For years prior to and on September 11, 2001, Saudi Arabia established, owned, operated and controlled a series of state-run "charity" organizations, namely
- the Muslim World League (MWL),
- the International Islamic Relief Organization (IIRO),
- the Rabita Trust,
- the World Assembly of Muslim Youth (WAMY),
- the Benevolence International Foundation (BIF),
- the al Haramain Islamic Foundation (AHIF),
- the Saudi High Commission for Relief of Bosnia and Herzegovina (SHC),
- the Saudi Joint Relief Committee for Kosovo and Albania (SJRC), and
- the Saudi Red Crescent (SRC),
and these organizations are referred to hereinafter as "Saudi Arabia's charity organizations" and, as further described herein, each of these organizations(i) were so closely related to Saudi Arabia that they must be considered as part of Saudi Arabia, and/or (ii) were government agents of and/or(iii) were alter-egos of Saudi Arabia, because Saudi Arabia:
established, controlled, operated and regulated each organization through its King, Council of Ministers, the Supreme Council of Islamic Affairs, the Council of Senior Ulema, Ministry of Islamic Affairs, Ministry of Foreign Affairs, other Ministries and bodies and Saudi Arabia's Embassies throughout the world;
maintained significant, repeated and extensive control of the day-to-day operations of each organization;
provided each organization with virtually all of its funding and determined how its funds were distributed;
established guidelines, plans and policies that each organization was required to follow;
appointed Saudi Arabia officials and employees to the lead positions within each organization;
staffed each organization with Saudi Arabia's officials and employees;
hired, fired and directed each organization’s officers and employees;
required each organization to obtain its approval for ordinary business decisions, including purchases, the locations of its operations and offices, banking, budgeting and grant decisions;
used each organization's personnel and property as its own;
ignored the separate legal status, if any, of each organization;
treated each organization as a part of Saudi Arabia;
used each organization to perform its core governmental functions, including foreign affairs and the advancement of Saudi Arabia's state religion of Wahhabism throughout the world;
and operated, controlled and used each organization in such a manner that it would work a fraud or injustice to regard the organization as a legal entity separate from Saudi Arabia.