizen of a
country other than the United States or Puerto Rico? Boxed
checked No.)................................................... 528
9. GMichael Berger email to Teodoro Obiang, dated July 2007,
re: Details re $100,000.00 Transaction Attached (Dear Mr.
Nguema, . . . I went to Bank of America, withdrew $100,000.00
of your money from my Bank of America client trust account,
purchased a cashier's check for $100,000.00 made out to
Unlimited Horizon, Inc. and deposited said cashier's check into
the new Unlimited Horizon, Inc. account at Citibank.).......... 529
10. GMichael Berger email to Teodoro Obiang, dated July 2007,
re: Accounting, June 1-July 11 (Also attached hereto is an
accounting of the funds that were deposited by me into my Bank
of America Client Trust Account on your behalf, and the checks
that I wrote on your behalf.).................................. 530
11. GSelect Incoming EG Wires to Berger Attorney-Client Account
at Bank of America, chart prepared by the U.S. Senate Permanent
Subcommittee on Investigations................................. 531
12. GSelect Disbursements from Berger Attorney-Client Account at
Bank of America, chart prepared by the U.S. Senate Permanent
Subcommittee on Investigations................................. 532
13. GBeautiful Vision Checks in Excess of $50,000, chart
prepared by the U.S. Senate Permanent Subcommittee on
Investigations................................................. 533
14. G$3.3 Million Beautiful Vision, Inc. Special Account Check
made payable to Cash, dated March 4, 2005; and cashiers check
for same amount................................................ 534
15. GGeorge Nagler fax to Marvin Freedman, dated September 2005,
re: Sweet Pink, Inc. (Sweet Pink, Inc. engagement letter signed
by Teodoro Nguema Obiang)...................................... 535
16. GGeorge Nagler email and fax to Teodoro Obiang, dated
February 2006, re: Malibu & Current Projects (Mr. Nguema, I
thought that I should send you a brief list of the things I am
doing or have been asked to do by you:)........................ 540
17. GGeorge Nagler email to Teodoro Obiang, dated May 2006, re:
Ed Mizrahi & Melinda & the bank accounts (It avoids you having
to go into the bank and sign the documents.)................... 543
18. GAmerican Property Management and Melinda Hehaven (Obiang
employee) email, dated June 2006, re: Wire and Bank Accounts (I
was just informed by the Manager at Cal National Bank that you
were inquiring why the $249,899.80 wire was transferred into
the American Equity Properties, Inc. ITF Sweetwater Malibu
account and not the Household account (that you are a signer
on) or the payroll account. . . . In the future, if you have
questions concerning the transfers of monies you should address
them with me or George Nagler, and not the bank manager.)...... 544
19. GCal National Bank email, dated December 2006, re: Champ
Award-John Hoppe (Without John reviewing the Statement of
Information and performing internet searches this PEP [Obiang]
may have been overlooked and the Bank would have been in
violation of our PEP Policy.).................................. 545
20. GCal National Bank internal emails, dated June 2004, re:
concerns with Obiang accounts (We have identified a number of
issues with this client, which should be addressed immediately.
. . . Since the client provided false information, we should
close the account.)............................................ 546
21. GCal National Bank internal email, dated July 2004, re:
Obiang (This afternoon I received a phone call from Teodoro
Obiang. . . . In our conversation he asked me why we closed the
account. I told him that we were provided with the incorrect
social security number and that we had tried to reach him on
many occasions and we were unsuccessful. After I told him that,
he said, ``I thought it was due to our country and the oil.''
He then asked me if we could reopen the account if he were to
come in and provide us with the correct social. I told him that
since we were unable to get a hold of him, the legal department
is now involved.).............................................. 547
22. GCopies of Sweetwater Management Inc. checks drawn on Nagler
law office account, dated July and August 2006................. 548
23. GEmails between George Nagler and Pacific Mercantile Bank,
dated July 2006, re: Teodoro Nguema Obiang..................... 549
24. GEmails between Paul J. Finestone and George Nagler, dated
June 2006, re: Quotes Withdrawn: AIG RE: Obiang, Teodora
Insurance for Sweetwater Estate (We have very bad news indeed.
We have this instant received a fax from the AIG underwriters
representative who advises that they have reviewed web sites
concerning Teodoro Obiang and that they are withdrawing the
written quotations submitted to us for you on all of the
coverage for the estate.)...................................... 551
25. GGeorge Nagler email to Teodoro Obiang, dated August 2007,
re: Need for Lease of House for Insurance Purposes (. . . you
should have a lease prepared between the limited liability
company that owns your Sweetwater home and you individually
showing that you are leasing the house from the company. This
will support the so called renters policy that provides
liability insurance for your protection.)...................... 552
26. GEmails between Paul Finestone (insurance broker) and
Melinda Hehaven (Obiang employee), dated July 2006, re:
Coverage Declination Without Automobile License.).............. 553
27. GGeorge Nagler fax to Simon T, dated June 2006, re: Teodoro
Nguema Obiang, providing Obiang business references in effort
to find a hangar for Obiang aircraft........................... 554
28. GExclusive Retainer Agreement to Locate Real Property
between Neal Baddin and Beautiful Vision, Inc. and
correspondence between Neal Baddin and Teodoro Obiang, dated
December 2005, re: Agreement Regarding Real Estate Agent
Commission on Sweetwater Mesa Road, Malibu, CA property........ 555
29. GConfidentiality Agreement (Broker), dated March 2006,
entered into for the benefit of Teodoro Nguema Obiang and
Sweetwater Mesa, LLC........................................... 561
30. GFirst American Title Company Buyer's Final Settlement
Statement, dated April 2006, reflecting payments totaling
$30,876,500 by Teodoro Nguema Obiang; Sweetwater Malibu, LLC,
for property located at 3620 Sweetwater Mesa Road, Malibu, CA.. 567
31. GEmails between McAfee & Taft and Dick Brown, Christine
Nasrallah, Eric Duret, dated March 2006, re: Escrow Funds
related to aircraft purchase (We need some information to
assure compliance with the US Patriot Act. . . . We also need
copies of Ebony's formation documents, list of officers and
principals and identify [sic] of the source of funds.)......... 568
32. GEmails between McAfee & Taft and Christine Nasrallah, Dick
Brown, dated April 2006, re: Gulfstream V SN/669 funds (I just
want to make sure everyone is on the same page and aware that
for us to continue to hold [the] funds I must be provided with
the Patriot Act due diligence by Monday morning, and it must be
in a form acceptable to us.)................................... 570
33. GChristine Nasrallah (Obiang representative) email, dated
April 2006, re: GV 669 (. . . Mcafeetaft sent back the 4.7 MUS$
to Kirk. Could you please reopen an escrow account in the name
of Blue Sapphire (NGUEMA) as the transaction was cancelled via
Mcfeetaft.).................................................... 580
34. GInsured Aircraft Title Service, Inc. Deposit Confirmation,
dated April 2006, re: Gulfstream G-V, Serial Number 669, N1UB
(This will confirm that I.A.T.S. has received into escrow the
sum of $4,700,000.00 as a deposit on the above referenced
aircraft. This deposit will be held for the account of Blue
Sapphire Service LTD (Nguema) . . .)........................... 581
35. GEmails between Insured Aircraft and UBS, dated May 2006,
re: Incoming Euro's (We are looking for incoming funds in the
amount of 50,000 Euro's.)...................................... 582
36. GEmail between Dick Brown, Eric Duret and IATS [Insured
Aircraft Title Service], dated March/June 2006 re: U.S. Patriot
Act (The owner of the GV is very concerned that this sale to
your client is not in compliance with the Patriot Act.)........ 583
37. GEmail between Dick Brown and IATS, dated June 2006 re:
Closing on GV S/N 669 (You should now have all the documents
necessary to close this transaction so please proceed to close
and transfer funds as quickly as possible.).................... 585
38. a. GWilliam J. Robinson legal opinion, dated June 9, 2006,
re: Patriot Act applicability to aircraft sale................. 594
b. GWilliam J. Robinson supplemental legal opinion, dated
June 27, 2006, re: Patriot Act applicability to aircraft sale.. 595
39. GEbony Shine International Limited documents dated June
2006, re: Gulfstream G-V aircraft MSN 669, signed by Teodoro
Nguema Obiang.................................................. 597
40. GEmails between IATS and Dick Brown, dated July 2006, re: S/
N 669 (I understand that the aircraft will be moved to the
Cayman Registry. The aircraft is being Managed by Jet Aviation
. . .)......................................................... 600
41. GU.S. Department of Justice Memorandum, dated September 4,
2007, re: Request for Assistance in the Investigation of
Teodoro Nguema OBIANG and his associates....................... 601
42. GImmigration and Customs Enforcement PowerPoint presentation
on Teodoro Nguema OBIANG, et al................................ 614
Bongo Case Documents:
43. a. GUnited Bank Wire Receipt, dated 3/31/05; Beneficiary:
The Grace Group LLC; Originator: El Hadj Omar Bongo Ondimba;
Amount: $599,933.01............................................ 631
b. GUnited Bank Wire Receipt, dated 4/7/05; Beneficiary: The
Grace Group LLC; Originator: El Hadj Omar Bongo Ondimba;
Amount: $241,973............................................... 633
c. GUnited Bank Wire Receipt, dated 6/17/05; Beneficiary:
The Grace Group LLC; Originator: Ayira; Amount: $4,999,934.56.. 635
d. GUnited Bank Wire Receipt, dated 7/21/05; Beneficiary:
The Grace Group LLC; Originator: Ayira; Amount: $5,999,934.73.. 637
e. GUnited Bank Funds Transfer Notification, dated 7/18/05,
Beneficiary: The Grace Group LLC; Originator: Ayira; Amount:
$5,999,934.36.................................................. 639
f. GUnited Bank Wire Receipt, dated 7/22/05, Beneficiary:
Abass Haidara; Originator: The Grace Group LLC; Amount:
$1,000,000..................................................... 640
g. GUnited Bank Wire Receipt, dated 8/31/05, Beneficiary:
Baba A Haidara; Originator: The Grace Group LLC; Amount:
$200,000....................................................... 642
h. GUnited Bank Wire Receipt, dated 10/20/05, Beneficiary:
Abass Haidara; Originator: The Grace Group LLC; Amount:
$3,061,809..................................................... 644
i. GUnited Bank Wire Receipt, dated 11/16/05, Beneficiary:
Michael Moussa; Originator: The Grace Group LLC; Amount:
$496,500....................................................... 646
j. GUnited Bank Wire Receipt, dated 11/18/05, Beneficiary:
Maxime Gandzion; Originator: The Grace Group LLC; Amount:
$250,000....................................................... 648
k. GUnited Bank Wire Receipt, dated 12/16/05, Beneficiary:
Hamid Mohammad Hakeem Bakhsh; Originator: The Grace Group LLC;
Amount: $184,000............................................... 650
l. GWire Receipt, dated 2/8/07, Beneficiary: The Gabonese
Republic H E Omar account in Malta; Originator: The Grace Group
LLC; Amount: $9,200,000........................................ 652
m. GUnited Bank Wire Receipt, dated 2/8/07, Beneficiary: The
Gabonese Republic H E Omar account in Malta; Originator: The
Grace Group LLC; Amount: $65,061............................... 656
44. GJeffrey Birrell (The Grace Group) email to Armormax, dated
April 2005, (I am making a series if [sic] acquisitions for the
Head of State, and these actions have created a lot of interest
among certain individuals.).................................... 658
45. GJeffrey Birrell (The Grace Group) email to Armormax, dated
June 2005, re: H2 Follow up (The representations regarding
delivery that you made to the General and to me were without
caveat or qualification. The President has been waiting since
April 9th for shipment notification.).......................... 659
46. GJeffrey Birrell (The Grace Group) fax, dated June 2005, re:
Transfer of funds.............................................. 660
47. GJeffrey Birrell (The Grace Group) email to Abass Haidara,
dated June 2005, re: C-130 Update/Financial (Will you please
advise President Bongo of the following information. The Grace
Group has received $5,000,000.00 USD. . . . This same amount,
minus wire transfer fees, has been re-deposited into a separate
account titled, ``Grace Group LLC, Client Escrow Account.'')... 661
48. GDelta Synergie correspondence to the U.S. Department of
State, dated October 2005, re: Request for Reexport
Authorization for C-130 E Aircraft from Saudi Arabia to Gabon
(Delta Synergie, a private-owned Gabon company owned in part by
Gabon's Head of State (in his private capacity) has agreed to
purchase two C-130 E cargo from Royal Saudi Air Force . . .)... 662
49. GJeffrey Birrell (The Grace Group) email to Department of
State, dated October 2005, re: C130 Brokering Request--Delta
Synergie and The Grace Group LLC (It would be very helpful to
know the status of this submission and to know how the process
can be moved along. President Bongo raised this matter with you
directly many months ago and he is very interested in a timely
resolution.)................................................... 665
50. GU.S. Department of State denial of application submitted by
Jeffrey Birrell (The Grace Group), dated November 2005,
(Commercial ownership and end-use of C-130 aircraft for
transportation of goods by a private company as outlined in
this request is inconsistent with the provisions of the Arms
Export Control Act . . .)...................................... 666
51. GJeffrey Birrell (The Grace Group) correspondence to the
U.S. Department of State, dated December 2005, (This request
for prior approval of brokering activities is now extremely
time sensitive. The items that we propose to broker between the
governments of Saudi Arabia and Gabon are urgently needed by
the end user.)................................................. 667
52. GJeffrey Birrell (The Grace Group) correspondence to Royal
Embassy of Saudi Arabia, dated May 2006, re: Congressional
Notification process........................................... 669
53. GU.S. Department of State correspondence to Jeffrey Birrell
(The Grace Group), dated August 2006, (The Department of State
has no objection to the permanent re-export of these six (6) C-
130B/E aircraft and approves your request)..................... 673
54. GJeffrey Birrell (The Grace Group) correspondence to His
Excellency, El Hadj Omar Bongo Ondimba, President, The Gabonese
Republic, dated September 2006, re: Approved Re-export of six
C130 Aircraft to Gabon......................................... 675
55. GPresident Omar Bongo correspondence to Saudi Prince Sultan
Bin Abdelaziz, dated October 2006, regarding the purchase of
six C-130 aircraft for $27.6 million........................... 677
56. GTwo (2) Jeff Birrell, The Grace Group LLC Escrow Account
checks made payable to the Royal Saudi Air Force, Kingdom of
Saudi Arabia, dated, 11/10/06, each in the amount of $4.6
million........................................................ 679
57. GJeffrey Birrell (The Grace Group) correspondence to Major
General Mohammed A. Kattoah of the Royal Saudi Air Force, dated
November 2006, (At the request of the Gabonese Republic, I am
providing the Royal Saudi Air Force two ``Official Bank
Checks'' in the amount of $4,600,000 USD each. These checks are
for payment of two C-130 aircraft . . .)....................... 681
58. GJeffrey Birrell (The Grace Group) correspondence to
Francois Meyer (President Bongo's legal counsel), dated January
2007, re: Interim Statement of expenses in connection with C-
130 purchase................................................... 682
59. GJeffrey Birrell (The Grace Group) email to Sofab Aerospace,
dated February 2007, re: C130 Project: Status (I am very sorry
to report that after months of trying, our efforts to buy the
six C130 aircraft have concluded without a purchase agreement.) 684
60. GUnited Bank Statement of Accounts for the Grace Group, for
the period 1/11/07 to 2/11/07, reflecting a deposit and wire
debit of $9,200,000 on 2/8/07.................................. 685
61. GJeffrey Birrell (The Grace Group) correspondence to
Francois Meyer (President Bongo's legal counsel), dated March
2007, re: C-130 Cargo Operations for Gabon (The purpose of our
discussion was to determine this group's interest in securing
the outside funds necessary to purchase the six C130 aircraft.) 686
62. GJeffrey Birrell (The Grace Group) email, dated August 2007,
re: Gabon MOU (Singpart is a Mauritian shell used to contract
for the MOU.).................................................. 689
63. GRepublic Bank California Account Opening for the Collins
Revocable Trust, dated 4/14/2000............................... 693
64. GHSBC internal emails, re: The Collins Revocable Trust,
dated December 2002 (I'm not getting anywhere on this. She
deposited 70,000 in cash on 11/25 and I have to explain the
source of funds. . . . She is Inge Collins Bongo.) and February
2003 (Inga Collins has been a client of Republic/HSBC for a few
years now. . . . She is married to an African Diplomat. She
says that is why she has unusual cash activities/transactions.) 695
65. GHSBC internal email, dated February 2003, re: P&C-GHQ CMP
Search (It would be grateful if you could arrange for searches
to be made in your region in order to determine whether any
member of the Group maintains any account or other relationship
with: 1. El Hadj Omar Bongo . . .)............................. 700
66. GHSBC wire receipt for account of Yamilee Bongo Astier,
dated May 2003, Originator: Republic of Gabon; Originator Bank:
Citibank; Beneficiary: Yamilee Bongo Astier; Amount: $183,500.. 702
67. GCommerce Bank internal email, dated December 2005, re:
Yamilee Bongo-Astier (She told me that she is a princess or
something from some african country, and the money she gets is
from her father.).............................................. 704
68. GCommerce Bank internal memorandum, dated December 2005, re:
Yamille Bongo-Astier (Bongo-Astier advised that she does not
have a job and her only source of income is monies received
from her father. The monies are received in the form of US
currency and a CTR is immediately filed by her when the funds
are deposited.)................................................ 705
69. GCommerce Bank email to Prime Associates, dated December
2005, re: PEP Entity (Recently, we had a customer who claimed
to be of royal decent from the country of Gabon. Her father
shows up on the PEP list, but she does not.)................... 707
70. GCommerce Bank internal email, dated October 2007, re:
Yamilee Bongo-Astier (We went to her safe deposit box where we
took out 10 sealed stacks of $100 bills each totaling
$100,000.00 for a grand total of $1,000,000.00. According to
Yamilee the money was given to her by her father, who she
explained is the President of Gabon.).......................... 709
71. GCommerce Bank internal memorandum, dated October 2007, re:
telephone interview of Yamille Bongo-Astier (Bong-Astier
advised that her father, President Omar Bongo often visits her
when he is in New York City to attend various diplomatic
meetings. She stated that upon his most recent visit to the
United Nations (9/27/07) to give a speech he gave her a gift of
$1MM to be used for the purchase of a condo in New York City.). 711
72. GCommerce Bank Request to Close Account of Yamille Bongo-
Astier, dated November 2007.................................... 713
73. GCollins Trust Transfers, chart prepared by the U.S. Senate
Permanent Subcommittee on Investigations....................... 716
Abubakar Case Documents:
74. GTotal Wire Transfers Sent By Offshore Corporations To U.S.
Bank Accounts, chart prepared by the U.S. Senate Permanent
Subcommittee on Investigations................................. 717
75. GSiemens Wire Transfers to Douglas Account at Citibank:
52096374, Using Citibank Wire Transfer Records, chart prepared
by the U.S. Senate Permanent Subcommittee on Investigations.... 718
76. GJennifer Douglas correspondence, dated November 21, 2003,
re: Explanation of Income...................................... 719
77. GCitibank internal emails, dated April 2007, re: Account
Close-out Extension--Jennifer Douglass Accounts--#52096374..... 721
78. GCitibank internal email from fraud investigator, dated
August 2007, re: Douglas accounts (Highly suspect that someone
claiming 30k in income to the IRS could obtain a 2.7 million
dollar home with no mortgages. Lifestyle of the borrower is not
reflected on the tax returns.)................................. 723
79. GChevy Chase Trust Memorandum, dated January 2006, re: JDA
Family Trust (Mr. Abubukar's [sic] source of wealth is
impractical to verify.)........................................ 724
80. GWachovia investigative report, dated 2007, re: Douglas
accounts (Mr. Weidenfeld wanted to know if the account was
being closed based on the fact that his client Jennifer Douglas
is married to the former Vice-President of Nigeria or if the
account closing had anything to do with money laundering
activities.)................................................... 727
81. GUBS-Wegelin email exchanges, dated October 2005 to February
2006, re: LetsGo and Sima Holdings wire transfers (Apparently,
both Letsgo and SIMA are owned by a wealthy Italian family
which is active in the oil business.).......................... 729
82. GUBS AML Investigation Report, dated February 2006, re:
LetsGo and Sima Holdings wire transfers (What is the business
of SIMA Holdings that they are transferring this amount of
money to ABTI? Is it the fathers money held in an account at
SIMA? If so, shouldn't he be listed as the Order Party?
Otherwise, the actual party to the transfer is disguised and we
do not really know the parties with whom we are dealing in such
a transaction.)................................................ 735
83. GAmerican University email, dated June 2003, re: ABTI
assessment (ABTI University Project--Nigeria . . . Khashoggi
factor. Is there a risk to AU=s [sic] reputation? Role of
rampant corruption and graft in Nigeria is unclear.)........... 739
84. GJennifer Douglas email, dated December 2006, re: Accounting
and hand over of AAUN account (There is no stated budget for
the account--the account functions as a ``pay as you go
account'' in that monies are sent in as it is requested for
paying either salaries or purchases the founder approved and
asked me to pay.).............................................. 741
85. GAmerican University email, dated February 2007, re: AAUN
budget matters (My understanding is that most of the
construction funds did not come from Atiku himself, but from
other donors. I have heard informally where some of the funds
have originated, but I do not have full information regarding
who contributed what.)......................................... 743
86. GAmerican University correspondence to the U.S. Department
of Education, January 2010, re: Foreign tranfers (. . . we are
reporting the following foreign gifts and contracts which
exceeded $250,000 for the period July 1, 1993 through December
31, 2009.)..................................................... 744
Angola Case Documents:
87. G2005 Bank of America's Global Anti-Money Laundering Unit
reviews of account of Sonia M. Falcone, Pierre Falcone and the
business entity named Monthigne Corp. (Although Mr. Falcone
appears to have been involved in the dealing and sale of Arms,
the activity for the accounts at Bank of America shows activity
that is normal for this type of high profile customer.)........ 746
88. GBanco Nacional De Angola Funding Agreement between MAS Inc.
(Mehenou S. Amouzou, President) and Banco Nacional de Angola,
dated February 2001............................................ 750
89. GBanco Nacional de Angola correspondence to Mehenou Amouzou
(MSA Inc.), dated January 2002, (. . . your mandate as Advisor
to the Government of Angola. In your capacity as Advisor you
are entitled to deal with public or private entities in order
to achieve the agreed and stated objectives.).................. 754
90. GMinutes of the Special Meeting, Board of Directors, MSA
Inc., dated July 2002, (The Board has agreed that Dr. Aguinaldo
Jaime be appointed the Acting Special CFO as an overseer of the
Fifty Million Dollars to be deposited in an International Prime
Bank.)......................................................... 755
91. GBank of America wire transfer documents, dated June 2002,
Originator: BNA Oil Taxes y Royalties; Amount: $50,000,000 USD;
Deposit To Secure Fnd'ing Fro [sic] Humanitarian Projects in
Angola......................................................... 757
92. GCitibank London June 2002 query to Banco Nacional de Angolo
regarding $50,000,000 transaction, (Citibank and its overseas
branches are bound by US Government requirements to comply with
US Government sanctions regarding payments to specific
countries, individuals and entities. Our compliance department
has requested that we contact you . . . to obtain further
information concerning . . . MSA.) . . . Aguinaldo Jaime
responded, (MSA stands for Mehenou Satou Amousou Inc., which is
an American company specialized in management and investment,
headquartered in California, San Diego. Its president is Dr.
Mehenou Satou Amouzou. The 50 million deposit is a colateral
[sic] to guarantee a humanitarian funding for development
projects for the Republic of Angola.).......................... 759
93. GBank of America signature card for MSA Inc., dated June
2002, signed by Mehenou Amouzou and Aguinaldo Jaime (Banco
Nacional de Angolo)............................................ 762
94. GBank of America internal email, dated June 2002, re:
Assistance (. . . could you please ensure that the money [$50
million] stays frozen . . .) while investigating origins of
funds.......................................................... 763
95. GBanco Nacional de Angola correspondence to Bank of America,
dated June 2002, re: return of $50 million..................... 765
96. GCiti correspondence to the Permanent Subcommittee on
Investigations, dated August 2007, forwarding January 2003
memorandum recommending closure of Banco Nacional de Angola
account........................................................ 766
97. GWire transfer, dated 7/26/02, Banco Nacional de Angola
account at Equator Bank Limited Nassau......................... 768
98. GMSA Inc. correspondence to Stanley Wayland, European
American Investment, dated August 2002, (The instruction has
been giving [sic] to HSBC to purchase the $50M US Treasury
Bills as soon as possible and I was assured it would be done on
Monday and no later than Tuesday of this week in London.)...... 769
99. GMSA Inc. fax to Euro American Investment, dated August
2002, re: Typed Copy of Swift (HSBC London advise the Angola
government to protect their asset by opening an Offshore
account on behalf of Banco Nacional De Angola in Bahamas. . .
.)............................................................. 770
100. GEuro-American Investments Information Summary, dated August
2002, (These funds were received from the Central Bank of
Angola for and on behalf of the Angolan Government to manage
these funds and for Euro-American Investments to generate a
profit, monitor and invest in Angola for the support the people
of Angola both with regard to the infrastructure of Angola,
food, health, welfare, social services, low cost housing,
medical care, aids, et al.).................................... 771
101. GBanco Nacional de Angola Letter of Authority to Euro-
American Investment LLC and Banco Nacional de Angolo message to
HSBC Equator Bank/London, dated August 2002, (Please purchase
in our name and on our behalf United States Treasury bills . .
. in an aggregate amount of Fifty Million United States
Dollars. . . .)................................................ 778
102. GEmail from Stanley Wayland to Jan Heger, dated August 2002,
re: Treasury Bill (The Central Bank of Angola is the client and
owner of the funds and therefore, do not need to answer HSBC's
questions about why they must transfer the T-Bill to Wells
Fargo.)........................................................ 780
103. GBanco Nacional de Angola Deed of Assignment of $49,994,363
of U.S. Treasury Bills to Euro-American Investments LLC, dated
August 2002.................................................... 782
104. GHSBC Statement of Assets as of August 14, 2002 for Banco
Nacional de Angola, Total: $49,994,363.37...................... 783
105. GHSBC Bank wire transfer instructions from Aguinaldo Jaime,
dated 9/11/02, (This is my authority for you to transfer the
described Treasury bearing cusip . . . to Jan Morton Heger,
Wells Fargo Securities . . .).................................. 784
106. GHSBC Bank internal email, dated September 2002, re: Tbills
(. . . regarding the transfer of BNA's Treasury Bills, I will
be delivering the securities to the account of Jan Morton Heger
at Wells Fargo Bank . . .)..................................... 785
107. GWells Fargo Online Brokerage statement for Jan Morton
Heger, dated September 13, 2002, reflecting a $49,927,229.60
Total Account Value............................................ 786
108. GHSBC Bank wire transfer instructions from Aguinaldo Jaime,
dated 9/20/02, Amount: $50,749,000............................. 787
109. GBanco Nacional de Angola correspondence to HSBC, dated
October 2002, re: Canceling transfer........................... 788
110. GHSBC correspondence to Aguinaldo Jaime, dated November
2002, re: Safekeeping Receipt.................................. 791
111. GHSBC internal email, dated November 2002, re: HSBC Equator
and Central Bank of Angola (Maybe, you could investigate about
the above company (in such a way that neither BNA or them know
we are doing so), and hopefully the information obtained would
give us all the peace of mind that we can continue to assist
BNA in the implementation of, what they firmly believe, an
important accomplishment for Angola.).......................... 792
112. GHSBC internal email, dated October 2000, re: Banco Nacional
de Angola (BNA) (We are currently holding the funds at HEQB but
know that BNA prefers to keep their deposits in an offshore
account to avoid possible Mareva injunctions. It is for this
reason that we approached HSBC Nassau, with whom EBL shares an
office.)....................................................... 795
113. GHSBC Equator internal fax, dated October 2000, re: Banco
Nacional de Angola (BNA) (. . . Deposits with the Bahamas are
not subject to the Mareva injunctions associated with the U.K.) 797
114. GHSBC internal email, dated March 2006, re: Banco Africano
de Investimento (Please provide us with background information
on all owners with 5% or more shares in the bank.)............. 801
115. GHSBC internal email, dated October and December 2006, re:
Banco Africano de Investimentos (I understand that we have been
waiting from [sic] some crucial KYC information from this
client for some while--they should understand that having
accommodated them in this way they should be more responsive to
our KYC Inquiries.)............................................ 802
116. GHSBC internal email, dated April 2007, re: BAI Shareholder
Information.................................................... 805
117. GHSBC internal email, dated December 2006, re: Banco
Africano de Investimentos outstandings (The above shareholders
were created as special purpose vehicles and there are various
individuals with interests in these firms.).................... 807
118. GHSBC internal email, dated February 2007, re: BAI AML
practices (As discussed, please pull whatever strings and
obtain a copy of the AML policy and your English translation
where relevant (use our AML questionnaire as a guide.)......... 810
119. GHSBC ``Know Your Customer'' questionnaire for account of
Banco Africano de Investimentos, undated....................... 812
120. GHSBC internal email, dated May 2006, re: Banco Africano de
Investimentos (There is no AML monitoring taking place but we
can get a report on a regular basis that would show us all the
cardholders and their activity.)............................... 815
121. GHSBC internal email, dated May 2007, re: BAI Shareholder
Information (. . . I'm satisfied with the answers on
ownership.).................................................... 817
122. GHSBC internal email, dated April 2007, re: BAI, Angola
(Ordinarily partial ownership by a state owned oil company
would be a point of interest and little more but the fact that
this information is so deeply buried and you had to really
fight to obtain details of ownership of Sforza, Dabas and
Arcinella suggests a desire to veil the bank's ownership for
reasons that I do not understand . . .)........................ 818
123. GHSBC Call Report, dated April 2007, re: Banco Africano de
Investimentos (TG was reminded that additional details on the
SPVs/shareholding were outstanding.)........................... 819
124. GHSBC certification regarding correspondent accounts for
foreign banks for the account of BAI, dated September 2002..... 821
125. GHSBC ``Know Your Customer'' questionnaire for account of
Banco Africano de Investimentos Angola, dated 2005............. 826
Other Documents:
126. GCorrespondence from Neal Baddin to the Permanent
Subcommittee on Investigations, dated February 9, 2010,
regarding his testimony at February 4, 2010 Subcommittee
hearing........................................................ 829
127. GCorrespondence between the Permanent Subcommittee on
Investigations and The Honorable Barrie Walkley regarding
information about Jeffrey Birrell and Gabonese President Omar
Bongo.......................................................... 830
128. GCorrespondence between the Permanent Subcommittee on
Investigations and the International Monetary Fund regarding
Banco Nacional de Angola....................................... 837
129. GCorrespondence from the Embassy of the Republic of Angola
to the Permanent Subcommittee on Investigations regarding the
Subcommittee's report, Keeping Foreign Corruption Out of the
United States: Four Case Histories............................. 848
130. GResponses to supplemental questions for the record
submitted to Janice Ayala, Assistant Director, Office of
Investigations, Immigration and Customs Enforcement (ICE)...... 862
131. GResponses to supplemental questions for the record
submitted to James H. Freis, Jr., Director, Financial Crimes
Enforcement Network (FinCEN)................................... 864
132. GResponses to supplemental questions for the record
submitted to The Honorable David T. Johnson, Assistant
Secretary, Bureau of International Narcotics and Law
Enforcement Affairs, U.S. Department of State.................. 866
133. a. GResponses to supplemental questions for the record
submitted February 19, 2010, to Wiecher H. Mandemaker,
Director, General Compliance, Personal Financial Services Anti-
Money Laundering Compliance, HSBC Bank USA, N.A................ 869
b. GResponses to supplemental questions for the record
submitted April 2, 2010, to Wiecher H. Mandemaker, Director,
General Compliance, Personal Financial Services Anti-Money
Laundering Compliance, HSBC Bank USA, N.A...................... 877
134. GDocuments relating to Footnotes found in the Staff Report,
Keeping Foreign Corruption Out of the United States: Four Case
Histories, prepared by the Majority and Minority Staff of the
Permanent Subcommittee on Investigations in conjunction with
the Subcommittee hearing held February 4, 2010: [Note:
Footnotes not listed are explanative, reference Subcommittee
interviews for which records are not available to the public,
or reference a widely available public document.].............. 881
* Retained in the files of the Subcommittee
Footnote No. 67, See Attachment.................................. 881
Footnote No. 94, See Attachments (4) [1 attachment is retained in
the files of the Subcommittee.]................................ 882
Footnote No. 97, See Hearing Exhibit No. 28 (above).............. 555
Footnote No. 98, See Attachment.................................. 885
Footnote No. 99, See Attachments (3)............................. 888
Footnote No. 100, See Footnote No. 99 (above).................... 888
Footnote No. 101-102, See Hearing Exhibit No. 3 (above).......... 518
Footnote No. 103, See Attachment................................. 903
Footnote No. 104, See Attachments (2) [1 attachment is a SEALED
EXHIBIT]....................................................... 904
Footnote No. 106, See Attachment................................. 905
Footnote No. 107, See Footnote 99 (above)........................ 888
Footnote No. 108, See Hearing Exhibit No. 10 (above)............. 530
Footnote No. 109, See Attachment................................. 906
Footnote No. 110-112, See Footnote No. 109 (above)............... 906
Footnote No. 114, See Attachment................................. 910
Footnote No. 115, See Attachment................................. 911
Footnote No. 116-117, See Footnote No. 115 (above)............... 911
Footnote No. 118, See Attachment................................. 912
Footnote No. 119, See Footnote No. 99 (above).................... 888
Footnote No. 121, See Attachment................................. 913
Footnote No. 122, See Attachment and Hearing Exhibit No. 4
(above)..................................................... 914, 523
Footnote No. 123, See Attachment................................. 915
Footnote No. 125, See Attachment and Hearing Exhibit No. 6
(above)..................................................... 917, 526
Footnote No. 126, See Attachment................................. 918
Footnote No. 127, See Footnote No. 126 (above)................... 918
Footnote No. 128, See Attachments (7)............................ 926
Footnote No. 129-130, See Footnote No. 104, (above) SEALED
EXHIBIT........................................................ *
Footnote No. 134, See Attachment................................. 943
Footnote No. 135, See Footnote No. 134 (above)................... 943
Footnote No. 136, See Attachment and Footnote No. 134 (above). 947, 943
Footnote No. 138, See Attachment................................. 948
Footnote No. 139, See Attachment................................. 949
Footnote No. 142, See Attachment................................. 950
Footnote No. 143, See Attachment................................. 953
Footnote No. 144-145, See Footnote No. 143 (above)............... 953
Footnote No. 146-147, See Footnote No. 142 (above)............... 950
Footnote No. 148, See Attachment................................. 957
Footnote No. 149, See Attachment................................. 959
Footnote No. 150, See Attachment................................. 960
Footnote No. 151, SEALED EXHIBIT................................. *
Footnote No. 152-153, See Footnote No. 151 (above), SEALED
EXHIBIT........................................................ *
Footnote No. 154, See Hearing Exhibit No. 14 (above)............. 534
Footnote No. 155, See Attachment................................. 961
Footnote No. 156, See Attachment................................. 962
Footnote No. 157, See Attachment................................. 964
Footnote No. 158, See Attachment................................. 969
Footnote No. 159, See Attachment................................. 971
Footnote No. 160, See Footnote No. 151 (above), SEALED EXHIBIT... *
Footnote No. 165, See Attachment................................. 973
Footnote No. 166, See Attachment................................. 974
Footnote No. 167, See Footnote No. 67 (above).................... 881
Footnote No. 168, See Attachment................................. 975
Footnote No. 169, See Attachment................................. 977
Footnote No. 170, See Attachment................................. 978
Footnote No. 171, See Attachment................................. 979
Footnote No. 172, See Attachments (2) [1 attachment is a SEALED
EXHIBIT]....................................................... 1004
Footnote No. 173, See Footnote No. 171 (above)................... 979
Footnote No. 174, See Attachment................................. 1026
Footnote No. 175, See Attachment................................. 1027
Footnote No. 176, See Hearing Exhibit No. 5 (above).............. 524
Footnote No. 177, See Attachment................................. 1029
Footnote No. 178, See Attachment................................. 1030
Footnote No. 179, See Attachment................................. 1031
Footnote No. 180, See Footnote No. 171 (above)................... 979
Footnote No. 181, See Attachment and Footnote No. 172 (above 1032, 1004
Footnote No. 182, See Footnote No. 171 (above)................... 979
Footnote No. 183, See Attachments (2) and Footnote No. 172
(above)................................................... 1034, 1004
Footnote No. 185, See Attachment................................. 1036
Footnote No. 186, See Attachment................................. 1037
Footnote No. 187, See Attachments (2)............................ 1045
Footnote No. 188, See Footnote No. 172 and Hearing Exhibit No. 10
(above).................................................... 1004, 530
Footnote No. 189, See Attachment................................. 1047
Footnote No. 190, See Attachment and Footnote No. 172 (above 1048, 1004
Footnote No. 191, See Attachment................................. 1049
Footnote No. 192, See Attachment................................. 1050
Footnote No. 193-194, See Footnote No. 192 (above)............... 1050
Footnote No. 195, See Attachment................................. 1051
Footnote No. 196, See Attachments (2)............................ 1052
Footnote No. 197, See Attachment................................. 1054
Footnote No. 198, See Attachments (2) and Footnote Nos. 171 and
178
(above).............................................. 1055, 979, 1030
Footnote No. 199, See Attachment and Footnote Nos. 181 and 183
(above)............................................. 1057, 1032, 1034
Footnote No. 200, See Attachment and Footnote Nos. 171 and 183
(above).............................................. 1058, 979, 1034
Footnote No. 201, See Attachment................................. 1059
Footnote No. 202, See Footnote No. 186 (above)................... 1037
Footnote No. 203, See Attachment................................. 1060
Footnote No. 204, See Attachment................................. 1061
Footnote No. 206, See Attachment................................. 1062
Footnote No. 207, See Footnote No. 206 (above)................... 1062
Footnote No. 208, See Footnote No. 104 (above), SEALED EXHIBIT... *
Footnote No. 209, See Attachment................................. 1068
Footnote No. 210, See Attachment................................. 1071
Footnote No. 211, See Attachment................................. 1072
Footnote No. 212, See Footnote No. 94 (above).................... 882
Footnote No. 215, See Attachment................................. 1073
Footnote No. 216-220, See Footnote No. 215 (above)............... 1073
Footnote No. 221, See Attachment................................. 1087
Footnote No. 222, See Attachment................................. 1088
Footnote No. 223, See Attachment................................. 1089
Footnote No. 225, See Footnote No. 215 (above)................... 1073
Footnote No. 226, See Attachment................................. 1090
Footnote No. 227, See Footnote 226 (above)....................... 1090
Footnote No. 228, See Attachment................................. 1091
Footnote No. 229, See Attachment and Footnote No. 115 (above) 1092, 911
Footnote No. 231, See Attachment and Footnote No. 215 (above 1094, 1073
Footnote No. 232, See Attachment................................. 1102
Footnote No. 233, See Attachment................................. 1105
Footnote No. 234, See Footnote No. 233 (above)................... 1105
Footnote No. 235, See Attachment................................. 1106
Footnote No. 236, See Attachment................................. 1114
Footnote No. 237, See Footnote No. 236 (above)................... 1114
Footnote No. 238, See Hearing Exhibit No. 29 (above)............. 561
Footnote No. 240, See Attachment................................. 1115
Footnote No. 241-242, See Footnote No. 215 (above)............... 1073
Footnote No. 243, See Attachment and Footnote No. 232 (above 1116, 1102
Footnote No. 244, See Attachment................................. 1117
Footnote No. 245, See Attachments (2)............................ 1120
Footnote No. 246, See Attachment and Footnote No. 215 (above 1133, 1073
Footnote No. 247, See Attachment................................. 1139
Footnote No. 248, See Attachment and Footnote No. 247 (above 1143, 1139
Footnote No. 249, See Attachment................................. 1145
Footnote No. 250, See Attachment................................. 1146
Footnote No. 252, See Hearing Exhibit No. 19 (above)............. 545
Footnote No. 253, See Attachment................................. 1151
Footnote No. 255, See Footnote No. 250 (above)................... 1146
Footnote No. 256, See Attachment................................. 1153
Footnote No. 257, See Footnote No. 253 (above)................... 1151
Footnote No. 258, See Attachment................................. 1155
Footnote No. 259, See Attachment................................. 1156
Footnote No. 260, See Hearing Exhibit No. 18 (above)............. 544
Footnote No. 261, See Attachment and Footnote No. 244 (above 1157, 1117
Footnote No. 262, See Hearing Exhibit No. 19 (above)............. 545
Footnote No. 264, See Hearing Exhibit No. 18 (above)............. 544
Footnote No. 265, See Attachment................................. 1158
Footnote No. 266, See Hearing Exhibit No. 18 (above)............. 544
Footnote No. 267, See Attachment................................. 1159
Footnote No. 268, See Attachment................................. 1160
Footnote No. 270, See Attachment................................. 1161
Footnote No. 271, See Attachment and Footnote No. 215 (above 1162, 1073
Footnote No. 274, See Attachments (2)............................ 1164
Footnote No. 275, See Attachment................................. 1171
Footnote No. 276, See Attachments (3) and Footnote No. 274
(above)................................................... 1176, 1164
Footnote No. 277, SEALED EXHIBIT and See Footnote No. 276 (above) 1176
Footnote No. 278, See Attachment................................. 1179
Footnote No. 282, See Attachments (2)............................ 1182
Footnote No. 284, See Attachment................................. 1184
Footnote No. 285, See Footnote No. 284 (above)................... 1184
Footnote No. 288, See Hearing Exhibit No. 20 (above)............. 546
Footnote No. 289, See Attachment................................. 1185
Footnote No. 290, See Attachment................................. 1186
Footnote No. 292, See Footnote No. 290 (above)................... 1186
Footnote No. 293, See Attachment................................. 1192
Footnote No. 295-297, See Footnote No. 290 (above)............... 1186
Footnote No. 298-199, See Footnote No. 67 (above)................ 881
Footnote No. 300, See Attachment................................. 1193
Footnote No. 301-302, See Footnote No. 300 (above)............... 1193
Footnote No. 303, See Attachment................................. 1200
Footnote No. 304, See Footnote No. 168 (above)................... 975
Footnote No. 305, See Attachment................................. 1201
Footnote No. 306-307, See Footnote No. 215 (above)............... 1073
Footnote No. 308, See Attachment and Footnote No. 215 (above 1204, 1073
Footnote No. 309-310, See Footnote No. 215 (above)............... 1973
Footnote No. 311, See Attachment and Footnote No. 215 (above 1205, 1073
Footnote No. 312, See Attachment................................. 1206
Footnote No. 313, See Footnote No. 215 (above)................... 1073
Footnote No. 314, See Attachment................................. 1207
Footnote No. 315, See Attachment................................. 1208
Footnote No. 316-319, See Footnote No. 215 (above)............... 1073
Footnote No. 320, See Attachment................................. 1209
Footnote No. 321, See Footnote No. 320 (above)................... 1209
Footnote No. 322, See Footnote No. 215 (above)................... 1073
Footnote No. 323, See Hearing Exhibit No. 3 (above).............. 518
Footnote No. 324, See Attachment................................. 1210
Footnote No. 330, See Hearing Exhibit No. 23 (above)............. 549
Footnote No. 333, See Footnote No. 215 (above)................... 1073
Footnote No. 334, See Attachments (3). [1 attachment is retained
in
the files of the Subcommittee.]................................ 1211
Footnote No. 335, See Attachment................................. 1213
Footnote No. 337, See Attachment................................. 1214
Footnote No. 338, See Attachment................................. 1217
Footnote No. 339, See Attachment................................. 1220
Footnote No. 340, See Attachments (3) and Footnote No. 339
(above)................................................... 1240, 1220
Footnote No. 341, See Attachment................................. 1251
Footnote No. 342, See Attachment................................. 1261
Footnote No. 343, See Attachment................................. 1265
Footnote No. 344, See Attachment and Footnote No. 340 (above 1266, 1240
Footnote No. 345, See Attachments (2) and Footnote No. 215
(above)................................................... 1267, 1073
Footnote No. 346, See Attachments (2)............................ 1269
Footnote No. 347, See Attachment and Footnote Nos. 337 and 345
(above)............................................. 1272, 1214, 1267
Footnote No. 349, SEALED EXHIBIT and See Footnote No. 282 (above) 1182
Footnote No. 350, See Attachment................................. 1273
Footnote No. 351-352, See Hearing Exhibit No. 23 (above)......... 549
Footnote No. 353, See Attachment................................. 1276
Footnote No. 355, SEALED EXHIBIT................................. *
Footnote No. 356-359, See Footnote No. 355, SEALED EXHIBIT....... *
Footnote No. 361, See Attachment................................. 1279
Footnote No. 362, See Attachment................................. 1280
Footnote No. 363, See Attachment................................. 1282
Footnote No. 365, See Attachments (2) and Footnote No. 363
(above)................................................... 1284, 1282
Footnote No. 366, See Attachment................................. 1287
Footnote No. 368, See Attachments (2)............................ 1288
Footnote No. 369, See Attachment................................. 1292
Footnote No. 370, See Footnote No. 369 (above)................... 1292
Footnote No. 371, See Attachment................................. 1294
Footnote No. 372, See Hearing Exhibit No. 24 (above)............. 551
Footnote No. 374, See Attachment................................ 1298
Footnote No. 375-376, See Footnote No. 374 (above)............... 1298
Footnote No. 377, See Attachment................................. 1301
Footnote No. 378-381, See Footnote No. 368 (above)............... 1288
Footnote No. 382, See Attachment................................. 1304
Footnote No. 383, See Footnote No. 368 (above)................... 1288
Footnote No. 384, See Hearing Exhibit No. 26 (above)............. 553
Footnote No. 385-386, See Hearing Exhibit No. 25 (above)......... 552
Footnote No. 387, See Attachment................................. 1307
Footnote No. 388, See Footnote No. 387 (above)................... 1307
Footnote No. 389, See Attachment................................. 1308
Footnote No. 390, See Attachment and Footnote No. 389 (above 1311, 1308
Footnote No. 391, See Attachment................................. 1313
Footnote No. 392, See Attachment................................. 1315
Footnote No. 393, See Footnote No. 391........................... 1313
Footnote No. 394, See Attachments (3)............................ 1316
Footnote No. 395, See Attachment................................. 1327
Footnote No. 396, See Hearing Exhibit No. 23 (above)............. 549
Footnote No. 397, See Attachment................................. 1328
Footnote No. 398, See Attachment................................. 1333
Footnote No. 399, See Attachment................................. 1335
Footnote No. 400, See Attachment................................. 1339
Footnote No. 401, See Attachment................................. 1340
Footnote No. 402, See Footnote No. 400 (above)................... 1339
Footnote No. 404, See Attachments (2), Footnote No. 368 and
Hearing Exhibit No. 25 (above)....................... 1341, 1288, 552
Footnote No. 413, See Hearing Exhibit No. 28 (above)............. 555
Footnote No. 415, See Attachment................................. 1343
Footnote No. 417 and 419-420, See Footnote No. 209 (above)....... 1068
Footnote No. 422, See Attachment................................. 1346
Footnote No. 423, 425 and 427, See Footnote No. 209 (above)...... 1068
Footnote No. 430, See Attachment................................. 1347
Footnote No. 431, See Attachment................................. 1348
Footnote No. 432, See Attachments (2)............................ 1350
Footnote No. 433, See Attachment................................. 1354
Footnote No. 435, See Hearing Exhibit No. 29 (above)............. 561
Footnote No. 436, See Attachment................................. 1355
Footnote No. 438, See Attachment................................. 1358
Footnote No. 439, See Footnote 209 (above)....................... 1068
Footnote No. 440, See Attachment and Footnote No. 209 (above 1360, 1068
Footnote No. 442, See Hearing Exhibit No. 30 (above)............. 567
Footnote No. 443, See Footnote No. 433 (above)................... 1354
Footnote No. 446, See Attachment................................. 1362
Footnote No. 448, See Attachment................................. 1377
Footnote No. 450, See Attachment................................. 1378
Footnote No. 451-452, See Footnote No. 209 (above)............... 1068
Footnote No. 455, See Attachment................................. 1380
Footnote No. 456, See Attachment................................. 1381
Footnote No. 457-461, See Footnote No. 456 (above)............... 1381
Footnote No. 463, See Attachment................................. 1397
Footnote No. 464-465, See Footnote No. 463 (above)............... 1397
Footnote No. 466, See Attachment................................. 1398
Footnote No. 467, See Footnote No. 151 (above), SEALED EXHIBIT... *
Footnote No. 470, See Attachments (6) and Footnote No. 456
(above)................................................... 1399, 1381
Footnote No. 471-472, See Footnote No. 456 (above)............... 1381
Footnote No. 476-478, See Footnote No. 432 (above)............... 1350
Footnote No. 479, See Attachment................................. 1433
Footnote No. 480, See Attachment................................. 1434
Footnote No. 481-486, See Footnote No. 432 (above)............... 1350
Footnote No. 488, See Attachment................................. 1436
Footnote No. 489, See Footnote No. 488 (above)................... 1436
Footnote No. 490, See Attachment................................. 1465
Footnote No. 492, See Attachment and Footnote No. 488 (above 1467, 1436
Footnote No. 493, See Footnote No. 488 (above)................... 1436
Footnote No. 494, See Footnote No. 492 (above)................... 1467
Footnote No. 495, See Footnote No. 488 (above)................... 1436
Footnote No. 496, See Attachment................................. 1479
Footnote No. 497, See Attachment................................. 1487
Footnote No. 498, See Attachment................................. 1489
Footnote No. 499, See Footnote No. 497 (above)................... 1487
Footnote No. 500, See Attachment................................. 1492
Footnote No. 501-502, See Footnote No. 498 (above)............... 1489
Footnote No. 506, See Attachment................................. 1494
Footnote No. 507, See Attachment and Footnote No. 506 (above).... 1502
Footnote No. 508, See Footnote No. 507 (above)................... 1502
Footnote No. 509, See Attachments (3)............................ 1504
Footnote No. 510, See Footnote No. 506 and 509 (above)...... 1494, 1504
Footnote No. 511, See Attachment................................. 1512
Footnote No. 512, See Attachment................................. 1518
Footnote No. 513, See Attachment................................. 1524
Footnote No. 514, See Footnote No. 513 (above)................... 1524
Footnote No. 515, See Attachment................................. 1527
Footnote No. 516, See Attachment................................. 1529
Footnote No. 517, See Attachment................................. 1539
Footnote No. 518, See Attachment................................. 1549
Footnote No. 519, See Hearing Exhibit No. 32 (above)............. 570
Footnote No. 521, See Attachments (2)............................ 1550
Footnote No. 522, See Hearing Exhibit No. 33 (above)............. 580
Footnote No. 523, See Hearing Exhibit No. 34 (above)............. 581
Footnote No. 524, See Attachment................................. 1555
Footnote No. 525, See Attachment................................. 1558
Footnote No. 526, See Footnote No. 525 (above)................... 1558
Footnote No. 527, See Attachment................................. 1565
Footnote No. 528, See Attachments (2)............................ 1571
Footnote No. 529, See Attachment................................. 1574
Footnote No. 530, See Attachment................................. 1575
Footnote No. 531, See Attachment................................. 1576
Footnote No. 532, See Attachment................................. 1578
Footnote No. 533, See Attachment................................. 1580
Footnote No. 534, See Footnote No. 533 (above)................... 1580
Footnote No. 535, See Attachment................................. 1582
Footnote No. 536, See Attachment................................. 1585
Footnote No. 537, See Attachment................................. 1586
Footnote No. 538-539, See Footnote No. 537 (above)............... 1586
Footnote No. 540, See Attachment................................. 1588
Footnote No. 541, See Attachment and Footnote Nos. 506 and 516
(above)............................................. 1592, 1494, 1529
Footnote No. 542, See Attachment................................. 1595
Footnote No. 543, See Attachments (4) and Footnote No. 530
(above)................................................... 1598, 1575
Footnote No. 545, See Attachment................................. 1602
VOLUME 2
Footnote No. 546, See Attachment................................. 1603
Footnote No. 547, See Attachment................................. 1604
Footnote No. 548, See Attachment................................. 1606
Footnote No. 549, See Attachments (2)............................ 1607
Footnote No. 550, See Footnote Nos. 400 and 401 (above)..... 1339, 1340
Footnote No. 551, See Attachment................................. 1612
Footnote No. 552, SEALED EXHIBIT................................. *
Footnote No. 557, See Attachment................................. 1615
Footnote 559, See Footnote 552 (above) SEALED EXHIBIT............ *
Footnote No. 562, SEALED EXHIBIT................................. *
Footnote No. 563-566, See Footnote No. 562 (above) SEALED EXHIBIT *
Footnote No. 567, See Footnote No. 432 (above)................... 1350
Footnote No. 584, See Attachment................................. 1617
Footnote No. 585, See Footnote No. 584 (above)................... 1617
Footnote No. 586, See Attachment................................. 1630
Footnote No. 587, See Footnote No. 586 (above)................... 1630
Footnote No. 590, See Attachment................................. 1637
Footnote No. 594, See Attachments (7)............................ 1639
Footnote No. 595, See Attachment................................. 1648
Footnote No. 597, See Attachment................................. 1649
Footnote No. 598, See Attachments (3)............................ 1651
Footnote No. 599, See Attachment................................. 1666
Footnote No. 600, See Attachment................................. 1667
Footnote No. 601, See Attachments (2)............................ 1669
Footnote No. 602, See Attachments (2)............................ 1671
Footnote No. 604, See Attachment................................. 1674
Footnote No. 605, See Attachment and Footnote No. 602 (above 1675, 1671
Footnote No. 606, See Attachment................................. 1676
Footnote No. 607, See Attachment................................. 1678
Footnote No. 608, See Attachments (2)............................ 1679
Footnote No. 611, See Attachments (3)............................ 1682
Footnote No. 612, See Attachment................................. 1685
Footnote No. 613, See Attachments (2)............................ 1686
Footnote No. 615, See Attachments (2)............................ 1688
Footnote No. 616, See Attachments (2)............................ 1691
Footnote No. 617, See Attachment and Footnote No. 611 (above 1694, 1682
Footnote No. 618, See Attachments (2)............................ 1695
Footnote No. 619, See Attachments (3)............................ 1697
Footnote No. 620, See Attachments (2)............................ 1700
Footnote No. 621, See Attachment................................. 1702
Footnote No. 622, See Attachments (2) and Footnote No. 613
(above)................................................... 1703, 1686
Footnote No. 623, See Footnote No. 619 (above)................... 1697
Footnote No. 624, See Footnote No. 611 (above)................... 1682
Footnote No. 625-626, See Footnote No. 613 (above)............... 1686
Footnote No. 627, See Attachment................................. 1707
Footnote No. 628, See Attachment................................. 1708
Footnote No. 629, See Attachment................................. 1709
Footnote No. 630, See Attachment................................. 1710
Footnote No. 631, See Footnote No. 630 (above)................... 1710
Footnote No. 632, See Attachment................................. 1712
Footnote No. 633, See Attachment................................. 1715
Footnote No. 634, See Attachment................................. 1716
Footnote No. 636, See Attachment................................. 1717
Footnote No. 637, See Footnote No. 636 (above)................... 1717
Footnote No. 638, See Attachment................................. 1718
Footnote No. 639, See Attachment................................. 1720
Footnote No. 640, See Attachment and Footnote No. 620 (above 1721, 1700
Footnote No. 641, See Footnote No. 611 (above)................... 1682
Footnote No. 642, See Attachment................................. 1722
Footnote No. 643, See Attachment................................. 1723
Footnote No. 645, See Attachment................................. 1724
Footnote No. 646, See Attachments (2) and Footnote No. 645
(above)................................................... 1726, 1724
Footnote No. 647, See Attachment................................. 1728
Footnote No. 648, See Attachment................................. 1730
Footnote No. 649, See Attachment................................. 1732
Footnote No. 650, See Footnote No. 608 (above)................... 1679
Footnote No. 651, See Attachment................................. 1734
Footnote No. 652, See Attachment................................. 1735
Footnote No. 653, See Attachment................................. 1736
Footnote No. 654, SEALED EXHIBIT................................. *
Footnote No. 655, See Footnote No. 618 (above)................... 1695
Footnote No. 656, See Attachment................................. 1737
Footnote No. 665, See Attachments (3)............................ 1738
Footnote No. 666, See Attachment................................. 1753
Footnote No. 667, See Attachment................................. 1754
Footnote No. 668, See Attachment and Footnote No. 667 (above 1756, 1754
Footnote No. 669, See Attachment and Footnote No. 606 (above 1757, 1676
Footnote No. 670, See Attachment................................. 1758
Footnote No. 671, See Attachments (2)............................ 1759
Footnote No. 672, See Attachments (2)............................ 1762
Footnote No. 673, See Attachment................................. 1764
Footnote No. 674, See Attachment and Footnote No. 672 (above 1766, 1762
Footnote No. 675, See Attachment................................. 1767
Footnote No. 676, See Attachment................................. 1769
Footnote No. 677, See Footnote No. 602 (above)................... 1671
Footnote No. 678, See Attachments (2)............................ 1771
Footnote No. 679, See Attachment................................. 1773
Footnote No. 680, See Attachment................................. 1774
Footnote No. 681, See Attachment................................. 1775
Footnote No. 682, See Attachment................................. 1777
Footnote No. 683, See Attachment................................. 1779
Footnote No. 684, See Footnote No. 683 (above)................... 1779
Footnote No. 685, See Attachment................................. 1782
Footnote No. 686, See Attachment................................. 1783
Footnote No. 687, See Attachment................................. 1785
Footnote No. 688, See Footnote No. 687 (above)................... 1785
Footnote No. 689, See Attachments (2)............................ 1788
Footnote No. 690, See Attachment................................. 1797
Footnote No. 691, See Attachment................................. 1798
Footnote No. 692, See Attachments (3)............................ 1801
Footnote No. 693, See Attachment................................. 1805
Footnote No. 694, See Attachment and Footnote No. 692 (above 1806, 1801
Footnote No. 695, See Attachments (6)............................ 1808
Footnote No. 696, See Attachment................................. 1817
Footnote No. 697, See Footnote No. 679........................... 1773
Footnote No. 698, See Attachment................................. 1818
Footnote No. 699, See Footnote No. 698 (above)................... 1818
Footnote No. 700, See Attachment................................. 1819
Footnote No. 701, See Attachment................................. 1820
Footnote No. 704, See Attachment................................. 1821
Footnote No. 705, See Attachment................................. 1825
Footnote No. 706, See Footnote No. 705........................... 1825
Footnote No. 707, See Attachment................................. 1829
Footnote No. 708, See Attachment................................. 1832
Footnote No. 709, See Attachment................................. 1834
Footnote No. 710, See Attachments (4)............................ 1837
Footnote No. 711, See Attachment................................. 1845
Footnote No. 713, See Attachment................................. 1846
Footnote No. 714, See Attachments (2)............................ 1847
Footnote No. 715, See Attachments (2)............................ 1850
Footnote No. 716, See Attachment and Footnote No. 715 (above 1853, 1850
Footnote No. 717, See Attachment................................. 1855
Footnote No. 718, See Attachment................................. 1856
Footnote No. 719, See Attachments (2)............................ 1857
Footnote No. 720, See Attachment................................. 1859
Footnote No. 721, See Footnote No. 720 (above)................... 1859
Footnote No. 722, See Attachments (4)............................ 1863
Footnote No. 723, See Attachment................................. 1870
Footnote No. 724, See Attachment................................. 1871
Footnote No. 725, See Footnote No. 722 (above)................... 1863
Footnote No. 726, See Attachment................................. 1872
Footnote No. 728, See Attachments (4)............................ 1873
Footnote No. 729, See Attachment................................. 1878
Footnote No. 731, See Attachment................................. 1879
Footnote No. 732, See Attachment................................. 1880
Footnote No. 733, See Attachment................................. 1881
Footnote No. 734, See Attachment................................. 1883
Footnote No. 735, See Attachment................................. 1884
Footnote No. 736, See Attachment................................. 1887
Footnote No. 737, See Attachment................................. 1889
Footnote No. 738, See Attachment................................. 1890
Footnote No. 739, See Attachment................................. 1892
Footnote No. 740, See Attachments (2)............................ 1893
Footnote No. 741, See Attachment................................. 1895
Footnote No. 742, See Footnote No. 740 (above)................... 1893
Footnote No. 743, See Attachment................................. 1896
Footnote No. 744, See Attachments (3)............................ 1897
Footnote No. 745, See Attachment................................. 1900
Footnote No. 746, See Attachment................................. 1901
Footnote No. 747, See Attachment................................. 1902
Footnote No. 748, See Attachment................................. 1904
Footnote No. 749, See Attachment................................. 1905
Footnote No. 751, See Attachment................................. 1906
Footnote No. 752, See Attachment................................. 1908
Footnote No. 753, See Attachment................................. 1909
Footnote No. 754, See Attachment, and Footnote No. 751 (abov 1910, 1906
Footnote No. 755, See Attachment................................. 1911
Footnote No. 756, See Footnote No. 755 (above)................... 1911
Footnote No. 757, See Attachment................................. 1914
Footnote No. 758, See Attachment and Hearing Exhibit No. 60
(above).................................................... 1916, 685
Footnote No. 759, See Hearing Exhibit No. 60 (above)............. 685
Footnote No. 760, See Attachment................................. 1918
Footnote No. 761, See Attachment................................. 1921
Footnote No. 762, See Attachment................................. 1923
Footnote No. 763, See Attachment................................. 1924
Footnote No. 764, See Attachment................................. 1926
Footnote No. 765, See Attachment................................. 1927
Footnote No. 766, See Attachment................................. 1928
Footnote No. 767, See Attachment................................. 1929
Footnote No. 768, See Attachment................................. 1933
Footnote No. 769, See Attachment................................. 1954
Footnote No. 770, See Attachment................................. 1957
Footnote No. 771, See Attachment................................. 1958
Footnote No. 772, See Attachments (4) and Footnote No. 767
(above)................................................... 1975, 1929
Footnote No. 773, See Attachment and Footnote No. 772 1981, 1975, 1929
Footnote No. 774, See Attachment................................. 1982
Footnote No. 775, See Attachment................................. 1983
Footnote No. 778, See Attachment................................. 1984
Footnote No. 779, See Attachment and Footnote No. 747 (above 1986, 1902
Footnote No. 780, See Footnote No. 747 (above)................... 1902
Footnote No. 781, See Attachment................................. 1987
Footnote No. 783, See Footnote No. 747 (above)................... 1902
Footnote No. 784, See Attachment and Footnote No. 675 (above 1988, 1767
Footnote No. 785, See Footnote No. 676 (above)................... 1769
Footnote No. 786, See Footnote No. 695 (above)................... 1808
Footnote No. 787, See Footnote No. 747 (above)................... 1902
Footnote Nos. 788-789, See Footnote No. 692 (above).............. 1801
Footnote No. 790, See Footnote No. 714 (above)................... 1847
Footnote No. 791, See Footnote No. 715 (above)................... 1850
Footnote No. 792, See Footnote No. 746 (above)................... 1901
Footnote Nos. 794-795, See Footnote No. 705 (above).............. 1825
Footnote No. 796, See Attachment................................. 1989
Footnote No. 798, See Attachment................................. 1990
Footnote No. 799, See Attachment................................. 1991
Footnote No. 802, See Attachment................................. 1992
Footnote No. 803, See Attachment................................. 1993
Footnote No. 804, See Attachment................................. 1994
Footnote No. 805, See Attachment................................. 1995
Footnote No. 806, See Attachment................................. 1996
Footnote No. 807, See Attachment................................. 1997
Footnote No. 809, See Attachment................................. 2009
Footnote No. 812, See Attachment................................. 2012
Footnote No. 814, See Attachment................................. 2013
Footnote No. 815, See Attachment................................. 2014
Footnote No. 817, See Attachment................................. 2015
Footnote No. 818, See Attachment................................. 2024
Footnote No. 819, See Footnote No. 817 (above)................... 2015
Footnote No. 821, See Attachment................................. 2025
Footnote No. 822-823, See Footnote No. 817 (above)............... 2015
Footnote No. 825, See Footnote No. 821 (above)................... 2025
Footnote No. 826, See Attachment................................. 2027
Footnote No. 828, See Footnote No. 821 (above)................... 2025
Footnote No. 830, See Attachment................................. 2029
Footnote No. 831, See Attachment................................. 2031
Footnote No. 832, See Attachment and Footnote No. 817 (above 2032, 2015
Footnote No. 833, See Attachment................................. 2033
Footnote No. 834, See Attachment................................. 2034
Footnote No. 835, See Attachment................................. 2035
Footnote No. 836-838, See Footnote No. 835 (above)............... 2035
Footnote No. 841, See Footnote No. 817 (above)................... 2015
Footnote No. 842, See Attachment................................. 2036
Footnote No. 843, See Footnote No. 842 (above)................... 2036
Footnote No. 844, See Attachment................................. 2040
Footnote No. 845, See Attachment................................. 2042
Footnote No. 847, See Attachment................................. 2043
Footnote No. 848, See Footnote No. 817 (above)................... 2015
Footnote No. 849-851, See Footnote No. 842 (above)............... 2036
Footnote No. 852, See Footnote No. 817 (above)................... 2015
Footnote No. 853, See Attachment................................. 2044
Footnote No. 854-856, See Footnote No. 853 (above)............... 2044
Footnote No. 862, See Attachment................................. 2047
Footnote No. 863-864, See Footnote No. 817 (above)............... 2015
Footnote No. 865, See Attachment................................. 2048
Footnote No. 866, See Attachment................................. 2049
Footnote No. 867, See Attachment................................. 2050
Footnote No. 868, See Footnote No. 817 (above)................... 2015
Footnote No. 869, See Attachment................................. 2051
Footnote No. 870, See Attachments (2)............................ 2052
Footnote No. 871, See Footnote No. 870 (above)................... 2052
Footnote No. 872, See Attachment and Footnote No. 817 (above 2057, 2015
Footnote No. 873-876, See Footnote No. 870 (above)............... 2052
Footnote No. 878, See Attachment................................. 2059
Footnote No. 879, See Attachment................................. 2061
Footnote No. 880-882, See Footnote No. 879 (above)............... 2061
Footnote No. 883, See Attachment................................. 2063
Footnote No. 884, See Attachment................................. 2065
Footnote No. 885-886, See Footnote No. 817 (above)............... 2015
Footnote No. 887, See Attachment................................. 2068
Footnote No. 888, See Attachments (2)............................ 2070
Footnote No. 889, See Attachments (2)............................ 2072
Footnote No. 893, See Attachment................................. 2074
Footnote No. 896, See Attachments (2)............................ 2077
Footnote No. 897, See Attachment................................. 2079
Footnote No. 901, See Footnote No. 897 (above)................... 2079
Footnote No. 904-905, See Footnote No. 897 (above)............... 2079
Footnote No. 906, See Attachment................................. 2084
Footnote No. 907, See Attachments (2) and Footnote No. 897
(above)................................................... 2086, 2079
Footnote No. 908, See Attachments (3)............................ 2093
Footnote No. 909, See Attachments (2)............................ 2101
Footnote No. 910, See Attachment and Footnote No. 908 (above 2105, 2093
Footnote No. 911, See Footnote No. 910 (above).............. 2105, 2093
Footnote No. 912, See Attachment and Footnote Nos. 896 and 897
(above)............................................. 2106, 2077, 2079
Footnote No. 913, See Footnote Nos. 897 and 910 (above)..... 2079, 2105
Footnote No. 917-918, See Footnote No. 897 (above)............... 2079
Footnote No. 919, See Attachments (3)............................ 2107
Footnote No. 920, See Attachments (6)............................ 2111
Footnote No. 921, See Attachment................................. 2123
Footnote No. 922, See Footnote No. 919 (above)................... 2107
Footnote No. 923, See Attachment................................. 2124
Footnote No. 924, See Footnote No. 923 (above)................... 2124
Footnote No. 926, See Attachment................................ 2126
Footnote No. 927, See Attachment and Footnote No. 926 (above 2128, 2126
Footnote No. 928-929, See Footnote No. 896 (above)............... 2077
Footnote No. 930, See Attachment................................. 2129
Footnote No. 932, See Attachment................................. 2141
Footnote No. 933, See Attachment................................. 2146
Footnote No. 934, See Attachment................................. 2147
Footnote No. 935, See Attachment................................. 2148
Footnote No. 936, See Attachment................................. 2149
Footnote No. 937, See Attachment................................. 2150
Footnote No. 938, See Attachment................................. 2151
Footnote No. 939, See Footnote No. 938 (above)................... 2151
Footnote No. 940, See Footnote No. 936 (above)................... 2149
Footnote No. 941, See Attachment................................. 2152
Footnote Nos. 942-943, See Footnote No. 920 (above).............. 2111
Footnote No. 944, See Attachments (2)............................ 2153
Footnote No. 945, See Attachment................................. 2156
Footnote No. 946, See Footnote No. 932 (above)................... 2141
Footnote No. 947, See Attachment................................. 2157
Footnote No. 948, See Attachment and Footnote No. 932 (above 2158, 2141
Footnote No. 949, See Attachment................................. 2159
Footnote No. 951, See Attachment................................. 2160
Footnote No. 952, See Footnote No. 951 (above)................... 2160
Footnote No. 981, See Attachment................................. 2162
Footnote No. 985-986, See Footnote No. 981 (above)............... 2162
Footnote No. 989, See Attachments (2)............................ 2168
Footnote No. 991, See Attachment................................. 2173
Footnote No. 992, See Attachment................................. 2183
Footnote No. 993, See Attachment and Footnote Nos. 981,
989 and 992 (above)........................... 2186, 2162, 2168, 2183
Footnote No. 995, See Attachment................................. 2219
Footnote No. 996, See Attachment and Footnote Nos. 981
and 992 (above)..................................... 2251, 2162, 2183
Footnote No. 997-998, See Footnote No. 996 (above)............... 2251
Footnote No. 999, See Footnote No. 992 (above)................... 2183
Footnote No. 1000, See Footnote No. 989 (above).................. 2168
Footnote No. 1001, See Footnote No. 996 (above).................. 2251
Footnote No. 1002, See Footnote Nos. 981 and 992 (above).... 2162, 2183
Footnote No. 1003-1004, See Footnote Nos. 992 and 996 (above 2183, 2251
Footnote No. 1005, See Footnote Nos. 981 and 996 (above).... 2162, 2251
Footnote No. 1006, See Footnote Nos. 989 and 993 (above).... 2168, 2186
Footnote No. 1007-1009, See Footnote No. 981 (above)............. 2162
Footnote No. 1018, See Attachment................................ *
Footnote No. 1020, See Attachment................................ 2257
Footnote No. 1024, See Footnote No. 1020 (above)................. 2257
Footnote No. 1026, See Attachments (2)........................... 2260
Footnote No. 1027, See Attachments (2), Footnote Nos. 186
and 1020 and Hearing Exhibit No. 76 (above).... 2262, 1037, 2257, 719
Footnote No. 1028, See Footnote No. 1027 (above)................. 2262
Footnote No. 1029, See Attachment................................ 2275
Footnote No. 1030, See Footnote No. 1027 (above)................. 2262
Footnote No. 1031, See Footnote 995.............................. 2219
Footnote No. 1036, See Attachments (2)........................... 2276
Footnote No. 1039, See Footnote No. 995 (above).................. 2219
Footnote No. 1040, SEALED EXHIBIT and See Footnote No. 995
(above)........................................................ 2219
Footnote No. 1041-1043, See Footnote No. 995 (above)............. 2219
Footnote No. 1044, See Footnote No. 996 (above).................. 2251
Footnote No. 1047-1049, See Footnote No. 996 (above)............. 2251
Footnote No. 1051, See Attachment................................ 2278
Footnote No. 1052, See Footnote 186 (above)...................... 1037
Footnote No. 1053, See Footnote No. 1051 (above)................. 2278
Footnote No. 1054, See Footnote No. 186 (above).................. 1037
Footnote No. 1056, See Footnote Nos. 186 and 1051 (above)... 1037, 2278
Footnote No. 1057, See Footnote No. 186 (above).................. 1037
Footnote No. 1058, See Footnote Nos. 186 and 1051 (above)... 1037, 2278
Footnote No. 1060, See Footnote No. 1051 (above)................. 2278
Footnote No. 1061, See Attachment and Footnote No. 186 (abov 2280, 1037
Footnote No. 1062, See Attachment and Footnote No. 1051 (abo 2282, 2278
Footnote No. 1063, See Footnote No. 1062 (above)................. 2282
Footnote No. 1064, See Attachment................................ 2285
Footnote No. 1066, See Footnote No. 1051 (above)................. 2278
Footnote No. 1067, See Footnote No. 186 (above).................. 1037
Footnote No. 1068, See Attachments (2)........................... 2290
Footnote No. 1069, See Footnote No. 995 (above).................. 2219
Footnote No. 1070, See Footnote No. 186 (above).................. 1037
Footnote No. 1071, See Attachment................................ 2307
Footnote No. 1072, See Footnote No. 995 (above).................. 2219
Footnote No. 1074, See Attachment................................ 2311
Footnote No. 1075-1079, See Footnote No. 186 (above)............. 1037
Footnote No. 1081, See Footnote No. 186 (above).................. 1037
Footnote No. 1083, See Attachment................................ 2314
Footnote No. 1084-1086, See Footnote No. 186 (above)............. 1037
Footnote No. 1087, See Attachment................................ 2316
Footnote No. 1091, See Attachment and Footnote No. 186 (abov 2318, 1037
Footnote No. 1097, See Attachment................................ 2319
Footnote No. 1098, See Footnote Nos. 995 and 1097 (above)... 2219, 2319
Footnote No. 1100, See Attachment................................ 2328
Footnote No. 1102-1103, See Footnote No. 186 (above)............. 1037
Footnote No. 1104, See Attachment................................ 2329
Footnote No. 1105-1106, See Footnote No. 1104 (above)............ 2329
Footnote No. 1107-1110, See Footnote No. 186 (above)............. 1037
Footnote No. 1112, See Attachment................................ 2331
Footnote No. 1113, See Attachment................................ 2332
Footnote No. 1114, See Attachment................................ 2334
Footnote No. 1115, See Attachment and Footnote No. 186 (abov 2336, 1037
Footnote No. 1116, See Attachment................................ 2338
Footnote No. 1117, See Hearing Exhibit No. 78 (above)............ 723
Footnote No. 1118, See Footnote No. 995 (above).................. 2219
Footnote No. 1119-1120, See Footnote No. 186 (above)............. 1037
Footnote No. 1121, See Attachment................................ 2339
Footnote No. 1122, See Footnote Nos. 993 and 1121 (above)... 2186, 2339
Footnote No. 1123, See Footnote No. 993 (above).................. 2186
Footnote No. 1124, See Footnote No. 1121 (above)................. 2339
Footnote No. 1125, See Attachment................................ 2346
Footnote No. 1126, See Attachment and Footnote No. 1121 (abo 2349, 2339
Footnote No. 1127-1128, See Footnote No. 993 (above)............. 2186
Footnote No. 1129, See Attachment................................ 2354
Footnote No. 1130, See Attachments (2) and Footnote Nos. 1121
and 1129 (above).................................... 2355, 2339, 2354
Footnote No. 1131, See Footnote No. 1121 (above)................. 2339
Footnote No. 1132, See Footnote No. 1130 (above)................. 2355
Footnote No. 1133, See Attachment................................ 2367
Footnote No. 1134, See Attachment and Footnote Nos. 1121
and 1126 (above).................................... 2369, 2339, 2349
Footnote No. 1135, See Attachment................................ 2373
Footnote No. 1136, See Footnote No. 1135 (above)................. 2373
Footnote No. 1137, See Attachment and Footnote No. 1135 (abo 2378, 2373
Footnote No. 1138, See Footnote No. 1126 (above)................. 2349
Footnote No. 1139, SEALED EXHIBIT................................ *
Footnote No. 1140, See Attachment................................ 2379
Footnote No. 1141, See Attachment................................ 2380
Footnote No. 1142, See Attachment................................ 2381
Footnote No. 1143, See Attachment................................ 2382
Footnote No. 1144-1145, See Footnote No. 1121 (above)............ 2339
Footnote No. 1146, See Attachment................................ 2383
Footnote No. 1147, See Attachment................................ 2384
Footnote No. 1148, See Attachment................................ 2386
Footnote No. 1149, See Attachment................................ 2390
Footnote No. 1150, See Attachment................................ 2391
Footnote No. 1151, See Footnote No. 1149 (above)................. 2390
Footnote No. 1152, See Attachment................................ 2392
Footnote No. 1153, See Attachment................................ 2393
Footnote No. 1155-1156, See Footnote No. 1121 (above)............ 2339
Footnote No. 1157, See Attachment................................ 2394
Footnote No. 1158, See Footnote No. 1121 (above)................. 2339
Footnote No. 1159, See Footnote No. 1157 (above)................. 2394
Footnote No. 1160, See Footnote No. 1121 (above)................. 2339
Footnote No. 1161-1162, See Footnote No. 1126 (above)............ 2349
Footnote No. 1163, See Footnote No. 1121 (above)................. 2339
Footnote No. 1164, See Attachments (2) and Footnote No. 1126
(above)................................................... 2395, 2349
Footnote No. 1165-1166, See Footnote No. 1121 (above)............ 2339
Footnote No. 1167, See Hearing Exhibit No. 79 (above)............ 724
Footnote No. 1168, See Attachment................................ 2400
Footnote No. 1170, See Footnote No. 1126 (above)................. 2349
Footnote No. 1171, See Footnote No. 1121 (above)................. 2339
Footnote No. 1172, See Footnote No. 995 (above).................. 2219
Footnote No. 1173, See Footnote Nos. 995 and 1121 (above)... 2219, 2339
Footnote No. 1174, See Footnote No. 995 (above).................. 2219
Footnote No. 1175, See Attachment................................ 2401
Footnote No. 1176, See Footnote Nos. 993 and 1121 (above)... 2186, 2339
Footnote No. 1177, See Attachment and Footnote No. 995 (abov 2403, 2219
Footnote No. 1178, See Attachment................................ 2405
Footnote No. 1179, See Attachment................................ 2407
Footnote No. 1180, See Attachment................................ 2409
Footnote No. 1181, See Attachment................................ 2413
Footnote No. 1182-1184, See Footnote No. 995 (above)............. 2219
Footnote No. 1185, See Footnote No. 1121 (above)................. 2339
Footnote No. 1187, See Attachment................................ 2416
Footnote No. 1190, See Footnote No. 1187 (above)................. 2416
Footnote No. 1195, See Attachment................................ 2418
Footnote No. 1197, See Attachment................................ 2419
Footnote No. 1200, See Attachment................................ 2421
Footnote No. 1201, See Attachment................................ 2422
Footnote No. 1202, See Footnote No. 1195 (above)................. 2418
Footnote No. 1205, See Attachment................................ 2423
Footnote No. 1206, See Attachment and Footnote No. 1201 (abo 2426, 2422
Footnote No. 1208, See Attachment................................ 2427
Footnote No. 1209, See Attachment................................ 2432
Footnote No. 1210, See Attachment................................ 2433
Footnote No. 1211, See Attachment................................ 2434
Footnote No. 1212, See Attachment................................ 2436
Footnote No. 1213, See Attachments (2)........................... 2440
Footnote No. 1214, See Attachment and Footnote No. 1208 (abo 2444, 2427
Footnote No. 1215, See Attachment................................ 2445
Footnote No. 1216, See Footnote No. 1215 (above)................. 2445
Footnote No. 1217, See Attachments (2) and Footnote No. 995
(above)................................................... 2446, 2219
Footnote No. 1218, See Attachment................................ 2452
Footnote No. 1219, See Attachment................................ 2453
Footnote No. 1220, See Attachment................................ 2457
Footnote No. 1221, See Attachment................................ 2470
Footnote No. 1222, See Attachment................................ 2475
Footnote No. 1225, See Attachment................................ 2478
Footnote No. 1226, See Footnote No. 1225 (above)................. 2478
Footnote No. 1227, See Attachment................................ 2479
Footnote No. 1228, See Attachment................................ 2480
Footnote No. 1229, See Footnote No. 1228 (above)................. 2480
Footnote No. 1230, See Attachments (2)........................... 2484
Footnote No. 1231-1233, See Footnote No. 1228 (above)............ 2480
Footnote No. 1234, See Attachment................................ 2487
Footnote No. 1235, See Hearing Exhibit No. 80 (above)............ 727
Footnote No. 1236, See Attachment................................ 2489
Footnote No. 1237, See Attachments (2)........................... 2491
Footnote No. 1238, See Attachment................................ 2497
Footnote No. 1239, See Hearing Exhibit No. 80 (above)............ 727
Footnote No. 1240-1241, See Footnote No. 995 (above)............. 2219
Footnote No. 1242, See Attachment................................ 2498
Footnote No. 1243, See Attachment................................ 2499
Footnote No. 1244, See Attachment................................ 2500
Footnote No. 1246, See Attachment................................ 2501
Footnote No. 1247-1250, See Footnote No. 995 (above)............. 2219
Footnote No. 1251, See Attachment................................ 2503
Footnote No. 1253, See Footnote No. 995 (above).................. 2219
Footnote No. 1254, See Attachment................................ 2504
Footnote No. 1258, See Footnote No. 1228 (above)................. 2480
Footnote No. 1259, See Footnote No. 995 (above).................. 2219
Footnote No. 1261, See Hearing Exhibit No. 79 (above)............ 724
Footnote No. 1262, See Attachment................................ 2507
Footnote No. 1263, See Attachment................................ 2509
Footnote No. 1264, SEALED EXHIBIT................................ *
Footnote No. 1265-1269, See Footnote No. 1263 (above)............ 2509
Footnote No. 1271-1276, See Footnote No. 1263 (above)............ 2509
Footnote No. 1277, See Attachment................................ 2515
Footnote No. 1278-1280, See Footnote No. 1277 (above)............ 2515
Footnote No. 1281-1282, See Footnote No. 996 (above)............. 2251
Footnote No. 1283, See Footnote No. 995 (above).................. 2219
Footnote No. 1286, See Attachment................................ 2519
Footnote No. 1287, See Footnote No. 1286 (above)................. 2519
Footnote No. 1288, See Attachment................................ 2525
Footnote No. 1289, See Attachment................................ 2527
Footnote No. 1290-1291, See Footnote No. 995 (above)............. 2219
Footnote No. 1293, See Footnote No. 1286 (above)................. 2519
Footnote No. 1295, See Attachment................................ 2530
Footnote No. 1296, See Footnote No. 1295 (above)................. 2530
Footnote No. 1298, See Footnote No. 1295 (above)................. 2530
Footnote No. 1299, See Attachment................................ 2532
Footnote No. 1301, See Attachment................................ 2536
Footnote No. 1302, See Attachments (2)........................... 2541
Footnote No. 1303, See Footnote No. 1286 (above)................. 2519
Footnote No. 1305, See Footnote No. 1302 (above)................. 2541
Footnote No. 1313, See Footnote No. 1289 (above)................. 2527
Footnote No. 1314, See Attachment................................ 2557
Footnote No. 1316, See Attachment................................ 2582
Footnote No. 1317, See Attachment................................ 2587
Footnote No. 1318, See Attachment................................ 2590
Footnote No. 1319, See Attachment................................ 2591
Footnote No. 1320, See Attachment................................ 2593
Footnote No. 1321, See Footnote No. 1302 (above)................. 2541
Footnote No. 1322, See Attachment................................ 2595
Footnote No. 1323, See Attachment................................ 2598
Footnote No. 1324, See Footnote No. 995 (above).................. 2219
Footnote No. 1325, See Footnote No. 1286 (above)................. 2519
Footnote No. 1326, See Attachment................................ 2600
Footnote No. 1327, See Attachment................................ 2602
Footnote No. 1331, See Attachment................................ 2604
Footnote No. 1376, See Hearing Exhibit No. 87 (above)............ 746
Footnote No. 1378, See Attachment................................ 2618
Footnote No. 1383, See Attachments (2)........................... 2621
Footnote No. 1384-1388, See Footnote No. 1383 (above)............ 2621
Footnote No. 1389, See Attachments (2) and Footnote No. 1383
(above)................................................... 2640, 2621
Footnote No. 1390, See Footnote No. 1389 (above)................. 2640
Footnote No. 1391-1392, See Footnote No. 1383 (above)............ 2621
Footnote No. 1393, See Attachment................................ 2649
Footnote No. 1394, See Footnote No. 1383 (above)................. 2621
Footnote No. 1395, See Footnote No. 1378 (above)................. 2618
Footnote No. 1396, See Attachments (2)........................... 2651
Footnote No. 1397, See Attachment................................ 2657
Footnote No. 1399-1404, See Footnote No. 1397 (above)............ 2657
Footnote No. 1407-1408, See Footnote No. 1389 (above)............ 2640
Footnote No. 1409, See Footnote No. 1383 (above)................. 2621
Footnote No. 1417, See Attachment................................ 2661
Footnote No. 1418, See Attachment................................ 2664
Footnote No. 1419, See Footnote No. 1389 (above)............ 2640, 2621
Footnote No. 1426, SEALED EXHIBIT................................ *
Footnote No. 1427-1428, See Footnote No. 1426 (above), SEALED
EXHIBIT........................................................ *
Footnote No. 1438, See Attachment................................ 2666
Footnote No. 1439, See Attachment................................ 2668
Footnote No. 1440, See Attachment................................ 2675
Footnote No. 1441, See Attachment................................ 2681
Footnote No. 1450, See Attachment................................ 2684
Footnote No. 1451, See Attachment................................ 2692
Footnote No. 1452, See Attachments (13).......................... 2695
Footnote No. 1454, See Attachment................................ 2759
Footnote No. 1455-1456, See Footnote No. 1454 (above)............ 2759
Footnote No. 1457, See Attachment and Footnote No. 1454 (abo 2760, 2759
Footnote No. 1461, See Attachment................................ 2761
Footnote No. 1462-1463, See Footnote No. 1461 (above)............ 2761
Footnote No. 1464, See Attachment................................ 2767
Footnote No. 1465, See Attachment................................ 2769
Footnote No. 1466, See Attachment................................ 2770
Footnote No. 1467, See Attachment................................ 2771
Footnote No. 1468, See Attachment................................ 2772
Footnote No. 1469, See Attachment................................ 2835
Footnote No. 1470, See Attachment................................ 2836
Footnote No. 1471, See Attachment................................ 2837
Footnote No. 1473, See Attachment................................ 2838
Footnote No. 1474, See Attachment................................ 2839
Footnote No. 1477, See Attachments (3)........................... 2841
Footnote No. 1478, See Footnote No. 1477 (above)................. 2841
Footnote No. 1479, See Attachment................................ 2847
Footnote No. 1480, See Footnote No. 1479 (above)................. 2847
Footnote No. 1481, See Attachment................................ 2853
Footnote No. 1482, See Footnote No. 1481 (above)................. 2853
Footnote No. 1483, See Attachments (2)........................... 2855
Footnote No. 1484, See Attachment and Footnote No. 1483 (abo 2860, 2855
Footnote No. 1485-1487, See Footnote No. 1483 (above)............ 2855
Footnote No. 1488, See Attachments (2)........................... 2861
Footnote No. 1489, See Attachment and Footnote No. 1488 (abo 2865, 2861
Footnote No. 1490, See Footnote Nos. 1483 and 1488 (above).. 2855, 2861
Footnote No. 1491, See Footnote No. 1483 (above)................. 2855
Footnote No. 1492, See Attachment................................ 2866
Footnote No. 1493, See Footnote No. 1492 (above)................. 2866
Footnote No. 1494, See Footnote No. 1477 (above)................. 2841
Footnote No. 1496, See Attachment................................ 2868
Footnote No. 1497, See Attachment................................ 2869
Footnote No. 1498, See Attachment................................ 2870
Footnote No. 1499, See Attachment................................ 2872
Footnote No. 1500, See Footnote No. 1499 (above)................. 2872
Footnote No. 1502, See Attachment and Footnote No. 1488 (abo 2874, 2861
Footnote No. 1503, See Attachment................................ 2875
Footnote No. 1504, See Attachment and Footnote No. 1488 (abo 2878, 2861
Footnote No. 1506, See Attachment................................ 2879
Footnote No. 1507, See Footnote No. 1504 (above)................. 2878
Footnote No. 1508, See Attachments (3) [1 attachment is a SEALED
EXHIBIT] and Footnote No. 1488 (above).................... 2881, 2861
Footnote No. 1509, See Attachment................................ 2886
Footnote No. 1510, See Footnote No. 1509 (above)................. 2886
Footnote No. 1511, See Attachment................................ 2887
Footnote No. 1512, See Attachment................................ 2889
Footnote No. 1513, See Attachment................................ 2891
Footnote No. 1514, See Footnote No. 1513 (above)................. 2891
Footnote No. 1515, See Attachment................................ 2892
Footnote No. 1516, See Attachment................................ 2894
Footnote No. 1517-1518, See Footnote No. 1516 (above)............ 2894
Footnote No. 1519, See Attachment................................ 2895
Footnote No. 1520, See Attachment and Hearing Exhibit No. 112
(above).................................................... 2897, 795
Footnote No. 1522, See Attachment and Hearing Exhibit No. 112
(above).................................................... 2903, 795
Footnote No. 1523-1525, See Hearing Exhibit No. 112 (above)...... 795
Footnote No. 1528, See Attachments (2)........................... 2905
Footnote No. 1529, See Footnote No. 1520 (above)................. 2897
Footnote No. 1531, See Footnote No. 1512 (above)................. 2889
Footnote No. 1535, See Attachment and Hearing Exhibit No. 100
(above).................................................... 2907, 771
Footnote No. 1536, See Attachment................................ 2926
Footnote No. 1537, See Attachment................................ 2928
Footnote No. 1538, See Footnote No. 1537 (above)................. 2928
Footnote No. 1539, See Attachment, Footnote No. 1537 (above) 2935, 2928
Footnote No. 1540, See Footnote No. 1537 (above)................. 2928
Footnote No. 1541, See Footnote No. 1535 (above)................. 2907
Footnote No. 1542, See Attachment................................ 2936
Footnote No. 1543, See Footnote No. 1512 (above)................. 2889
Footnote No. 1544, See Attachment................................ 2938
Footnote No. 1545, See Footnote No. 1544 (above)................. 2938
Footnote No. 1546, See Footnote No. 1512 (above)................. 2889
Footnote No. 1547, See Attachment................................ 2939
Footnote No. 1548, See Attachments (2)........................... 2940
Footnote No. 1549, See Attachment................................ 2943
Footnote No. 1551, See Attachment................................ 2945
Footnote No. 1552, See Attachment................................ 2946
Footnote No. 1553, See Attachment................................ 2948
Footnote No. 1554, See Attachment................................ 2949
Footnote No. 1555, See Attachment................................ 2950
Footnote No. 1556, See Attachment................................ 2951
Footnote No. 1557, See Attachments (3)........................... 2952
Footnote No. 1558, See Attachment................................ 2961
Footnote No. 1559, See Footnote No. 1557 (above)................. 2952
Footnote No. 1560, See Attachment................................ 2964
Footnote No. 1561, See Attachments (3)........................... 2965
Footnote No. 1562, See Attachment................................ 2969
Footnote No. 1563, See Footnote No. 1562 (above)................. 2969
Footnote No. 1564, See Attachment................................ 2971
Footnote No. 1565, See Attachment................................ 2974
Footnote No. 1566, See Attachment................................ 2977
Footnote No. 1567, See Attachment................................ 2978
Footnote No. 1568, See Attachment................................ 2979
Footnote No. 1569, See Attachment................................ 2980
Footnote No. 1570-1571, See Footnote No. 1569 (above)............ 2980
Footnote No. 1572, See Attachment................................ 2983
Footnote No. 1575, See Attachment and Hearing Exhibit No. 105
(above).................................................... 2984, 784
Footnote No. 1576, See Attachment and Hearing Exhibit No. 105
(above).................................................... 2986, 784
Footnote No. 1577, See Attachment................................ 3001
Footnote No. 1578, See Attachment................................ 3002
Footnote No. 1579, See Attachment................................ 3004
Footnote No. 1580, See Footnote No. 1579 (above)................. 3004
Footnote No. 1581, See Attachment................................ 3005
Footnote No. 1582, See Attachment................................ 3006
Footnote No. 1583, See Footnote No. 1582 (above)................. 3006
Footnote No. 1584, See Attachment................................ 3007
Footnote No. 1585, See Attachment................................ 3008
Footnote No. 1586, See Footnote No. 1585 (above)................. 3008
Footnote No. 1588, See Attachment and Footnote No. 1585 (abo 3010, 3008
Footnote No. 1589, See Attachment................................ 3011
Footnote No. 1591, See Attachments (3)........................... 3012
Footnote No. 1592, See Attachment................................ 3015
Footnote No. 1593, See Attachment and Footnote No. 1591 (abo 3016, 3012
Footnote No. 1594, See Attachment................................ 3017
Footnote No. 1595, See Attachment and Hearing Exhibit No. 108
(above).................................................... 3018, 787
Footnote No. 1596-1597, See Footnote No. 1595 (above)............ 3018
Footnote No. 1598, See Attachment................................ 3020
Footnote No. 1599, See Attachment................................ 3021
Footnote No. 1600, See Attachment................................ 3022
Footnote No. 1601, See Attachment................................ 3024
Footnote No. 1602, See Attachment............................... 3025
Footnote No. 1603, See Hearing Exhibit No. 109 (above)........... 788
Footnote No. 1604, See Attachment and Hearing Exhibit No. 109
(above).................................................... 3027, 788
Footnote No. 1605, See Attachment................................ 3029
Footnote No. 1606, See Footnote No. 1605......................... 3029
Footnote No. 1609, See Attachment................................ 3030
Footnote No. 1610-1611, See Footnote No. 1609 (above)............ 3030
Footnote No. 1612, See Attachment................................ 3033
Footnote No. 1613-1614, See Footnote No. 1612 (above)............ 3033
Footnote No. 1615, See Attachments (4)........................... 3036
Footnote No. 1616, See Attachment................................ 3042
Footnote No. 1617, See Attachment................................ 3043
Footnote No. 1618, See Attachment................................ 3044
Footnote No. 1619, See Attachments (2)........................... 3046
Footnote No. 1620-1621, See Footnote No. 1619 (above)............ 3046
Footnote No. 1622, See Attachments (2)........................... 3068
Footnote No. 1623, See Attachment and Footnote No. 1622 (abo 3088, 3068
Footnote No. 1624-1625, See Footnote No. 1622 (above)............ 3068
Footnote No. 1626-1627, See Footnote No. 1619 (above)............ 3046
Footnote No. 1628, See Footnote Nos. 1619 and 1622 (above).. 3046, 3068
Footnote No. 1629-1630, See Footnote No. 1619 (above)............ 3046
Footnote No. 1632, See Footnote No. 1619 (above)................. 3046
Footnote No. 1633, See Footnote No. 1622 (above)................. 3068
Footnote No. 1639, See Attachment................................ 3094
Footnote No. 1640, See Footnote No. 1639 (above)................. 3094
Footnote No. 1641, See Attachment and Footnote No. 1639 (abo 3095, 3094
Footnote No. 1642, See Footnote No. 1619 (above)................. 3046
Footnote No. 1643, See Footnote No. 1622 (above)................. 3068
Footnote No. 1644, See Attachment................................ 3096
Footnote No. 1645, See Footnote No. 1619 (above)................. 3046
Footnote No. 1646, See Footnote No. 1619 and Hearing Exhibit
No. 115 (above)............................................ 3046, 802
Footnote No. 1647, See Footnote Nos. 1619, 1622, 1623
and 1639 (above).............................. 3046, 3088, 3068, 3094
Footnote No. 1648-1649, See Footnote No. 1619 (above)............ 3046
Footnote No. 1650, SEALED EXHIBIT................................ *
Footnote No. 1651, See Attachment and Footnote No. 930 (abov 3099, 2129
Footnote No. 1652-1653, See Footnote No. 1622 (above)............ 3068
Footnote No. 1654, See Footnote No. 1619 (above)................. 3046
Footnote No. 1656, See Footnote Nos. 1619, 1623 and 1639
(above)............................................. 3046, 3088, 3094
Footnote No. 1657, See Footnote No. 930 (above).................. 2129
Footnote No. 1658, See Footnote No. 1619 (above)................. 3046
Footnote No. 1659, See Hearing Exhibit No. 124 (above)........... 821
Footnote No. 1661, See Attachment................................ 3108
Footnote No. 1662, See Footnote No. 1622 and Hearing Exhibit
No. 114 (above)............................................ 3068, 801
Footnote No. 1663, See Footnote No. 1622 (above)................. 3068
Footnote No. 1664, See Attachment and Hearing Exhibit No. 124
(above).................................................... 3111, 821
Footnote No. 1665-1666, See Footnote No. 1664 (above)............ 3111
Footnote No. 1667-1669, See Hearing Exhibit No. 115 (above)...... 802
Footnote No. 1670, See Attachment and Hearing Exhibit No. 115
(above).................................................... 3113, 802
Footnote No. 1671, See Hearing Exhibit No. 115 (above)........... 802
Footnote No. 1672, See Hearing Exhibit No. 117 (above)........... 807
Footnote No. 1673, See Footnote No. 1661 (above)................. 3108
Footnote No. 1674-1676, See Hearing Exhibit No. 117 (above)...... 807
Footnote No. 1677, See Footnote No. 930 and Hearing Exhibit No.
115
(above).................................................... 2129, 802
Footnote No. 1678-1681, See Hearing Exhibit No. 116 (above)...... 805
Footnote No. 1682, See Footnote No. 1619 (above)................. 3046
Footnote No. 1683, See Attachment................................ 3122
Footnote No. 1684, See Footnote No. 1683 (above)................. 3122
Footnote No. 1685-1686, See Hearing Exhibit No. 123 (above)...... 819
Footnote No. 1687-1688, See Footnote No. 1683 (above)............ 3122
Footnote No. 1689, See Hearing Exhibit No. 121 (above)........... 817
Footnote No. 1690, See Footnote No. 1670 (above)................. 3113
Footnote No. 1691, See Attachment................................ 3131
Footnote No. 1692, See Footnote No. 1670 (above)................. 3113
Footnote No. 1694, See Footnote No. 1622 (above)................. 3068
Footnote No. 1695, See Footnote No. 1623 (above)................. 3088
Footnote No. 1696-1697, See Footnote No. 1619 (above)............ 3046
Footnote No. 1698-1700, See Hearing Exhibit No. 125 (above)...... 826
Footnote No. 1701-1702, See Hearing Exhibit No. 118 (above)...... 810
Footnote No. 1703, See Footnote No. 930 and Hearing Exhibit No.
118
(above).................................................... 2129, 810
Footnote No. 1704-1705, See Hearing Exhibit No. 118 (above)...... 810
Footnote No. 1706, See Attachment and Hearing Exhibit No. 119
(above).................................................... 3132, 812
Footnote No. 1707, See Hearing Exhibit No. 123 (above)........... 819
Footnote No. 1708, See Footnote No. 930 (above).................. 2129
Footnote No. 1709-1710, See Footnote No. 1670 (above)............ 3113
Footnote No. 1711, See Attachment................................ 3135
Footnote No. 1712, See Footnote Nos. 1670 and 1711 (above).. 3113, 3135
Footnote No. 1713, See Footnote No. 1711 (above)................. 3135
Footnote No. 1714, See Footnote No. 1670 (above)................. 3113
Footnote No. 1715, See Attachment................................ 3136
Footnote No. 1716, See Footnote No. 1639 (above)................. 3094
Footnote No. 1717, See Attachment................................ 3137
Footnote No. 1718, See Attachment................................ 3138
Footnote No. 1719, See Attachment................................ 3139
Footnote No. 1720, See Footnote No. 1661 (above)................. 3108
Footnote No. 1721-1722, See Footnote No. 1670 (above)............ 3113
Footnote No. 1723, See Attachments (3)........................... 3141
Footnote No. 1725, See Attachment................................ 3159
Footnote No. 1726, See Attachment................................ 3160
Footnote No. 1727, See Footnote No. 1723 (above)................. 3141
Footnote No. 1729, See Hearing Exhibit No. 120 (above)........... 815
Footnote No. 1730, See Footnote No. 1715 and Hearing Exhibit
No. 120 (above)............................................ 3136, 815
Footnote No. 1731, See Footnote No. 1727 (above)................. 3141
Footnote No. 1732, See Footnote No. 1719 (above)................. 3139
Footnote No. 1733, See Footnote No. 1723 and Hearing Exhibit
No. 122 (above)................................................ 3141
Footnote No. 1734-1736, See Footnote No. 1733 (above)........ 3141, 818
Footnote No. 1737, See Footnote No. 1619 (above)................. 3046
Footnote No. 1739, See Footnote No. 1691 and Hearing Exhibit
No. 121 (above)............................................ 3131, 817
Footnote No. 1740, See Footnote Nos. 1619, 1670 and 1691
(above)............................................. 3046, 3113, 3131
Footnote No. 1741, See Footnote No. 1661 (above)................. 3108
Footnote No. 1742, See Footnote No. 1619 (above)................. 3046
Footnote No. 1745-1749, See Footnote No. 1619 (above)............ 3046
Footnote No. 1750, See Attachment and Footnote No. 1619 (abo 3161, 3046
Footnote No. 1751-1752, See Hearing Exhibit No. 122 (above)...... 818
Footnote No. 1753-1754, See Footnote No. 1670 (above)............ 3113
Footnote No. 1755, SEALED EXHIBIT................................ *
KEEPING FOREIGN CORRUPTION OUT OF
THE UNITED STATES: FOUR CASE
HISTORIES--VOLUME 1
----------
THURSDAY, FEBRUARY 4, 2010
U.S. Senate,
Permanent Subcommittee on Investigations,
of the Committee on Homeland Security
and Governmental Affairs,
Washington, DC.
The Subcommittee met, pursuant to notice, at 9:38 a.m., in
room SD-342, Dirksen Senate Office Building, Hon. Carl Levin,
Chairman of the Subcommittee, presiding.
Present: Senators Levin and Coburn.
Staff Present: Elise J. Bean, Staff Director and Chief
Counsel; Mary D. Roertson, Chief Clerk; Robert L. Roach,
Counsel and Chief Investigator; Laura E. Stuber, Counsel; David
H. Katz, Counsel; Adam Henderson, Professional Staff Member;
Jason E. Medica, Detailee (ICE); Christopher J. Barkley, Staff
Director to the Minority; Justin J. Rood, Senior Investigator
to the Minority; Robert Kaplan, Intern; Jeff Kruszewski, Law
Clerk; Kevin Rosenbaum, Intern; Thomas Caballero, Office of the
Senate Legal Counsel.
OPENING STATEMENT OF SENATOR LEVIN
Senator Levin. Good morning, everybody. I would now like to
call our first panel of witnesses for this morning's hearing of
the Permanent Subcommittee on Investigations. We will, prior to
asking them questions, begin with our opening statements.
Corruption is a cancer which corrodes the rule of law,
undermines economic development, and eats away at the fabric of
civil society. In extreme cases, corruption can destabilize
communities and lead to failed states, lawlessness, and
terrorism. For the United States, which is so much riding on
global stability, corruption is a direct threat to our national
interests.
That is why the United States is engaged in a relentless
worldwide battle to stop the flow of illegal money into and
within places like Iraq and Afghanistan. Laundered money is
used to train and provide support for terrorists and terrorism.
If you want to credibly lead efforts to stop illegal money
abroad, we have got to stop it here at home, as well.
The fact is that those engaged in large-scale corruption
want to put their money in a modern financial system that can
store, protect, invest, and transfer their funds efficiently.
They want access, in other words, to U.S. banks, and it is our
job to stop them, to keep foreign corruption out of the United
States.
As the report that we are releasing today shows, it is not
an easy job. With the help of U.S. lawyers, real estate and
escrow agents, lobbyists, and others, politically powerful
foreign officials, and those close to them, they have found
ways to use the U.S. financial system to protect and enhance
their ill-gotten gains. While U.S. financial institutions have
become more vigilant and built stronger barriers to keep out
suspect funds, their anti-money laundering safeguards still
have holes.
Our report presents four case studies exposing how
politically powerful individuals, known internationally as
Politically Exposed Persons (PEPs), are taking advantage of the
U.S. financial system. In each case, weaknesses in our
financial regulations have allowed these PEPs to move millions
of dollars into or through U.S. bank accounts, often by using
shell company accounts, attorney-client accounts, escrow
accounts, or other accounts, or by sending wire transfers that
shoot through the system before our banks can react. In
addition to exposing these tactics, our report offers a number
of recommendations to stop the abuses, and I will get to those
recommendations in a moment.
In conducting our investigation, the Subcommittee conducted
more than 100 interviews, viewed millions of pages of
documents, and traced millions of dollars. The stories we
uncovered are striking in their misuse of our financial system.
Start with Teodoro Obiang, the 40-year-old son of the
President of Equatorial Guinea who is currently under
investigation by the Justice Department for corruption and
other misconduct. Between 2004 and 2008, Mr. Obiang used U.S.
lawyers, bankers, and real estate and escrow agents to move
more than $100 million in suspect funds through U.S. bank
accounts, and he did it even at U.S. banks that made it clear
that they didn't want his business.
With the help of two lawyers, Michael Berger and George
Nagler, Mr. Obiang created five U.S. shell companies with names
like Beautiful Vision, Unlimited Horizon, and Sweet Pink. His
lawyers then opened accounts for those shell companies at
multiple U.S. banks and used them to transact business for Mr.
Obiang. In addition, Mr. Obiang wired millions of dollars from
Equatorial Guinea into his attorney's own law office and
attorney-client accounts, which they then used to transact
business on his behalf, all without alerting the host bank. His
attorneys became hidden conduits for his suspect funds, which
most U.S. banks would be unwilling to accept.
At the same time, two real estate agents, Neal Baddin and
John Kerrigan, helped Mr. Obiang buy and sell California real
estate, including a $30 million Malibu residence which he paid
for by wiring cash from Equatorial Guinea to the U.S. bank
account of the escrow agent, First American. Mr. Obiang also
bought a $38 million U.S.-built Gulfstream jet. When one U.S.
escrow agent, as an anti-money laundering precaution, refused
to proceed until it had more information on the source of Mr.
Obiang's funds, another escrow agent, Insured Aircraft Title
Services, Inc., stepped in and completed the transaction with
no questions asked. U.S. regulations currently exempt real
estate agents and escrow agents from any requirement to
establish anti-money laundering programs, a loophole through
which Mr. Obiang poured millions of dollars in suspect money.
Now, next consider Omar Bongo, President of Gabon for 41
years until his death last year, and his eldest son, Ali Bongo,
Minister of Defense until he took his father's place as
President of the country. Both men are notorious for
accumulating massive wealth while in office in a country known
for its poverty.
From 2003 until at least 2007, President Omar Bongo hired a
U.S. lobbyist, Jeffrey Birrell, to buy U.S.-made armored
vehicles and to obtain U.S. Government permission to buy six C-
130 military cargo aircraft from Saudi Arabia to support his
regime. In connection with those projects, more than $18
million was wire transferred from Gabon into Mr. Birrell's U.S.
corporate bank accounts. Part of that money came from President
Bongo's personal account. Most came from an entity in Gabon
called Ayira.
At President Bongo's direction, Mr. Birrell spent millions
of dollars of the Gabon money on the armored car and aircraft
projects, including wiring more than $1 million to various
consultants around the world, and at least another $4 million
to a Bongo advisor with accounts in Brussels and Paris. When
the aircraft deal fell through, Mr. Birrell wired $9.2 million
of the Ayira money to an account in President Bongo's name, not
in Gabon, but in the country of Malta. In short, his corporate
bank accounts became conduits for multi-million-dollar
suspicious wire transfers directed by President Omar Bongo
through the U.S. financial system.
Now, there is more. Between 2000 and 2007, President Omar
Bongo provided large amounts of cash to his daughter, Yamilee
Bongo-Astier, who was then living in New York and who stashed
the money in accounts and safe deposit boxes in New York banks.
These banks were told by Ms. Bongo-Astier that she was an
unemployed student. The databases they used didn't identify her
as a PEP. The banks allowed multiple large cash deposits and
offshore wire transfers into her accounts.
One bank finally called it quits after a $183,000 wire
transfer from Gabon. Another did so after it discovered she had
a million dollars in shrink-wrapped $100 bills in her safe
deposit box, money which she said her father had brought into
the country under his diplomatic status in 2007 without
declaring that money as required by law. The Subcommittee
double-checked and confirmed that no declaration was filed by
President Bongo for the million dollars in shrink-wrapped
bills.
Another relative, Inge Collins Bongo, wife to the current
President, Ali Bongo, established a U.S. trust in her maiden
name, opened U.S. bank accounts in the name of that trust, and
brought in millions of dollars in suspect funds into the United
States without the banks realizing her PEP status.
Our third case history examines Jennifer Douglas, a U.S.
citizen and a wife of Atiku Abubakar, former Vice President and
former presidential candidate in Nigeria. From 2000 to 2008,
she helped her husband bring more than $40 million in suspect
money into the United States through wire transfers from
offshore corporations. Ms. Douglas is alleged in a 2008 civil
complaint filed by the Securities and Exchange Commission to
have received $2.8 million in bribe payments from a German
conglomerate, Siemens AG.
Siemens has pleaded guilty to criminal charges and settled
civil charges related to the Foreign Corrupt Practices act and
told the Subcommittee that it sent payments to her account at
Citibank. The Subcommittee located three wire transfers
substantiating $1.7 million in payments from Siemens to Ms.
Douglas in 2001 and 2002. Of the $40 million, the Subcommittee
traced nearly $25 million in offshore wire transfers into U.S.
accounts controlled by Ms. Douglas, provided primarily by three
offshore corporations called LetsGo, Sima Holdings, and
Guernsey Trust Company.
The banks holding her accounts were generally unaware of
Ms. Douglas' PEP status and did not subject her accounts to
enhanced monitoring, despite multiple incoming wire transfers
from Switzerland and Nigeria. One bank took 7 years to find out
she was a PEP. After it did, it reviewed her account activity
and closed her accounts.
The last of our case histories involves Angola and targets
accounts used by an Angolan arms dealer, the former head of the
Angolan Central Bank, and a private bank that caters to PEPs.
Pierre Falcone is a notorious arms dealer who is a close
associate of Angolan President Dos Santos, having supplied him
with weapons during Angola's civil war in violation of the U.N.
arms embargo. He has a long history of run-ins with the law,
was incarcerated for a year in 2000, was a fugitive from a 2004
global arrest warrant, and is now serving a 6-year prison term
in France.
Yet between 1989 and 2007, Mr. Falcone had more than 30
U.S. accounts at a Bank of America branch in Arizona. Bank of
America never designated him as a PEP, even though he was an
Angolan Ambassador, and never designated his accounts as at
high risk of money laundering, despite rivers of offshore money
moving through those accounts.
A second Angolan, Aguinaldo Jaime, was head of Angolan's
Central Bank in 2002 when he tried twice to transfer $50
million in Angolan government funds to private U.S. accounts.
The transfers were initially allowed. Then they were reversed
when bank or securities firm personnel got suspicious. As a
result of those transfers and the corruption concerns they
raised, Citibank closed his accounts for the Angolan Central
Bank and all other Angolan government entities.
In contrast, however, another bank that will be testifying
here today, HSBC, not only continues to provide U.S.
correspondent accounts to the Angolan Central Bank, but also
may be supplying the Angolan Central Bank with offshore
accounts in the Bahamas. Here you have a central bank of a
nation that is creating offshore secrecy bank accounts. That is
a new one on me.
Finally, Banco Africano de Investimentos (BAI), is a $7
billion Angolan private bank whose largest shareholder is
Angola's state-owned oil company and which caters to PEP
clients. Over the last decade, BAI has gained access to the
U.S. financial system through accounts at HSBC in New York.
Despite the presence of PEPs in BAI's management and clientele,
and despite the fact that BAI has hidden owners and has failed
to provide, at least apparently until today, a copy of its
anti-money laundering procedures to HSBC, despite multiple
requests, HSBC continues to provide the BAI bank with ready
access to the U.S. financial system.
Now, how can the United States tell other countries to stop
the flow of illegal money, money which is frequently laundered
and ends up in the hands of terrorists or terrorist support
groups, when we don't do a better job of it within our own
borders? Each of these case studies exposes loopholes and gaps
in our financial regulations that have been exploited to hide,
launder, and invest foreign corruption proceeds in the United
States.
It does not have to be that way. There is a lot more that
can be done to combat foreign corruption. Here are just a few
of the highlights. We could first implement stronger PEP
controls, as laid out in a recent World Bank report. That
includes requiring banks to use reliable databases to screen
clients for PEPs; requiring beneficial ownership forms for all
accounts so that hidden PEPs are exposed; and conducting annual
reviews of PEP accounts to detect suspicious activity.
A related measure which this Subcommittee has been
promoting for years is to require persons setting up U.S. shell
companies to identify the beneficial owners to the States that
are handling incorporations. Equally important is for the
Department of Treasury to revoke the exemptions that it granted
back in 2002 to the USA PATRIOT Act's anti-money laundering
requirements so that real estate and escrow agents will have to
know their customers, evaluate the source of their funds, and
turn away suspect clients. The Treasury also needs to address
the misuse of attorney-client and law office accounts by
requiring banks to treat them as high-risk accounts and get
certifications that the accounts won't be used to circumvent
bank control.
The rest of the examples, I will put in the record and
conclude by saying that stopping the flow of illegal money is
critical because foreign corruption damages civil society,
undermines the rule of law, and threatens American security.\1\
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\1\ The prepared statement of Senator Levin appears in the Appendix
on page 47.
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I would like to thank my Ranking Member, Senator Coburn,
and his staff for joining in this effort, for doing so much to
facilitate this investigation, and I now turn to him for his
opening remarks.
OPENING STATEMENT OF SENATOR COBURN
Senator Coburn. Well, thank you, Mr. Chairman. I have a
statement for the record, but due to the expediency of time, I
will ask unanimous consent that it be placed in the record.\2\
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\2\ The prepared statement of Senator Coburn appears in the
Appendix on page 51.
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I also would like to thank your staff. We are new to this
Subcommittee over the past 2 years and I have seen the work
that is carried out and I am very appreciative of the
cooperative and collegial nature in which this Committee
operates.
Senator Levin. Thank you.
Senator Coburn. We plan to continue that.
I find it curious, Mr. Chairman, that this morning, in the
Wall Street Journal, a lawyer for Mr. Berger says his client
won't comment until after the hearing. Yet it is my
understanding he is not going to comment during the hearing, as
well, so much to be found out in the future about what has gone
on in the past.
I congratulate you. I think you are well on the way with
your bill that you are introducing, which we hopefully can work
out, then I can cosponsor. I think we are there. I think we
need maybe a little more balance in terms of not inhibiting
regular trade, but I look forward to working with you on that
and I would yield back my time.
Senator Levin. Well, we thank you. Your statement will be
made part of the record.
And now we will move to our first panel of witnesses,
Michael Jay Berger, George Nagler, and Jeffrey Birrell.
Pursuant to Rule 6, all witnesses who testify before the
Subcommittee are required to be sworn. So at this time, I would
ask each of you to please stand and raise your right hand.
Do you swear that the testimony you are about to give will
be the truth, the whole truth, and nothing but the truth, so
help you, God?
Mr. Berger. I do.
Mr. Nagler. I do.
Mr. Birrell. I do.
Senator Levin. Do any of you have any opening statement?
Mr. Berger.
Mr. Berger. No, sir.
Senator Levin. Mr. Nagler.
Mr. Nagler. No, sir.
Senator Levin. Mr. Birrell.
Mr. Birrell. No, sir.
Senator Levin. Our first witness is Michael Jay Berger,
from Beverly Hills, California, an attorney for Teodoro Obiang.
Mr. Berger, did you serve as President of Beautiful Vision,
Inc.?
TESTIMONY OF MICHAEL JAY BERGER, ATTORNEY FOR EQUATORIAL GUINEA
CABINET MINISTER TEODORO OBIANG NGUEMA MANGUE
Mr. Berger. On advice of counsel, I must respectfully
decline to answer your question based on my Fifth Amendment
rights against self-incrimination.
Senator Levin. Mr. Berger, do you have any corrections to
the statement of facts in my opening statement or to the case
history in the report released by the Subcommittee this week?
Mr. Berger. I think there are many things wrong with it,
but on advice of counsel, I must respectfully decline to answer
your question based on my Fifth Amendment rights against self-
incrimination. And to the extent that the question could call
for me to reveal information covered by the attorney-client
privilege and attorney work product doctrine, I respectfully
decline to answer your question on that basis, as well.
Senator Levin. The Subcommittee is not going to rule on
your claim of attorney-client privilege because you have
exercised your Fifth Amendment rights. And given the fact that
you intend to assert a Fifth Amendment right against self-
incrimination to all questions asked of you by this
Subcommittee, you are excused.
Before you are excused, let me just consult.
[Pause.]
Senator Levin. Mr. Berger, before I excuse you, I have
another question. Senator Coburn referred to an article in the
Wall Street Journal today which says that Brian Sun, your
lawyer, said that you won't comment until after the hearing. Is
that true?
Mr. Berger. Mr. Sun is my attorney and he is here with me--
--
Senator Levin. Is it true----
Mr. Berger [continuing]. But I haven't seen the piece.
Senator Levin. Has he said that you will talk to the press
but not to us?
Mr. Berger. I don't know.
Senator Levin. You don't know, then, whether that is what
your intention is?
Mr. Berger. I don't know what he said to the press----
Senator Levin. Is that your intention, sir?
Mr. Berger. At the moment, I have no current intention to
talk to the press about this matter.
Senator Levin. You are excused.
Mr. Berger. Thank you.
Senator Levin. Next, George Nagler, from Beverly Hills,
California, is an attorney for Teodoro Obiang.
Mr. Nagler, did you open bank accounts used by Mr. Obiang
at the California National Bank, City National Bank, and
Pacific Mercantile Bank?
TESTIMONY OF GEORGE I. NAGLER, ATTORNEY FOR EQUATORIAL GUINEA
CABINET MINISTER TEODORO OBIANG NGUEMA MANGUE
Mr. Nagler. On advice of counsel, I respectfully invoke my
Fifth Amendment rights and decline to answer the question.
Senator Levin. Do you have any corrections to the statement
of facts in my opening statement or to the case history in the
report released by the Subcommittee this week?
Mr. Nagler. Same answer, sir.
Senator Levin. Which is you are asserting your Fifth
Amendment privilege?
Mr. Nagler. Yes.
Senator Levin. Mr. Nagler, you have been asked specific
questions about matters of interest to this Subcommittee. In
response to each question, you have asserted your Fifth
Amendment privilege. Is it your intention to assert your Fifth
Amendment privilege to any question that might be directed to
you by the Subcommittee today?
Mr. Nagler. Yes, sir.
Senator Levin. Given the fact that you intend to assert a
Fifth Amendment right against self-incrimination to all
questions asked of you by this Subcommittee, you are excused.
Mr. Nagler. Thank you.
Senator Levin. Mr. Berger, I see that you are still here
and I want to ask you the same question. Mr. Berger.
Mr. Berger. Yes?
Senator Levin. I want to ask you the same question that I
asked Mr. Nagler, and that is that when you were asked specific
questions about matters of interest to this Subcommittee, you
asserted your Fifth Amendment privilege, and I should have
asked you the following question. Is it your intention to
assert your Fifth Amendment privilege to any question that
might be directed to you by the Subcommittee today?
Mr. Berger. I don't want to prolong the questioning. I
could imagine a lot of questions that I could answer. If you
say, am I a lawyer or am I----
Senator Levin. Is it your intention, sir, to assert your
Fifth Amendment privilege to any question that might be
directed to you by the Subcommittee today?
Mr. Berger. No, Mr. Chairman, only to questions to which
relate to this investigation, only to questions to which I
would have the Fifth Amendment privilege or the attorney-client
privilege.
I could imagine a lot of questions that you could ask me
that would be general and which I would be happy to respond to.
Senator Levin. All right. In that case, you will now be
subpoenaed to a deposition, sir. Since you have not indicated
that you are going to assert your Fifth Amendment privilege, we
will be having a deposition where you will be asked questions.
So you can then decide whether you are going to assert a Fifth
Amendment privilege, and we will then have a determination that
you are not allowed to pick and choose the answers that you
will make to questions of this Subcommittee.
But since you have not indicated that you are going to
assert a Fifth Amendment privilege to all questions of this
Subcommittee, as you had previously indicated you would, we are
now going to adjourn your matter. Instead of excusing you, we
are going to adjourn your matter. We are going to subpoena you
to a deposition, and if you then refuse to answer questions, we
will then take this matter further, in court, if necessary.
Mr. Berger. Mr. Chairman, could I have a moment to consult
with my counsel?
Senator Levin. Yes.
Mr. Berger. Perhaps I have given the wrong answer to the
question.
Senator Levin. Of course.
[Pause.]
Mr. Berger. Mr. Chairman, I want to amend my answer.
Senator Levin. All right. Let me ask it again.
Mr. Berger. Yes.
Senator Levin. Is it your intention to assert your Fifth
Amendment privilege to any question that might be directed to
you by the Subcommittee today?
Mr. Berger. It is.
Senator Levin. Now you are excused.
Mr. Berger. Thank you, Mr. Chairman.
Senator Levin. Our last witness on this panel is Jeffrey
Birrell. Mr. Birrell is from the Grace Group of McLean,
Virginia, a registered agent for the Republic of Gabon.
TESTIMONY OF JEFFREY C. BIRRELL, REGISTERED AGENT FOR THE
REPUBLIC OF GABON, THE GRACE GROUP
Senator Levin. Mr. Birrell, did your company, the Grace
Group, receive funds from both Mr. Omar Bongo, and an entity
named Ayira?
Mr. Birrell. Mr. Chairman, Dr. Coburn, based on advice of
counsel, I respectfully refuse to answer that question pursuant
to the rights afforded me under the Fifth Amendment to the U.S.
Constitution.
Senator Levin. Mr. Birrell, do you have any corrections to
the statement of facts in my opening statement or the case
history in the report released by the Subcommittee this week?
Mr. Birrell. Mr. Chairman, Dr. Coburn, based on advice of
counsel, I respectfully refuse to answer that question pursuant
to the rights afforded to me under the Fifth Amendment to the
U.S. Constitution.
Senator Levin. Mr. Birrell, you have been asked specific
questions about matters of interest to this Subcommittee. In
response to each question, you have asserted your Fifth
Amendment privilege. Is it your intention to assert your Fifth
Amendment privilege to any question that might be directed to
you by the Subcommittee today?
Mr. Birrell. Yes, Mr. Chairman.
Senator Levin. Given the fact that you intend to assert a
Fifth Amendment right against self-incrimination to all
questions asked of you by this Subcommittee, you are excused.
Mr. Birrell. Thank you, gentlemen.
Senator Levin. We will now call our second panel of
witnesses, Neal Baddin of West Hollywood, California, a Realtor
for Teodoro Obiang; Brenda Cobb, the Vice President of Insured
Aircraft Title Service of Oklahoma City; William Fox, Senior
Vice President and Global Anti-Money Laundering and Economic
Sanctions Executive at Bank of America in Charlotte, North
Carolina; and Wiecher Mandemaker, Director of General
Compliance, Personal Financial Services, Anti-Money Laundering
Compliance at HSBC Bank USA here in Washington, DC.
We thank each of you for being with us this morning, and
pursuant to Rule 6, all witnesses who testify before the
Subcommittee are required to be sworn. At this time, I would
ask each of you to please stand and to raise your right hand.
Do you swear that the testimony that you will give before
this Subcommittee will be the truth, the whole truth, and
nothing but the truth, so help you, God?
Mr. Baddin. I do.
Ms. Cobb. I do.
Mr. Fox. I do.
Mr. Mandemaker. I do.
Senator Levin. Thank you.
We are going to be using a timing system today. About a
minute before the red light comes on, you will see lights
change from green to yellow, which will give you an opportunity
to conclude your remarks. Your written testimony will be
printed in the record in its entirety and we would appreciate
that you limit your oral testimony to no more than 5 minutes.
Mr. Baddin, we will have you go first, followed by Ms.
Cobb, then Mr. Fox, then Mr. Mandemaker.
TESTIMONY OF NEAL BADDIN,\1\ REALTOR FOR EQUATORIAL GUINEA
CABINET MINISTER TEODORO OBIANG NGUEMA MANGUE
Mr. Baddin. Good morning. Mr. Chairman and Members of the
Subcommittee, I appear today to answer your questions about my
role as a real estate agent for Mr. Teodoro Nguema Obiang in
the 2006 purchase of a $30 million property in Malibu,
California.
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\1\ The prepared statement of Mr. Baddin appears in the Appendix on
page 52.
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I have assisted the Subcommittee in its review of this
matter since being contacted by its staff in 2008, and I am
here today to answer any further questions you may have beyond
those that I have already answered in my 2008 interview with
the staff and a written submission. My statement today
addresses questions raised in the Subcommittee's letter of
invitation dated January 21, 2010.
I am an independent contractor associated with Coldwell
Banker Residential Brokerage in the Los Angeles area. I
represented Mr. Nguema in his purchase over a period of 15
months. I prepared offers and counteroffers on his behalf. I
communicated these offers to the broker who represented the
owner and the seller of the property. I arranged for access to
the property in order for Mr. Nguema, his staff, and other
professionals to view and inspect the property.
Senator Levin. Is Mr. Nguema Teodoro Obiang Nguema? Is that
the full name?
Mr. Baddin. Teodoro Nguema Obiang, as far as I know.
Senator Levin. Obiang. OK. Thank you.
Mr. Baddin. OK. I ensured that the required inspections,
reports, certifications, and compliance with various government
requirements concerning the property were obtained for closing.
I requested and obtained information from the seller's agent
and broker as the transaction proceeded, and otherwise, acted
as Mr. Nguema's real estate agent in the purchase of the
property.
The final terms and conditions for the sale of the property
were contained in a written purchase agreement. An escrow was
opened to consummate the purchase. The sale was consummated
without obtaining a mortgage. I was aware of the initial
deposit of funds into the escrow, but I was never involved in
handling any of that money or transferring any of the funds
needed to close the transaction. I did not know the source of
any of Mr. Nguema's funds, and I was not involved in
identifying or verifying the source of Mr. Nguema's funds.
I know this Subcommittee is concerned with the problem of
scrutinizing the activities, especially financial transactions,
of Politically Exposed Persons. I was and remain largely
unfamiliar with this term. I am neither knowledgeable nor
trained in how to handle matters involving such persons, and I
believe this is the case for most real estate agents. I do not
believe that I was under any obligation in 2006, nor am I under
an obligation today, to assume such a responsibility.
I understand that the Subcommittee accepts this, but they
want to change the rules. I understand the importance of anti-
money laundering programs. However, this is not an area in
which I have any expertise or knowledge. I believe I would need
guidance in what to look for, what to do, and how to handle
this. Thank you.
Senator Levin. Thank you, Mr. Baddin, very much. Ms. Cobb.
TESTIMONY OF BRENDA K. COBB,\1\ VICE PRESIDENT, INSURED
AIRCRAFT TITLE SERVICE, INC
Ms. Cobb. Many citizens, including lawyers and judges whom
Insured Aircraft Title Service (IATS) counsel has encountered,
are not aware that the Aircraft Registry of the Federal
Aviation Administration (FAA) in Oklahoma City is the central
repository for documents affecting title to aircraft owned by
citizens of the United States, unlike the 50 State Departments
of Motor Vehicles for automobile and boat titles. As a result,
there are approximately 18 title companies and three major law
firms in Oklahoma City which assist owners, lenders, and
encumbrancers in filing instruments at the Registry as a
service to such entities. IATS is such a title company and has
been in business since 1963.
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\1\ The prepared statement of Ms. Cobb with an attached letter
appears in the Appendix on page 53.
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In addition to filing bills of sale, security agreements,
and related documents, e.g., registration statements, for a
fee, thereby obviating as physical presence of such entities at
the Registry, IATS acts as an escrowee for money and documents
to consummate an aircraft purchase and sale agreement or
security agreement to likewise obviate the presence of parties
at a closing. As a result, it is rare that any party is present
in Oklahoma City at a closing, unlike a real estate closing at
a local abstract company with which one might be familiar.
The purchase price is wired to the bank account of the
escrowee by the buyer, and the bills of sale, security
agreements, and related documents are delivered by couriers to
IATS in Oklahoma City by sellers, lenders, and encumbrancers
for filing at the Registry, for which the escrowee IATS charges
a fee. Most communications between the parties and escrowee are
by phone, fax, or email.
As a result of its longstanding service efficiency and
integrity, IATS is also used in transactions which may not
involve citizens of the United States or one not requiring the
Aircraft Registry, or any transaction just involving the
International Registry pursuant to the Capetown Treaty.
Senator Levin. Is that it? Thank you very much.
Ms. Cobb. Thank you.
Senator Levin. Mr. Fox.
TESTIMONY OF WILLIAM J. FOX,\2\ SENIOR VICE PRESIDENT AND
GLOBAL ANTI-MONEY LAUNDERING AND ECONOMIC SANCTIONS EXECUTIVE,
BANK OF AMERICA
Mr. Fox. Chairman Levin, Ranking Member Coburn, Members of
the Committee, and staff of the Subcommittee, good morning and
thank you for the opportunity to appear before you today.
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\2\ The prepared statement of Mr. Fox appears in the Appendix on
page 58.
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I am here today representing Bank of America to provide
information relating to the Subcommittee's important work and
investigation into the financial transactions of certain
Politically Exposed Persons. I am the Global Anti-Money
Laundering and Economic Sanctions Executive at Bank of America,
a position that I have held since August 2006. Before joining
Bank of America in 2006, I served for over 2 years as the
Director of the Financial Crimes Enforcement Network, the U.S.
financial intelligence unit and the Treasury agency responsible
for administering the Bank Secrecy Act as well as certain
provisions of Title 3 of the USA PATRIOT Act. Since 2001, my
career has been focused almost solely on the prevention and
detection of money laundering, terrorist financing, and other
financial crime.
At Bank of America, we believe that a clean and transparent
financial system is in the direct interest of all responsible
financial institutions. A clean and transparent financial
system levels the playing field for all. We have developed a
robust program to address the problems and risks associated
with money laundering, terrorist financing, and other financial
crimes. We provide training on these issues to the vast
majority of Bank of America's over 300,000 associates.
At its most basic level, our program rests on three main
principles. First, the collection of sufficient due diligence
information at the time of onboarding to ensure positive
identification of prospective clients and to enable us to know
better our clients as they walk in the door.
Second, we conduct ongoing diligence of the client through
an intelligence-based program of the active monitoring of, and
in certain cases surveillance of, our clients' activity.
And third, a dedicated program to analyze potentially
suspicious activity, and when suspicious activity is found, to
work proactively with law enforcement agencies to assist in any
investigation they may undertake.
We are proud of our program, and I state unequivocally that
our program has significantly improved over the past few years.
We have dramatically increased staff and spent tens of millions
of dollars on sophisticated systems which help us to detect and
report suspicious activity to appropriate authorities.
Our proactive engagement with law enforcement has been very
successful. We have received many letters and commendations
from law enforcement agencies thanking us for our work and
complimenting our efforts.
Our company's commitment to do what we can to address the
important problems of money laundering, terrorist financing,
and other financial crime goes well beyond the necessity to
comply with regulatory requirements or the fear of a damaged
reputation. I can testify here today that I have received
nothing but outstanding support for our program from the top
leadership of Bank of America. The support is there on both
strategic initiatives and on specific matters.
Our commitment on these issues is further demonstrated by
our longstanding record of full cooperation and complete
transparency with this Subcommittee. Notably, our cooperation
has gone beyond complying with requests for information and
subpoenas. We have actively assisted your staff to better
examine and analyze the financial services industry as well as
our own procedures and products, both in the past and it has
completed the important work that led to the report issued
yesterday.
Regarding our role in the case studies before the
Subcommittee today, we have provided your staff with the facts.
While there is no question that Bank of America associates
involved in these matters were acting in good faith, when we
look at the facts today with hindsight, we believe we should
have done better. I am confident that the decisions we would
make today would be different than the decisions we made
several years ago, given the improvements in our program.
Our current program processes, systems, oversight, and
methods are all much more robust today than they were in years
past. I am confident that if we had today's processes, systems,
and oversight in place when the activity in question was
occurring, we would have caught or prevented the activity. And
even when mistakes are made--and Mr. Chairman, they are made--
today, it is far more likely that we would catch those mistakes
and correct them sooner.
I would like to highlight some of the enhancements that are
specific to the issues before the Subcommittee today. Through
our intelligence and screening processes, we have improved our
ability to detect attempts by customers who have had their
accounts closed to reenter our bank. We have adopted policies
in our company to go beyond what is legally required in the
United States that will require certain non-publicly traded
entity customers to provide beneficial ownership information
when opening accounts. We have also decided to make no
distinction between foreign and domestic Politically Exposed
Persons.
We believe it is prudent to take these steps to effectively
manage our money laundering and sanctions risks, and while some
may say it will place our firm at a competitive disadvantage,
we do not believe that is the case. It is just simply the right
thing to do.
Finally, Mr. Chairman, I would respectfully submit to this
Subcommittee that a practical and immediate way to move forward
on the important issues you are discussing today is to
encourage a more robust implementation of the public-private
partnership envisioned by Title 3 of the USA PATRIOT Act.
Specifically, Section 314(a) of that Act contemplates a new
paradigm, an approach to address the problems of money
laundering, terrorist financing, and other financial crime.
The timely non-public sharing of sensitive information in
the government's possession with financial institutions could
do as much to prevent access by kleptocrats and their
associates and families to the U.S. financial system as almost
any other action the government could take. This partnership in
sharing is helping to keep us safer every day in the context of
terrorism investigations, and I believe this same approach
would be very useful in addressing this significant issue.
No program is perfect, Mr. Chairman. However, I can testify
to you that my company remains committed to continually
improving our systems and procedures as technology advances and
as the environment in which we operate evolves, as financial
crimes become more sophisticated.
Thank you, Mr. Chairman, Ranking Member Coburn. We
appreciate your time. We will be pleased to answer any
questions you have.
Senator Levin. Thank you, Mr. Fox. You have pointed out
that you have cooperated with this Subcommittee and it is
appropriate that you point that out, because, in fact, you
have. We are appreciative of that cooperation of you and other
witnesses. I am glad you noted it and we are more than willing
to acknowledge it.
Mr. Fox. Thank you, Mr. Chairman. We appreciate that very
much. Mr. Mandemaker.
TESTIMONY OF WIECHER H. MANDEMAKER,\1\ DIRECTOR, GENERAL
COMPLIANCE, PERSONAL FINANCIAL SERVICES, ANTI-MONEY LAUNDERING
COMPLIANCE, HSBC BANK USA, N.A.
Mr. Mandemaker. Good morning, Chairman Levin, Ranking
Member Coburn, and Subcommittee Members. My name is Wiecher
Mandemaker. I am a Director of General Compliance at HSBC Bank
USA.
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\1\ The prepared statement of Mr. Mandemaker appears in the
Appendix on page 66.
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Thank you for the opportunity to appear before you today to
discuss our efforts to combat money laundering and the misuse
of international banking facilities by Politically Exposed
Persons (PEPs). HSBC appreciates your longstanding interest and
leadership on these issues.
HSBC adopted a policy addressing our banking relationships
with PEPs in 2000. Our policy predated the USA PATRIOT Act and
was implemented before any Federal statutes or regulations
required banks to conduct enhanced due diligence on PEPs.
Today, our broader anti-money laundering (AML) practices
continue to exceed Federal requirements. HSBC applies enhanced
due diligence to all accounts held by PEPs as a component of
its overall risk-based approach. In high-risk jurisdictions,
HSBC also conducts due diligence on non-publicly traded foreign
correspondent banking clients down to the 5 percent ownership
level.
The most effective anti-money laundering practices are
risk-based and require pragmatic balancing acts and tradeoffs.
We are, therefore, always on the lookout for improper activity
or customers that may slip through our first lines of defense.
Despite our best efforts, we do not always catch every instance
of unusual activity as soon as we would like. We also know that
even the best AML programs have room for improvement. Your
investigation has helped highlight this reality and we welcome
your insight on these issues.
On balance, we are very proud of our record, which
evidences a consistent pattern: HSBC employees routinely seek
out guidance from compliance, and when we have become aware of
issues, we have refused to process those transactions and
carefully scrutinized the relationships. When we discover a
pattern of unexplained or questionable activity, we have
promptly ended relationships and taken other appropriate
actions.
You have asked me to address a number of specific topics
today, and I have attempted to address them all candidly in my
written statement. In the interest of time, I will not go into
detail now except to briefly address the report's case study on
HSBC's banking relationships in Angola.
Let me be clear, HSBC is committed to being a positive
force in Angola and we work hard to ensure that our facilities
are not used to further money laundering schemes. To that end,
we have long applied the highest level of scrutiny to our
relationships with Angolan banks. We have also, as a benchmark,
recently looked at the BAI wire transfer activity we provided
to the Permanent Subcommittee on Investigations (PSI) for
December 2003 and December 2006. Ninety-eight percent of those
funds are flowing from the United States to Angola. In other
words, those funds clearly reflect investments from the United
States into the Angolan economy.
We do not see patterns that are obvious indicia of funds
inappropriately going from Angola into the United States.
Indeed, we are pleased that today's report contains not a
single allegation of fraudulent transactions connected to BAI.
We also take comfort in the fact that the United States Export-
Import Bank has recently selected BAI as one of four partners
to help facilitate U.S. exports to Angola.
We understand that today's report suggests we should know
more about BAI, including more about beneficial owners and more
about BAI's AML procedures. We believe we have more than met
the law's requirements, but will also look for ways to be
responsive to your concerns.
As a first step, I want to let you know that this morning,
one of our employees was able to obtain from BAI a current
translated AML policy.
Finally, I want to emphasize that HSBC stands ready to
support the efforts of this Subcommittee to strengthen the
current U.S. regulatory and enforcement regime. As the
``World's Local Bank,'' located in far more countries around
the globe than most other institutions, we understand the
unique opportunities and challenges we have in the fight
against corrupt practices. We accept this responsibility and
seek to positively influence countries that are working hard to
strengthen their financial systems and banking practices.
I will be pleased to answer any questions that you have.
Senator Levin. Thank you very much, Mr. Mandemaker.
Let me start with Ms. Cobb. Please take a look, if you
would, Ms. Cobb, at Exhibit 32 in the book in front of you
there.\1\ Using a shell corporation called Ebony Shine
International, Mr. Obiang purchased a Gulfstream jet for $38
million. Now, the escrow agent, McAfee and Taft, who was
supposed to handle the transaction, had set up its own anti-
money laundering program, not because it was required by law to
do so--it is not required by law--but because that is the way
they wanted to do business. When McAfee and Taft learned that
Mr. Obiang was involved in the transaction, they asked for
information on the source of his funds. They asked repeatedly
with no success, and finally on April 7, 2006, they sent this
email, Exhibit 32. We have a chart with a piece of that email
on it.
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\1\ See Exhibit No. 32 which appears in the Appendix on page 570.
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This is what Scott McCreary from McAfee and Taft wrote. ``I
just want to make sure that everyone is on the same page and
aware that for us to continue to hold funds, I must be provided
with the PATRIOT Act due diligence by Monday morning and it
must be in a form acceptable to us. If I don't have the
information or if I am in any way unsure, I will wire the funds
back to the account of the party sending said funds to us or we
can wire the funds back to IATS if they are willing to act as
escrow agent.''
McAfee and Taft never got the information on the source of
the funds and they sent the money back. That is when your
company, Ms. Cobb, Insured Aircraft Title Service, stepped in
and completed the transaction.
Now, can you give us the reasoning of your company, why you
decided to complete a transaction when McAfee and Taft declined
to do so?
Ms. Cobb. We were unaware that McAfee and Taft had declined
the transaction or their reasons thereof. We work closely with
McAfee and Taft on a lot of transactions. It is a very small
community, the escrow community for aircraft transactions. It
is my understanding that not only had we wired funds at the
instruction of Mr. Obiang to McAfee and Taft, but he had wired
them funds directly, as well. In going over some of the
material that was not in my escrow file, it was shown that the
funds were all wired back to the originating sources.
We acted as the escrowee for the purchase. The purchase
price was wired to IATS pursuant to the contract. We closed the
transaction. The funds originated from the party that was
listed on the purchase agreement. It was our understanding that
the reason the transaction--our funds were sent to McAfee and
Taft initially was because the seller had purchased the
aircraft using McAfee and Taft as their escrow agent, so they
were very familiar with them. As I stated, we had no way of
knowing why McAfee and Taft declined to do the transaction. We
just received the funds back from them.
Senator Levin. Were you aware that it was Mr. Obiang who
was purchasing the aircraft?
Ms. Cobb. Yes.
Senator Levin. And did you have any idea about his
background?
Ms. Cobb. No, sir.
Senator Levin. Now, McAfee and Taft lost that work, or gave
up that work, because it had a voluntary anti-money laundering
program. Your company did not have that same kind of a
voluntary program. Would it have made a difference to you if
you were aware of his background?
Ms. Cobb. Absolutely.
Senator Levin. And if all escrow agents were required by
law to know their customers, if there were, in other words, not
that exemption that the Department of Treasury had granted, I
assume your company would then follow the law----
Ms. Cobb. Oh, absolutely.
Senator Levin. That is a given. Do you have a position as
to whether or not that exemption should be removed and whether
all escrow companies should be required to follow an anti-money
laundering law? Do you have an opinion on that?
Ms. Cobb. I think we should be required to look deeper into
our clients. To date, we have relied on the banks to not
forward the funds into our account if they have done their due
diligence. We assume that due diligence has been performed
before the funds are released to us.
Senator Levin. And what this transaction shows is really
the power of the PATRIOT Act. We have one company that
voluntarily followed a ``know your customer'' rule that applies
to banks by the PATRIOT Act. Another company which was not
required to have a ``know your customer'' rule and it did not
adopt it, which it was its right not to do. But it shows just
in this example that if we had some kind of a ``know your
customer'' rule for escrow agents, that it could make a real
difference. And we very much appreciate your forthright
testimony on the subject.
I am going to turn to Senator Coburn.
Senator Coburn. Ms. Cobb, thank you for being here.
Ms. Cobb. Thank you.
Senator Coburn. Welcome, as an Oklahoman to an Oklahoman.
I note in the document that is up there, and I would like
for you to explain to me why McAfee and Taft would talk about
that the funds originated with you, obviously, because in the
last sentence of this email, their communication says, ``or we
can wire the funds back to IATS if they are unwilling to act as
an escrow agent.''
So I have two real questions for you. One, is they got the
money from you, according to this email, originally? Two, is it
often that you all encounter someone else who has turned down a
deal that you will take? And do you ask questions as to why
somebody might have turned down a deal?
Ms. Cobb. As to the first question, we didn't wire the
entire proceeds. We had received an initial deposit. It is not
uncommon for us to receive deposits prior to receipt of a
purchase agreement. When they were dealing with Blue Sapphire,
Blue Sapphire desired to use McAfee and Taft. Mr. Obiang asked
us to forward that deposit to McAfee and Taft. Also, I believe
McAfee and Taft did not have a Union Bank of Switzerland (UBS)
account that would accept Euros and convert the dollars.
Senator Coburn. All right.
Ms. Cobb. So that is how those funds came to us. Now, I
understand that there were funds that went through UBS later
that went directly to McAfee and Taft. I have had people come
to me with transactions that they did not like the company that
the seller picked out and they desire to use us instead of one
of our competitors.
McAfee and Taft, this is the first that I have heard that
they have these procedures for exercising PATRIOT Act issues.
To my knowledge, they are the only one of the three major law
firms and 18 title companies that has a procedure like that,
and I think it is a good procedure to follow. But as I said, we
generally depend upon the banks to perform their due diligence
before those funds arrive to us.
Senator Coburn. So you are hoping the backstop is the banks
before it gets to you----
Ms. Cobb. That is correct.
Senator Coburn. And it is not uncommon that people might
change escrow accounts or who is managing the escrow accounts
and completing transactions, title transactions. That is not an
uncommon occurrence?
Ms. Cobb. No, it is not uncommon.
Senator Coburn. All right. I would like to go to Mr. Baddin
for a minute. I am curious as to why you did not want your name
listed as a selling agent in a very large transaction, which
usually is something that helps. As a matter of fact, I get
cards all the time from agents that have big sales because I
actually have one piece of property that I have considered
selling, and they are always bragging about the big sales they
have made. Why would you not want your name associated with
this transaction?
Mr. Baddin. Sir, I am not a braggart. That is not my style.
But in Los Angeles, it gets to be a small community and I did
not want a lot of questions asked of me, because a lot of
agents get very jealous or they want to know everything about
large transactions. All I was trying to do was be very low key
about it. I wasn't trying to hide anything other than the fact
that I was involved in the real estate transaction.
Senator Coburn. Would you mind submitting to the
Subcommittee numerous other examples of properties of similar
size that you have sold where you have chosen not to have your
name listed as the selling agent?
Mr. Baddin. I have not sold other properties of this
magnitude.
Senator Coburn. Well, how about of even smaller magnitudes?
Do you routinely exclude your name as the selling agent?
Mr. Baddin. Not routinely, but I have done it before.
Senator Coburn. Would you mind submitting those instances
to the Subcommittee?
Mr. Baddin. I can't really think of one right now. I can't
think of something that--I have had a career of 30 years, and--
--
Senator Coburn. Well, when was the last time, other than
this time, that you chose to keep your name off as the selling
agent for a property?
Mr. Baddin. I think probably about 20 years ago.\1\
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\1\ See post-hearing letter submitted to the Subcommittee by Mr.
Baddin as Exhibit No. 126 appears in the Appendix on page 829.
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Senator Coburn. In terms of your testimony, you were
unaware of the reputation of the individual you were
representing as a corrupt foreign official when you began
working for him.
Mr. Baddin. Yes, sir. That is correct.
Senator Coburn. And when did you first become aware of the
characteristics that the Subcommittee would tend to ascribe to
what was going on?
Mr. Baddin. Probably when I was approached by your
Subcommittee in 2008.
Senator Coburn. Not before? So it wasn't suspicious to you
at all? This is the first time you have handled a sale of this
size, magnitudes of order above what you have handled before--
--
Mr. Baddin. Yes, sir.
Senator Coburn [continuing]. And that wasn't suspicious to
you at all. And are there, in fact, other agencies and
independent real estate agents in your area that have routinely
handled sales of this size?
Mr. Baddin. Well, I know other sales of large magnitude
have been closed. There have been purchases for large amounts
of money.
Senator Coburn. Did you ever have any inclination to ask
Mr. Obiang about the source of his wealth or the reliability of
his resources?
Mr. Baddin. No, I did not, sir.
Senator Coburn. Were you curious at all to know that
someone could come to you and purchase an asset like this?
There was no curiosity as to the source?
Mr. Baddin. I didn't ask because I had a little bit of
background information as to possibly how wealthy he was.
Senator Coburn. And what was that background information?
Mr. Baddin. Well, it goes back to sometime in probably
early 2004. I was going around on a Sunday afternoon looking at
open houses, which real estate agents do once in a while, and
just by the odds of it, I walked into a very large property
that I saw was listed for seven or eight million dollars, a
very odd kind of property, and I knew the listing agent so we
started talking. I said something like, gee, who would own a
property like this, and he said, oh, it is a minister of a
foreign country. Then I said, oh, wow. And he says, well, if
you want to see something really interesting, let me show you
the garage. All right.
So we went down to the garage and I saw several of what I
thought were very expensive cars and very fancy motorcycles. I
don't know anything about motorcycles, but these were very
beautiful looking machinery. I realized, thinking to myself,
whoever owns this property has a lot of money. And that was it
and I left. I walked out.
Subsequently, several months later, Mr. Berger called me
and said, I may have a client that I would like to refer you
to. And we started talking and it became obvious that this was
the same gentleman that owned this house on a street called
Antelo Drive. Mr. Berger said to me that he would like to
purchase a property, a very expensive property, and he can
afford to do that. That is my background. That is how I knew.
Senator Coburn. One further question on that and then I
will yield back to my Chairman. Was that your first contact
with Mr. Berger?
Mr. Baddin. No.
Senator Coburn. Have you had an acquaintance with him
through the years?
Mr. Baddin. Yes, sir.
Senator Coburn. And has he referred you multiple clients in
the past?
Mr. Baddin. A couple.
Senator Coburn. But none of this magnitude?
Mr. Baddin. No.
Senator Coburn. All right. Do you have any second thoughts
or reflections about having handled this transaction?
Mr. Baddin. Now, I do.
Senator Coburn. And what are they?
Mr. Baddin. I don't think I would have gotten involved.
Senator Coburn. You see the fact of the theft of property
from some of the poorest people in the world to live in luxury
at the expense of their demise.
Mr. Baddin. I don't really have all that information, but I
have heard a lot of things.
Senator Coburn. All right. Thank you, Mr. Chairman.
Senator Levin. One of the suspicious things, I think you
would agree, is that instead of a mortgage on a $30 million
property, that there was $30 million wired into an escrow
account. Was that something which struck you as unusual, to
have no mortgage on a $30 million property? Was that fairly
rare?
Mr. Baddin. I had never handled a $30 million property.
Senator Levin. Generally, would there be mortgages on
properties that were of large size?
Mr. Baddin. Sir, I have never handled a $30 million
property. I am assuming that--I don't even know how you would
qualify to get a $30 million mortgage. I have no idea.
Senator Levin. Have you handled a lot of properties where
there was no mortgage?
Mr. Baddin. Every once in a while, I do.
Senator Levin. Where it was just all cash?
Mr. Baddin. Yes, sir.
Senator Levin. I think you told our staff that it was
something which surprised you, that this was all cash, did it
not?
Mr. Baddin. I don't remember that.
Senator Levin. All right. Were you familiar with Exhibit
30--take a look at Exhibit 30, if you would.\1\
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\1\ See Exhibit No. 30 which appears in the Appendix on page 567.
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Mr. Baddin. Oh, thanks.
Senator Levin. When is the first time you saw that?
Mr. Baddin. I don't remember the first time I ever saw it,
and I am not sure when I did see it, but I believe this is from
the escrow, which I don't get involved with as far as paperwork
and----
Senator Levin. Have you seen this before?
Mr. Baddin. I think I have seen it, but I don't know when
or the first time that I actually saw it.
Senator Levin. This shows escrow deposits, $5 million, $5
million, $5 million, $5 million, $5 million. Do you see all
those deposits?
Mr. Baddin. Yes, I do.
Senator Levin. All right. This is what the Department of
Justice says about Mr. Obiang, that they are investigating
suspected criminal conduct of Mr. Obiang and his associates
involving the illicit transfer and laundering of assets
believed to be derived from extortion, bribery, and/or
misappropriation, theft, or embezzlement of public funds. That
is from a Department of Justice document, which is Exhibit
41.\2\ Knowing about that, would that trouble you to be
involved in that kind of a transaction in any way?
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\2\ See Exhibit No. 41 which appears in the Appendix on page 601.
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Mr. Baddin. I was not aware of that document.
Senator Levin. No, I know, but knowing that now, would it
trouble you to be involved in a transaction----
Mr. Baddin. At this point in time, yes, sir.
Senator Levin. You may have answered this already. Did you
attempt to determine how Mr. Obiang would obtain funds like
this?
Mr. Baddin. I did not.
Senator Levin. To your knowledge, did anyone involved in
the transaction attempt to learn how or where Mr. Obiang would
obtain funds to pay for this property?
Mr. Baddin. Sir, the only person that would be probably
concerned with it would be the escrow officer.
Senator Levin. But you don't know whether any effort was
made to obtain the source of funds?
Mr. Baddin. I don't.
Senator Levin. Mr. Fox, let me ask you about the Falcone
accounts at Bank of America. Now, Mr. Falcone is a notorious
arms dealer. He supplied weapons during Angola's civil war. He
is a close associate of Angolan President Jose Eduardo Dos
Santos. He supplied arms to Angola in violation of the arms
embargo. As I indicated, he had lots of problems with the law,
serving a 6-year prison sentence now for bribery, tax fraud,
and other misconduct.
Now, when that was going on, he opened 30 U.S. accounts
with Bank of America, used those accounts to move millions of
dollars in suspect funds through the United States and abroad.
There were a number of suspicious transactions, and you have
been very forthright in acknowledging that these transactions
should have been subjected to greater scrutiny.
The account got $6 million in wire transfers from
unidentified clients in secrecy jurisdictions like Caymans,
Luxembourg, Singapore, and Switzerland. They got $2 million
from obscure offshore corporations like AALL Trust and Banking
Corporation, Cullen Investments, Rego Holdings, and Valley
Marketing. They set up a shell company in Arizona called, it
looks like Monthigne Corporation, funneled millions to that
account. The accounts often transferred large dollar amounts
from one Falcone account to another, often on the same day.
This was what the State Department said in 2005 about
Angola, that the laundering of funds derived from high-level
corruption is a concern, as is the poorly controlled trade in
diamonds and the potential use of diamonds as a vehicle for
money laundering. Their report, again 2005, when a number of
these transactions took place, that the government's record
includes the following: Unlawful killings, disappearances,
torture, beatings, abuse of persons, corruption with impunity,
violence and discrimination against women and children.
Now, the Banking Center--and let me now refer you to
Exhibit 87\1\--this is what your--Bank of America's review
showed. The Banking Center believes, at the bottom of paragraph
one, that the customer conducted these transactions--these are
certain identified transactions--in an attempt to avoid CTR
reporting. So you have right off the bat in 2004 a belief on
the part of your own bank that the customer was conducting
those transactions to avoid--in an attempt to avoid currency
transaction reports. That is what CTR means.
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\1\ See Exhibit No. 87 which appears in the Appendix on page 746.
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Then in the middle of the next paragraph, it says--and this
is your bank's own words--that through Falcone's deals, he,
because of his involvement and knowledge of the arms for sale
programs, Falcone developed a very close and tight relationship
with the government of Angola, so much that he was even granted
citizenship. Because of this close relationship, it was soon
discovered that Falcone and his business partner, Gaydamark,
were benefiting financially, from Angolan diamonds and oil.
Falcone was brought before a French court on charges of
corruption, for which he was indicted and sentenced to 1 year
in jail. Now, that is your report by your anti-money laundering
folks.
But then the conclusion on page two, which is incredible to
me, is that the activity for the accounts of the Falcones is
not unusual. How could anyone, having laid out all of that on
page one, then conclude at the top of page two of the anti-
money laundering report that his activity does not appear to be
unusual?
Mr. Fox. Mr. Chairman, I agree. Listen, I think that what
we believe happened in this particular case is that we had an
investigator that was focused very distinctly on the
structuring violation, if you will, even though she actually
did a good job, I think, of finding information, she missed the
relevance of that information or pulling all of that
information together. I would even go farther, Mr. Chairman, in
saying that I think our investigator missed looking back at the
histories and the wire activity that has been involved with the
Falcone accounts.
I think this was clearly a bad judgment call on behalf of
the investigator, and I think our processes have been
significantly enhanced since that time. I believe that not only
would we have presented the entire piece of the information for
investigators so that they can look at these sort of situations
more holistically, but we have instituted an oversight process
where a more robust review occurs before these matters are
actually finalized.
I can also say that we have instituted a post-closing, if
you will, review and testing process where we go back and test
decisions that are made to make sure that we aren't making
decisions that, candidly, are wrong. And so I think that based
on these particular facts, in hindsight, we would have made a
very different decision today if we would have had the right
processes in place back then. I think the good news, Mr.
Chairman, or what I can testify today is that we have
significantly enhanced those processes. I do not believe the
same errors would be made today.
Senator Levin. So you would agree that those accounts are
actually the epitome of high-risk accounts and should have been
handled that way?
Mr. Fox. I believe today, we would----
Senator Levin. Not even just today, but that a mistake was
made back then in not handling them better?
Mr. Fox. Yes, sir. I think we should have handled these in
a better way.
Senator Levin. Dr. Coburn.
Senator Coburn. Mr. Fox, how do you handle business clients
today who do not want to disclose their ownership information?
Mr. Fox. At this point in time, Senator, we pretty much
require that information.
Senator Coburn. Are there exceptions to that?
Mr. Fox. You never want to say----
Senator Coburn. Well, if there are, what are the
exceptions?
Mr. Fox. I think that in our present policy today, we
require that companies generally get beneficial ownership
information, particularly non-publicly-traded companies.
Senator Coburn. All right. But you said generally.
Mr. Fox. Yes.
Senator Coburn. So what are the exceptions?
Mr. Fox. There are times for entities that we deem as
standard risk, and when we know that customer or we know that
entity, we will not gather that information.
Senator Coburn. So I could have been a long-term customer
and you could know me and then I want to set up a new account
for some subversive reason that would not necessarily be
appropriate by your standards, and it might be that 80 percent
of what I am doing is owned by somebody else and you are not
going to look at it.
Mr. Fox. Actually, we would look at it, Senator, in this
sense, that while we may not go and gather that information on
that particular account, we would continue to monitor very
actively that account, and if there was activity in that
account that caused the trip to trigger, that could cause us to
go back, re-look at it. We would reinvestigate. Then we would
go and get that information.
But I do want to emphasize, Senator, if I can, that for the
vast majority of accounts, that for any elevated risk, we now
have a stated policy where we will acquire that information for
those companies.
Senator Coburn. The new burdens of having your beneficial
ownership rules, have they created any burdens for smaller
businesses?
Mr. Fox. I think that any additional information that is
required, Senator, to open up bank accounts is, I think,
business would deem a burden. I think in our case, we balance
the burden with the risk and we believe that it is an
acceptable burden to do. So far, the experience we have had, to
my knowledge, has been quite good with businesses.
Senator Coburn. OK. Could you relate to me Bank of
America's definition of beneficial ownership?
Mr. Fox. Yes, sir. Today--I just want to get it right--a
beneficial owner is any individual who has a level of control
over or entitlement to the funds or assets in the account that
enables the individual directly or indirectly to control,
direct, or manage the account.
Senator Coburn. OK. Thank you.
Mr. Mandemaker, you are one of the world's biggest banks
and you move more money through more countries than probably
anyone else. What would it require for you to lead the world in
anti-money laundering versus what you are doing today? And I
don't mean any incrimination by that, so please don't take it
that way. But since you are one of the world's leaders in terms
of money transfer around the world, what would it require at
your firm to change this to where you become the leader in this
rather than not the leader?
Mr. Mandemaker. Thank you, Dr. Coburn. I believe that we
have taken a leadership role in this matter. HSBC was one of
the founding members of the Wolfsberg Group, which was
recognized in the report as setting standards for PEPs
voluntarily very early on. We continually look to take those
efforts further. I believe we have taken measures that take us
beyond the requirements of the law. We will take a close look
at this report. If we believe that there are opportunities to
improve on our activities, I am sure that we will do so.
And quite frankly, Senator, we are not perfect, but I do
believe that we are one of the leading institutions, especially
when it comes to identifying appropriate anti-money laundering
practices, and not doing business with individuals that we
shouldn't be doing business with, and I am quite proud to be
part of that institution.
Senator Coburn. All right. Thank you. What do you think we
could do, as the U.S. Government, that would help you in that
regard? Other than create more rules and regulations for you to
have to comply with.
Mr. Mandemaker. Yes. This is always a great challenge
because we absolutely want to make sure that our financial
system is safeguarded from any improper activities. And so I
think certainly the identification of Politically Exposed
Persons (PEPs), if there is any way that the U.S. Government
can assist in the compilation of a standard list, that will
certainly not mean that we will only adhere to that standard
list, but I think it is recognized that there are challenges in
name matching, and I think that is recognized in other matters,
as well.
With respect to beneficial ownership, I think there are
some good efforts underway to help that. I believe those are
particularly important to law enforcement and we want to have a
strong partnership with law enforcement on that. We identify
beneficial owners. There are some recommendations around the
recording of that in an official manner, and if we can
implement that without too much undue burden, we will certainly
work on that, Senator.
Senator Coburn. Are there exceptions to your beneficial
ownership rules?
Mr. Mandemaker. I am not aware of any exceptions to our
beneficial ownership rules.
Senator Coburn. So accounts opened with HSBC, you are going
to know the beneficial owners of those accounts?
Mr. Mandemaker. We know the beneficial owners of accounts
opened today. Under the PATRIOT Act, we were not required to do
a look-back. But I can assure you that if a customer with an
existing account prior to the implementation of the PATRIOT Act
came in today, we would apply today's standard to identifying
that owner.
Senator Coburn. OK. Thank you. Thank you, Mr. Chairman.
Senator Levin. Thank you.
Going back to you, Mr. Fox, on this beneficial ownership
thing, I think you said something which is significant relative
to this issue, but I don't think it was clear and I want you to
clarify it. Do I understand that the Bank of America is
announcing that you are going to require corporate clients to
require their beneficial owners in writing on their form--on a
form?
Mr. Fox. Yes, sir. What we are going to do for, again, the
majority of--or for clients--let me be clear here--for
corporate clients that are of elevated risk, either medium or
high risk as we determine them, they will need to identify
beneficial ownership information as that term was defined, and
as I mentioned, I would be happy to discuss that definition, as
well.
Senator Levin. All right.
Mr. Fox. Our goal, Mr. Chairman, is to get to the two-
legged person so that we know who is behind these entities.
Senator Levin. OK, and that is something which is overdue
in the United States, in my judgment, and that is what our bill
would cure because we are telling other countries and putting a
lot of pressure on other countries to be transparent. We are
going after the secrecy tax havens so that the people who owe
taxes will pay those taxes. And other countries in many
instances require beneficial owners to be identified, and it is
important that happens because we don't have much standing to
go after secret bank accounts and hidden bank accounts in
offshore jurisdictions if we tolerate not knowing who the
beneficial owners are of our own bank accounts here.
And what you are announcing today, I think, is a
significant step, and I hope it is taken note of, that the Bank
of America, at least with a significant number or certain
categories of clients, is going to obtain the beneficial
ownership of those accounts.
Mr. Fox. Yes, sir.
Senator Levin. OK. Is this similar to what is called Form A
in Switzerland, do you know?
Mr. Fox. Well, I think we all have our different systems. I
mean, what we will do is require as part of our initial due
diligence processes for these customers or clients, they will
need to be able to provide that information, and, of course,
that information will then be reviewed for all the various
purposes we would review them. If they don't provide the
information, they are not going to get the accounts.
Senator Levin. And you are implementing doing this, as I
understand it, a World Bank recommendation which calls for
those forms?
Mr. Fox. I am a little confused about the form, Mr.
Chairman. What we are going to do is require the information,
make sure that we keep the information, make sure that it is
available, not only for law enforcement, but for our purposes,
our risk management purposes.
Senator Levin. All right. Well, thank you. We want to thank
you for taking this step. It is an important step. We hope
other banks will follow, those who don't already do it.
Mr. Mandemaker, let me ask you now about the incident
involving the head of the Central Bank of Angola, Dr. Jaime. In
2002, Dr. Jaime transferred $50 million from the Angolan
Central Bank account in London to HSBC in New York. HSBC opened
up a securities account called a collateral account with Dr.
Jaime as the sole signatory. And then there was a moment when
they asked you to use the money to buy $50 million in Treasury
bills, and so far that is not anything unusual for a Central
Bank to do.
But then in August 2002, Dr. Jaime asked HSBC to transfer
those Treasury bills to a securities account at Wells Fargo. It
was held by an attorney in California by the name of Jan Morton
Heger. But the bank on the other end of the transfer, Wells
Fargo, saw it as suspicious and they sent it back to you. So
they saw something as suspicious. You apparently did not. Why
didn't you see it suspiciously and they did?
Mr. Mandemaker. Senator, the Wells Fargo institution, and
as I have certainly learned more from the report today, was
able to look at that transaction in context with the record of
Mr. Heger at that time. That made them, if I recall correctly,
uncomfortable with the situation. We certainly regret that we
did not catch that sooner. I just want to be clear that HSBC
employees, as the report indicates, were not complicit in this
scheme. Following that transaction, there were some other
attempted transactions that were appropriately escalated. They
were brought to the attention of our compliance officers and
they stopped the transaction. In the end, the money was
returned to the Central Bank of Angola.
And so could we have caught that sooner? Absolutely. Do I
think we have appropriate processes in place today that will
catch it sooner? I believe so and I am very proud that our
record on that matter has evolved to where we are today.
Senator Levin. Well, let us go into some detail on that
transaction because it is not quite as positive a transaction
as you describe, at least in my judgment. In October 2002, Dr.
Jaime told your bank that the bank could keep the $50 million
in T-bills in the New York account for the Angolan Central Bank
on a condition, and that condition was that the bank--and that
is the HSBC Bank--provide him with a negotiable safe keeping
receipt, in other words, a document that shows the $50 million
value of the T-bills in custody at HSBC and which could be sold
to someone else.
Now, I think you would agree that was a highly unusual
request. Would you agree with that, going in?
Mr. Mandemaker. That would be a transaction of concern,
certainly.
Senator Levin. OK. But HSBC in the first instance agreed to
that condition, and that is Exhibit 109.\1\ It is on Angolan
National Bank stationery, signed by Dr. Jaime, and he is asking
you to agree to this unusual deal, which puts $50 million under
his personal control. He signs the letter, and then your Mr.
Godino acknowledges and he agrees to it, signing it as HSBC
Bank USA as collateral agent. Do you know Mr. Godino?
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\1\ See Exhibit No. 109 which appears in the Appendix on page 788.
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Mr. Mandemaker. I am not familiar with Mr. Godino.
Senator Levin. All right. And then on HSBC stationery--it
is part of the same exhibit--signed by Mr. Tischler, Senior
Vice President, HSBC, that you write to Governor Jaime, ``that
you are enclosing an original of that October 16 letter on
which Frank J. Godino, from my office, has affixed his
signature and corporate seal of HSBC Bank USA, indicating that
the bank as collateral agent has acknowledged and agreed to the
terms in the letter.'' So HSBC, before it reversed itself
later, agreed to this, is that accurate?
Mr. Mandemaker. Senator, I can't speak for Mr. Godino----
Senator Levin. No. I am saying this letter shows that HSBC
agreed to the terms of the letter.
Mr. Mandemaker. Again, it is hard for me to understand what
Mr. Godino believed he agreed to, because there are other
components of that letter. Dr. Jaime asked us to cancel the
prior instructions, and then he asked us to issue the safe
keeping receipt. It would be very reasonable to understand that
as Mr. Godino was agreeing at least to the cancellation. And as
our record indicates, we drafted that document, but when it got
to our compliance people for final review, before it was
released to Dr. Jaime, it was stopped. We did not get any push-
back from the business in stopping that and it was never
actually released to Dr. Jaime.
Senator Levin. But there was an agreement reached which was
then not implemented. According to this document, it says the
agreement was signed. It is on HSBC stationery. The words
``agreed to the terms of the letter,'' the letter referred to
is October 16, 2002, and it is Exhibit 109. I mean, that speaks
for itself, does it not? There was an agreement signed.
Mr. Mandemaker. I understand that Mr. Godino has provided
testimony to the Subcommittee on that and----
Senator Levin. I am just talking about the letter on your
stationery, sir.
Mr. Mandemaker. I understand that, Senator.
Senator Levin. Am I reading this correctly? If you would
look at Exhibit 109----
Mr. Mandemaker. Yes. What you are stating is in the letter,
that is correct, yes.
Senator Levin. All right. And this is signed by a Senior
Vice President of HSBC?
Mr. Mandemaker. Yes. I don't know--you said one signed by
Mr. Tischler? Because I don't see that. What is the number on
that exhibit?
Senator Levin. Exhibit 109.
Mr. Mandemaker. Exhibit 109, because I have three pieces of
paper. OK. Yes, I see it. That is a cover letter and it is my
understanding when Mr. Tischler prepared that letter to
accompany the document, that was then reviewed for final
release, and then it was stopped by our legal and compliance--
--
Senator Levin. I know you say it was stopped later on, but
there was an agreement that he acknowledged, is that not true,
in that letter itself?
Mr. Mandemaker. That appears to be the case.
Senator Levin. All right. Now, your compliance officer then
later on pointed out--and this would have been, I guess, a
couple of weeks later--that this is improper and the
transaction should not go forward, as you have pointed out.
Now, after this incident occurred, Citibank, which had
accounts for the Angolan Central Bank in London, closed its
account. Citibank closed all of the accounts that it had for
the Angolan government, including for its state-owned oil
company. It also closed its office in Angola. And if you will
take a look at Exhibit 96,\1\ here is what Citibank did.
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\1\ See Exhibit No. 96 which appears in the Appendix on page 766.
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The memorandum was prepared, it says, in 2003, Exhibit 96.
It is a letter that is addressed to someone named Jean Paul and
it is advising that after deliberations inside Citibank, that
the decision has been to terminate business in Angola. ``In
June of last year,''--and this is a Citibank document of
January 2003--``the Angolan National Bank, BNA, instructed
us''--I am reading about the sixth line--``to pay U.S. fifty-
million dollars in a dubious account with Bank of America in
San Diego.'' Here is that same $50 million they are referring
to. ``This payment was ultimately reversed a few weeks later,''
as we just talked about, ``and we were never provided a
satisfactory explanation of the underlying transaction by the
BNA.''
And then when you jump down to the next paragraph, ``We
were advised in November of last year by the outgoing BNA
Governor that BNA had gone ahead with the USDA 50 million
transaction with another bank using a `fiscal paradise,' ''
presumably an offshore tax haven somewhere in what someone
thinks is paradise.
Then in the next paragraph, it says, ``Unfortunately, the
players in the government of Angola are the same, with a few
key players in positions of power and closely managed under the
leadership of the current President, Jose Eduardo Dos Santos.
At the end of the day, we are uncomfortable with the character
of the senior officials in the Angola government and any amount
of policing may not deter financial impropriety.''
It goes on, ``The above action plan''--this is January
2003--``can be franchise threatening.'' And then jumping a
couple of lines down, it says, ``In all likelihood, the
reaction of the Angolan National Bank to our decision will be
far-reaching and may result in our being asked to leave the
country. We should expect a backlash from all the government-
owned and private sector banks based on the strong control of
the government in the bank and other priority sectors, like oil
and gas. I believe that we must work with this contingency in
mind and plan to exit the country.'' So they have now decided
they don't want any more of these kind of dealings.
Now, that deal looked mighty suspicious to them, and I
guess it also did, finally, to your compliance people at some
point and you reversed it. But here is what I understand has
happened, that the bank, the Angolan National Bank then opened
accounts in the Bahamas, and I want to refer you to Exhibit
112.\1\ This is referring now to a bank called the Equator Bank
in Bahamas, which is owned by HSBC--is that correct, by the
way? Would you agree Equator Bank in the Bahamas is owned by
HSBC?
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\1\ See Exhibit No. 112 which appears in the Appendix on page 795.
---------------------------------------------------------------------------
Mr. Mandemaker. I believe HSBC has a subsidiary Equator
Bank, yes.
Senator Levin. All right.
Mr. Mandemaker. I am not sure if it is domiciled in the
Bahamas.
Senator Levin. And there is also something called HSBC
Bahamas. So would you look at Exhibit 112. This is an exchange
now between Equator Bank, owned by HSBC, and HSBC on this
issue.
Mr. Mandemaker. Senator, just to clarify on the Equator
Bank, if I may----
Senator Levin. Yes.
Mr. Mandemaker [continuing]. That is an entity that is no
longer in operation.
Senator Levin. But it was then?
Mr. Mandemaker. It was at that time, correct.
Senator Levin. So now look at Exhibit 112. Here is what the
Equator Bank representative wrote to your bank, HSBC Bahamas.
``Equator Bank Limited is a 100 percent subsidiary of Equator
Holdings, sister bank of HSBC, Equator Bank London, which is
HEQB.'' That is the name for Equator Bank London, owned by
HSBC. ``It has an excellent relationship with Banco Nacional de
Angola''--that is the Central Bank of Angola--``for the last 20
years. During this time, EBL,'' Equator Bank, ``has earned in
excess of $80 million from short-term trade finance lines which
are serviced by an assignment of oil proceeds.''
Then two lines down, it says that because of a large
deposit of $103 million, that is going to push them above the
limit for any account. And it says, ``Unfortunately, we cannot
accept these funds in Nassau as they would cause us to
contravene our trigger ratios.''
So now here is what they do in Exhibit 112. This is HSBC.
This is what you guys do. ``We are currently holding the funds
at HEQB''--now that is in London--``but we know that BNA,
Angolan National Bank, prefers to keep their deposits in an
offshore account to avoid possible Mareva injunctions. It is
for this reason that we approached HSBC Nassau,'' we being
HSBC, ``with whom EBL shares an office.''
So now a Mareva injunction is a British court order that
freezes a defendant's assets so they cannot be transferred
beyond the court's jurisdiction. So the email exchange
indicates that HSBC helps to open an account for Angola, in an
offshore jurisdiction in some tax haven presumably, even though
one of the stated purposes is to enable the Angolan Central
Bank to avoid compliance with British court orders. Now,
Britain happens to be the home of HSBC. So you have HSBC
saying, we can help the Angolan Central Bank avoid our
country's lawful orders if they move to this offshore bank.
Now, we interviewed an HSBC representative about this. He
replied that it was legitimate for the client to choose to hold
an account in a jurisdiction where its assets won't be subject
to certain attachments. Those are your government's
attachments. That is your government's court orders that you
are helping to evade. Is it really your position--is it HSBC's
position that when a client informs you that it wants to
establish an account where it can lawfully avoid your own
government's court orders, that you view that as a legitimate
request?
Mr. Mandemaker. Senator, I will answer that question. If I
may just briefly clarify on the matter with the signed letter.
It is my understanding that the letter regarding the
safeguarding receipt was signed in advance because the person
signing it went on vacation, and that is why it was ready to be
signed before it was stopped by the compliance process.
With regards to the Mareva injunction, I will be honest
with you: I am not an attorney. I had to look this up in
Wikipedia when I saw the term in the report, and my
understanding is that the definition is very close to as you
describe it. It also indicated that it is considered sometimes
harsh on defendants because it is granted without due process
or a trial, as we would expect in this country.
Senator Levin. In England?
Mr. Mandemaker. In England, correct. It is a Commonwealth
law.
Senator Levin. You are a British company, right?
Mr. Mandemaker. I am representing HSBC Bank USA, which is a
U.S. company. Our parent company is located in England.
Senator Levin. So your parent company located in England,
you have your people saying, we are going to help a client,
which is a national bank putting its money offshore, which is
suspicious enough, I would think--any national bank that is
moving to a tax haven some of its funds ought to trigger all
kinds of alarm bells to begin with. I can't even think of any
other country that does it, but maybe there are some beside
Angola. But that is not my question.
You, HSBC, is facilitating that customer to move its funds
to a place where it will not be reachable by a court order of
your own home country. Is that your policy?
Mr. Mandemaker. Senator, it is my understanding that
certain entities, central banks, companies, even in this
country choose a venue that they believe is appropriate for
them and that there are different business laws, and so we
allow----
Senator Levin. Is it HSBC's policy to facilitate, to help a
client such as that client to move money offshore in order to
avoid your own government's court order?
Mr. Mandemaker. That is not our policy. I don't believe
that is what the letter reflects, and----
Senator Levin. That is exactly what it does reflect. That
is precisely what it says.
Mr. Mandemaker. It states that at the request of the
customer. I think that is indicative that it is not our policy
to promote this.
Senator Levin. Well, you say you represent HSBC USA. Take a
look at Exhibit 113.\1\ ``Dear Fred, I refer to our earlier
discussion with respect to HSBC Bahamas opening a deposit
account at the request of BNA. You asked that I provide you
with some background on the deposit account opening request.''
And then you say--look on page two--``Due to capital weighting
constraints, we are unable to accept any further deposits from
BNA, so BNA indicated to us that they would like to deposit an
additional $200 million. In this regard,'' and listen to these
lines--you say it is not your policy--``we''--we, HSBC--``have
encouraged BNA,'' Bank of Angola, ``to open a deposit account
with HSBC Bahamas for the following reasons.''
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\1\ See Exhibit No. 113 which appears in the Appendix on page 797.
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Look at reason No. 2. ``Deposits with the Bahamas are not
subject to the Mareva injunctions associated with the U.K.''
You folks are encouraging your client to move money offshore to
avoid legal process in your home country. That is what this
says. This is signed by that same guy, John Kearney. Was he
going on vacation? Did he pre-sign this one, too?
Mr. Mandemaker. I am not aware of that, Senator. I
recognize what the letter said. I can't tell you from my
understanding whether that is an active policy of the bank or
whether that is a statement made by that individual, who
certainly at that point was in a position to represent the
bank.
Senator Levin. And take a look at Exhibit 113, that same
exhibit. Where is that cover sheet from?
Mr. Mandemaker. The first cover sheet, Senator?
Senator Levin. Take a look at the third page.
Mr. Mandemaker. The third page?
Senator Levin. Do you see where this was sent from?
Mr. Mandemaker. This appears to be sent from an operations
center in Connecticut for HSBC Equator.
Senator Levin. Yes, 45 Glastonbury Boulevard, Glastonbury,
Connecticut, right?
Mr. Mandemaker. Correct.
Senator Levin. Well, when you testify today about HSBC and
all what you call enhanced due diligence, you use that in your
opening statement, highest level of scrutiny, you claim that
you are a leader in anti-money laundering rules enforcement.
You go beyond the requirements of law, you said. You are one of
the leading institutions when it comes to anti-money
laundering. What these documents show is quite the opposite,
that you facilitate people evading the law of your own
country--back then.
Maybe that is not the policy now. You don't know what the
policy is now. But these documents are pretty damning documents
and I would think that it is in your interest that you, if you
don't know what the policy is now, that you file with this
Subcommittee after this hearing is over, that you go back and
file with this Subcommittee what your policy is relative to
this. Will you do that?
Mr. Mandemaker. Relative to this issue----
Senator Levin. Whether or not it was appropriate at the
time and whether or not it is still your policy.
Mr. Mandemaker. We will be able to get back to you on that,
Senator.
Senator Levin. Do you know whether or not HSBC has offshore
accounts today for the Angolan Central Bank?
Mr. Mandemaker. I am not aware of HSBC Bank USA having
offshore accounts for the Angolan Central Bank.
Senator Levin. Does that refer to HSBC's main office or
HSBC USA?
Mr. Mandemaker. I am a representative of HSBC Bank USA. I
don't know if there are group institutions that have accounts
in the jurisdiction that you are referring to. If there are, it
is my understanding that the laws in that jurisdiction would
prevent us from disclosing that to you, Senator.
Senator Levin. Well, wait a minute. You represent HSBC USA,
so you are within our jurisdiction. We are not going to let the
laws of the Bahamas or anywhere else deny us information which
we legitimately seek. Have you been advised that you cannot
disclose to this Subcommittee, information of this nature
because of Bahamas law when you are HSBC USA and when you
clearly were involved in this transaction through these faxes
and emails which emanated from Connecticut? Is that what you
are saying?
Mr. Mandemaker. Senator, if I can be clear on this, HSBC
Bank USA was never a party to these faxes. This was a
subsidiary of HSBC London. I am here today to represent HSBC
Bank USA.
Senator Levin. But it was involved because you acknowledged
that the fax came from HSBC in Connecticut.
Mr. Mandemaker. Which is not the same entity as HSBC Bank
USA. That was a subsidiary of HSBC in London, Senator.
Senator Levin. Do you know Carolyn Wind?
Mr. Mandemaker. Senator, just to confirm with you, the HSBC
U.S. entity does not have any accounts for the Angolan Central
Bank in the Bahamas.
Senator Levin. Do you know Carolyn Wind?
Mr. Mandemaker. Yes.
Senator Levin. And who does she work for?
Mr. Mandemaker. She used to work for HSBC. I don't know who
she works for currently, Senator.
Senator Levin. Did she used to work for HSBC USA?
Mr. Mandemaker. I believe she was an employee of HSBC Bank
USA.
Senator Levin. And she received a copy of the email which
we discussed.
Mr. Mandemaker. OK.
Senator Levin. Is that right?
Mr. Mandemaker. I don't know.
Senator Levin. Well, take a look at it. Take a look at
Exhibit 112.\1\ Do you see at the top, Carolyn Wind, CC?
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\1\ See Exhibit No. 112 which appears in the Appendix on page 795.
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Mr. Mandemaker. Yes.
Senator Levin. She is, or was--does she still work for
HSBC, do you know?
Mr. Mandemaker. She does not work for HSBC today, Senator.
Senator Levin. At the time, she was, as I understand it, a
Senior Compliance Officer located in New York, is that correct?
Mr. Mandemaker. That is correct.
Senator Levin. Now, the discussions that led to this email
took place, as I understand it according to this fax, in
Connecticut, is that correct?
Mr. Mandemaker. It appears to be the case, Senator.
Senator Levin. All right.
Mr. Mandemaker. Yes. Senator, if I can just again confirm,
HSBC Bank USA does not have any accounts in the Bahamas----
Senator Levin. No, I understand----
Mr. Mandemaker [continuing]. For this entity, and if there
are other records that you would like us to provide to the
Subcommittee, we can certainly get back to you on that.
Senator Levin. OK. Well, we are asking for those records.
We want to know whether or not HSBC Equator, whether HSBC, the
main branch, has opened up any offshore tax haven accounts for
PEPs or for other national banks. Will you provide that for us?
Mr. Mandemaker. I will convey your request.
Senator Levin. OK. And then if you are not going to supply
that, you will have to let us know why, because that, then, is
going to become an issue between the Subcommittee and our
authority. Since part of these transactions occurred in the
United States, we will then have to take that issue up with you
and your lawyers at that time. But you will get back to us on
that?
Mr. Mandemaker. Yes, Senator.
Senator Levin. All right. Are you saying that you don't
know whether or not there is an Angolan Central Bank account in
an HSBC Bank in the Bahamas at this time? Not USA, but any HSBC
account? Do you know the answer to that question?
Mr. Mandemaker. I don't know the answer to that question,
Senator.
Senator Levin. OK. Mr. Fox, let me ask you just a few more
questions about Teodoro Obiang. From 2004 to 2007, Mr. Obiang
used your bank not by opening an account in his own name, but
he had an attorney, Mr. Berger, form a U.S. shell corporation
called Beautiful Vision. He opened three accounts at your bank
in the name of that shell corporation and Mr. Berger was the
signatory on two of them and Mr. Obiang was the sole signatory
on one of those Beautiful Vision accounts.
In addition, a year later, Mr. Berger opened an attorney-
client account at your bank, and over a 4-year period, Mr.
Obiang deposited over $9 million into those accounts, about
$1.6 million in wire transfers from Equatorial Guinea and over
$4 million from the sale of a property in California. Mr.
Obiang wrote checks in excess of $7 million, including a $3.3
million cashier's check that was cashed in Equatorial Guinea.
In 2005, Bank of America discovered that Mr. Obiang was
making use of Beautiful Vision accounts and I understand that
when you discovered that, that you then closed the accounts, is
that correct?
Mr. Fox. Yes.
Senator Levin. OK. Now, why did you close those accounts?
Mr. Fox. Well, because we had closed the relationship with
Mr. Obiang, our review of the matter at the time indicated his
involvement in the Beautiful Vision accounts and we proceeded
to close the accounts.
Senator Levin. And it was suspicious or suspect funds, was
that true?
Mr. Fox. Yes.
Senator Levin. OK. Now, after you closed those accounts,
for the next 2 years, from 2005 to 2007, Mr. Obiang then sent
multiple wires from Equatorial Guinea to the Berger attorney-
client account, and then Mr. Berger used the funds to pay
Obiang bills or transferred money to other shell company
accounts that he controlled, such as an Unlimited Horizon
account at Citibank.
Now, Mr. Fox, when the Bank of America knew that Mr. Berger
had opened the Beautiful Vision shell company accounts for Mr.
Obiang in 2004, why didn't the bank at least monitor it more
closely to see that millions of dollars in Equatorial Guinea
wire transfers were going into that account?
Mr. Fox. It is a very good question and a fair question,
Mr. Chairman. I think when we look back on facts of that
matter, we agree that judgment calls were made that probably
were not the correct judgment calls, and I think that our
systems at that time were not as robust as they are today. I
think had we made those decisions today or with the same rigor
and standards that we have today, we would have reached a very
different conclusion.
Senator Levin. Is there some sense of reluctance to really
take a close look at and monitor an attorney-client or a law
firm account?
Mr. Fox. Not on our part, sir. We are very aware of the
attorney-client relationship in the United States. It is an
important aspect to our judicial system. But, candidly, we are
looking for the movement of suspect funds. When we see that
even if it involves an attorney, we fulfill our regulatory
obligations.
Senator Levin. Mr. Fox, you have indicated today that you
are adopting a rule about beneficial ownership disclosure, and
we applaud you for that. Some of us have been working to try to
obtain beneficial ownership information for U.S. corporations
with the States obtaining that information when there is
incorporation in States of the United States. Would that make
your life easier, if beneficial ownership information was part
of the States' incorporation process?
Mr. Fox. Mr. Chairman, anything that we could collectively
do that would make it easier to obtain or utilize information
to verify the information that we obtain on beneficial
ownership would make our lives a lot easier.
Senator Levin. Including that?
Mr. Fox. Yes, sir.
Senator Levin. We thank you all. You have been a very
informative panel. We appreciate your being here and you are
excused.
Well, we thank our third panel for their work, the
responsibilities that you all have undertaken. It is important
work for our security, economic, and physical security, as a
matter of fact. We have taken a little longer to get to you
probably than you expected, so we appreciate your patience, as
well.
Do you have any opening statements that you would like to
give? Mr. Johnson, you raised your hand first, so we will call
on you first.
I have to swear you in. I am reminded all of our witnesses
have to be sworn in by this Subcommittee. Would you raise your
right hands, please.
Do you swear that the testimony that you are about to give
to this Subcommittee will be the truth, the whole truth, and
nothing but the truth, so help you, God?
Mr. Johnson. I do.
Ms. Ayala. I do.
Mr. Freis. I do.
Senator Levin. Thank you. Mr. Johnson, do you want to start
off?
TESTIMONY OF DAVID T. JOHNSON,\1\ ASSISTANT SECRETARY, BUREAU
OF INTERNATIONAL NARCOTICS AND LAW ENFORCEMENT AFFAIRS, U.S.
DEPARTMENT OF STATE
Mr. Johnson. Thank you, Mr. Chairman. I am grateful for the
opportunity to discuss the impact of foreign corruption on the
United States and why combating it is a key U.S. foreign policy
objective. My colleagues and I, at the Department of State, are
grateful for your leadership and that of your staff and the
focus that today's hearing brings to this important national
security issue.
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\1\ The prepared statement of Mr. Johnson appears in the Appendix
on page 80.
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The United States has long been a leader in the fight
against corruption, since it harms U.S. business, undermines
democracy and stability, and can allow criminals and terrorists
to operate with impunity. Building on the 1977 Foreign Corrupt
Practices Act, in the 1990s, the United States pressed the
anti-bribery agenda forward internationally and in 1997 secured
the agreement of the Organization for Economic Cooperation and
Development to criminalize bribery of foreign public officials
for business purposes and to enforce those laws, creating a
more level playing field for American business.
U.S. leadership in the fight against corruption has
continued over the last decade. Under my own Bureau's
leadership, in partnership with the Department of Justice and
with the assistance of other U.S. Government agencies, the
United States successfully secured a comprehensive treaty
against corruption, the United Nations Convention Against
Corruption (UNCAC). This convention not only brings its 143
parties into line with the OECD anti-bribery standards, it goes
beyond it to require criminalization of other corrupt conduct,
including money laundering. The treaty also contains
groundbreaking road maps on prevention and on recovery of
illicit proceeds. The UNCAC establishes important new
frameworks for cooperation in mutual legal assistance and
extradition, as well.
The goal of these treaties is to change the environment in
which Politically Exposed Persons and other officials operate.
In many cases, however, countries lack institutional or legal
capacity and political will successfully to undertake reform.
To address this, the United States seeks to build political
will and pressure for political will through the actions and
resolutions of forums such as the G-8 and G-20. We support the
Extractive Industries Transparency Initiative, and we support a
wide range of technical assistance programs on anti-corruption
and related criminal law.
The United States is also committed to denying safe haven
to corrupt officials and to those who corrupt them. To
accomplish this, the Department of State draws in part upon
Presidential Proclamation 7750, which provides authority to
deny entry to the United States to corrupt officials and to
those who bribe them, even in the absence of a conviction. In
doing so, we benefit from our good cooperation with the
Department of Homeland Security (DHS), with FinCEN, the
Department of Justice, and other U.S. Government agencies, and
we have jointly taken steps to enhance that cooperation.
Presidential Proclamation 7750 is an extremely useful
policy tool. When no other provision of our visa law is
available, it lets us reach the most culpable without
disadvantaging the citizens they have already victimized.
Apart from Presidential Proclamation 7750, many thousands
of corrupt officials have been the subject of visa actions
under a wide variety of other provisions of the Immigration and
Nationality Act. The Department also works tirelessly to keep
these corrupt individuals from benefiting from the fruits of
their corruption by supporting international efforts to prevent
the financial system from sheltering proceeds of corruption and
advancing efforts to recover those proceeds.
This Administration is committed to combating corruption,
including international business bribery, kleptocracy, and
abuse of the financial system. In that regard, I am pleased to
tell you that I am again increasing staff resources within my
Bureau that are devoted to address these important issues,
including Presidential Proclamation 7750, for the second time
in the last year.
Thank you for your time, Mr. Chairman, and I would be happy
to address any questions at the appropriate time.
Senator Levin. Thank you so much, Mr. Johnson.
I should have introduced you and the other panelists and I
failed to do that, so let me now, thank you. You are the
Assistant Secretary for International Narcotics and Law
Enforcement Affairs at the U.S. Department of State.
Our next witness will be Janice Ayala, who is the Assistant
Director for the Office of Investigations at the Immigration
and Customs Enforcement, and then James Freis, Jr., the
Director of the Financial Crimes Enforcement Network, also
known as FinCEN. So now that I have given you all a proper
introduction, Ms. Ayala.
TESTIMONY OF JANICE AYALA,\1\ ASSISTANT DIRECTOR, OFFICE OF
INVESTIGATIONS, U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT,
DEPARTMENT OF HOMELAND SECURITY
Ms. Ayala. Chairman Levin, Ranking Member Coburn, and
distinguished Members of the Subcommittee, on behalf of
Secretary Napolitano and Assistant Secretary Morton, thank you
for the opportunity to testify today on Immigration and Customs
Enforcement (ICE) efforts to pursue corrupt foreign officials
who plunder State coffers and attempt to place those illicit
funds in the U.S. financial system.
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\1\ The prepared statement of Ms. Ayala appears in the Appendix on
page 87.
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Corruption erodes public trust and creates an unstable
environment where criminal and terrorist organizations
flourish. It further perpetuates a cycle of poverty,
instability, and crime that denies the most vulnerable nations
and people prosperity.
I commend the Subcommittee for its recently released staff
report detailing many years of hard work in this area and
assure you that ICE will continue to pursue those who exploit
their positions of power for personal gain.
ICE has the most expansive investigative authority and
largest investigators group in the Department of Homeland
Security. We protect national security and uphold public safety
by disrupting and dismantling trends, national criminal
networks, and terrorist organizations that seek to exploit our
Nation's immigration and customs laws. We utilize our financial
expertise to target criminal enterprises that threaten our
Nation's economy and security. ICE works domestically and in
the foreign arena with our more than 60 offices in 44 countries
to provide investigative support to our foreign law enforcement
counterparts in cases involving Politically Exposed Persons
(PEPs).
In 2003, ICE established a Foreign Corruption
Investigations Group in Miami, Florida, to target foreign
public officials engaged in criminal acts involving the
laundering of proceeds emanating from foreign public
corruption, bribery, or embezzlement, to prevent their ill-
gotten gains from entering the U.S. financial system, seize
identified assets, and repatriate those funds to victimized
governments. ICE is the only U.S. law enforcement agency with
an investigative group dedicated to combating kleptocracy.
Since its inception, ICE has initiated 182 investigations
and made 80 criminal arrests, secured 148 indictments, and
seized over $131 million. So ICE's anti-kleptocracy
investigations, I would just like to highlight significant
recent successes.
Pursuant to mutual legal assistance requests from Romania,
ICE, in coordination with Romanian authorities, arrested the
former director of Romania's national railroad, Romania's No. 1
fugitive, who was accused of stealing $110 million in
government funds while in office. Throughout the course of the
investigation, we were able to locate numerous properties, bank
accounts, and corporations associated with the former director
who is currently pending extradition to Romania on charges of
theft and misappropriation of government funds.
Operation Persistence exemplifies the versatility of ICE
expertise that is brought to bear at foreign corruption
investigations. Operation Persistence began as a narcotics
investigation that utilized an undercover vessel to transport
300 kilograms of cocaine from Colombia to Miami. As a result,
over 20 Colombian nationals were indicted, extradited from
Colombia, and convicted. The subsequent investigation uncovered
corruption by a Colombian navy captain who provided security
and intelligence to the drug smuggling organization. Currently,
he is incarcerated in Colombia and also pending extradition.
As we examine solutions to combat kleptocracy, ICE
recognizes the significance and integral role that the industry
groups play in establishing and bolstering anti-money
laundering guidance and oversight. Throughout our Operation
Cornerstone Initiative, ICE partners with the private sector to
combat financial and trade crimes by establishing,
implementing, and promoting best practices to deny entry of
illegal proceeds and facilitating sharing of suspicious
financial information.
In conjunction with the Department of State, ICE provides
financial investigations training to foreign governments, which
has proven to be a conduit for foreign governments to
communicate corruption allegations and a platform for
international dialogue in facilitating asset recovery and
strengthening international financial system integrity.
ICE acknowledges the Subcommittee's concern about the use
of U.S. shell corporations by PEPs and the related
complications in money laundering and kleptocracy
investigations. The lack of corporate transparency has allowed
unlawful elements gateway into the U.S. financial system. The
same vulnerability exists when attorney-client, law office, or
shell company accounts are used to hold funds of corrupt public
officials and facilitate transactions for them. The difficulty
of law enforcement in obtaining true beneficial ownership
information impedes investigators' ability to follow the
criminal proceeds. Obtaining information on true beneficial
owners and providing the information to law enforcement upon a
receipt of a summons or subpoena would assist DHS in its
endeavor to protect the homeland. We anticipate that developing
nations, often the most susceptible to the threat of corrupt
officials, will continue to seek the expertise of ICE in the
fight against corruption, and we stand willing to assist in
this worthy endeavor.
We appreciate the interest of the Subcommittee Members and
the awareness you bring to this issue and would like to thank
you for your continued support of ICE and our law enforcement
mission.
I would be pleased to answer any questions that you may
have at this time.
Senator Levin. Thank you, Ms. Ayala. Mr. Freis.
TESTIMONY OF JAMES H. FREIS, JR.,\1\ DIRECTOR, FINANCIAL CRIMES
ENFORCEMENT NETWORK, U.S. DEPARTMENT OF THE TREASURY
Mr. Freis. Thank you. Chairman Levin, Senator Coburn, and
Members of the Subcommittee, I am Jim Freis, the Director of
Financial Crimes Enforcement Network (FinCEN), and I am pleased
to be here today to discuss the Treasury Department's work in
combating the flow of proceeds of foreign corruption into the
United States.
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\1\ The prepared statement of Mr. Freis appears in the Appendix on
page 98.
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It is more important than ever for our government to be
particularly vigilant in this area, and FinCEN continues to
exercise its authorities provided by Congress to operate at the
intersection of the law enforcement, regulatory, and
international communities.
My testimony today will focus on some of the strategic
initiatives under which our authorities assist in the detection
and prosecution of fraudulent actors and to prevent the
laundering of proceeds of foreign corruption through our
financial system.
The Treasury's approach includes working with our
government partners to better understand the flow of foreign
corrupt assets, which in turn informs the targeted elements of
our strategy to combat foreign corruption. This includes
requiring financial institutions to apply enhanced due
diligence to banking accounts held by senior foreign political
figures, attuning U.S. financial institutions to risks, and
providing guidance with respect to suspicious activity
reporting requirements, and exercising our authorities under
the Bank Secrecy Act to promote the transparency of
transactions in U.S. legal entities that may otherwise mask
foreign corrupt activities of senior foreign political figures.
There is still much more to be done, and we must also
continue to increase global public awareness of the threat
posed by foreign corruption so that our efforts to combat this
threat become a priority for all nations.
I am pleased to say that following the recent meeting of
the G-20 leaders in September of last year, a public statement
was released asking the Financial Action Task Force (FATF) to
help detect and deter the proceeds of corruption by
prioritizing work to strengthen standards on customer due
diligence, beneficial ownership, and transparency, and the
United States is working with other FATF member jurisdictions
and organizations to outline what further steps the FATF could
consider.
The Treasury also appreciates the work that the World Bank
put into its policy paper on strengthening preventative
measures for PEPs and we are reviewing this paper, along with
other colleagues within the U.S. Government. We do note,
however, that some of their findings and recommendations with
respect to current PEP control measures are based on principles
that exceed current requirements of U.S. law.
The Treasury agrees with the Subcommittee that enhancing
access to the beneficial ownership information of shell
corporations in order to combat the abusive legal entities is
an important part of fighting corruption, as well as other
illicit activity.
Our current strategy involves a three-pronged approach,
which includes enhancing the availability of beneficial
ownership information of U.S. legal entities, clarifying and
strengthening customer due diligence requirements for U.S.
financial institutions with respect to the beneficial ownership
of legal entity account holders and clarifying and facilitating
global implementation of international standards regarding
beneficial ownership. We look forward to continuing our work
with the Subcommittee to accomplish these objectives.
The Treasury also recognizes the risks of money laundering
in the real estate industry, and our approach to addressing the
vulnerabilities continues to evolve and be guided by the
insights from our law enforcement partners and from our
analysis of the risks involved.
FinCEN's largest focus of law enforcement support continues
to be fighting fraud in residential mortgages. In July 2009,
the Treasury, through FinCEN, announced that it is considering
applying anti-money laundering programs and SAR regulations to
non-bank residential mortgage lenders and originators. This
action marks the next step in an incremental approach to
implementation of anti-money laundering regulations for the
real estate industry.
We will consider further steps in applying BSA requirements
to additional participants in the real estate and finance
sectors, including settlement attorneys, as information about
vulnerabilities and our ability to mitigate them develops. In
the interim, we continue to work collaboratively with the FATF
and the American Bar Association (ABA) to develop guidance on
the risk-based approach to combating money laundering and
terrorist financing for legal professionals.
FinCEN will also continue its priority efforts with our law
enforcement and financial intelligence unit partners around the
globe to follow the money across borders, to detect, deter,
prosecute, and recover proceeds of corruption.
Thank you for the opportunity to testify before you today.
I would be happy to answer any questions that you have.
Senator Levin. Thank you all.
First, Mr. Freis, let me ask you the first question. The
September 11, 2001, attack was not the first time, but
dramatically showed how terrorists were using our financial
system against us. We enacted the PATRIOT Act in 2001, which
beefed up our laws to combat money laundering, among other
provisions. And one of the big steps that was taken by the
PATRIOT Act was to require a number of entities that handle
large sums of money and which were already listed in the U.S.
anti-money laundering (AML) laws, to establish programs unless
the Department of Treasury exempted certain areas of certain
industries.
Now, the Treasury issued regulations requiring a number of
businesses to set up AML programs, including banks, security
firms, insurance companies, casinos, jewelry businesses, and
money service businesses. They are now up and running. They
have made a real difference. But the Treasury issued rules in
2002 what were designated as temporary exemptions for a few
groups, primarily real estate agents and escrow agents handling
real estate closings, sellers of vehicles like luxury cars,
yachts, and aircraft, and also hedge funds.
So the temporary exemptions are now 8 years old and we
think it is time to end them and require real estate escrow
agents to know their clients, to evaluate the source of their
funds, and report suspicious transactions to law enforcement.
You have made reference to that in your testimony and I am just
wondering whether you agree with us that it is time to end
these exemptions.
Mr. Freis. Senator Levin, as you correctly stated, the
Treasury Department did issue temporary deferrals going forward
with an expansion of its anti-money laundering rules on a
variety of sectors, and over the interim time period, we have
been gradually moving forward, resources permitting, with
respect to expansion covering additional areas.
I agree with you completely that I would love to see
broader application of these protections, and the fundamental
premise that the Congress saw in extending it to the PATRIOT
Act is that any way that money can be moved, any way that funds
can be intermediated can, indeed, be abused by criminal actors.
What we have seen, however, is that the practical aspect of
moving to an effective implementation in certain sectors is
much more complicated than in others. We have also seen that
the risks of abuse by criminal actors is potentially greater in
some sectors rather than others. So our approach to a gradual
expansion to various sectors has attempted to be based both on
that combination of what the relative risks are in certain
sectors, in particular as compared to the legitimate activity
that would be affected by the regulatory framework, as well as
our ability to practically go out to mitigate them.
If I may elaborate upon that, one of the issues that is
very significant for us to try and overcome as we move away
from the traditional notion of the financial sector, in
particular the banks, regardless of charter type, where they
have a very strong supervisory framework. FinCEN, as you well
know, does not have any persons dedicated to directly going
into regulated entities and undertaking compliance
examinations. So we delegate that authority to the Federal
financial regulators, the five banking agencies, the SEC, and
the CFTC.
With respect to all other sectors for which we have issued
anti-money laundering regulations, we within the Treasury
Department have worked out an arrangement for the Internal
Revenue Service (IRS) to dedicate some staff to go in and
examine for compliance over industry sectors over which they
otherwise have no regulatory framework.
As we look to some of these additional sectors that have
been identified by the Congress in the PATRIOT Act where there
is certainly no Federal regulator, in many cases no State
regulator, we would love to work with the Congress and this
Subcommittee in defining appropriate definitions of the
regulated industry. But I hesitate to go out with rules without
an ability to ensure some type of compliance with that
framework.
Senator Levin. Has there been formal consideration by the
Treasury to end these exemptions?
Mr. Freis. We regularly review the various sectors, so as I
just mentioned in my testimony, there are two areas in which we
are actively involved in expanding the anti-money laundering
regulations. First, with respect to stored value products, as
you are aware, FinCEN has regulated stored value as a component
of money services businesses since 1999. That regulatory
framework is a little lighter. Some of the materials, or some
of the requirements do not apply to that, and now we are
expanding the scope of application of those as required by the
CARD Act passed last year.
The other area that we started working on publicly is the
area of mortgage brokers. Prior to the financial crisis, about
half of all residential real estate mortgages were initiated
from banking institutions and the other half by non-bank
institution mortgage brokers, and we found through our law
enforcement case work that has been a real regulatory loophole
that allowed perhaps fraudulent actors to exploit. So that is
another area, a subcomponent of loan and finance companies, one
of the areas of deferred sectors where we are going to look
forward to continuing our work.
But as I said, in each of these sectors, there are areas
for which there is no Federal regulator. We are looking at ways
how we might be able to work with States and other entities,
but there are very serious practical aspects to going out and
establishing a program that we really think has the intended
effect, because in all cases and certainly the many pertinent
examples that the Subcommittee has found in its report, there
will always be a few bad apples in any industry sector that
will look to get around the rules, that will certainly abuse
and maybe even directly commit criminal activity.
If I put out rules, I certainly know that will have impact
on the overall industry as people in good faith strive to
apply. But if it is apparent that those rules are toothless and
I don't have an implementation framework, I am not sure that I
would be able to have any method of confidence that would
actually get at the few bad actors who already are abusing the
system.
Senator Levin. The law covers jewelry stores.
Mr. Freis. Correct.
Senator Levin. You have not exempted jewelry stores. I
don't know how that one is enforced. How do you enforce it
against jewelry stores?
Mr. Freis. We do have an arrangement, once again, with the
IRS, a component of the IRS that sends examiners into some
members of the Precious Metals and Jewelry Institute to try to
determine whether there is compliance, but----
Senator Levin. But you can't do that with real estate
brokers or escrow agents?
Mr. Freis. We certainly----
Senator Levin. The IRS could go there just as easily as a
jewelry store.
Mr. Freis. Absolutely, Senator, and that is why I very much
appreciate any guidance the Subcommittee has in terms of what
sectors for us to prioritize with our limited resources.
Senator Levin. Well, our report looks at two pretty big
loopholes--or three of them, actually, because lawyers ought to
be included in this. This is not just a rare case. Obviously,
most lawyers, like other professions, are honest and care and
aren't going to take dirty money. But there is some evidence
that there are some escrow agents that don't care, who will
look the other way, and if there is no law that prohibits them
taking money which banks could not take, then many of them will
take it, won't make any effort to know their customer, for
instance.
We also had some testimony, not just today but in our
investigation, that escrow agents, real estate agents, they
will abide by a ``know your customer'' requirement if that is
the requirement. We asked directly that question today. I don't
know if you were all here or not when I asked that question. So
you may not be able to have the same kind of enforcement with
an escrow agent as you do with a bank, but it is a lot better
than a jewelry store, it would seem to me, and I would hope
that you would look into some of these loopholes.
The ABA has promised for a long time that they are going to
have a code of conduct. I think you ought to ask them, where is
that code of conduct in terms of the misuse of their accounts.
Did you ever talk to the ABA about that?
Mr. Freis. Yes, indeed, Senator. As I mentioned in my
affirmative testimony, we have had some very active discussions
with them and I certainly wish to continue that.
Senator Levin. Will you let the Subcommittee know the next
time that FinCEN or the Treasury looks at the three areas that
we talked about today? The next time you analyze whether or not
you are going to try to end their exemption, will you let us
know what the outcome of that is?
Mr. Freis. I certainly will, Senator. As I mentioned, we
are actively looking at a component of that. We started that
last August with our Advanced Notice of Proposed Rulemaking
seeking public comment on an incremental approach to the two
categories that somewhat overlap, loan and finance companies
and entities involved in real estate closings and settlements.
On the basis of that public comment, that is helping us define
our approach to this component with respect to mortgage
brokers.
Senator Levin. Now, were escrow agents included in that
notice?
Mr. Freis. We asked about broad categories of entities that
would be covered. My recollection is we referred to in excess
of about 60 different classes of corporate entities based on
commercial classification and put forward our preference that
based on the financial crisis and the impact, obviously, that
has had to Americans all over the country as well as the global
financial system, that mortgage brokerage would be the area
that we would put first in line as we move forward.
Senator Levin. Well, does that mean escrow agents are not
included or they are?
Mr. Freis. That means it is part of the class of
activities, but we probably would be looking at a subset first
that would not be the escrow agents.
Senator Levin. All right. Well, let us know the next time
you look at the three categories that we focused on today,
would you? So if we don't hear from you in 6 months or a year,
we will assume you have not looked at it.
Mr. Freis. Yes, indeed, Senator.
Senator Levin. Just back to the lawyers for a moment. FATF,
the international anti-money laundering body, has identified
attorneys as one of the key gatekeepers for illegal funds
getting into the financial system and they issued anti-money
laundering guidance for attorneys. Is that the guidance you are
talking about with the ABA, that FATF guidance?
Mr. Freis. Yes, indeed. We worked as part of the U.S.
delegation with respect to the FATF guidance and we have been
talking with U.S. components, the ABA, about the relevance and
possible ways to implement that----
Senator Levin. All right, and the other Bar associations,
too.
Mr. Freis. Yes.
Senator Levin. Relative to the question of beneficial
ownership, we saw some pretty good examples again today about
how the real owners can be hidden and how shell corporations
can be involved in that process. We have had previous hearings
on the outcome of what the result is of that kind of opaqueness
in terms of collecting tax revenues that are owed and so forth.
We have a bill which I have introduced with Senators
Grassley and McCaskill, S. 569. Actually, when President Obama
was a Senator, he cosponsored our bill. Treasury Secretary
Geithner has endorsed at least the principle of our bill. The
approach which was endorsed is to require States to obtain
beneficial ownership information for the companies that are
formed within their borders at the time of formation and then
they keep that information at the State level and provide it to
law enforcement upon receiving a summons or a subpoena.
Is there a formal position of the Treasury Department on
our bill, do you know? I know Secretary Geithner has spoken on
it, but is there a formal position?
Mr. Freis. Yes, Senator. I believe that was stated by
Assistant Secretary David Cohen in his testimony before the
full Committee back in November of last year.
Senator Levin. OK. Now, does DHS have a position on it?
Ms. Ayala. I don't think there is a formal position, but
from a law enforcement perspective, certainly it would make our
lives easier as far as following up on criminal proceeds that
are introduced into the U.S. financial infrastructure through
corporations or limited liability companies, would be to have
access to true beneficial ownership on a timely basis so that
we have access to information that is updated and that we are
able to access that immediately through summons or subpoena. I
think that would really help us in our ability to defend the
Nation.
Senator Levin. That is very helpful. If you would, could
you check back and see if we could get a formal position, as
well, from DHS?
Ms. Ayala. Yes, Chairman.
Senator Levin. Thank you.
Then, Mr. Johnson, for you, the Bush Administration issued
a proclamation in 2004 called Proclamation No. 7750, and this
provided a legal basis for denying visas to foreign officials
that are involved in corruption. In 2009, Congress enacted
legislation requiring the State Department to maintain ``a list
of officials of foreign governments and their immediate family
members who the Secretary has credible evidence have been
involved in corruption relating to the extraction of natural
resources,'' and making such persons ineligible for admission
to the United States.
And one of our recommendations in our report, today's
report, is that the State Department should strengthen its
enforcement of the law and Presidential Proclamation 7750. I
believe you indicated there was an increase in staffing, and I
wasn't sure exactly where that increase was.
Mr. Johnson. That is within the office that I am
responsible for, the INL's office devoted to crime issues. And
I think the real challenge in administering this Presidential
Proclamation is resources, but not just human resources, it is
information, because we have to gather sufficient information
to meet an appropriate standard so that we can recommend to the
Under Secretary that a visa be denied or a visa be revoked.
Senator Levin. All right. Now, are some of the people, the
additional people that you talked about, going to be involved
in the implementation of that Presidential Proclamation 7750
program?
Mr. Johnson. That is exactly what I am referring to,
Senator.
Senator Levin. OK. So that additional help will be
addressing that issue of enforcement of that Presidential
Proclamation.
Mr. Johnson. They will be devoted to preparing cases for
recommendation so that visas can be canceled, revoked, or
denied in appropriate circumstances.
Senator Levin. And that would include corruption?
Mr. Johnson. Absolutely.
Senator Levin. We know terrorism will obviously be involved
on that, but corruption----
Mr. Johnson. No, sir. That is what these individuals work
on, that and the extractive industries issue that you referred
to earlier.
Senator Levin. Great. That is good news. Now, this is a
confidential list, I gather, is that correct?
Mr. Johnson. The visa law requires that visa records be
confidential, and so, yes, this would be a confidential----
Senator Levin. That is by law.
Mr. Johnson. Yes, sir.
Senator Levin. So to make a change in that, Congress would
have to make a change. Do you recommend any change in that law
so we would not keep confidential names of people who are
ineligible to get visas or to keep visas?
Mr. Johnson. Mr. Chairman, I think that any change of that
magnitude which would potentially encompass the administration
of the entire visa statute would have to be considered
extremely carefully. I think that the confidentiality of the
records has served us well. We are able in a closed setting to
engage with your colleagues, with you on these individual cases
and explain our reasoning about how we are going about doing
our business and we would be glad to engage in that further
with you if you would find that useful.
Senator Levin. All right. Now, is the Presidential
Proclamation list, is that something that might be considered
separately from the overall philosophical approach of who gets
visas, granting visas, denying visas? Is that something which
is--and I would add to this, I think, a possibility of a list
broader than just corruption, but a terrorist list--is there
not an advantage in having that list be public?
Mr. Johnson. Not necessarily. Many of these individuals--I
mean, granting or withholding travel status to the United
States is one of the options in dealing with a corrupt
situation. I would say that in the case where those individuals
have engaged in conduct which falls within the criminal
jurisdiction of the United States, the last thing you would
want to do is hold up a sign saying, don't come here, when
likely the individual would be outside the jurisdiction of the
court if they did not enter the United States voluntarily. So
it would be, at best, a double-edged sword and would have some
potentially unintended consequences with respect to the
potential administration of our criminal laws.
Senator Levin. So, in effect, you would have to have two
lists, one that would be made public and one where you don't
want to make it public because it would have a negative
consequence.
Mr. Johnson. Well, I think that if you were to make a list
of any kind public, you would foreclose the possibility of
discovery at some future point of criminal conduct you might
want to pursue.
Senator Levin. Do you know whether or not Mr. Obiang is
being considered for placement on this list? He has come in and
out of the United States 35 times in the last 2 years. Do you
know the status of that review?
Mr. Johnson. Mr. Chairman, I am well aware of it, and in a
closed setting, I would be pleased to go over it with you in
detail.
Senator Levin. All right. One of the recommendations that
we are making in our report is that Congress and the
Administration consider making significant acts of foreign
corruption a legal basis for designating a PEP and any family
member inadmissible to enter and removable from the United
States. Is that needed, and if so, what is your reaction?
Mr. Johnson. The Department hasn't developed a firm
position on that question. I would like an opportunity to
consult with my colleagues and come back to you with a
considered response. I think, in general, we think that the
opportunities we have under Presidential Proclamation 7750 are
serving us well, but I would want to consult with my
colleagues, particularly in the Consular Affairs Bureau that
administer the visa law as a whole and come back to you with a
considered response.
Senator Levin. Will you come back, then, to us with that?
Mr. Johnson. Yes, sir.
Senator Levin. And what about you, Ms. Ayala?
Ms. Ayala. Well, we would certainly appreciate the ability
to have additional enforcement tools to further our
investigations, especially in this area. Not knowing all the
details, I wouldn't be able to comment on that right now.
Senator Levin. Could you get back to us on your agency's
position on this recommendation?
Ms. Ayala. Yes, sir.
Senator Levin. OK. Thank you all. Again, we want to
apologize for the long wait that you experienced here because I
think it was very important for the Subcommittee to get the
information that we got. But we want to compliment you and your
agencies for your work, for your cooperation, obviously, with
Congress, also for the vital work that you do. I don't think we
need too many more reminders of what is at stake here. We have
them almost every week. You are right on the firing line in
terms of implementing important policies for our security, both
physical and financial security. We are grateful for that.
The hearing will stand adjourned. Thank you.
[Whereupon, at 12:17 p.m., the Subcommittee was adjourned.]
A P P E N D I X
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