Chapter 29

At the Financial Crimes Enforcement Network’s headquarters in Vienna, Virginia, the introduction of the Holy Land Charitable Trust of Germany into their proprietary SQS, or suspicious activity query system, set off a string of alarm bells. The suspicious activity query system drew on a database of more than ten million suspicious activity reports and cash transaction reports filed by American financial institutions over the past ten years, and included all reports filed by banks, savings and loans, brokerage houses, cash-transmitting agencies, and more recently, casinos. Additionally, the SQS combed the Treasury Enforcement Computer System, NADDIS, and the Internal Revenue Department’s proprietary database.

Utilizing an artificial intelligence program, the SQS was able not only to search for precisely defined keywords, such as “Holy Land Charitable Trust” or “Gemeinschaft Bank of Dresden,” but to sift and evaluate the descriptive portion of each report-the two or three paragraphs written by the teller who had actually witnessed the criminal activity-for catchphrases, partial names, and possible references to the account or individual being interrogated.

At.36 seconds, the first hit appeared on Bobby Freedman’s screen. It came from TECS, and stated that during a year 2000 investigation conducted by the United States Customs Department into software piracy, the Holy Land Charitable Trust had been linked to Inteltech, a registered Paraguayan corporation thought to be engaged in the illegal copying and wholesaling of software patented by American software concerns. The Trust’s name was listed as a beneficiary of a German account said to be a conduit for Inteltech’s funds. Due to a lack of cooperation by the Paraguayan government, the investigation had been shelved.

The second hit arrived at.78 seconds. The Trust’s name was found in a suspicious activity report filed by the Gemeinschaft Bank of Dresden stating that the account frequently received multimillion-dollar transfers from high criminal activity points, including Brazil, Colombia, Panama, Dubai, and Pakistan. Again, no action had been taken.

Freedman studied the reports. With Chapel’s words echoing in his ears, he phoned the head of compliance at Thornhill Guaranty at his home in Manhattan at 5:21 A.M. Stating that the terrorist who two days earlier had blown up three American law enforcement professionals had been discovered to have ties to the Holy Land Charitable Trust’s account at Thornhill’s Gemeinschaft Bank subsidiary, he requested them to supply-of their own volition, naturally-all pertinent account records.

At 7:01, a forty-six-page E-mail chronicling the Holy Land Charitable Trust’s entire banking history at the Gemeinschaft Bank of Dresden arrived in his mailbox. At 7:08, Freedman called Allan Halsey at FTAT and advised him to log on to his computer and to have plenty of paper ready for the download.

It took Allan Halsey one hour to find the connection-the irrefutable link that Chapel had been begging for. When he saw the numbers, and ran them past the ones Chapel had given him five hours earlier, and noted that “yes, they were the same, by God,” he felt as if he’d been hit in the stomach by a line drive.

For the past eighteen months, the Holy Land Charitable Trust of Germany had regularly received money from the same numbered account at the Deutsche International Bank that was funneling money to Albert Daudin at the Bank Montparnasse in Paris.

Immediately, Halsey contacted the Office of Foreign Asset Control (OFAC) and requested that the Trust’s account be frozen pending an IEEPA edict. IEEPA stood for the International Emergency Economic Powers Act. It was the sledgehammer Halsey had promised, a broad, all-controlling measure granted to the executive branch of the United States government to deal with any unusual or extraordinary threats to the country’s national security, foreign policy, or economy.

A flurry of phone calls ensued.

OFAC called the White House. The White House called FTAT to confirm that OFAC’s IEEPA request was legit, then followed up with a call to the undersecretary of the Treasury for Enforcement to double-check. The undersecretary called the secretary of the Treasury and sug- gested he might want to contact the chairman of Thornhill Guaranty to let him know that his bank was about to be put in the same bed as a cele- brated terrorist. He then dialed Admiral Owen Glendenning, and said, “Wasn’t the Patriot Act a great thing? And it was nice working with you, too.”

The chairman of Thornhill Guaranty, however, was not so cheery. A generous donor to the ruling party, he phoned the White House to request that Thornhill’s name be left out of it, and that only the Gemeinschaft Bank of Dresden be mentioned. In soothing tones, he was informed that the President was otherwise engaged, but that his comments would be passed along with all due haste. It was the truth. At that moment, the President was closeted with his press secretary, communications chief, and foreign policy czar, figuring a way to work the news into the day’s public addresses at a UAW rally in Saginaw, Michigan (easy), and a luncheon for the National Midwives Association in Hannibal, Missouri (hard). All were agreed, though, that it would be a marvelous theme on which to base his after-dinner comments at the state dinner honoring King Bandar, the new ruler of Saudi Arabia, being held Saturday evening.

Decision taken, the White House called back OFAC and signaled their accord.

At 8:21, a provisional freeze was put on all assets of the Holy Land Charitable Trust of Germany held by the Gemeinschaft Bank of Dresden.

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