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202 616 8187
AARAN MONEY WIRE SERVICE, INC.) and GARAD NOR, all<fa GAR.W JAMA.
Plaintiffs, ;
Civil Action -_
THE UNITED STATES of .AMERICA;
JOHN ASHCROFT, in his official capacity as Attorney General of the United States; PAUL H. O'NEILL, in his official capacity as Secretary of the Treasury of the United States of America; COLIN L. POWELL. in his official capacity as Secretary of State of the United Stales of America; R. RICHARD NEWCOMB,
in his official capacity 3S Director, United States Department of the Treasury, Office of Foreign Asset Control; and ROBERT S. MUELLER., III. in his official capacity as Director, Federal Bureau of Investigations.
Aaran Money Wiring Service, Inc. ("Aaran") and Garad Nor, for their Complaint against
the Defendants. hereby state and allege as follows:
I. Defendant John Ashcroft (,<Ashcroft") is the Attorney General of the United
States. He is named as a defendant herein solely in his official capacity.
2. Defendant Paul H. O'Neill ("O'Neill") is the Secretary of the Treasury of the
United States. He is named as a defendant herein solely in his official capacity.
3. Defendant Colin L Powell ("Powell") is the Secretary of State of the United
Slates, He is named as a defendant herein solely in his official capacity.
All redactions on this page made pursuant to exemptions (b)(2) and (b)(5)
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4. Defendant R. Richard Newcomb ("Newcomb") is the Director of the United
Stales Department of the Treasury, Office of Foreign Assets Control ("OF AC"). He is named as
a defendant herein solely in his official capacity.
5. Defendant Robert S. Mueller, III ("Mueller") is the Director of the Federal Bureau
of Investigations of the United States ("FBI"). He is named as a defendant herein solely in his
official capacity.
Plaintiff Aaran is a Minnesota corporation with its principal place of business in
Minneapolis, Minnesota. (!) Prior to ceasing its operations on November 7, 2001, Aaran was ~~gaged in the transfer business. Its business activities included accepting money from its customers •
ost of whom were Somali, Ethiopian, or Kenyan immigrants to the United States. and then
ransfer ring the funds by wire to another company, Arnal Express ("Am.al"), through the Bank of
ubai in the United Arab Emirates. Amal in turn would deliver the money to the intended
recipients. The majority of the intended recipients were impoverished family members of
Aaran's customers who resided in Somalia, Ethiopia. and Kenya-s-cften in refugee camps.
CO Upon information and belief. Aaran's customers include naturalized United States
citizens as well as non-citizen immigrants to the United States.
~ Aaran is a small business owned and operated by Plaintiff Garad Nor. Mr. Nor
immigrated to the United States from Somalia in 1992 and became a naturalized United States
citizen in 1997. His religion is Islam.
/// 10. ; In exchange for its services, A aran charged its customers a commission of up to
( ...._.......-----"
five percent Of the total commission charged, Aaran retained thirty-three percent and forwarded
the remainder to Amal, Arnal used its share of [he commission to pay for its operating expenses,
LeeR Q & R - 013189
All redactions on this page made pursuant to exemptions (b)(2) and (b)(5)
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including rent, utilities. salaries, bank fees, and other charges. Mr. Nor's average gross monthly
salary for operating Aaran was S1,500 per month.
1]. This action, arises under the International Emergency Economic Powers Act, 50
U.S.C. §§ 1701·1706 (HIE EPA"), and the Fourth. Fifth, and Sixth Amendments to the
Constitution of the United States.
12. This Court has jurisdiction under the Administrative Procedure Act ("APA"). 5
U.S.C. §§ 702-04, and 28 U.S.C. §§ 1331 and 1346.
A substantial pan of the events or omissions giving rise to Plaintiffs" claims
urred in Minnesota, and a substantia! part of the property that is the subject of this action is
situated in Minnesota. Venue in the District of Minnesota is proper pursuant to 28 U.S.C. §
1391(e)(2) for these reasons.
A. Blotking Notice
14. On November 7, 200t, defendant Newcomb. acting on behalf of OFAC. issued
Blocking Notice FAC No. SDT-196711. which states that OFAC has determined that Aaran "is
an entity that provides financial support or other services to persons who commit, threaten to
commit or support terrorism." and has designated Aaran to be a "Specially Designated Global
Terrorist" ("SDGT"). A copy of the Blocking Notice is attached hereto as Exhibit A.
15. Similarly) on November 30, 200 I, defendant Newcomb, acting on behalf or
OFAC, issued Blocking Notice FAe No. SDT~196720. which states that OFAC has added Mr.
Nor. individually, (0 its list of "persons who commit, threaten to commit, or support terrorism, ,;
All redactions on this page made pursuant to exemptions (b)(2) and (b)(Q)
and has designated Mr. Nor to be a "Specially Designated Global Terrorist" ('<SDGT"). A copy
of the Blocking Notice is attached hereto as Exhibit B.
16. In connection with the Blocking Notice, OF AC published Plaintiffs' names and
addresses on its website (httpi/zwww.treas.gowofac) on its master list of "Specially Designated
Nationals and Blocked Persons," and in its brochure on "Terrorism." Upon information and
belief, OF AC also has ejther published or intends to publish Plaintiffs' names in its list of
blocked persons contained in Appendix A to 31 C.F.R. chapter V.
17. Pursuant to B locking Notice FAC No. SDr ~ 196711, all teal and personal property
belonging to Aaran has been "blocked," and it has been forced to cease all operations. Blocked
property includes Aaran's office, furnishings and equipment, business records, and bank
accounts. .
60 On November 7, 2001, agents operating under the control and direction of Defendants raided Aaran's place of business. seized all of its property, including cash and
checks, and barred reentry to the business premises. No receipt or inventory was provided by the
Funds in the following bank account have been blocked pursuant to the Blocking
Notice against Aaran:
(a) Associated Bank, Account No. 2283000699 I 801 Ri verside Avenue
Minneapolis Minnesota 55458
Balance: Approximately S J 66, 111.86.
20. 'Pursuant to Blocking Notice FAC No. SDT-196720, all real and personal property
be~onging to Mr. Nor individually has also been "blocked." Blocked property includes not only Mr. Nor's bank accounts and records. but also any real property in which he holds an interest, his furniture, his household goods, and his personal effects.
All redactions on this page made pursuant to exemptions (b)(2) and (b)(5)
21. Funds in the following bank account have been blocked pursuant to the Blocking
Notice against Mr. Nor:
(a) Wells Fargo Bank Minnesota, NA, Account No. 397¥2664550 Nicollet & Lake Office
P.O. Box B514
Minneapolis Minnesota 55479 Balance: Approximately 54l ,225.35.
22. Plaintiffs are presently unable to ascertain the exact amounts held in the blocked
accounts, because the government has seized all of their business and financial records.
Aaran has used Mr. Nor's personal account to hold funds deposited for transfer by
including smaller money transfer agencies in the United States who lacked the
capacity to make direct wire transfers to Dubai, Aaran utilized Mr. Nor's personal account for
Ibis purpose because Wells Fargo, the bank holding that account, has a larger national presence
than Associated Bank and a greater number of branches in which such customers could mor-e
easily deposit funds.
24. Both blocked accounts ccnrain funds entrusted to Plaintiffs by customers as
bailees [or transfer to intended recipients. as well :J.S funds in which Plaintiffs have direct
proprietary interests. Plaintiffs are presently unable [0 identify the customers whose funds are
held in the blocked accounts, because the government has seized all of their business and
financial records.
25. Under the terms of the Blocking Notice, transferring, withdrawing. exporting,
paying or otherwise dealing in blocked property is prohibited without prior OF AC authorization.
Transactions involving property in which Plaintiffs have any interest, including property owned
by third parties in Plaintiffs' possession or control, are similarly prohibited in the absence of
specific OFAC authorization. Upon information and belief. no interest accrues on the blocked
26. The Blocking Notices allege that OFAC's determinations are authorized pursuant
to Executive Order No. 13224 (66FR49079), issued by President Bush on September 23, 2001
(the "Executive Order"), and the IEEPA. A copy of Executive Order No. 13224 is attached
hereto as Exhibit C.
27, According to the Executive Order, Section 1, the determination whether to block
an individual on the ground that he commits, threatens to commit, or supports terrorism, or [0
block an entity on the ground that it provides financial support or other services to persons
engaged in such conduct, must be made by Defendant O'Neill in consultation with Defendants
Powell and Ashcroft, in their respective capacities as Secretary of the Treasury, Secretary of
State. and Attorney General: Upon information and belief. OFAC's actions were undertaken
with [he knowledge and approval of Defendants O'Neill, Powell and Ashcroft.
@ Aaran has no connection to terrorism or anyone involved in terrorism. It has never committed, threatened to commit, or supported any act of terrorism, and it has never
provided financial support or other services 10 any person engaged in such activities. On the
contrary, Aaran provides a valuable humanitarian service to honest, hard-working United States
immigrants by providing them with a means to send support to their impoverished families. ("29~, Mr. Nor similarly lacks any connection to terrorism or anyone involved in \...._ ... __ . .l
terrorism. He has never committed. threatened to commit, or supported any act of terrorism, and
has never provided financial support or other services to any person engaged in such activities.
Instead, he is an innovative and hard-working American citizen who, through Aaran, has
endeavored to meet the critical needs of immigrants from war-tom East African nations.
202 616 8187
I~ Plaintiffs have no knowledge that Amal financially supports or is in any other
\,vay connected with persons engaged in terrorist activities. 1f Amal is connected with such
persons, however, Plain ri ffs are totally unaware of the same, and have never possessed
information from which a reasonable person would conclude the same to be true. Upon
information and belief. OFAC has never issued a Blocking Notice against Arnal, designated it as
an SDGT, or otherwise found it to be connected with terrorist activities. Indeed, Arnal is known
internationally as a medium for p~vidingfinanci3.1 assistance to those in need in the Puntland
region of Central Somalia. The United Nations, Red Cross,' and other humanitarian relief
organizations have relied can Amal to assi.st them in getting funds to impoverished people in.
31.' Plaintiffs similarly have no knowledge or information of any connection between
Aaran's customers and persons engaged ill terrorist activities.
32. Neither OFAC nor any other agency of the United States government has offered
evidence to substantiate either the allegation that Aaran "is an entity that provides financial
support or other services to persons who commit, threaten to commit or support terrorism." or
the allegation that Mr. Nor is a person who "couimij[s], threaten[s] to commit, or support[sJ
terrorism. "
33. The Blocking Notices have caused extreme hardship to Aaran, Under the
Blocking Notice against Aaran, it is prohibited from conducting any business whatsoever. It is
thus unable either to earn an income or pay its bills from existing funds and. as a result, is in
arrears on irs utilities. rent and salaries. Moreover, Aaran's goodwill among its customers has
been severely damaged, and their trust in Aaran has been eroded. Several of Aarans customers
are becoming angry about its inability to deliver their money. and a few have even threatened
violence against Mr. Nor and his family. For these reasons, even if the Blocking Notice is li fled
it will be extremely difficult, if not impossible, for Aaran to resume operations as a going
34. The Blocking Notices have caused extreme hardship to Mr. Nor and his family
members individually. As a result of the aforementioned threats, Mr. Nor is concerned for his
family's safety. Moreover. he no longer has any income with which to support his wife and two
small children-c-one of whom was born five months premature with lung damage and ather
health problems. Furthermore, because OFAC has issued a Blocking Notice against Mr. Nor
individually, be is entirely incapacitated from functioning legally in society. Under' the Blocking
Notice, he is prohibited from satisfying even the most basic human needs including, inte» alia,
earning an. income, paying utility bills, paying for housing, paying his family's medical
expenses, or even purchasing groceries. Convicted, incarcerated prisoners have greater rights.
The government has done nothing to compensate Mr. Nor, a United Scates citizen, for (his
unconscionable hardship.
G The Blocking Notices have caused extreme hardship '0 Aaran's customers. It is unconscionable to withhold money belonging to these individuals, many of whom are the sole
support for indigent family members in Africa who have no other means [0 obtain food, clean
water, clothing and shelter. Upon information and belief, t.he government has never even alleged
that any of Aaran's customers is connected with terrorism or persons engaged in terrorist
36. On December 14, 2001, Plaintiffs filed separate Applications with Of A . C,:,",
pursuant to 3] C.F.R. §§ 806-807, for the Release of Blocked Funds. The Applications are
a ttached hereto as Exhibits D and E. In its applies ticn, Aaran offered, pursuant to 31 C.F .R. §
282 bIb ol!;;f(
501.807(a), to reorganize its business in such a way as to negate any basis for the government's
designation of it as an SDGT. Aaran further stated that, if necessary, it would sever its business
relationship with Arnal.
37. As an alternative basis {or relief, Plaintiffs applied for a license, pursuant to 31
C.F.R. § 801, authorizing the release of such funds necessary to pay their salaries, rent. utility
bills, and other expenses, and to restore the funds belonging to Aaran 's customers.
38. On December 14,2001. the undersigned counsel specifically requested a limited
license from OF AC to receive funds from the blocked accounts necessary to satisfy Plaintiffs'
leg:ll fees and expenses, Despite the immediate need for such a license, OFAC has utterly
ignored this request.
39. On January 7, 2002, a representative of OFAC told counsel that OFAC was
precessing the license request. however. no license was ever issued. On February 7. 2002, the
OF AC representative stated that he did not understand why OF AC had not issued the requested
license and indicated that he would investigate the issue. On February 26, 2002, counsel again
spoke with the representative. who stated that he had no information regarding the status of the
1 icense req uest, but that he would put a "red star" next to it. Notwithstanding this representation.
OFAC has never issued a license to counsel to receive funds from the blocked 'accounts for
payment of Plaintiffs' legal fees and expenses.
40. OFAC al~o has failed to respond to Plaintiffs' request for a license to use the
funds needed to pay fOT their other immediate expenses, Or to restore Aaran 's customers' funds.
41. Notwithstanding the immediate and extreme hardship suffered by Aaran, Mr. Nor,
and Aarans customers as a result of the Blocking Notice, OFAC has,.ignored Plaintiffs'
--~------ ~--~--------------------------~
teen Q & R - 013196
Applications for the Release of Blocked Funds and failed to reach any determination In
connection therewith.
42. On December 28, 2001, the undersigned counsel wrote to OFAC noting that
Plaintiffs had received no. acknowledgement of receipt of their Applications. The letter further
noted that because one of the Blocking Notices covers Mr. Nor individually> "it is vtrtually
impossible for him to pay any bills or receive any funds whatsoever. This is an extreme
emergency for him that requires immediate attention." Despite the urgency of this plea, OFAC
has continued to ignore Plaintiffs' Applications and communications from counsel regarding the
same. Counsel wrote to OFAC on January 10,2002, January 15,2002, and February 14,2002,
urging it to lift the Blocking Notice against Mr. Nor. OFAC has not responded 10 any of these
leiters, and has not returned telephone calls requesting infcnnation about the status of Pbimiffs'
applications on January 23, 2002. and February 10, 2002. Counsel contacted OFAC again on
March 11. 2002, but OF AC also failed to respond to this call,
43. The regulations governing Applications for the Release of Blocked Funds
establish no lime limit during which OFAC must issue a decision. See 31 C.F.R. §§ 501.806·
S07. Thus, OFAC's regulations purport to authorize it to block property indefinitely.
notwithstanding the severe, immediate and irreparable harm caused to affected persons.
B. Search and Seizure
6 On November 1, 200 I, agents of the FEr, Internal Revenue Service, United States Customs Service, and others, under the direction of Defendants, conducted a search of Aaran's
office at 1806 Riverside Avenue, Second Floor, in Minneapolis, Minnesota.
//45 .. j At [he lime of the search, the agents seized the entirety of the premises and its L_-.-/
contents, including all of Aaraa's 0 ffice equipment, furniture, and business records, by
physically locking the office and preventing Mr. Nor from reentering.
G Upon information and belief, the agents did not have a valid warrant at the time of the search.
Upon information and belief. the government did not have probable cause to
conduct the search.
48. The seizure of Plainitffs' property has caused irreparable harm. As a result of (he
seizure, Aaran has been unable to conduct business for a period of several months. Furthermore,
Defendants' seizure of Aaran' s business records has effectively prevented Plaintiffs from
obtaining information necessary 10 file tax returns and to support their administrative and legal
claims, including the identify of Aaran's customers and the amounts owed to them, the total
amounts held in the blocked accounts, and the portion of the blocked funds owned by Aaran,
IEEPA. so U.S.C. § 1702 (a}{l) (Against the all Defendants)
49. Plaintiffs restate and incorporate by reference the preceding paragraphs.
SQ, The IEEPA provides that the President may, uponthe declaration of a national
emergency pursuant to SO U .S.C. § 170 I, investigate, regulate or prohibit "(1) any transactions in
foreign exchange; (ii) transfers of credit or payments between. by, through, or to any banking
institution. to the extent that such transfers or payments involve any interest of any foreign
country or a national thereof; (and] (iii) the importing or exporting of currency or securities." The IE.EPA further provides that under such circumstances the President may "investigate,
regulate ... or prohibit, ... use ... \ v ith respect to, or transactions involving, any property ill
______ ~~ ~_~ ~ ~_ll ~
w hicl: any foreign COWltlY or a national thereof has Glly interest ... by any person ... subject to
the jurisdiction of the United States." (emphasis added.)
51. The IEEPA does not authorize the President or any agency of the United States
government to block, freeze, prohibit the use of, or prohibit transactions involving property
owned by United States citizens.
52. Aaran is a United States corporation owned and controlled by Mr. Nor, a United
States citizen. Upon informaticn and belief, many of Aarari's customers also are United States
53. For these reasons, to the extent that Defendants have blocked Aaraa's property,
Mr. Nor's property, and the property of Aaran customers who are United States Citizens. they
ha ..... e engaged in illegal, ultra vires acts which ~re not authorized under the IEEPA.
54. Plaintiffs have no adequate remedy at Jaw and will suffer irreparable injury if
Defendants are not enjoined from engaging in the activities described herein.
COUNT II PROCEDURAL DUE PROCESS (Against all Defendants)
55. Plaintiffs restate and incorporate by reference the preceding paragraphs.
56. Defendants seized Plaintiffs' property and blocked their assets without notice, and
without providing them with an administrative or judicial hearing or other review of any kind.
57. Defendants' actions, as described herein, have deprived Plaintiffs of their property
interests (including, but not limited to, the right to access, use, sell, transfer, or otherwise dispose
of the property) without due process of law, Such conduct violates the Fifth Amendment to the
United States Consriturion.
. . ---,
~2 biD 8il:J?
COUNT HI SUBSTANTIVE DUE PROCESS (Against AU Defendants)
58. Plaintiffs restate and incorporate by reference the preceding paragraphs.
59. Defendants, through the actions described herein, have imposed severe
punishment on Plaintiffs and deprived them of their fundamental rights without conviction of
any crime by the United States or any State thereof.
60. Defendants' conduct is arbitrary and overbroad, LInd is not reasonably tailored to
mee-t legitimate government needs.
6 L Defendants' conduct thus violated Plaintiffs' right. to substantive' due process
under the Fifth Amendment to the United States Constitution.
TAKING WITHOUT JUST COMPENSATION (Against AU Defendants)
62. Plaintiffs restate and incorporate by reference the preceding paragraphs.
63. Defendants have never compensated Plaintiffs for the total loss of use of any of
their funds. business records, office space, furniture, equipment. or other property.
64, Defendants' conduct has effected .1 taking of private property for public use
without just compensation, in violation of the Takings Clause of the Fifth Amendment 10 the
United Slates Constitution.
COUNTY EQUAL PROTECTION (Against All Defendants)
65. Plaintiffs restate and incorporate by reference the preceding paragraphs.
66. Prior to the cessation of its business on November 7, Aaran operated its business
ina fashion similar to other wiring services such 2S Western Union Financial Services, Inc.
(,'Western Union").
67. Published n,ew5 reports indicate that in the three days prior to the terrorist attacks
against the United States on September 11, 2001, the hijackers involved in those attacks sent four
payments to the United Arab Emirates using the services of West em Union.
68. Unlike Western Union, there is no direct or indirect connection between Aaran
and terrorism or persons engaged in terrorist activities.
69. Upon information and belief, Defendants have never subjected West em Union to
a blocking notice of any kind.
70. Defendants' disparate treatment of Aaran, as compared to 'Western Union, is
motivated in whole or in pan by the national origin and religious beliefs of Mr. Nor, its owner.
71. Defendants' conduct is not narrowly tailored (~ meet compelling government
interests. and thus violates the Equal Protection Clause of the Fourteenth Amendment as
incorporated into to the Fifth Amendment to the United States Constitution.
RIGHT TO ASSISTANCE OF COUNSEL (Against All Defendants)
72. Plaintiffs restate and incorporate by reference the preceding paragraphs.
73. OF AC's failure to grant the undersigned counsel even a limited license for the
payment of Plaintiffs' legal fees and expenses threatens to deprive them of the assistance
necessary to prosecute their claims. Counsel cannot, as a practical matter, continue to represent Plaintiffs indefinitely without payment oflegal fees.
74. Without the requested license, Plaintiffs are incapable even of paying their own
court costs and filing fees.
75. Defendants' refusal to permit Plaintiffs to pay court costs and legal fees directly
and immediately violates {heir right 10 assistance of counsel under the Sixth Amendment to the
United States Constitution.
OTHER SIXTH AMENDMENT TRIAL RIGHTS (Against All Defendants)
76. Plaintiffs restate and incorporate by reference the preceding paragraphs.
77. Defendants' conduct. as described herein, imposed severe punishment against
Plaintiffs without affording them (heir rights under the Sixth Amendment to the United States
Constitution to notice of the charges against them, to confront any witnesses against them, to
compulsory process for obtaining witnesses in their favor. to a trial by jury, and to assistance of
COUNT VIII FOURTH AMENDMENT (Against All Defendants)
78. Plaintiffs restate and incorporate by reference the preceding paragraphs.
79. Upon information and belief, Defendants' search and seizure of Aaran's property
was not supported by probable cause nor conduc ted pursuant to a warrant.
80. Defendants have thus effected an unreasonable search and seizure in violation of
the Fourth Amendment to [he United States Constitution.
FED. R. CRIM. P. RULE 41 (Against AU Defen dants)
S 1. Plaintiffs restate and incorporate by reference the preceding paragraphs.
202 616 818'1
82. Upon information and belief, Defendants' search and seizure of Aaran's property
was' not supported by probable cause nor conducted pursuant to a warrant, and is therefore unlawful.
83. A failure to ,return Aaran's property will result in irreparable harm.
84. For these reasons, Aaran is entitled to the return of the seized property under Rule 41 (e) of the Federal Rules of Criminal Procedure.
WHEREFORE, Plaintiffs, on behalf of themselves and as bailees for their customers, respectfully request the following re-lief: .
1. A declaration that Defendants' actions violate the Fourth. Fifth. and Sixth
Amendments to the United States Constitution and the International Emergency Economic Powers Act;
2. A preliminary and permanent injunction directing Defendants to remove all
restrictions on persons and property subject to Blocking Notice FAC No. SDT -196711;
3. A preliminary and permanent injunction directing Defendants to remove all
restrictions on persons and property subj ect to Blocking Notice F AC No. SDT -196720;
4. A preliminary and permanent injunction directing Defendants to remove any
designation of either Aaran or Mr. Nor as a "Specially Designated Global Terrorist," "Specially Designated National" or "Blocked Person" from all electronic and non-electronic publications issued by Defendants including. without limitation, OFAC's master list cf vSpecially Designated Nationals and Blocked Persons," its brochure on "Terrorism," and Appendix A to 3] C.F.R. chapter V;
5. A preliminary and penn anent injunction directing Defendants to return all
property seized from Aaran;
6. In the alternative, a preliminary and permanent injunction directing Defendants to
issue a 1 icense to the undersigned counsel which would permit the receipt of funds from the
blocked accounts for the payment of Plaintiffs' legal fees and expenses;
7. In the alternative, a preliminary and permanent injunction directing Defendants to
issue a license to Mr. Nor for the receipt of a salary and payment of basic expenses for food,
clothing, shelter. transportation, utilities, and medical care; and
8. Such other and further relief as the Court deems just and equitable.
Dared: April 12.2002
John W. Lundquist .LI6S286) Dulce J. Foster (#285419) FREDRIKSON & BYRON, P.A. 1100 International Centre
900 Second Avenue South Minneapolis. Minnesota 55402 Telephone: (612) 347-7000 Facsimile: (612) 347-7077
A TTOR.!"1EYS FOR PLAINTIFfS AARAN MONEY WIRE SERVICE. INC. and GARAD NOR
~02 616 8187
All redactions on this page made pursuant to exemptions (b )(6), (b )(7)(C)
MinnC'lpoii. london \v~~hin;;ttll\. DC
j\ lex i,~ Ci ~ \V3r~~w i\t.;,nrt(~1 Torcnro Val')(o'J"cr
1100 hlrcrn,lrlnrl'll C entre
900 S~~nml Avenue Sourh ~lmnr;\?t11ij. r.IN )3401·339i (61.2) l~j·iOOO
FAX (b12) ;Jj·;"07i "'\\'\1". (rrdl~w. ,,)m
Attorneys and Advisol',S'
April 16,2002
VIA CERTIFIED MAIL - RETURN RECElJlT REQUESTED
To the parties on the attached Service List
Re: Global Services International. Inc. and Abdullah! Farah v. United Srates of America, et al.
Dear Interested Party:
Enclosed and served upon you please find a Summons and Complaint in connection with the above-entitled matter. ..
~- .
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LeeR Q & R - 013205
<t!<J<!' bib 1::Htf( P, 23
................................ GlO..baJ.5erl!ices ... llll.erllluiol'al~Ju.c. ... an.dAbdullaJJi.Farah ... v, .....
United States of America. et al.
Office of the United States Attorney ATTN: Civil Process Clerk or
U.S. Attorney Thomas B. Heffelfinger United Stares Courthouse
300 South 4111 Street, Suite 600 Minneapolis. MN 55415
J ohn Ashcroft. United States Attorney General U.S, Department of Justice
950 Pennsylvania Avenue. NW
Washington. DC 20530wOOO 1
Director R.Richard Newcomb United States Department of Treasury Office of Foreign Assets Control Senate Banking, Housing and
Urban Affairs Committee
1500 Pennsylvania Avenue, NW Washington. D.C. 20220
Paul O' Neill. Secretary of the Treasury United States Department of the Treasury 1500 Pennsylvania Avenue, NW Washington. DC 20220
Robert S. Mueller III, Director Federal Bureau of Investigation J, Edgar Hoover Building
935 Pennsylvania Avenue, NW Washington, D,C. 20535-0001
All redactions on this page made pursuant
to exemptions (b)(6) & (b)(7)(C)
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December J 4, 200 I
R. Richard Newcomb, Director U.S. Department of Treasury Office of Foreign Assets Control
1500 Pennsylvania A venue NW (Annex) Washington, DC 20~:2U
Re: License Request of Fredriksen & Byron, lP.A.
Dear Mr. Newcomb:
As counsel [I)[ Aaron Money Wire Service, [ne{'Aaron") and Garad Nor, we have filed two Applications for Release of Blocked Funds with your office. Copies are attached hereto for
your reference.
By this letter, Fredriksen & Byron, P.A. requests that your office gran! a license so that we may be paid for our legal services, past and future, provided to Aaron and Mr. Nor. These services will include representation of Aaron and Mr. Nor in all matters related to the Blocking Notices dated November 7, 200 1, counse ling regarding the requirements 0 f relevant law, legal assistance in dealing with federal law enforcement agencies, defending our clients blocked property (including preparation of the enclosed Application), representation before OFAC and any litigation that may result therefrom. We believe that such a license is proper under 31 C.F.R. § 585.506 and may also be constitutionally required.
At this lime we request a license far the paY.DJQ.1t orS_for these services.
/" ". . ---:::- -' .
We base this request on the attached Please let me know as soon as possible if separate i'0n11 should be submitted.
lications that arc Incorporated by reference.
information or believe that a
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clo Fredri.kson ~; 3y=nn, P.A_
P'O~iAL COCE
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Hovl~;nber 7, 20Cl
I:!;£NEFIC: .... RY 'FINANCiAL l:-.tsnrunou NAME .i. ADDRESS
OESCHIPT;~NOF u~D£RL "fJNG TRANSAC:-lClN IATTACi-1 r:EP ..... ~_.l;·JE: !:;ltC.=7 /'S NEEDEDI
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Aa r on, Ama l Expr ass .e.nd ',~l r i cus cus tame~!:i
money t. rnr.s [-(:.;:(s
,",P9;_:C,.l Tim. CERTIFIC.>TtCtl: I. ,HE u tIDERSIGNEJ. HEREEY OEGURE -HAT. ~O -loE :lEST OF 'ilY \<NCWLc:OG E_ ',hE :NFC:GMATICN !'ROVlCEO ON THIS ;"P"l:CAT,CN M:O ANY ;"C:::OMF<;NYING OOCUMENTA rIGN:5 ,RUTHFUL ANa COMPUi.'E,
I .: v,~~,
, ,/
All redactions on this page made pursuant to exemptions (b)(6) & (b)(7)(C)
>: rn: D ST A [T,S o LY ,\ nr '. IE :-d' 0 F TilE TRi~_':'_S Ln. 'I OFFICE OF FOREIC;\ ASSET CO~'iTROL
PFT1TlO\ 1:\ SClJPORT OF THE :\PPLlC\TIO:-,;S OF AARON \IONE'{ \-VIRE SERVICE, L\C. :\.\'1) (;--\!{\I) ,\OR FOR THE RELEASE: OF BLOCKED FL:'iDS
App I icarus, Aaron i'vioney \-Vi re Service, Inc. (" Aaron") and Ci mad 1\ or (""lor") ::1, k.a.
Garad lama (collectively referred to herein as "Applicants"), respectfully represent to and
petition the United Stares Department of the Treasury, Office of Foreign ASSet Control
COFAe'') as follows:
Pursuant to :\ 1 C.F,R, §§ 501.801, 501.806 and 501.807, Applicants submit this
memOI"J.ndU111 iri support of their Applications and requests for the following: (I) the unblocking
of funds believed LO have he en blocked due to a mistake of fact or mistaken identity; and (2) the
removal of Aaron's and Nor's names from Appendix A to Title J 1 ClR Chapter V, all versions
of OFACs Specially Designated Nationals and Blocked Persons ("SDN") list and OFA.C's
brochure on terrorism.
"To many Somali immigrants in Minnesota, Garad [Nor] is known as 'J savior of sorts
who began a service that enables them to quickly wire cash to impoverished relatives in 2omalia,
where there is no banking system." See Joy Powell, To IIWIlJ' Somalis, Gamel .!WI1U has helped
ihousands, vlinneapo lis S tar Tribune, Nov, S, 2001 at 11 ttp :,'/\V\V\v. startribune. com/srories;484/
8 tJ952,html.
i.ccs Q & R " 013209
All redactions on this page made pursuant to exemptions (b )(6) & (b )(7}(C)
.vere interested til sending money back to
[heir families, 3.$ well. Mr. Nor began assisting such people our of his home. A rCC(;T1L
All redactions on this page made pursuant to exemptions (b)(6) & (b}(7)(C)
S] 3952.l1Llni.
In approximately 199o, [vir, ~or formed the Somali International Relief Organization
("SlRO"), a non-profit organization established to help other Somali immigrants :,'enn monev
back to Africa. \'fr. Nor operated SfRO for approximately one year. o
The number of people Mr. Nor helped eventually grew to between 40 and 50. As the
number of people grew, so did the administrative burdens associated with the task. Thus, rather
than continuing as :1 non-profit organization, Mr. Nor decided to restructure 3S a for-profit
company. In 1996, 1\'1r. Nor dosed SrRO and formed Aaron .
. ,
Prior to the Blocking Notice, Aaron, like SIRO, wus engaged in the money transfer
business. Aaron's business operations consisted of Aaron receiving money from its customers,
most of whom are unmigrants from Somalia, Kenya and Ethiopia, and then transferring the
money to another company in Dubai, United Arab Emirates, called Amal Express CArnal"). A
Minneapolis newspaper article reports that "li]n United Arab Emirates, Arnal ... workers pick
up the money at the Bank of Dubai and take it in heavily guarded cars into Somalia or refugee
CilITlpS In Kenya."
See Minneapolis Star Tribune,
[9, 2000 at
htlp:.:.:wv,.w,starrribune,com'storics,'484/SJOO:;,hrmL --In \lw most remote areas. money-transfer
companies hire couriers who ride donkeys and camels," [d. The people receiving the money are
pri man l~ re lugees ind i mpo verished indi viduals li vi ng I n refugee camps throughout Eastern
All redactions on this page made pursuant to exemptions (b )(6) & (b )(7)(C)
Me Nor operated Aaron unri! November 7, 2001. On that date, Aaron's assets were
frozen and all of its property and records were seized pursuant to a Blocking Notice_
l(b)(2) I
_ (vir. Nors personal assets were also frozen pursuant to J. Blocking Notice (SDT-
_ The Notices are attached hereto as Exhibits A and B. Mr. Nor and Aaron have also
been locked out of tl.eir rented office space. Notwithstanding the lock out, Aaron continues to
incur rent expenses pursuant to irs rental agreement with its landlord. As a direct result of the
blockings and seizure, Aaron was farced to cease its business operations. Also as a result of the
blackings, Mr. Nor Las been left with no income and no money with which to support himself
and his family.
Amal is owned by _businessmen that formerly operated small money transfer
companies and eventually joined together, for economic and competitive reasons, to form Arnal.
Mr. Nor IS J. member of the board of directors for Arnal. Arnal was not named in the Order JS a
SDGT. Radler, Amal is known intcmutionully as J medium for providing financial assistance to
those in need in i:ht! Puntland region of Central Somalia. Indeed. (he L.N .. Red Cross and other
! Lt.., ,__<
r. DISCCSSIO:'\{
A. AARON'S AND MR. NOR'S FL.'\DS Ai\D PROPERTY SHOULD BE UNBLOCKE.D.
The vBlocking Notices" received by counsel for Aaron on November 2l, 2001 and by
Mr. Nor on November .30,1001 state that, pursuant to Executive Order No. 13224 (the "Order")
and under the authority of 50 U.S.c. § 170 I ,06, OFAC has "determined" that Aaron and Mr. Nor
have provided "financial support Or other services to persons who commit, threaten to commit or
support terrorism."
Aaron and Mr. Nor vigorously and categorically deny these claims.
Under the International Emergency Economic Powers Act ("IEEPA"), the President of
the United States is authorized [0 deal with "any unusual and extraordinary threat, which has its
source in whole or substantial part outside the United States, to the national security, foreign
policy, or economy IJf the United States, if [he President declares a national emergency with
respect to such threat." See 50 U.SC § FOlia). Behring IntI, Inc v. Miller, 504 F. Supp. 552,
556 (D. N.J. 1980). The President's authority under [EEPA is enumerated and therefore limited
to those specific powers granted under the act. The enumerated powers granted to the President
bv lcEPA are the powers to investigate, regulate. direct and compel, nullify, void, prevent or
prohibit, JI1Y acqui.sition, holding, withholding, usc, transfer. withdrawal. transportation,
i mportation or exportation 'J C. or ,Jeal\ll~ in. IJr ex ere: sing an y right. power. I))' pri vi lege xv i ih
directly or indirectly:
(1) any postal, telegraphic. or other personal communication, which does not involve
the transfer of anything of value;
(2) donations, by persons subject to the jurisdiction of the United Stutes -. ofartivles,
such as food, clothing, and medicine, intended to be used to relieve human suffering, except to the extent that the President determines that such donations (A) would seriously impair his ability to deal with any national emergency declared under [50 USC. § 1701- 06J, (B) are in response to coercion against the proposed recipient or donor, or (C) would endanger Armed Forces of the United States which are engaged in hostilities or are in a situation where imminent involvement in hostilities is clearly indicated by the circumstances.
See so US C. §§ .l702(3)(b)(1)-0)·
fa this case, the President's Order provides, in -relevant part, 3S follows:
all property and interests in property of the following persons that are in the United States or that hereafter come within the United States, OT that hereafter come within the possession or control of United States persons are blocked:
(d) persons determined by the Secretary of the Treasury, in consultation with the
Secretary of State and the Attorney General;
(i) to assist in, sponsor, or provide financial, material, or technical support
for, or financial or other services to or in support of, such act of terrorism or those persons listed in the Annex to this order or determined to be subject to this order;
(ii) to be otherwise associated with those persons listed in the Annex to this
order or those persons determined to be subject to subsection l(b), 1 (c), or I(d)(i) of this order.
See Executive Order I 3224 at Section J (d). The Order further states that the President has made
the following determinations:
the making or donations otrhe type specified in section 203(b)(2) of the IEEPA (50 liSe. 1702{b)(2)) by Lni ted Stares persons ,0 persons determined to be subject to this order would seriously impair my ability to deal with the national emergency declared in this order. JnJ would endanger Armed Forces of the United States that are in a situation where imminent involvement in hostilities is clearly indicated by the circumstances and hereby prohint such uonationsas provided by section 1 of [his order.
With respect to those persons dtsigm!lCd pursuant to subsection ltd) ofihis order, the Secretary ofthe Treasury, in [he exercise orhis discretion and in consultation with the Secretary ofSture and the Attorney General, may take such other actions than the complete blocking of property or interests in property as the President is authorized to take under the rEEF.\ and UNP.'\ ifthe Secretarv of the Treasurv. in consultation with
. .' - ... '
the Secretary of State ami the Attorney General, deems such other actions to be consistent
With the national interests of the United States, considering such factors as he deems appropriate.
It!. at Section 5.
Acting under the authority delegated to it by the Order, OFAC has determined that Aaron
ami [VLr. Nor are SDGTs and therefore subject to the blocking and other sanctions authorized by
the Order. To withstand judicial scrutiny, determinations by OFAC may not be unreasonable,
arbitrary, capricious or an abuse of discretion. See Behring 504 F. Supp at 556 (citing Sardina v.
Federal Reserve Bank of New York. 361 F.2d 106 (ld Cif. 1965), cert denied, 385 US 898
(1966); Veterans & Reservists for Peace in Viet-Nom v. Regional Comm 'I' ofCustoms, .459 F.2d
676 (3d eir. t 972), cere denied 409 US. 933 ~ (972)).
When funds are blocked at 3. financial institution pursuant to a blocking notice and a
party believes the funds have been blocked due to mistaken identity, that party may seek to have
such funds unblocked. See 31 C F.R. § 501.806. Aaron and NIr. Nor seek to have their funds c unblocked based upon its belief that tbey have been mistakenly identified as a parties associated
with terrorist activities.
A request to have funds unblocked must contain the following information:
( 1 ) . the name o f the financi 31 j nsii rution in which .hc funds arc blocked:
(~:) the date or the blocking;
All redactions on this page made pursuant to exemptions (b)(6) & (b)(7)(C)
I,.!] [ile idc!li.!l:. ,)~-~ill' ,)['i:,::'I,:j :';':;;:ll~'! ,_·:'lill; ,'uld:: ~..,hl ~"l\ j[ikT!l;,:dulch t-ul~lnc~~ll :nsri·.·.!uOI~:~:
j/J) :1 description 0['[11<:: underlying transuction including copies 01' r(i:ueG documents:
(-;) the nature of the uppl icun t sin terest; and
\ S) a statement 0 r the reasons wb y the app \ icunt believes the run ds we re blocked due to mistaken identity.
See J / CF,R, 517/.806(d).
1 :)2. Financial Institutions and Amounts
Funds in Aaron's account have been blocked at the following financial institution:
approximately $l66, 111,86 at Associated Bank, Account Number 2283000699, 1 SO L Riverside
Avenue, Minneapoiis,\I(innesota 55458. The following funds in Mr. Nor's account have been
blocked: approximately
Nor's personal account was used by Aaron to hold funds deposited for transfer by smaller Arnal
agt:nts around the western U.S. Since the other Arnal agents were smaller than Aaron in terms of
volume of business and not able to effectively and efficiently make money transfers, they relied
on Aaron to collect and transfer funds that the smaller agents received from their customers.
Because Aaron's bank account was maintained at Associated Bank, a Midwest regional bank,
Amal agents operating outside the Midwest could not easily deposit money into Aaron's account
Thus, instead of .ising Aaron's account the agents deposited money into ]\1[[. Nor's account at
\Y ells Fartro. J bank with branches! oc ated throughout the western hal f of the U ,S,
- '
Neither .\3['011 nor .\[r. :'<01' can determine [he exact amount of money [hat has been
b lacked bee uuse ull of' rhci r li nancial records were ~cized by the go vcrnrnent.
tcca Q & R - 013216
..t. l dcn tiry of the Origill~d Remitter or rile Funds and In termed iary Finun ciul Institu t iun ,
Numerous customers and other Arnal agel1lS remitted funds that wac deposited by Aaron
cllld Mr. Nor into rhe blocked accounts. The names of the customers and other Arna! agents
cannot be provided without access to Aaron's and 1'\'1r. Nor's records.
~. The In ten ded Beneficiaries.
The intendedbeneficiaries of the blocked funds arc primarily East African refugees that
are related to those sending money from Minnesota via Aaron. These people rely on the money
for their very existence, and there is no indication that they supply or direct money to terrorists.
Instead, a recent newspaper article described one of the "beneficiaries" and the journey she
endures to pick-up and utilize the money sent by her daughter in America as follows:
[A] 68-year old mother walks more than an hour through bombed-out dusty roads, past waiting thieves, flying bullets, beggars and murderous gangs to the office in Mogadishu's Medina district.
At Al-Barakaat, she collects her money in U.S. currency. To be sure she won't be harassed, she asks for small bills to give people who beg or bother her.
A line of people awaits her back home. She doesn't tell them she has money, but everyone knows why she left so early. Each of them will leave her yard with a dollar or hVo.
She will buy g;7 worth at' water, enough to fill the tank for a week. She will spend the rest on a small bit of goat meat and beef, Dour, sugar and other staples she can stretch for her large family.
See, Somalis In the Us. worry about closed wire-transfer offices, Minneapolis Star
I'ribune. pp. :-\1, 12, :,ov. to. 2i)UL.
The funds should be returned [0 their lawful owners. It is unconscinnable to withhold
All redactions on this page made pursuant to exemptions (b)(6) & (b)(7)(C)
h\ their :·~lrndv ;nCll hl.;, .. r~~ :t~ ,\(~·i\·.1 I'H' !,,"l'!"'h:'d !~I~ ljl'~' ':!_~.:-·lj .. 1j~·~L'~':':. Sorue l:!" .v.irons '_':U~aCtTi':r~';
. -
The United N8lio[1s representative to Somalia. Randolph Kent, bas said "[tjhe [money
.ransfer business] closure is having a very, very serious effect. *** We are a!,. '~':;'.' ····bert we
have to stan anticipating a crisis that could be unique in the modem state system - the collapse
of an entire national economy." See Minneapolis Star Tribune, p. AI, December 1, 200 1.
A portion of the money belongs to Aaron. Without its records, it cannot ascertain what
the correct amount is. Aaron is in arrears on rent, utilities and salary. 1\'1L Nor has no income
It is, thus, urgent that the funds be
returned to Aaron, Mr. Nul' and Aaron's customers so that the customers can make alternative
arrangements to get the money to their relatives and Mr. N
portion of the money belongs to Arnal. Without access to their records, Aaron and Mr. Nor are
unable to determine what portions of the money belong to Aaron, Amal and Aaron's customers.
6. The Underlying Transactions
The underlying transactions at issue here consist of transactions akin to a Western Union
money wire transfer in that they involve customers bringing sums of money (usually $ lOO -
.'5500, although occasionally S5,000 or more) to a business location for the purpose of having the
money transferred to someone else. As described above, Aaron accepts money from its
customers and dcpos.ts the funds inro its banks accounts. At least LlOCt: a day, Aaron, via fax or
preceding month, I B ascd upon the m formau on contai ned in th e f na nc i a I documents, the
companies determine the amount of commission Aaron eJm,~d or the mane: I ;~'" ,'e;': b:- .varon
for commissions, 1\3[On paid its operating expenses and employee salaries. None of (he money
earned by Aaron was provided [0 terrorists or terrorist organizations, and it is aware or none of
the amounts transferred being used for such purposes,
Although Aaron operates in a fashion similar to Western Union, it is interesting to note
that no action h:1S been taken against it despite clear evidence that Western Union has been
directly linked to terrorist activity. News reports stale that it has been determined that "[i]n the:
three days preceding September II, four separate payments were sent to the United Arab
Emirates by the alleged highj ackers. /1..11 four were made through Western Union Financial
Services, Inc. agents in [he U,S. , , . ." See Heather Timmons, Western Union: Where the Money
is _ in Smal! Bills, Business Week Online, Nov, 15, 200 1 at httpvbiz.yahco.com/bizwk/
OlII15/ewybxkSdqr6jt4mf_pdsrq_l.html. Western Union remains open and unaffected by any
blackings, Unlike Western Union. there is no direct or indirect connection between Aaron or
Mr. Nor and the events of September 11 ill or any other terrorist activities. Notwithstanding the
lack of such a connection, Aarons and vlr. Nor's accounts have been frozen and Aaron's
operations closed. ~;uci1 actions CJO only be \' iewcd as unreasonable, arbitrary. capricious, and
1 ]
-vuron ~!Ild \!r. \or have both direct '.\illl indirect interests ill the blocked funds. First,
also have an interest in the funds belonging to :\aron's customers and Amell; as Aaron holds
those amounts :15 agent for the benefit of its customers and/or Arnal. Thus, ,t.~.;:J" ::1' .. : ><~-. Nor
have all interest in al] of the frozen funds which belong either to Aaron's customers and/or Arnal,
who bestowed their trust in Aaron to make sure that the money was delivered to the designated
recipients in Africa.
8. Reasons Aaron and Mr. Nor Believe the Funds Were Blocked Based Upon Mistaken Identity.
The Blocking Notices indicate (hac Aaron and Mr. Nor have been identified as an entity
or indi vidual that "provided financial support or other services to persons who commit, threaten
to commit or support terrorism (Specially Designated Global Terrorist ("SDGT")). The term
SDGT is not defined in either the Order or the Blocking Notices. Aaron and Mr. Nor me thus
left to assume that the term refers to "an entity that provides financial support or other services to
persons who commit, threaten to commit or support terrorism." See Blocking Notice at 'jj 1. The
Order defines terrorism as follows: "an activity that-
(i) involves a violent act or an act dangerous to human life, property, or infrastructure; and
(ii) appears to be intended -
(A) to intimidate or coerce a civilian population;
(8) [Q influence [he policy of a govemrnent by intimidation or coercion; or
(C) to affect the conduct of J government by mass destruction, assassination,
kidnapping, or hostage taking.
All redactions on this page made pursuant to exemptions (b)(6) & (b)(7)(C)
thaicommits violent ;1(t5 Dr ~ClS dangerolls to human li Ce, property or infrastructure that appear
[0 be intended to intimidate or coerce a civilizarion, influence the policy of a government by
intimidation or coercion or affect the conduct of 3 government by mass cle~.e"::.Clion,
ussassinarion. kidnapping or hostage taking. To the contrary, Aaron and Mr. Nor supplied
o· - ~ - -
humanitarian relief by providing a service that enabled U.S. immigrants to supply money to their
impoverished family members back in Africa Support for the claim that Aaron and Mr. Nor
provided humanitarian services and not support for terrorists is found in statements recently
made by other S01l13.ii immigrants. For example,
leader has instructed local Somalis to contact federal authorities if they know of anyone
collecting. money for terrorists or planning terrorist activities. See,Minneapolis Star Tribune,
October 14, 200 I at http://www.stJrtribune.com/stones/ 1576;813 722.hlml.
continued stating "[iJt's bad for our community. If we find that somebody is doing that in our
community, we won't hide them." Id. Notwithstanding
ornments, he supports
Aaron's and NfL Nor's requests for the unblocking of the frozen funds.
A Somali man employed by the Somali Justice Center also commented that "[tlhis is a
matter of li(e and death [0 the Somali community." ld. T:1C man continued staling "what
happened to us [011 ~Io'vl'mbt:r 7. 200 I] is beyond comprehension," Id. Another Somali woman
commented: "[w]« are the foundation of our people. the spinal cord. Without us, our families
wil! die. But [ wonder. does America care?" See, Somalis ill the C.S. wony about closed wire-
iransicr offices. \llnl1':Jpo([S Star Tribune. p .. \ (.~. :-10\'. I I), 200 t.
AUSA John Marti
who may be reached at
Consideration of the above bets indicates that the funds should be unblocked. The
primary beneficiaries of the funds are innocent, starving people who rely very heavily on the
funds for their survival. There is no connection between Aaron, Mr. Nor or the beneficiaries and
terrorism. The underlying transactions are legal, proper and needed by the Somali-American
community that relics on the transactions to assist their needy families back in Africa. There is
no evidence to support a claim that Aaron and Mr. Nor were appropriately determined to be
supporting terrorists. Therefore, the funds should be unblocked so that Aaron, YU. Nor, Arnal
and Aaron's customers can use the funds that unquestionably belong to them.
B. .-\L TER0iATIVEL v, A..:\.RON Ai""JD ~rlR. NOR SH01JLD RECEI,/E LICENSES TO ALLO\V THE~ v ! TO SATISFY THEIR LEGAL OBLIGATIONS.
For [he reasons set tanh above, Auton and :'v1L Nor alrematively request licenses that will
uilo« rhcrn to pay their salaries. rent. uriiiry bills :UlJ other operating expenses, 3S wcl] as [0
teen Q & R - 013222
.unounts thereof.
C. AARON'S A:'{D :VlR NOR'S NAMES SHOULD BE REMOVED FRO!'.·l APPENDJX A, ALL VERSIONS Of OFACS SPECr.-\LLY DESIGNATED N,ATIONALS .\.ND !3LOCKED P.EH.SC),\:S {"SD~,") UST .-\.'';]} OF-\C'S BROCHURE, ON TERRORIS[VI.
a. There is no basis for the deterrnin ation.
According to the Blocking Notices, [he Department of Treasury has identified Aaron and
Mr. Nor as entities or individuals that "provide]d] financial support or other services to persons
who C0l111l11 t, threute 11 to com 111 i [ Of support terrori srn (S pee i a Il y Des i gnaied Aaron Terrorist
("SDGT")). The Order lists SlRO as a SDGT. The Blocking Notices, however, provide no
evidence in support of such allegations. Thus, Aaron, Slk.O and Mr. Nor seek to have their
names removed ['rOIL Appendix A to Title 31 eFR Chapter V, all versions of OFAC's Specially
Designated Nationals ami Blocked Persons ("SDN") list and OFAC's brochure on terrorism.
Nei ther Aaron no r Mr. Nor have any known COl1t1CC t ions to terrorism, tho se corn 111 iuiug
terrorist acts, those threatening to commit terrorist acts, nor those supporting terrorism. To the
contrary, Aaron is a company dedicated to providing a much needed and very valuable service [0
the Somali immigrant community In Minneupnlisv Minnesota. Rather than providing financial
support to terrorists, Aaron pro v ides f nanci ul services to honest wo rki ng peep Ie that live in
Minnesota. yet have family members back in Africa. Some of these people work two or three
jobs so that they em cam enough money to support themselves and their C .. \l1111\(;s here 111 the
U .. S., plus send money back to family members in Africa. For a very modest icc, Aaron provides
:l medium that allows these immigrants to send a portion of their earnings back to family
All redactions on this page made pursuant to exemptions (b)(6) & (b)(7)(C)
'!cilher .vlr. :\or or
that turns our to be lht: case . Aaron will readily sever all business relationships it has with Amal.
Likewise, AJTOn and Mr. Nor are not aware of any connections between those designated 10
receive the money sent by Aaron's customers and any terrorists, political organizations, warlords
or others with terrorist affiliations. Indeed, according to Mr. Nor, "[tlhe whole idea is we help
Somali people." See Minneapolis Star Tribune, Money-transfer businesses answer a need,
owners say, Nov. IS, 2000, at http://www.startribune.com/stories/484!5300J.htmL Mr. Nor
continued stating "[i]f we get the government [operating], then we have a solution and we won't
need- the wire services. The money goes to individuals. Not tribes. Not factions, Not
warlords." Id.
ill the Somali community, trust is at a premium when it comes to establishing business
relationships. Aaron's customers do business with the company because of the reputation of
trust that Aaron and [vl.r. Nor have earned with Aaron's customers, Aaron and Mr. Nor, like any
other business or businessman, earned such a reputation by delivering the services that they
promised their customers. That service is simply getting the money quickly, as they promised
[hey would, to the starving, impoverished and dying people in Africa that rely on (he money for
their very survival.
Although the Order prohibits !~~nitcd Statts persons rrorn making humanitarian donations
[0 persons determined to be subject :0 the Order, it does not prohibit United States persons from
pnJ\'lJing humuniturian relief ro others. parricularlv those in desperate need of the assistance in
LeeR Q & R - 013224
th.u are giving/donating money 10 others, including i~lmily members in :30111:1Iia. Ethiopia and
KC:I1\a. \Ioney Sent bv .'\;lfon's customers is used tu meet basic needs Cor iced, clothing and
sheller. Providing such ui1(Hlcial assistance to the people M Somalia is not only proper and legal,
but also consistent \\ ith the financial support being provided to the people or Somalia by the
international community and urgently needed by the recipients.
The United Nations
Consolidated Inter-Agency Appeal for Somalia 2002 provides, in part, as follows:
As the world "aces the prospect of fundamental global political and economic change, the future of marginalized societies like Somalia is increasingly important, Beset by hunger, disease and disarray, Somalia is slowly reconstructing its place within the international community.
Facing some o f [he most appalling living conditions in the world - where 45 women die every day in labor and one in four children do not reach the age of tive - Somalia is still reliant on international assistance to provide basic life saving support and protection of livelihoods.
See United Nations Consolidated Inter-Agency Appeal for Somalia 2002. U.N. Office for the
Coordination of Humanitarian Affairs, at 1. in light of the U.N.'s findings, it is committed to
raising $83,683,971 in U.S. funds during 2002 to focus primarily on humanitarian actions to
address the pending crisis in Somalia. Id. The funds blocked in Aaron's and tvIr. Nor's accounts
are also targeted to address the needs of the families in Somalia. Since the funds blocked in
Aaron's and Mr. Nor's accounts CU'C akin to the funds being provided to the people of Sornalia by
the Lr~ and [he international cornmunny, there is no basis for determining that Aaron or Mr.
Nor are invoked in providing financial support :0 terrorist.
teen Q & R - 013225
h. ..\:11'0 [] is \\ ill ill g to n:()rgan IZt;.
i!1ll11igLU11 ccmmunity located in vlinneapolis, -varon wishes to continue providing such services
to its customers. .'\:LfOIl, however. is mindful iha: it may need to reorganize its company to
accomplish [hat goal and it is willing to conduct such 3. reorganization. A blocked person may
jJ repose rcrnedi al steps 011 the person's part, such 85 corporate reo rganization vhich 1'''-': 0(:T5011
believes would negate the basis for the designation. See 31 CF.R 501807(a) Since Aaron and
Mr. Nor have no connections to terrorists and the government has not provided any information
to show why it has placed such designations on Aaron and Mr. Nor, they are left to speculate
why the government has made the determinations. President Bush has been quoted accusing
such services of "skirnlming] from every transaction to benefit terrorists. See David Stout, (.[.S.
Acts [0 Freeze Assets of Terror Groups, The New York Times, November 7, 2001, at
htlp:!/www.newyourti111eS.comJ200 Iii 11/07/national/07CND-PREX.htmJ? Notwithstanding the
President's accusations, however, United States Treasury Department Secretary Paul O'Neill has
acknowledged that "[ w]e have lOO,OOO Somali's in the United States and it is not an unusual
practice of foreign born people residing in the United States ... to send money back to their
families who are living in very impoverished circumstances to help them out." Sec, Fed Raids
Expose Somali Wire Transfer, Minneapolis Star Tribune, Nov. 7, lOOi, at http.z/www.
startribune.comhtoriesI709/812997.html. Moreover, O'Neill has said [hat unless such services
are listed as a terrorist organization. "peop le sho uid assume that they're 0 K." See Government
(0 look into other !'/IOllev transferfirms, Minneapolis Star Tribune. Nov. 9, 2001. at http.i.www.
startri bune. com/stori e.s. 484:3 16-:-99. htrnl.
tees Q & R" 013226
suspender! \LS opertu ~011S m Somali. In addition, ·-Western union charges about three Limes as much as the.rcent fee the Somalia-run services typically charge to wire :s 100 from Minnesota to Africa", according to Thus, Aaron proposes reorganizing its company so that it can still provide valuable services to its customers, yet avoid any accusations that third parities that it may deal with are diverting funds to support terrorist operations.
D. OTHER LEGAL rSSUES PRESERVED
In the event that this matter is litigated in a court of law, Aaron and Mr. Nor reserve all
other legal issues inc.udirig, but not limited to, the following:
I. That the Blocking Notices and seizures-violate Aaron's and Mr. Nor's due
process rights;
2. That the seizures violate the Fourth Amendment;
3. That the seizures were broader than necessary and were not authorized by law;
4. That Mr. Nor's equal protection rights have been via lated; and
5. That the seizure of personal property, computers and records; the closure of Aura n' s bus iness; anc tile excl usion of Aaron from its leased premises are unauthorized by law.
:'! .. aron and lVfJ'_ Nor respectfully request that OFAC rirst provide access to Aaron's and vlr. Nor' s records (both paper and e lectrcnicj, so that _ \J.fO n ~H1d :'vI r. ;\;01' can provide. an
.iccuurning of the specific iJ5eS lor the funds ;11 rhe blocked accounts. Aaron and \ .. lr. \or [hen
All redactions on this page made pursuant to exemptions (b )(6) & (b )(7)(C)
Dated: December 11 200 l
ney Wire Service, ,
tees Q & R" 013228
1 .5 .:J F. R i v e r s ; dE: T\.~·l·e :11.,lf~ r ~Yl i:1!lE a.r_:;c.l is, ~.\:. ':"'..:Lf.: s :._-:tc_
':'eu. a z e hereby rro t a f i e d that: pursuant to 2x~cut:i.'1e Order No. 13224 (66PR49079), i38U",d by Pre,sident Bu s h on September 23, 2001 (the "Order"), and under the authorities granted by the
r n ce z-na t i one l Emergency Economic Powers Act, 50 u,s.C, §§ 1701- 06 ("IEE!?A" I, the of f i ce of Foreign Assets Cc n t.z c I ("OFJI..C"),
U. S. Department of the Tr-eas1..'.ry, has determined that Aaron [,<lo[',ey I'li:::e f;le:r:vice ("AL\1WS") is an entity that provides financial auppo r t or other services to pe r sone who commit, thn"1atGn to commit or support terro=ism (Specially Designated Global Terrorist ("SDGT")) .
This notice is also to inform you that pursuant to the Order,
all r e a L arid :;:ersonal property of p.J"TI'lS; including but rio c limited to all offices, furnishings, equipment and vehicles, ~,,, 'tJell as all funds and accounts in wh i ch AMWS has any interest, a;::-e blocked, All assets of JI._r'''lWS, including but not limit_ec t.o bank, charge and investment accounts, securities, and safe deposit boxes at any financial 'institution located in ~hE United States or organized under the laws of the United States, including their overseas branches, are blocked. Blocked property may not be transferred, withdrawn, exported, paid, or otherwise dealt in without prior authorizatiori from OFAC.
All transactions involving property in which JI.MWS has any interest, including any prcperty of third parties in the' possession or centrol of AMNS, are ~rohibited without sper.ific authoriZation from OFAC. As a conseque~ce of this action, activities in, use af, and occupation of AJI1NS offices, Lric Lud i nq chi s f ac i 1 i t y and each Ai'1WS office subj ect t c Un i t ~d St ates ~urisdiccicn, aye hereby prohibited, All perscns on these pr:2mises are:iirected to t ermrna c e all acc i v i t i.e s f o r '-:1:" en ·oeh.~~lf of A1J!~~iSf and c c Le av e t he pr erni s ea . No rrcper:':l may ;:>.~ ~emcved £~G~ che premises a~her than ~ro~er~y ttat is ~12arif
t~::_~: f:~!.-~cDa::' s:r·:;pe~::'1 of: the: ir:di~tidua2. l:"r::<.~L:e8ti:1~ cc :-~mC-F'::
:;~ .. ~cl-_ prope!:'"~:'_/ f z crn tl-.:.'2 9:rerrl.~ __ 8es. ?ersc·ns :,vh:::; ,:J."_::-e ··J.r~ab~'2 r c
~~mcve ~~e:r ;erscnal bel~nging8 ac C~i3 ~i~e ~usc ~c~=acc :~ar
'I l. --
All redactions on this page made pursuant to exemptions (b)(6) & (b)(7)(C)
Lacters may be sent via facs~m~le Co
:657, R~q~~sts Ec= speci£lc l~censes Eor ~a!menc cf cu~stan~!n~ £.in.:=.tu:.:;tal cb I i q a t l c r;s O','/EO 'c-/ F·J-·H~S~ such as s e La r y , :(en':. I~nd
'-.1 c. i J .1 t.~; p2 .. ~_./"il1e r; .. t; S I a iT~C~9 c t ~~:-8 f G"1US:: a L S () Lie {'i~ace i.c. ::i r ; r. i. :-:_<.:; ~ :,-_,
che ::tbo";e arid re a s .
Willful violations of IEEPA and of licensee and ord.rs issued thereunder, i::~cluding this Blocking Notice, are pu n Ls hab Le by criminal penalties ranging up to 10 years in prison and/or fines up to $500,00(1 for corporations and up to $250,000 fQr individuals. Civil penalties of up to $11,000 per count may be imposed by OFAC.
Should you wi8h to seek a license to engage in ~ny transaction involving blocked property, please refer to the licensing procedures. set: forth in §§ 501.801-802 of the Reporting and I?rocedures Requlations, 31 C.F.R. Part 501, (the "R~porting Regulations") .
I::- it is b~liwred that this de.signa'tion a.::_l an SDGT is in e r ro r and .i:i.iVIWS 'dishes to challenge it, a ler:ter should be sen .. 1:,0 the' attention Qf the Director at the address indica.ted above. Foc further information, please refer to § 501.807 of the Reperting Regulations.
IE you have aay questions concerning this notification, please contact OF.l:\.C Chief of Enforcement Hal Harmon at (202) 622 -24,30.
Ct'.l\'2 E.nfor-:ement Off i.c e r day cE. Novembe:::, 201}1..
;,_' 1'''.,/
~ .. ;
. ~
.~ ~c
.. ~
-, =:"
, ~ .. "l
OEPARTMEi'H OF TH E TR E,",SURY WASH INGTON. D.C :~0220
l(b)(6) & (b)(7)(C) I
Dear ['·ir. J a ma :
This letter is ro inform you that pursuant to Ex~cutive Or~c~
N c _ 1 J 2 2 .oJ (6 6 ;: F~ t! 90 7 9), i 5 ~3U e d by Pre s id ell t Bus h 0 (! S e pte rub 09 r 2 3 I 2001 (the "Order") I and under the a~thori:ies granted by [he
I n t e.r na t i oria I Eme r q en c y Econcmic Powers Ac t , 50 U. S . c, §§ 1701- 06 ("IEE?A"), '[he OfEice of foreign As s e t s Control ("OFAC"), U.S. Departmen: of the Treasury, added your name to the list of persons who commit, threaten to comrni t , or support terrorism
(Specially Designated Global Terrorist ("SDGT")).
You are hereby advised that any and all property in which you have an interest, direct or indirect, that are in the United States O~ that hereafter come within the United States, or that hereafter come within the possession or control of United States persons, are blocked. The term property includes, but is not
1 imi ted to, money, b a n k accounts (c h e ck i nq and savings), charge accounts, investment accounts, securities, safe deposit boxes, real estate and real estate mortgages, deeds of trust, debts, loans, insura~ce policies and ~ontracts of any nature whatsoever. Blocked property may not be transferred, withdrawn, exported, paid, or otherwise dealt in without prior authorization from OFAC.
Any unlicensed transaction or dealing by Unit.ed States person:::: or within the United States in property or interests in property in wn i ch you have an interest is a violation of the Order ar9d IEEPP._. Willful violations of IEEPA and orders or licenses issued thereunder, including this Notice of Blocking, are punishable by criminal penalties of up to ten years imprisonment and/or $250,000 per caunt for individuals, includ~ng corporate officers, ci.i re o t.o.r s , and agents who knowingly participate in a corporate violation, and up to $500,000 per count for organizations, SO U.S.C. § 1705{b); 18 U.S,C, § 3571; Regulations § 595.701 Civil penalties of up to $11,000 per count may ce imposed by OFAC_
___ ,_~ ... o;,:;:-r·"'·.·."-"'II
2~0C6d~~25 sec ~~~~~ ~~ §§ SJl.30:-282 cf c~e Repc~~i~S d~d ;.:J.co(:E:c3.L:res ;:;,egu2.C':.:'~lOl'S, 21. C.~~',R ?a'ct, =:;:01., '\::l~~e "2epcc:Ll1S Regu~.a."clCJnsll _: .
Shculd JOU believe :.hac chis desig113Cicn as an SGGT is l~ e:rcr 3:1.d you ',115[--. t<J ch2,_I_]_enge i.t; I you may contact cr-,E: U. S. Department of the TreC':.sury, Office of Foreign Assets Conc~ol, Actn: Director. 1500 Pennsylvania AvenuE, NW, Washin9~on, 2.C. 20220. For further information, please refer to § 501.8C·· of the Reporting RegulC':.tions.
If you have any questions concerning this notification, please corit ac r OFl·~C Chief of Enforcement Hal Harmon at (202) 622~2·'lJO.
!Q~er1YI, J I/U,:dt-ti!;JJia~'">J
iR. Richard Newcomb Director
Office of Foreign Assets Control
All redactions on this page made pursuant to exemptions (b)(6) & (b)(7)(C) unless otherwise indicated
VIAFACSINIlLE (612) 347-7077 A..'ID FIRST- CLASS MAIL
Fredriksen & Byron, 900 Second Avenue South, Suite 1100
Minneapolis, M:N" 55402-3397
Re: FACNo.
Dear Sir or Madam:
As you know, Aaran Money Wire Service, Inc. C'Aaran") was designated as a Special.ly DesignatedGlobal Terrorist ("SDGT') by the Secretary of the Treasury on November 7,2001. This made Aaran subject to the blocking provisions set forth in Executive Order 13224 of September 23, 2001 (''Blocking Property and Prohibiting Transactions with Persons Who Commit, Threaten to Commit, Or Support Terrorism") based on its affiliation with the Barakaat network. Addition3ny, you should be aware that Aaran also ~ been placed by the Security Council committee established pursuant to UN Security C,outtfllResolution ("UNSCR") 1267 on the consolidated list of individuals and entities designated pursuant to UNSCRs 1267 and 1390. UN member states are required to freeze the financial assets and economic resources of individuals and entities so listed.
The United States bas reason to believe that the Barakaat network was utilized to funnel money: to support terrorist activities. TIle designation of November 7, 2001, is not based on a showing that Aaran was directly engaged in acts of terrorism. For that reason, we understand that it may be appropriate in certain circumstances to return blocked funds and to remove persons from the list of designated individuals and entities. Specifically, we believe such action may be appropriate when there is no evidence of witting participation in the support for terrorist activities and the designated individual or person severs all affiliations or other associations "With networks or 'persons supporting terrorism.
As the Director of the Treasury Department's Office of Foreign Assets Control
("OF AC"), I write this letter to set forth. a procedure by which Aaran can seek to have its name removed from the list of entities and individuals subject to the blocking requirements of Executive Order 13224 ("SDGT Jist") and to have its assets returned. The process Is
designed to assist Aaran in demonstrating that it has severed all ties with the Barakaat ,I /
network of companies and any other entity or individual designated under the Executivi' / ; / Order. Toward that end, a certification to attest to these facts is attached, as well as a
current copy of the SDGT list. I '
1 Updated versions of the SDGT list are maintained as part ofOFAC's Web site at http:
IIwww.treas.gov/offices/enforcement /ofac/terrorism.html. .
All redactions on this page made pursuant to exemptions (b)(6) & (b)(7)(C)
We have also prepared a set of questions and requests for information, the responses to which 'Will further assist: Aaran in demonstrating actions it has undertaken to disassociate itseIffrom the Barakaat network of companies. These questions and requests for information are found below. Please provide any response in the form. of a signed original statement, submitted with any documentation in support of the answers given. In order to avoid delay, original statements and documents prepared in a language ather than English should be accompanied by English translations.
1. Association with Barakaat :Network. Please describe in full the nature of any association or affiliation Aaran had with the Barakaat network, including but not limited to the following:
, j
. j.
q. . AI Baraka Exchange LLC Al Barakaat
Al Barakaat Bank Al-Barakat Bank of Somalia
Al-Barakaat Group oj Companies Somalia Ltd. Al-Barakaat Global Telecommunications Baraka Trading Co.
Barakaat Construction Company
Barakat Red Sea Telecommunications Co. Barakaat Telecommunications Company Ltd. Barako Trading Co. UC i. i !.
Parka Trading Company \
Please also describe the nature of any association or affiliation Aaran bad with any other entities or individuals on the SDGT list. If any association or affiliation was the subject of a written contract, a copy should be provided. Please include in the description a list of any outstanding obligations that Aaran owes to any entity or individual on the SDGT list. Please provide any documentation that demonstrates the severing of any such associations or affiliations between Aaran arid the Barakaat network of companies, including but not limited to the list of entities and individuals listed above at 1 a-q.. . . -
2. Shared Accounts and Asset~i. Please describe in full the nature of any type of shared accounts, property or other assets that Aaran held with the Barakat network, including but / / not limited to the entities and individuals listed above in Ia-q, or that Aaran held with,· Yj / ! individuals or entities acting for or on behalf of such entities and individuals.
Please describe the full nature and extent of any shares or other forms of ownership that
Aaran owned in the Barakaat network, to include but not limited to the entities listed above. Please explain the circumstances under which any such ownership stake occurred and the nature of any transfers of stock out of Aaran's name. Please identify to whom this stock or ownership interest was transferred.
3. Bank: Accounts and Assets. Please provide copies of any bank: statements held in Aaran's name issued between January 1,2001, and the present.
4, rfu.position of Blocked Fuo.d§. Describe in detail how Aaran "Will dispose of any blocked funds returned to it. If Aaran proposes to transmit these blocked funds or any funds overseas; please describe in detail to whom the funds would be transmitted, the location to where such funds would be sent, and 'the purpose of the transmittal, It is prohibited to directly or indirectly transfer or otherwise deal in funds in which an entity or individual on the SDOT list has an interest.
5. Voluntary Inspection. If Aaran were to be removed from the SOGT list, would it consent to periodic voluntary inspections of its business records by OF AC?
, 1- , ,
, .
6, Additional rDform.arion. Provide any additional information Aaran deems appropriate which could assist the Treasury Department in assessing Aaran's past or present relationship with the Barakaat network,
, t I
Please note that we may pose additional questions and mate documentary requests as we proceed through this process.
Please feel free to call Stevenson Munro, Deputy Chief Counsel (Foreign Assets Control), at (202) 622-2410' should you have any questions.
. . .
. ~ ;; J041 J¥ihJJ~
(] FIr ltv. k R ... Richard Newcomb (J
V"'-" _. ~ 7) _. Director
.. Office of Foreign Assets Control '
Cc: _'epartment of Justice, Fed~ivision
All redactions on this page made pursuant to exemptions (b)(6) & (b)(7)(C)
L declare' that r am the duly appointed representative of Aaran Money
WIfe Service, Inc. and am authorized to makethis certification on its behalf I further declare that to my knowledge said entity has ceased and terminated any and all associations, direct or indirect, that existed between itself and the Barakaat network, including but not limited to the following:
a IU Baraka Exchange LLC
b. .Al Barakaat
c. A.1 Barakaat Bank
d. Al-Barakat Bank of Somalia
e. Al-Barakaat Group of Companies Somalia Ltd.
f Al-Barakaat Global Telecommunications
g. Baraka Trading Co.
b. Barakaat Construction Company
1. Barakat Red Sea Telecommunications Co.
j. Barakaat Telecommunications Company Ltd.
k. Banko Trading Co. LLC.
1. Parka Trading Company
, . -,
n. o. p. 'q.
Neither Aaran Money Wrre Service, Inc. nor any enterprise owned or controlled by it shall engage in any activities for or on behalf of or Under the direction or control of entities or' • • . individuals designated as Specially Designated Global Terrorist Entities ("SDGTs") in or pursuant to Executive Order 13224, September 23, 2001, or for or on behalf of any business, agent or representative acting for or on behalf of any such designated entities or individuals.
Aaran Money Wife Service, Inc. will.not knowingly acquire or accept any contracts, investments, joint ventures, employment, or any other form of business arrangement from or on behalf of any entity or individual designated as an.SDGT in or pursuant to Executive Order 13224. If Aaran Money WIre Service, Inc. receives knowledge afany such involvement, it will
take immediate Steps to terminate the relationship. .
I declare under penalty of perjury that the foregoing is true and ton-ea.
_________________ [Printed Name and Title)
_______ ----------- [Signature]
Executed on __ ----,. [Date] at [location]
LCCR Q & R w 013236
All redactions on this page made pursuant to exemptions (b )(6) & (b )(7)(C) unless otherwise indicated
I <I.blllit.l-n
\\,""hil12(t1ll1, DC :If)'iku"r:
llllll Inral1.HHH1.d Centre
'lOU S~(,,"d ,-\'-,,11\,( Smith ;"lil1lle.II"':;'. \10: 5Q02-.i3'J7 (612) 3-17-7000
Ilttomeys lind Advisors
\ \'.lr,.l\\, .\l"ntn.:.t1 '1~)ron[(1
\ '~\nlLlHln:r
June 4,20022
VIA FACSli\,1I LE AND U.S. MAIL
R. Richard Newcomb, Director U.S. Department 0 f Treasury Office of Foreign Assets Control
1500 Pennsylvania Avenue NW (Annex) Washington, DC 20220
Aaran M FAe Nos.
tad Nor
l(b)(2) I
Dear Mr. Newcomb:
On behalf of our clients, Aaron Money Wire Service, Inc. and Garad Nor, lam enclosing
a response to your letter dated May 21, 2002.
Enclosed are the following documents:
I. Statement of Aaran Money Wire Service, Inc. dated May 29, 2002;
2. Statement of Garad Nor dated May 29, 2002;
3. Certificate in the form submitted with your May 2 I correspondence, executed by Gamel Nor; and
4. Certi fication enclosed with your May 21 correspondence, executed by Aaran Money Wire Service, Inc,
w/Enc L) w/Encl.)
lease let us know immediately ifOFAC the Jist of designated
We trust [hat this is responsi ve [0 your is willing to release the blocked funds and indi viduals and enti Lies.
teen Q & R - 013237
Aaran Money Wire Service, Inc. ("Aaran"), by and through its undersigned owner, Garad Nor, hereby responds to the questions set forth in correspondence from K Richard Newcomb dated May 21, 2002. The numeric references below correspond to the numbered questions in Mr. Newcomb's letter.
1. Aaran has never had any association or affiliation with the Barakaat network, nor with any of the entities or individuals on the SDGT list As we previously advised, Aaran used the facilities of . Arnal Express to transfer money. See the application filed by Aaran with the Office of Foreign Assets Control on or about December 14, 2001, which is incorporated herein by reference. Although Aaran has not knowingly associated with any of the entities or individuals on the SDGT list, we are nevertheless providing the certification you requested.
2. Aaran does not have any accounts, property or other assets held with the Barakaat network, including the names set forth in paragraph 1 a-q of your letter, nor does Aaran have any ownership interest in the Barakaat network.
3. We are enclosing copies of bank statements obtained in response to your request.
The only accounts are those identified in the application to OF AC referenced above. The records for these accounts were seized pursuant to the blocking notices.
4. Aaran intends to return the blocked funds to its customers. In order to accomplish this, Aaran will need access to its documents and computer so that it can identify its customers and the amounts owed to each. Aaran would retain for itself those funds which belong to it. Aaran would also return to Arnal Express the funds which belong to it. These funds would be transferred to Al Amal Commercial Brokerage which is located in Dubai, U.A.E.
5. It is doubtful that Aaran would be in a position to resume business operations. In the event that it did resume operations as a money transfer business, it would agree 1:0 periodic voluntary inspections of its business records by OF AC.
6., Please refer to the application referenced previously for additional background on Aaran.
AARA.l\T MONEY WIRE SERVICE, INC.
Dated ') }lc) I 0 ·L ,2002
attachment !!265Si03\1
All redactions on this page made pursuant to exemptions (b)(6) & (b)(7)(C)
Garad Nor hereby responds to the questions set forth in correspondence from R. Richard Newcomb dated May 21, 2002. The numeric references below correspond to the numbered questions in ML Newcomb's tetter.
1. Neither NIL Nor nor his business, Aaran Money Wire Service, Inc., had any affiliation or association with the Barakaat network, including the entities and individuals identified in your letter. Mr. Nor has not had any employment or other association with any entities or individuals on the SDGT list. He has no outstanding obligations to any such entities or individuals.
Mr. Nor was emplo November 7 2001.
Mr. Nor cannot provide any documentation severing his employment andlor association with the Barakaat network of companies because he never had any such employment or association in the first place. Nevertheless, he is providing the certification on the form attached to your letter as a showing of good faith.
2. Mr. Nor has no such accounts and has no ownership in the Barakaat network.
3. Please see the response of Aaran Money Wire Service, Inc. This is the only account I have had in my name between January 1,2001 and the present
4. I have never traveled to Afghanistan but did travel to Somalia in August, 1999. I traveled to the Portland (phonetic) region in Northeastern Somalia. My purpose was to visit the Amal Express offices. r did not engage in any financia1 transactions not incident to my trip and personal maintenance.
5. Please see the application I filed with OFAC on or about December 14,2001 for more information.
By t_I_t.~_\~~~, __ /~_. _
Garad Nor
teen Q & R - 013239
MAl'-21-2002 20:29
202 522 9937 P.13/l.3
All redactions on this page made pursuant to exemptions (b )(6) & (b )(7)(C) unless otherwise indicated
I, b&!.'fJ .. &Q. .. J,j,:..r, declare that I am the duly appointed representative of Aaran Money Wire Service, Inc. and am authorized to make this certification on its behalf. I further declare that to my knowledge said entity has ceased and terminated any and all associations, direct or indirect, that existed between itself and the Barakaat network, including but not limited to the following:
a. A1 Baraka Exchange LLC
b. A1 Barakaat
c. Al Barakaat Bank
d. Al-Barakat Bank of Somalia
e. Al-Barakaat Group of'Compsnies Somalia Ltd.
f. Al-Barakaat Global Telecommunications
g. Baraka Trading CD.
h. Barakaat Construction Company
1. Barakat Red Sea Telecommunicatious Co.
j. . Barakaat Telecommunications Company Ltd.
k. Barako Trading Co. LLC.
I. Parka Trading Company
Ill. S', Internet
n. o.
?1 __ I ~y-
\ ,\e:f-e. r\€.\J!Z1 l!\J:\S ctl'1 'j S qL~'\. re. \(At ro I'\.$ ,p, .
,---- Neither Aaran Money Wire Service, Inc. nor any enterprise owned or controlled by it shall engage in any activities for or on behalf of or under the direction or control of entities orindividuals designated as Specially Designated Global Terrorist Entities ("SDGTs") in or pursuant to Executive Order 13224, September 23, 2001, or for or on behalf of any business, agent or representative acting for or on behalf of any such designated entities Of individuals.
p. q.
Aaran Money Wire Service, Inc. will not knowingly acquire or accept any contracts, investments, joint ventures, employment, or any other form of business arrangement from or on behalf of any entity or individual designated as an SDGT in Of pursuant to Executive Order 13224. If Aaran Money Wire Service, Inc. receives knowledge of any such involvement, it will take immediate steps to terminate the relationship.
I declare under penalty of perjury that the foregoing is true and correct.
_--O=~O=)={\..o..ll~_:l\t.::..,~-,---,-:"-,·<)"",,O'-Lf---:---,-"O,-\=j-'"-'-'·Vl,--e._r [printed Name and Title]
--?;~·-(~~.~~~-f--·)~/(_._' .. [Signature]
Executed on S {2.'SID1- [Date] at /1Irl·JJar.pAI),NI.j; [location]
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text:
This and That
By BeadedTail S on January 24, 2013
BlogHer Network
What do you get when you combine busy work days for Mommy plus our hogging the computer watching birdie videos? A little of this and that for today's post. We'll start with my starvation diet. I have lost .6 lbs in nearly two months so am down to 12.6 lbs but at least I'm maintaining my Tortieness. . . .
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subset: commoncrawl


text:
Family shares Indy 500 tradition that spans 104 years
At 99 races, they say their tradition is just beginning.
Sponsored by:
At 99 races, they say their tradition is just beginning.
Louise Burcope celebrated her 100th birthday in April and happy to ring in the 100th running of the Indianapolis 500 in the same year.
Janet Guthrie was the first woman to race in 1977.
For the third year in a row, the Indianapolis Motor Speedway offered glamping, which stands for glamorous camping.
Start race day with the team that is all local, all morning.
Some students now face the consequences and the possibility they won't be walking across the stage on graduation day.
Last summer was the first season ever for the new water park.
He sang Back Home Again in Indiana for more than 30 years and he talked to 24-Hour News 8 in an exclusive interview.
Thinking about it too much could work against the task at hand, winning a race and making history.
Amy Keever's husband set her on fire, then drove head-on into traffic on I-65, killing himself.
44 nurses were granted active nursing licenses because of a legal loophole in state law.
"It was terrible because I didn't have much already," Cox said.
Purchasing tickets are currently on a first-come-first- served basis. Tickets at some shuttle services have already sold out for the race.
The race is sold out and police are warning of online scams.


text:
Layton Police Station
1. Layton City Police Department
429 Wasatch DrLayton, UT 84041
From Business: The Layton Police Department resolves public safety concerns and safeguards civil rights. It maintains administration, patrol, compliance, investigations, police re…
2. City of Layton
437 Wasatch DrLayton, UT 84041
3. Kaysville Police Dept
58 E 100 NKaysville, UT 84037
From Business: The Kaysville Police Department works to provide law enforcement services to residents and safeguard civil rights. It has a communication and dispatch unit that han…
4. Utah Highway Patrol
255 S StateVernal, UT 84078
5. Roy City Police Dept
5051 S 1900 WRoy, UT 84067
From Business: The Roy City Police Department is a full-service law enforcement agency that prevents crime, preserves peace, maintains social order, and protects residents' lives …
6. Riverdale Police Dept
4580 Weber River DrOgden, UT 84405
From Business: The Riverdale City Police Department is a law enforcement agency that prevents crime, preserves peace and protects residents lives and property. It employs more tha…
7. Syracuse City Police Dept
1751 S 2000 WSyracuse, UT 84075
From Business: The Syracuse City Fire Department offers fire prevention and emergency medical services. It maintains a community emergency response team that provides citizens wit…
8. Clearfield Justice Court
55 S State StClearfield, UT 84015
9. Police Department
2209 W 1500 SSyracuse, UT 84075
10. West Point City Police Department
800 W State StFarmington, UT 84025
11. Utah State University Hrtcltrl
28 E State St Ste 200Farmington, UT 84025
12. Clinton City Hall
2267 N 1500 WClearfield, UT 84015
13. Roy Fire Dept
5051 S 1900 WRoy, UT 84067
From Business: Established in 1955, the Roy Fire Department offers a range of fire prevention and rescue services. It additionally provides fire suppression services. The fire dep…
14. Roy City Personnel Department
5051 S 1900 WRoy, UT 84067
15. Washington Terrace Water Maintenance
275 E 4425 SOgden, UT 84405
16. Highway Patrol
631 Lagoon DrFarmington, UT 84025
From Business: Utah Highway Patrol is responsible for general police traffic supervision and criminal law enforcement on the rural highways of Utah. It offers commercial vehicle e…
17. Police Station
2209 N 1500 WClearfield, UT 84015
From Business: The Clinton Police Department prevents, detects and investigates criminal activities, and maintains peace and order through the enforcement of local, state and fede…
18. Farmington Police Department
286 S 200 EFarmington, UT 84025
19. Sheriffs Office
50 S 1000 WOgden, UT 84404
20. Riverdale Police Dept
4580 Weber River DrOgden, UT 84405
21. West Bountiful City
550 N 800 WWest Bountiful, UT 84087
22. South Ogden Recreation Office
3950 Adams Ave # 1Ogden, UT 84403
From Business: The South Ogden Police Department is a law enforcement agency that works for the protection of residents lives and properties. The department provides criminal inve…
23. Washington Terrace City Office
5249 S Southpoint TerOgden, UT 84405
24. Police Dept-Detective Division
2186 Lincoln AveOgden, UT 84401
25. Ogden City Animal Svc
1490 Park BlvdOgden, UT 84401
26. Weber County Sheriffs Office
721 West 12th StreetOgden, UT 84401
27. Nusane
560 39th StOgden, UT 84403
28. Sheriff-Civil Office
457 26th StOgden, UT 84401
29. Huntsville Town
2380 Washington BlvdOgden, UT 84401
30. North Ogden City Court
515 E 2600 NOgden, UT 84414
From Business: The North Ogden Police Department is a full-service law enforcement agency that promotes public safety, identifies and solves criminal cases and safeguards citizens…