WITHDRAWAL NOTICE
RG: 148
Box: 00001 Folder: 0003 Document: 10
Series: Team 4 Files
Copies: 1 Pages: 23
ACCESS RESTRICTED
The item identified below has been withdrawn from this file:
Folder Title: Trading Information Received
Document Date:
Document Type: FBI 302
Special Media
From:
To
Subject: FBI reports on markets and trading re: 9/11/2001
In the review of this file this item was removed because access to it is
restricted. Restrictions on records in the National Archives are stated in
general and specific record group restriction statements which are available
for examination
NND: 401
Withdrawn: 10-01-2008 by: Ww
RETRIEVAL #: 401 00001 0003 10
System DocID: 46938/14/2003
This time line will be limited to significant developments concerning the
U.S. and Foreign Financial Markets Team of she Financial Review Group, FBL
Headquarters, during the period trom September 17, 2001 until October 20, 2001
September 17, 2001:
1) USS. and Foreign Financial Markets Team of the Financial Review Group
was created by Section Chief Dennis Lormel of the Financial Crimes Section,
Crminal Division. The U.S. and Foreign Financial Markets Team mandate was to
investigate activities on the stock and commodities markets prior to and following
the terrorist attacks. The team was to determine if any of the hijackers, their
associates and/or affiliated terrorist groups had devised a scheme to profit from the
terronst attacks using U.S. or foreign stock or commodities markets . The team
‘was also to determine if anyone profiting from market trades as a result of the
terrorist attacks had a plausible explanation for their profit or if they were in a
position to have prior knowledge of the attacks and were trying to profit from ‘he
attacks.
Atall times, an underlying goal of the entire Financial Review Group was to
‘identify all associates of the 19 hijackers in order to develop additional evidence
and possibly prevent another terrorist attack. Subsequently, Section Chief Lormel
expanded our team duties to include the international investigation of financial
activities of the 19 hijackers and their associates. =
Initially, the U.S. and Foreign Financial Markets Team consisted of
Supervisory Special Agents 911 LawénforcementPrivacy William M.
Mackey and two Financial Analysts. Collectively, the team had over 50 years of
Investigative experience in complex financial investigations, Subsequently, the
tear complement was expanded with the addition of two Special Agent
accountants and two more Financial Analysts
AnnnnareeSeptember 18. 2001
1)9!"1 LavEnforcementSenstve
were provided with the
nd limited biographical data of the 9 hijackers. These sources were
requested 10 check data bases available to them for any positive or negat:ve
information. which might identity current or tormer brokerage accounts of the
yackers in the industry. No U.S, brokerage accounts were located for any of the
hijackers,
rumnes
2) Due to the extreme urgency of the investigation and the potential for
another terrorist attack, a decision was made to seek immediate help from experts
responsible for the security of the different markets to quickly determine if a
deliberate effort was made by anyone to profit from the terrorist attacks, [fso, the
experts would be in 2 position to identify the involved accounts and would have
the needed institutional knowledge to recognize suspicious activities.
September 19, 2001
1) Meetings were quickly arranged between FBI personnel and senior
personnel of the United States Securities and Exchange Commission (SEC); the
National Association of Securities Dealers (NASD) and the Commodity Futures
‘Tracing Commission (CFTC) to address investigative issues
2) Simalar requests for information were made to sensitive FBI Sources as
names and/or aliases of suspected associates of the hijackers were developed.
3) FBI sensitive sources were also provided with the “non-law
enforcement” version of the FBI “Watch List” containing several hundred names
and limited biographical information developed from investigative leatls. It is
noted this “Watch List” changed daily as some people were added while others
eared as the investigation continued. Again. the request of the sensitive
sources was the same, In several instances, the sensitive sources were able to
provide positive information concerning some of the names on the “Watch List”.
However, further investigation cleared those individuals ftom involvement in the
PENTTBOM investigation and those names were removed rom the “Watch
List”. The sensitive sources were periodically provided updated “non-law
enforcement” versions of the FBI “Watch List” to make necessary inquizies
new additions to the list
REO 5-13 0000001574) Myron Levin and Henry Weinstein of the Los Angeles Times, wrote en
article “Options Exchange Joins Trading Probe - Markers: Inquiry seeks evidence
of manipulation by people with advance knowledge of attacks”. ‘The article
reported the Chicago Board Options Exchange (CBOE) was investigating an
unusually high volume of sales of “put” options on stocks such as United Airlines
(UAL) and American Airlines (AMR Corp.) In the days before the attacks
September 20, 2001:
1) A meeting was arranged by Joseph J. Cella III, Chief of SEC's Office of
Market Surveiliance at SEC headquarters. The meeting was attended by senior
SEC staff membersiy— ---eementPriy Of the Washington Field Office of the FBI,
SSAS| MentorcementPrivacy anc Mackey representing the U.S. and Foreign
Financial Markets Team. The primary topic of the meeting was how someone
could profit from the terrorist attacks using the stock market. The different
industries affected by the attacks which included Airlines and Aerospace;
Insurance and Reinsurance; Financial Services; Banks; Defense; Index Products;
Cruise Lines and International Markets were discussed. The SEC and FBI
personnel developed a list of key securities in each industry which should be
examined . The group agreed that relevant press releases and market reports
impacting on securities in these areas should be reviewed for at least thirty days
prior to the attacks. These releases and reports might be a mitigating reason for an
unusual rise or fall in prices of individual securities. SEC personnel arranged for
reviews to be conducted of the NASDQ 100 Index and the S&P 500 Index;
‘Treasury securities and activities on the American Stock Exchange; New York
Stock Exchange; Philadelphia Stock Exchange; Chicago Board Options Exchange
and the Pacific Exchange. The SEC would use SEC contacts to identify accounts
which profited trom market activities as a result of the attacks and idengfy
suspic‘ous trades and account holders. Finally, the SEC offered to contact their
counterparts in Europe and the Far East with che same request.
2) SASH enamantDivary and Mackey met with Mr. Cam Funkhouser,
National Association of Securities Dealers (NASD) Vice President for Market
regulation, Mr. Funkhouser advised he had a copy of the watch list and his staff
had run all of the names through their Central Registration Depository (CRD)
looking tor any identical matches, Based on last name alone they found numerous
potential metches, however there were none thar matched name and date of birth.
address, sucia! security account number, or some other type of identifying dara.Mr, Funkhouser was asked to run the names 9/11 LawEinforcementSensitve
9/11 LawenforcementSensitive
O01 camerys, Mi Funkhouser agreed. He stated le would also complete an
ASUS! The NASD looking for any unusual activity, spikes, or appearances of
any significant profits in one of the industries affected by the atteck, either by
selling short, dumping stock before the attack, or purchasing any stock which has
gone up in value since the attack, 9/11 LewEnforcementSensitive
ent
LavEnforcementSensi
Mr. Funkhouser identifier’ one af the indivichats 198/11 Personal Privacy
9/11 Personal Privacy
3) ABC News Correspondent Antonio Mora ceported that an investigation
was underway to determine whether the terrorists made financial gains from the
stock marker, Details were given about a form of insider trading “betting” ona
stock drop in American Airlines, United Airlines and Morgan Stanley which
occupied a large number of dloors in the World Trade Center.
4) A tip was called in to FB{, Minneapolis, (approximate date - exact date
unknown) reporting short selling of American Airlines stock on hwo exchanges
The information was provided to the SEC to determine who placed the orders at
the particular exchanges and whether or not these orders apgear to Be consistent
with the buyers trading strategy.
September 21, 200
1) SSAsOTthavEnforcementPmvacyac4 Mackey et with Liz Hastings, Dan
Narhan, and Phyllis Cela, at the Commodities Funure Trading Commission
(CFTC), In preparation for our meeting, they checked with the 10 largest
brokerage houses in the country that handle commodities. The brokerage houses
ered include Gold and Silver, Currency, Stocks, Oil and Energy, and Interest
rates.
Each of the brokerage houses were provided with the FBI Watch List, %11Peso
911 1Personal 7 p ‘ ral Privacy
pee was identitied from she watch list as being a registered trader from
May 1992 uniil 1996 with a company named CIBC.
RRO 5-13 AnnanniEaThe CFTC also checked with their foreign counserparts including
9/1 1LawEnforcementSensitive
regarding te appearance of any unusual trading patterns which would have
ved ina large profit as a result of the attack on the World Trade Center.
‘None of the Foreign exchange markets have idenuitied sransactions resulting ina
profits due to a position taken prior to the attack.
Liz Hastings spoke to abi tawenlor® United States Secret Service (USSS),
New York, regarding a rumor that he was trying to track down thai there had been
a sizeable transaction in 5 Year Treasury notes between August 27 and September
4. 2001, Hastings advised she had not received any information regarding this
thom any of the exchanges but that she kad a conference call set up later that day
with the agent to get more details, She further advised that 842 indicated he
received the information from a bond trader who saw the crdnsaction as being
contrary to market mdicators.
‘The FED would be the prime source of inZormetion for any transactions
involving Interest Rates, Currency Markets, or Treastry notes
The brokerage houses would have any information regarding Over The
Counter (OTC) trades which could be expected in the areas of precious Metals,
Oil, and Bonds
Ms. Hastings said she would recontact the FBI, if warranted, after hearing
back from all of their foreign counterparts.
2) Joseph J. Cella Ml, Chief of SEC's Office of Market Surveillance
provided the FBI with the initial results of the review by the Enforcement
Division into trading in the financial markets prior to September 11,2001. This
review included activities on the American Stock Exchange; New York Stock
Exciange, Philadelphia Stock Exchange; Chicago Board Options Exchange and
the Pacitic Exchange. SEC personnel also contacted the National Association of
Securities Dealers. Mr. Cella noted the SEC was reviewing wading in the common
stock and derivative seeunties of the individual companies listed below by
industry category. He stated the SEC's initial focus was large transactions in the
options markets for the subject securities.
es and Aerospace
9/1 LawEnforcementSensitve9/1 1LawinforcementSensitive
2. Insurance
9/1 1LawEnforcementSensitive
3. Financial Services
9/1 1LawEnforcementSensitive
4. Banks
9/1 tLawEnforcementSensitiy
e5. Defense
911 1LawEnforcementSensitive
6. Security Providers
9/1 1LawEnforcementSensitive
7. Index Products
Mr. Cella noted the American Stock Exchange and the Chicago Board
Options Exchange tade numerous products based on various indices. He stated
the Exchanges’ surveillance staffs reviewed trading in these products and, so far,
did not see problematic trades in the vast majority of such products. Mr. Cella
noted the Oo most heavily traded products, the NASDAQ 100 Index and the S&P
300 Index, were still being reviewed.
8. Miscellaneous
9/1 1LawEnforcementSensitive
9. Other Areas of inquiry
Mr. Cella said the SEC had spoken with the Legal an¢ Compliance s
she major securittes ticms and requested that they survey che:r srading desks
ro determine if they noted any unusual activity prior to September !1. 200!, Aso.
he SEC nad contacted the Depository Trust Company, the National Securities
Clearing Corp. and Loanet to attempt to identity short positions and large sales: Tn ~
anannntK?addition, the SEC had spoken with the surveillance staff of the Federal Reserve
Bark in New York with respect to the market for treasury securities.
In rd to international markets, Mr. Celle advised the SEC had been in
contact with regulators in Europe and the Far East and requested that they review
wading in their markets. As of September 21, 2001, Mr. Cella noted the SEC
received responses from®11tawéntorcementSerstive
ades had yet been detected.
indicating no problemasic
The Chicago Board of Options Exchange advised Mr. Cella that they had
selected a series of stock index options for review. They reported to Mr. Cella that
their review found ro apparent unusual activity based or litle, if any, option
volume.
A review of both index options and Exchange Traded Funds on the
American Sto
Exchange showed no unusual activity.
3) Mr. Cella identitied 29 trading accounts at various brokerage firms
which had profited from stock and /or options trades either before the markets
ceased operations on September 11, 200 lor after the markets reopened on
September 17°, 2001, It is noted that while some of the short trades were arranged
as recently as September 10, 2001, arrangements for other trades dated back te
February 8, 2000. Mr. Cella noted that some of the 29 accounts were either hedge
fund or proprietary accounts which had been in existence for years. Other
accounts were being examined by SEC or Exchange personnel to dev@lop further
formation. Mr. Cella advised any accounts which appeared suspicious to SEC
personne! would be referred to the FBL
4) Mr. Cella referred ewo suspicious trades to the FBI for further FBI
tion, They are described as follows:
Trade #1: During the period from Seorember 6 :hrough 10, 2001,
shares of stock of “Stratesec” was purchased by two brokerage accounss owned by
9/1 1Personal Privacy
yen ga anannate?otPes a :
‘onal SEC advised “Stratesec” w
airport set
as identified as a company which provides
ty systems,
5) Subsequent FBI investigation reveaied that “Stratesee” is a provider of
secumty services for commercial and government facilities. The US. Army isa
major client of the company. “Stratesec” issued a total of 81,000 shares . 56,500
shares were purchased beoween September 6 ard LO, 2001 by 911Personal Privacy
9/1 1Personal Privacy
9 tPersonal Prvaey Eo llowing the terrorist attacks, the price per share of stock rose
om .75 per share to $1.49 per share (an increase in value of $41,810.00) on
September 17, 2001. As of October 12, 2001, the stock had not been sold and had
an unrealized profit of over $30,000.00.
investigation determined 911Personal Privacy
9/4 4Personal Privacy
which is a Washington, D.C. based investment firm. No negative information or
nes to terrorism was located concerning" tPersonal Privacy
SM1Personal Pavacy “Therefore, no further invest:gation was warranted.
6) Trade #2: On September 6, 2001,°" Personal Privacy
11 : :
Siren” sold short 2,090 shares of United Airlines stock. He also sold-short shares
of stock for British Telecom and Quest Communications
Subsequent FBI investigation revealed that®"!Persona! Privacy
9/1 1Personal Privacy
Br Pereral Yo nesanive information or tiesto terrorism was located conceming
and ao curther investigation was warranted.
pen 6.13 nannnni 6aington Post reported that Est Welteke, President of
Bundesbank, Germanys Central Bank. claimed there was mounting evidence that
people connected with the terrorist attacks in the United States profited from
icsider wading on European stock and commodities markets. Welteke claimed
their was massive short selling of airlines and insurance stocks and an inexplicabie
rise in world oil prices prior to the attacks
200
Septe
1) On September 2.
. 200, another meeting was held at the SEC
concerning the investigation of the markets. In addition t Mr. Cella, SSAs
EnforcementP?
OM awEnforcemenPNIEY anid Mackey, the meeting was attended by 1 1LawEnforcement
from the FBI; Assistant United
ates Attorneys Rob Khuzami (Souther District of New Yorks) and Ken Breen
(Eastern District of New York); and SEC personnel Charles Clark (Deputy
Assistant Director of Enforcement) , Bili Baker (Associate Director of
Enforcement) , Yuri Zel:nsky (Office of International Affairs) , Antonia Chion
(Assistant Director of Enforcement) and Elizabeth Jacobs. (Office of Intemational
Affairs) of the SEC. In this meeting, FBI and United States Attomeys Offices
personnel were provided with an overview of the initial results of the SEC
investigation as described on September 21
9/1 1LawEnforcementPrivacy
One of the issues discussed in the meeting related to press reports
conceming an unusually high volume of sales of “put” options on stocks such as
United Airlines (UAL), American Airlines (AMR Corp.) and other businesses
ich were directly affected by the terrorist attacks. SEC personnel identified
teen uisticutiona! accounts which purchased between 100 and 15,000 “put” or
as United Airlines, American Airlines, British
Airways, Marriot Corporation. Marsh MeLennan and AIG dur:
“call” options for
A stac
a period from
August 2+, 2001 to September 10, 2001, The institutional accounss included arg.
such as Dean Winter: Paine Webber
Morgan Stanley: Salomon Smith
QFn R72 nananntesan Brothers. Initial inquiries indicated thet options trading wes
: gy by large hedge funds. Many of the involved institutional
accounts were valued in the millions of dollars. SEC personnel agreed to conduct
the initial inquiries based upon their expertise and refer any suspicious activities to
the FBI for further investigation
2) Another issue discussed related to the September 22, 2001 report in The
Washington Post that Emst Welteke, President of Bundesbank, Germany's
Central Bank, claimed there was mounting evidence that people connected with
the tecrorist attacks in the United States profited from insider trading on Eusopear:
stock ard commodities markets, [n the article, Welteke claimed their was massive
short selling of airlines and insurance stocks and an inexplicable rise in world oil
prices prior to the attacks.
SEC personnel advised this information was completely opposite
information the SEC had been provided by European regulators and was not
reflected in market reports. SEC personnel also noted that the Bundesbank
issued a press release retracting many of the statements made by Welteke on
September 24, 2001, SEC personnel agreed to continue monitoring this issue
through their European contacts
3) _A wire transter of $20,000 USD was sent by Fedwire in the name
9/1 1PersonalPrivacy
BS News Correspondent Sheryl Akisson reported a similar story
about suspicious wades in the markers combining what was reaorted by other ni
neies with remarks of
mst Welteke. President of Bundesdank, Germany'sCentral Bar
September 27, 2001;
1) SSAGttaWEnt spoke :o FBI, Chicago, regarding the Chicago Board of
s trades. SSAg Maen learned that Chicago interviewed the Market maker
who placed several large orders for Puts in United Air Lines stock prior to the
attack, Four accounts were identified, one each at Deutch Bank, Goldman Sachs,
Lehman Brothers and Smith Bamey. Total profit estimated to be $1.5 to S1.6
mutlion, Note: The market Maker says that in his opinion, regardless of what the | Fax
regulators (SEC) say, he feels thete was an inordinate number of Puts in UAL
prior to the incident, SSA 9/7 @"E*" instructed Chicago to send a lead to New Yor
to contact each of the companies to identity the buyers ( one or numerous) ané,
resolve their reason or strategy for the trades,
Opi
2) Liz Hastings of the CFTC called SSAStilawent and advised that she
checked with Debbie Robinson at :he FED regarding any large purchases or sales
of treasuries in the amounts discussed. She advised that there had been nothing
significant in that area, She also checked with Goldman Sachs as they would
expect a hedge offsetting any purchase or sale that large... There also had been no
activity on either side of a trade of those proportions.
Liz Hastings also provided SSASIN 2" with background information
concerning" tPesonalPrivacy Tis information was reviewed by SSA®/!1LawEntfor
fe ¢9/11Persona . =. c
ible lead information regarding financial activity of pymer on" ter
S/PersonalPrivacy vas removed from the FBI
for 30:
sequent FSI investigation,
Watch List
September 29. 2001:
1) FBI invest
card accounts for the 19 hiyackers. As the accounts became available, account
records for each account were individually examined by $SAs0/1tLawEnfore
7 : ‘ementPrivacy
tion uncovered over forty bank accounts and over $0 ezedit9/1 1Lawnfore : : ,
ementPrivacy OF Mackey for any information which could lead to a brokerage
None was fourd
Qetober 1
1) The October 1, 200! edition of TIME Magazine contained an article
captioned “How bin Laden Funds His Network” by Adam Cohen. The article
repeated information from earlies press reports about suspicious trading activities
in the markets and interred that market speculation was a means for bin Laden to
finance his terrorist network
October 2, 2001:
AMR IBRAHIM ELGINDY
On October 2, 2001, AUSA Kenneth Breen, Eastem District of New York
(EDNY), met with SSAs fi" tevEntorcementPrvae ond Mackey concerning suspicious
‘activities, AUSA Breen saié AMR IBRAHIM ELGINDY, an Egyptian
ng in California, wes y the SEC and the NASD for stock
manipelation, Elgindy had previously been convicted of fraud and had a
reputation for "short sells" in the market. AUSA Breen leamed that on the
afternoon of September 10, 2001, Elgindy was attempting to quickly liquidate
brokerage accounts. Elgindy contacted his broker and said "I need to liquidate
nts, The marker is going t 3000”. On September 11, 2001,
E:gindy leamed the liquidation of the accounts had got been done. Aceording to
AUSA Breen, has a brother, 9/"1PersonalPrivacy
9/11PersonalPrivacy
cing investigate
my children’s accot
Breen heard the brother
either cid not show up for work on September L1, 2001, or left minutes before the
on the Pentagon. Finally, Breen learned chat Elyindy was scheduled to leave
ona ‘rip to E, t. Kosova and Macedonia on October 16, 2001. AUSA Breen
said New York FBI SSASMLawEntoree a4 EBT SA Jeff Royer in Gallup, New
mentPrivacy
Mexico, were tamiliar with Elgindy’s activitesSubsequent investigation revealed Elgindy, known as a professional marker
held merous stocks at
Solomon Smith Bamey, one for each of his children. Collectively, the accounts
¢ valued at about $300,0U0 but had cropped about five percent in vaiue in the
's month. On the aftemoon of September 10, 260!, Elgindy contacted his
broker and asked that the accounts be licuidated. He was told to send in a written
30pm,
short
¢ managed accounts cortaini
authorization for the liquidation. Tae Elgindy authorization arrived at
PST, 90 minutes after the deadline, Elgindy called the broker the next day and
learned the accounts had not been liquidated. During this call, Elgindy told the
broker that his brother 9/11PersonalPrivacy
9/1 1PersonalPrvacy
On May 17, 2002, Elgindy was indicted on charges of Racketeering in the
EDNY, with four other subjects (including former FBI SAs Jeff Royer and
LynnWingate). AUSA Breen appeared at a bail hearing for Elgindy and brought
¢ information to the Court's attention. When questioned by the Court,
AUSA Breen could not prove the information at that time. On 6/13/2003, a
superceding indictment was handed down by the EDNY. Trial is pending
‘the ab
October 3, 2001:
1) The Washington Post reported the SEC was investigating trading shares
of 38 companies including major airlines, cruise lines, General Motors and
Raytheon io determine whether people with advance knowledge of theSeptember
| terror attacks used it to profit som the stock and options trading.
October 4.2001:
1) Bloomberg News published an article captioned “Bank of America
Among tocks in SEC's Attack Probe". This article describes the investig:
ne SEC. FBL and T
Aannnas 6aOctober OL:
1) On October 5,2001, the CFTC learned from their liaison representative
at the Chicago Board of Trade (CBT) that an unusually large number of
"electronic" orders placed on September 10,2001 have surfaced at the CBT. The
CFIC advised these orders were placed using Internet trade accounts after the
CBT closed on September 10, 2001. An initial review indicates the orders appear
to de "individual" orders affecting specific commodities (not further identified) on
the CBT. The CFTC has requested a list of all electronic orders made after the
CBT closed on September 10,2001. They have also requested available brokerage
account information concerning each of these orders. CFTC will review the trades
and refer any suspicious accounts to the FBL
October 9, 2001: _
1) SSA Mackey prepared a summary report of the U.S. and International
Financial Markets investigation up to that date. The report stated:
"The following is a summary of the Markets/International Team's activities
concerning the investigation of activity on the United States and foreign financial
markets prior to the September |, 2001 terrorist attacks.”
US. Financial Markets
"We have requested the Securities and Exchange commission (SEC);
Commodities Futures Trading Commission (CFTC) and the National Association
of Securities Dealers (NASD) to review trading in the financial markets prior to
September 11, 2001. These agencies are looking for any abnormalities which
might identify individuals who may have had prior knowledge of the terrorist
ata to profit from the events, These agencies have been
requested by the FBI to conduct inquiries in their areas of expertise to identify yee
suspicious activity. All suspicious activity will be referred to the FBI for further | /9/ «/
; frogs
. Refer
ven ga79 anannnr749cunities and Exchange Commission (SEC
In the United States, the SEC focused on the following at all of the U.S.
Stock Exchanges:
A) 12 major stocks in the airline and aerospace industry;
B) 14 major stocks in the insurance industry;
C) 5 major stocks in the Financial Services industry;
D) stocks in 3 major banks;
B) stocks of 3 major defense contractors;
F) 9 stocks for major security providers;
G) stocks of 2 major cruise lines;
H) The NASDAQ 100 Index;
1) The S&P 500 Index;
J) other Index stocks on the American Stock Exchange and the Chicago Board of
Options Exchange. "
“In addition, the SEC has contacted the Legal and Cormpliance staffs of all
the major securities firms requesting they survey their major trading desks for any
unusual activity prior to September 11, 2001."
“The SEC has also made similar requests with the Federal Reserve Bank in
New York; the Depository Trust Company; The National Securities Clearing
Corporation and Loannet. "
"To date, the SEC has identified approximately thirty trades in affected
industry securities which resulted in profits. However, SEC interviews of market
personnel and others in the industry reflect many of the trades were usually made
by long standing customers who were making "hedge" trades as part of a market
strateg’
Airlines (AMR) stock for September 10, 2001. SEC determined from interviews
¢ trades were made by long-standing customers who. were all U.S. citizens
For example, SEC reviewed all of the "put" contracts on AmericanAtmost all of the buyers of these contracts refer to an article published in
newstetter September 9,200 | recommending that readers "go short" on AMR, due
+o it being downgraded by Goldman and Sachs the previous week."
"A few questionable trades are under investigation by the FBI with the
assistance of SEC investigators. ”
"Intemationally, the SEC has made similar requests with regulators in
Europe and the Far East, To date, the SEC has not received any information from
either European or Far East regulators icentitving any abnormalities in the sale of
sect s which affected industries identified by the SEC."
“On September 22, 2001, The Washington Post reported that Emst Welteke,
President of Bundesbank, Germany's Central Bank, claimed there was mounting
evidence that peuple connected to the terrorist attacks in the United States profited
trom insider trading on European stock and commodities markets. Welteke~
claigied their was massive short selling of airlines and insurance stocks and an
se in world oil [2rices before the attacks. The SEC advised this
opposite information which the SEC had been
inex |2licable rm
information was complete!
provided by European regulators and Welteke's claims were not reflected in
market reports. On September 24,2001, the SEC advised the Bundesbank issued a
many of the statements made by Mr. Welteke."
press release retract
9/1 1LawEnforcementSensitive9/1 1LawEnforcementSensitive
Commodities Fupires Trading Commission (CFTC
“The CFTC contacted the ten (10) largest brokerage houses in the country
which trade commodities. The brokerage houses contacted are involved in the
purchase and sale of , commodities contracts for Gold and Silver; Currency;
Stocks; Oil and Energy; and Interest rates.
ote CET nein & 9/1 1LawEnforcementSe
The CFTC also contacted their foreign counterparts in petive
tSensiti
9/1 1LawEnforcementSensitive and other countries ree
ding the appearance of any
unusual trading patterns which would have resulted in a large profit as a result of.
@ attack on the World Trade Center. N one of the Foreign exchange markets
have identitied transactions resulting in a profits due to a position taken prior
the attack." ~
ice) a USS. citizen, was identified trom the FBI watch list
a registered trader from May 92 until 1996 with a company named CIBC.
The CFTC obtained registration information from the Nationai Futures
9/1 1PersonalPriv
as bei:
Association (NFA) concerning
“On October §.2001. ch
tz Chicago Board of Trade (CBT) that an unusually large number of "electronic"
CFTC learned trom their iiaison representative at
req 6-19 Aananni73orders placed on September 10.2001 have surfaced at the CBT. The CFTC advised
these orders were placed using Internet wade accounts after the CBT closed on
September 10, 200!. An initial review indicates the orders appear to be
“ndivicual” orders aftecting specitic commodities (nct further identified} on “he
CBT. The CFTC has requested a list of all electronic orders made after the CBT
closed on September 10,2001. They have also requested available brokerage
account information concerning each of these orders."
National Association of Securities Dealers (NASD)
"The NASD is conducting an analysis of the NASDQ. The NASD is looking
for any unusual activity, spikes, or appearances of any significant profits in one of
the industries affected by the attack, either by selling short, dumping stock hefore
the attack, or purchasing any stock which has gone up in value since the attack
Al! suspicious activity will be referred to the FBI for further investigation. ”
"The NASD was provided with a copy of the FBI "Watch List". The names
contained on the "watch list” were compared with the NASD Central Registration
Depository (CRD) to locate any identical matches. Based on last name alone they
had tound numerous potential matches, however there were none which matched
name and date of birth, address, social security account number, or some other
type of identifying data, 9 1bawEntorcementsensitive
9/1 1LawEnforcementSensitive
October 1, 2001:
1) Joseph J. Cella IIL. Chief of SEC's Otfice of Market Surveillance, advised
toe SEC hus most of the information from the excharges on vTading mansactions
or the ame period surrounding the attacks and would be able to provide it to the
FBI by early next week, The informacion will be on a CD Rom and will be in the
nanaani7aeittta
wEnfore
The SEC was checking <0 see if
format "D" Limited text field. Cella advised the SEC was also looking at
9/1 1LawEnforcementSensitive
there were any suspicious trades involving either large purchases of a stock prior
to the attack or as a possible indicator of future attacks,
October 17, 2001:
L. The Washington Post Foreign Service reported in an article captioned
“EU Probe Finds No Terrorist Link to Suspect Stock Sales “ that European
Union finance ministers said they were s
il investigating "unusual transactions” in
stock tradi
across Europe before the September [1, 2001 terror attacks in the
Un:ted States but there was still no evidence linking the trades to the perpetrators.
{n mid October, 2001, Mr. Cells represented the SEC at a high level
meeting of FBI and &1-aventorcementSensitive at FBI Headquarters
concerning the United Srates and 9! tLawEnforcementSensit in vestigation off
PENTTBOM. I was present at this meeting when Mr. Cella reiterated the findings
of the SEC investigation in the United States as well as what SEC personnel
leared fom European regulators as described above
October 21
003
1) SSA Mackey rerumec to his supervisory as:
ment at the FBI Academy.
‘The U.S. and Intemattonal Financial Markets team was consolidated into the
expanded International Financial Team and SSA Pat Ford was designated tear.
leader. Information developed as a result of the initial investigation of the U.S.
1 9/1 1LawEnforce
mentPrivacy
an
emational Financial Maricets was assigned t0 SSA