Khalid bin Mahfouz

To Whom It May Concern:

This is a request under the Freedom of Information Act. I hereby request the following records:

Records pertaining to Khalid bin Mahfouz (December 26, 1949 - August 16, 2009) who was a Saudi Arabian billionaire, banker, investor and former chairman of the National Commercial Bank (NCB). Khalid is the son of Salem Bin Mahfouz, a Saudi entrepreneur who rose from being a smalltime moneychanger to becoming the founder of the NBC, the first private Saudi bank. He was a non-executive director of Bank of Credit and Commerce International, a financial conglomerate later convicted of money laundering, bribery, support of terrorism, arms trafficking, and many other crimes. He was also a donor to Usama (Osama) bin Laden's organization and a friend of Salem bin Laden. Please include records on his charity Muwafaq Foundation, designated a front organization by the State Department, and his bank National Commercial Bank (NCB) which was accused of funding al-Qaida (Qaeda). Proof of death his not required, as his death has been widely reported. http://www.nytimes.com/2009/08/28/world/middleeast/28mahfouz.html

FOIA case law establishes the extent to which agencies MUST search all records system reasonably believed to contain responsive documents, even if it means contacting former employees. Truitt v. Department of State, 897 F.2d 540, 542 (D.C. Cir. 1990) makes it explicitly clear that it is the obligation of the Department to “conduct a search reasonably calculated to uncover all relevant documents.” In addition, the Justice Department’s May 2004 FOIA Guide states that an agency “cannot limit its search to only one record system if there are others that are likely to turn up the information requested.”

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 20 business days, as the statute requires.

Sincerely,

Michael Best

I am appealing the decision to issue a GLOMAR response, as it is not appropriate in this instance, as CIA has previously disclosed its knowledge of and monitoring of the subject. This has been specifically disclosed by CIA Director James Woolsey in Congressional testimony.