[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


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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\
---------------------------------------------------------------------------
    \1\ The prepared statement of Senator Levin appears in the Appendix 
on page 47.
---------------------------------------------------------------------------
    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\
---------------------------------------------------------------------------
    \2\ The prepared statement of Senator Coburn appears in the 
Appendix on page 51.
---------------------------------------------------------------------------
    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.
---------------------------------------------------------------------------
    \1\ The prepared statement of Mr. Baddin appears in the Appendix on 
page 52.
---------------------------------------------------------------------------
    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.
---------------------------------------------------------------------------
    \1\ The prepared statement of Ms. Cobb with an attached letter 
appears in the Appendix on page 53.
---------------------------------------------------------------------------
    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.
---------------------------------------------------------------------------
    \2\ The prepared statement of Mr. Fox appears in the Appendix on 
page 58.
---------------------------------------------------------------------------
    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.
---------------------------------------------------------------------------
    \1\ The prepared statement of Mr. Mandemaker appears in the 
Appendix on page 66.
---------------------------------------------------------------------------
    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.
---------------------------------------------------------------------------
    \1\ See Exhibit No. 32 which appears in the Appendix on page 570.
---------------------------------------------------------------------------
    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\
---------------------------------------------------------------------------
    \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.
---------------------------------------------------------------------------
    \1\ See Exhibit No. 87 which appears in the Appendix on page 746.
---------------------------------------------------------------------------
    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?
---------------------------------------------------------------------------
    \1\ See Exhibit No. 109 which appears in the Appendix on page 788.
---------------------------------------------------------------------------
    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.
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    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.''
---------------------------------------------------------------------------
    \1\ See Exhibit No. 113 which appears in the Appendix on page 797.
---------------------------------------------------------------------------
    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.
---------------------------------------------------------------------------
    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.
---------------------------------------------------------------------------
    \1\ The prepared statement of Mr. Johnson appears in the Appendix 
on page 80.
---------------------------------------------------------------------------
    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.
---------------------------------------------------------------------------
    \1\ The prepared statement of Ms. Ayala appears in the Appendix on 
page 87.
---------------------------------------------------------------------------
    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.
---------------------------------------------------------------------------
    \1\ The prepared statement of Mr. Freis appears in the Appendix on 
page 98.
---------------------------------------------------------------------------
    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.]


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