3. One of the principal goals of al Qaeda was to
drive the United States armed forces out of Saudi Arabia (and elsewhere on the
Saudi Arabian peninsula) and Somalia by violence. Members of al Qaeda issued
fatwahs (rulings on Islamic law) indicating that such attacks were both proper
4. Al Qaeda functioned both on its own and
through some of the terrorist organizations that operated under its umbrella,
including: Egyptian Islamic Jihad, which was led by Ayman al-Zawahiri, and at
times, the Islamic Group (also known as "el Gamaa Islamia" or simply
"Gamaa't"), and a number of jihad groups in other countries, including the
Sudan, Egypt, Saudi Arabia, Yemen, Somalia, Eritrea, Djibouti, Afghanistan,
Pakistan, Bosnia, Croatia, Albania, Algeria, Tunisia, Lebanon, the Philippines,
Tajikistan, Azerbaijan, and the Kashmiri region of India and the Chechnyan
region of Russia. Al Qaeda also maintained cells and personnel in a number of
countries to facilitate its activities, including in Kenya, Tanzania, the
United Kingdom, Germany, Canada, Malaysia, and the United States.
5. Al Qaeda had a command and control structure
which included a majlis al shura (or consultation council) which discussed and
approved major undertakings, including terrorist operations. Al Qaeda also had
a "military committee" which considered and approved "military" matters.
6. Usama Bin Laden and al Qaeda also forged
alliances with the National Islamic Front in the Sudan and with representatives
of the government of Iran, and its associated terrorist group Hizballah, for
the purpose of working together against their perceived common enemies in the
West, particularly the United States.
7. Since at least 1989, until the filing of this
Indictment, Usama Bin Laden and the terrorist group al Qaeda sponsored,
managed, and/or financially supported training camps in Afghanistan, which
camps were used to instruct members and associates of al Qaeda and its
affiliated terrorist groups in the use of firearms, explosives, chemical
weapons, and other weapons of mass destruction. In addition to providing
training in the use of various weapons, these camps were used to conduct
operational planning against United States targets around the world and
experiments in the use of chemical and biological weapons. These camps were
also used to train others in security and counterintelligence methods, such as
the use of codes and passwords, and to teach members and associates of al Qaeda
about traveling to perform operations. For example, al Qaeda instructed its
members and associates to dress in "Western" attire and to use other methods to
avoid detection by security officials. The group also taught its members and
associates to monitor media reporting of its operations to determine the
effectiveness of their terrorist activities.
8. Since in or about 1996, Usama Bin Laden and
others operated al Qaeda from their headquarters in Afghanistan. During this
time, Bin Laden and others forged close relations with the Taliban in
Afghanistan. To that end, Bin Laden informed other al Qaeda members and
associates outside Afghanistan of their support of, and alliance with, the
Taliban. Bin Laden also endorsed a declaration of jihad (holy war) issued by
the "Ulema Union of Afghanistan." ...
In furtherance of the conspiracy, and to effect
its objects, the defendant, and others known and unknown to the Grand Jury,
committed the following overt acts:
The Provision of Guesthouses and Training Camps
1. At various times from at least as early as
1989, Usama Bin Laden, and others known and unknown, provided training camps
and guesthouses in Afghanistan, including camps known as Khalden, Derunta,
Khost, Siddiq, and Jihad Wal, for the use of al Qaeda and its affiliated
2. At various times from at least as early as
1990, unindicted co-conspirators, known and unknown, provided military and
intelligence training in various areas, including Afghanistan, Pakistan, and
the Sudan, for the use of al Qaeda and its affiliated groups, including the
Egyptian Islamic Jihad.
Financial and Business Dealings
3. At various times from at least as early as
1989 until the date of the filing of this Indictment, Usama Bin Laden, and
others known and unknown, engaged in financial and business transactions on
behalf of al Qaeda, including, but not limited to: purchasing land for training
camps; purchasing warehouses for storage of items, including explosives;
purchasing communications and electronics equipment; transferring funds between
corporate accounts; and transporting currency and weapons to members of al
Qaeda and its associated terrorist organizations in various countries
throughout the world.
The Efforts to Obtain Nuclear Weapons and Their Components
4. At various times from at least as early as
1992, Usama Bin Laden, and others known and unknown, made efforts to obtain the
components of nuclear weapons.
The Fatwahs Against American Troops in Saudi Arabia and Yemen
5. At various times from in or about 1992 until
the date of the filing of this Indictment, Usama Bin Laden, working together
with members of the fatwah committee of al Qaeda, disseminated fatwahs to other
members and associates of al Qaeda that the United States forces stationed on
the Saudi Arabian peninsula, including both Saudi Arabia and Yemen, should be
The Fatwah Against American Troops in Somalia
6. At various times from in or about 1992 until
in or about 1993, Usama Bin Laden, working together with members of the fatwah
committee of al Qaeda, disseminated fatwahs to other members and associates of
al Qaeda that the United States forces stationed in the Horn of Africa,
including Somalia, should be attacked.
The Fatwah Regarding Deaths of Nonbelievers
7. On various occasions, an unindicted
co-conspirator advised other members of al Qaeda that it was Islamically proper
to engage in violent actions against "infidels" (nonbelievers), even if others
might be killed by such actions, because if the others were "innocent," they
would go to paradise, and if they were not "innocent," they deserved to die.
The August 1996 Declaration of War
8. On or about August 23, 1996, a Declaration of
Jihad indicating that it was from the Hindu Kush mountains in Afghanistan
entitled, "Message from Usamah Bin-Muhammad Bin-Laden to His Muslim Brothers in
the Whole World and Especially in the Arabian Peninsula: Declaration of Jihad
Against the Americans Occupying the Land of the Two Holy Mosques; Expel the
Heretics from the Arabian Peninsula" was disseminated.
The February 1998 Fatwah Against American Civilians
9. In February 1998, Usama Bin Laden endorsed a
fatwah under the banner of the "International Islamic Front for Jihad on the
Jews and Crusaders." This fatwah, published in the publication Al-Quds
al-'Arabi on February 23, 1998, stated that Muslims should kill Americans
-- including civilians -- anywhere in the world where they can be found.
10. In an address in or about 1998, Usama Bin
Laden cited American aggression against Islam and encouraged a jihad that would
eliminate the Americans from the Arabian Peninsula.
Bin Laden Endorses the Nuclear Bomb of Islam
11. On or about May 29, 1998, Usama Bin Laden
issued a statement entitled "The Nuclear Bomb of Islam," under the banner of
the "International Islamic Front for Fighting the Jews and the Crusaders," in
which he stated that "it is the duty of the Muslims to prepare as much force as
possible to terrorize the enemies of God."
Usama Bin Laden Issues Further Threats in June 1999
12. In or about June 1999, in an interview with
an Arabic-language television station, Usama Bin Laden issued a further threat
indicating that all American males should be killed.
Usama Bin Laden Calls for "Jihad" to Free Imprisoned Terrorists
13. In or about September 2000, in an interview
with an Arabic-language television station, Usama Bin Laden called for a
"jihad" to release the "brothers" in jail "everywhere."
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