United States v. Lebanese Canadian Bank SAL, Southern District of New York (June 25, 2013)

USD(" SOY\, 

UNITED STATES DISTRICT COURT DOCUl\J[\T 

SOUTHERN DISTRICT OF NEW YORK ELECTRO\IC\LLY HI FJ) 
DOC #:._____.....,-_ 

--------------------------------------------------------------x DATE FILED:j ()e; {(~ 

UNITED STATES OF AMERICA, S 

Plaintiff, 

- v. ­

LEBANESE CANADIAN BANK SAL et aI., 

Defendants, 

ALL ASSETS OF LEBANESE CANADIAN 
BANK SAL OR ASSETS TRACEABLE 
THERETO, et al., 

Defendants in rem. 

--------------------------------------------------------------x 

WHEREAS, on or about December 15, 2011, a Verified Complaint, 11 Civ. 9186 

(RJH) (the "Complaint") was filed in the United States District Court for the Southern District of 

New York seeking the forfeiture of certain properties pursuant to Title 18, United States Code, 

Section 98I(a)(l)(A) and (a)(l)(C), and seeking civil money laundering penalties pursuant to 

Title 18, United States Code, Section 1956 against certain parties; 

WHEREAS, on or about October 26,2012, the United States filed a Verified First 

Amended Complaint (the "Amended Complaint"); 

WHEREAS, the Defendants in rem in this action include all assets of Lebanese 

Canadian Bank SAL ("LCB") and assets traceable thereto (the "Defendant Property"); 

WHEREAS, the Amended Complaint alleges that the Defendant Property 

(a) constitutes or was derived from proceeds traceable to violations of executive orders and 

regulations issued pursuant to the International Emergency Economic Powers Act of 1977 

OF SETTLEMENT REGARDING 
LEBANESE CANADIAN BANK 
AND SOCIETE GENERALE 
DE BANQUE AU LIDAN S.A.L. 

11 Civ. 9186 (PAE) 



("IEEPA"), codified at 50 U.S.C. §§ 1701-1705; and (b) constitutes property involved in money 

laundering transactions in violation of Title 18, United States Code, Sections 1956 and 1957; 

WHEREAS, the Amended Complaint also seeks a civil money laundering penalty 

from LCB in the amount of approximately $230,000,000 pursuant to Title 18, United States 

Code, Section 1956(b); 

WHEREAS, on or about December 15, 2011, the Court issued a post-complaint 

restraining order pursuant to 18 U.S.C. § 9830)(1) and Rule 0(7) of the Supplemental Rules for 

Admiralty or Maritime Claims and Asset Forfeiture, prohibiting the transfer or dissipation of the 

Defendant Property (the "Restraining Order"); 

WHEREAS, on or about February 10,2011, the United States Department of the 

Treasury, Financial Crimes Enforcement Network ("FinCEN") issued a Notice of Finding, 

finding that reasonable grounds exist for concluding that LCB was a "financial institution of 

primary money laundering concern" pursuant to Title 31, United States Code, Section 5318A; 

and further issued a Notice of Proposed Rule Making giving notice of FinCEN's proposal to 

issue a rule prohibiting, inter alia, all covered financial institutions from establishing, 

maintaining, administering, or managing a correspondent or payable-through account in the 

United States for, or on behalf of LCB; 

WHEREAS, LCB asserts that, through counsel, it promptly engaged in meetings 

with the United States Treasury Department and that it committed to taking necessary steps to 

address the concerns raised in the Notice of Finding and Notice of Proposed Rule Making; 

WHEREAS LCB asserts that on March 3, 2011, after having received and 

reviewed offers from several banks, and pursuant to the provisions of Article 10 of Lebanese 

Law 192, dated 4 January 1993 (on facilitating bank mergers) ("Law 192/93") and in 

2 




accordance with reVIew and approval of the Central Bank of Lebanon, LCB's Board of 

Directors, for commercial reasons, resolved to sell all of its assets, liabilities, rights and 

obligations to Societe Generale de Banque au Liban S.A.L. ("SGBL"); 

WHEREAS, pursuant to an agreement dated June 22, 2011 (the "Sale and 

Purchase Agreement") between LCB and SGBL, SGBL agreed to acquire substantially all of the 

assets of LCB, in exchange for the payment of a purchase price of $580 million (the "Purchase 

Price") subject to the final review and approval of the Central Bank of Lebanon; 

WHEREAS, on September 7, 2011, the Central Council of the Central Bank of 

Lebanon issued its decision number 1/27/11 by virtue of which it granted its final approval of the 

acquisition by SGBL of the assets and liabilities of LCB pursuant to the provisions of Articles 

(2-3) and (10) of Law 192/93; 

WHEREAS, LCB maintains that subsequent to the execution of the Sale and 

Purchase Agreement, LCB for commercial reasons ceased its banking activities, placed itself 

under liquidation, and, consequently, requested to strike its banking license off of the bank list, 

which request was consented to by the Central Bank of Lebanon pursuant to Decision no. 10799 

all in accordance with the provisions of Article (l0) Law 192/93; 

WHEREAS, pursuant to an agreement dated September 8, 2011 (the "Escrow 

Agreement") between LCB, SGBL, and a Lebanese bank acting as escrow agent (the "Escrow 

Agent"), $150 million of the Purchase Price (the "Escrow Funds") was to be held in escrow by 

the Escrow Agent pending the satisfaction of certain conditions pursuant to the Sale and 

Purchase Agreement; 

3 




WHEREAS, pursuant to the terms of the Sale and Purchase Agreement and the 

Escrow Agreement, the proceedings concerning the release and distribution of the Escrow Funds 

between SGBL and LCB are currently pending in Lebanon; 

WHEREAS, pursuant to Title 18, United States Code, Section 981 (k), the Escrow 

Funds are deemed to have been deposited into the interbank account in the United States of the 

Escrow Agent; 

WHEREAS, the United States has seized, pursuant to Title 18, United States 

Code, 981(k), $150 million from an interbank account of the Escrow Agent (the "Seized 

Funds"); 

WHEREAS, SGBL has filed a sworn claim in this action (the "Claim") for 

$90,000,000 of Seized Funds plus interest (the "Claimed Funds"), representing claims in the 

amounts of $60,000,000 (the "First Claimed Amount"), $30,000,000 (the "Second Claimed 

Amount"), and interest on the First and Second Claimed Amounts (the "Interest Funds") from 

the Escrow Funds; 

WHEREAS, LCB agrees that SGBL is entitled to receive payment of the First 

Claimed Amount from the Escrow Funds in accordance with the terms of the Sale and Purchase 

Agreement and the terms of the Escrow Agreement, but reserves the right to contest the Second 

Claimed Amount; 

WHEREAS, LCB, SGBL, and the United States agree that the First Claimed 

Amount will be paid by (a) the release by the United States to the Escrow Agent of $48,000,000 

from the Seized Funds (the "Released Funds") and (b) LCB causing $12,000,000 to be 

transferred to the Escrow Agent (the "First Additional Funds"); 

4 




WHEREAS, SGBL agrees to credit the Released Funds and the First Additional 

Funds in full satisfaction of SGBL's First Claimed Amount and except for LCB's continued 

irrevocable and unconditional obligations pursuant to the Sale and Purchase Agreement and the 

Addendum (the "Addendum"), a copy of which shall be filed with the Court under seal, shall not 

seek a total amount relating to the Escrow Funds or the New Escrow Funds (as defined below) in 

an amount over or above the Claimed Funds and the Second Additional Funds (as defined 

below) plus any interest SGBL is entitled to under the Sale and Purchase Agreement; 

WHEREAS, LCB asserts that it had no knowledge, or reason to know, of any 

alleged unlawful activity taking place at or through the auspices of LCB prior to its designation 

as a "financial institution of primary money laundering concern" by the United States Treasury 

Department on or about February 10, 2011, including allegations of a scheme to launder 

proceeds oflEEPA violations and narcotics transactions through the U.S. used car market; 

WHEREAS, SGBL asserts it is an innocent purchaser of the assets and liabilities 

of LCB and that the transaction was subject to the review and approval of the Central Bank of 

Lebanon; 

WHEREAS, SGBL and LCB have agreed to settle this matter upon the terms and 

conditions set forth below and in accordance with the Addendum attached hereto; 

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and 

between the United States of America, through its attorney, Preet Bharara, United States 

Attorney for the Southern District of New York, Sharon Cohen Levin, Michael D. Lockard, 

Jason H. Cowley, and Alexander J. Wilson, Assistant United States Attorneys, of counsel, LCB 

and its counsel of record, Evan T. Barr, Esq., of Steptoe & Johnson LLP and John M. 

5 




Hillebrecht, Esq. of DLA Piper LLP, and SGBL and its counsel of record, Michael J. Sullivan, 

Esq., of The Ashcroft Law Firm, LLC, as follows: 

1. LeB and its respective officers, directors, shareholders, subsidiaries, and affiliates 

acknowledge that each has been made aware of allegations, as set forth in the Amended 

Complaint, of a scheme to launder the proceeds ofviolations of rEEP A and proceeds ofnarcotics 

transactions, including through the purchase of used cars in the United States; their subsequent 

shipment to West Africa for sale; the commingling of the proceeds of those sales with narcotics 

proceeds; and transportation of those funds into Lebanon; and allegations that Hizballah 

members and supporters were involved at various points in the above-described alleged money 

laundering scheme (the "Alleged Scheme"). 

2. LCB, having contested all of the allegations referred to in the Amended 

Complaint. and having consistently denied allegations of wrongdoing or management complicity 

or involvement in drugs, terrorist or money laundering activities, has agreed to settle this matter 

on such basis and solely for purposes of terminating this litigation and facilitating the completion 

of the Sale and Purchase Agreement. 

3. SGBL is aware of the allegations set forth in the Amended Complaint and 

described above in paragraph 1 and believes its officers, directors and controlling shareholders 

are also aware of these allegations. 

4. LCB, as part of the settlement set forth herein, shall forfeit to the United States for 

disposition according to law all ofLCB's right, title, and interest in the Seized Funds. 

5. Within ten business days of the entry of this Stipulation and Order of Settlement 

("Stipulation and Order"), the United States shall release the Released Funds to the Escrow 

Agent, in full satisfaction of SGBL's sworn claim in this action. 

6 




6. Within ten business days of the entry of this Stipulation and Order, SGBL and 

LCB shall cause the Central Bank of Lebanon to acknowledge and/or to authorize the entry into 

the Addendum, as applicable, and LCB shall cause (a) the First Additional Funds of $12,000,000 

and (b) an additional amount of $49,100,000 (the "Second Additional Funds," together the "New 

Escrow Funds") to be transferred to the Escrow Agent and deposited in a new or in the existing 

escrow account. The Released Funds and the New Escrow Funds shall be allocated for any final 

resolution of any and all outstanding financial obligations between LCB and SGBL pursuant to 

(i) the Sale and Purchase Agreement, (ii) the Addendum and (iii) the new or amended escrow 

agreement with the Escrow Agent. 

7. Within ten business days of the entry of this Stipulation and Order, LCB shall 

cause the Escrow Agent to release to SGBL, $60,000,000 in full satisfaction of SGBL's First 

Claimed Amount. 

8. SGBL (a) agrees that the amount of the Released Funds and the New Escrow 

Funds shall be credited towards any amount of funds to be awarded to SGBL in Lebanon in 

respect of the (i) First Claimed Amount, (ii) the Second Claimed Amount, and (iii) the other 

claims expressly set out in the Addendum; (b) expressly, specifically, and irrevocably waives its 

rights pursuant to Section 7 of the Sale and Purchase Agreement to make any additional claims 

against LCB for any additional funds relating to any purported unrecorded liabilities in an 

amount over or above the financial limit set out in the Addendum; (c) except for LCB's 

Addendum obligations, expressly, specifically, and irrevocably waives its rights pursuant to 

Section 8 of the Sale and Purchase Agreement to make any additional claims against LCB for 

any additional funds relating to any purported warranties other than those set out in the 

Addendum; (d) agrees that its claims against LCB and the New Escrow Funds, except for LCB's 

7 




Addendum obligations, shall be limited to (i) Claims not to exceed the Second Additional Funds 

and (ii) any claims in relation to LCB's agreement to indemnify SGBL in the manner described 

in the Addendum; and (e) agrees that except for LCB's obligations under Paragraph 8.d(ii) the 

Released Funds and the New Escrow Funds are subject to a final resolution of all and any 

continued irrevocable and unconditional outstanding financial obligations between LCB and 

SGBL pursuant to (i) the Sale and Purchase Agreement, (ii) the Addendum and (ii) the new or 

amended escrow agreement with the Escrow Agent. 

9. The United States shall not bring any claims against the Escrow Agent or any of 

its agents and employees in connection with the Escrow Agent's receipt of the Released Funds 

and New Escrow Funds and its lawful transfer of all or a portion of such funds to SGBL or LCB, 

pursuant to (a) this Stipulation and Order; (b) the Sale and Purchase Agreement; or (c) any other 

agreement between SGBL and LCB. The United States acknowledges that SGBL and LCB 

agree to hold the Escrow Agent harmless from and against any liability or claim arising out or in 

connection with the maintaining and release of the Released Funds and/or the New Escrow 

Funds to either LCB or SGBL. 

10. The United States shall not bring any claim against SGBL, its directors, officers, 

shareholders, agents, employees, or affiliates arising out of the lawful acquisition of LCB' s 

assets and liabilities pursuant to the Sale and Purchase Agreement, for the Alleged Scheme 

and/or under a theory of successor liability. 

11. Upon entry of this Stipulation and Order and the completion of the transfers 

described in paragraphs 5, 6 and 7 above (a) SGBL's claim in this action shall be deemed to be 

dismissed with prejudice and without leave to file any new or additional claims to the Seized 

Funds in this action; (b) the claims in the Amended Complaint for forfeiture of the Defendant 

8 




Property, including the Released Funds and the Purchase Price, shall be dismissed with 

prejudice, except with respect to $102,000,000 of the Seized Funds (the "Forfeited Funds"); (c) 

the Restraining Order shall be amended so as to no longer apply to the Defendant Property, 

including any further restraint of accounts held in the name of LCB located at various banks in 

Lebanon as specified in the sealed attachments to the Stipulation and Order between LCB and 

the United States entered on or about March 27, 2013; (d) the civil money laundering penalty 

claim pursuant to Title 18, United States Code, Section 1956(b) shall be dismissed with prejudice 

as to LCB; and (e) the Forfeited Funds shall be deemed forfeited to the United States, subject to 

the resolution of any remaining pending claims relating to them. 

12. This Stipulation and Order is intended to fully and finally resolve all pending 

claims made by the United States in this action relating to LCB and the Defendant Property. 

Specifically, it is agreed that LCB's forfeiture of all right, title, and interest in the Seized Funds 

and its compliance with its obligations as set forth in this Stipulation and Order shall constitute 

full and complete satisfaction of (a) any in rem claim by the United States arising out of the 

Alleged Scheme set forth in the Amended Complaint as against the Defendant Property, 

including funds from the Purchase Price paid or distributed to other parties in connection with 

the liquidation and winding up of LCB; (b) any in personam claim by the United States arising 

out of the Alleged Scheme set forth in the Amended Complaint for civil money laundering 

penalties or other relief against LCB; and (c) any in personam claims by the United States arising 

out of the Alleged Scheme set forth in the Amended Complaint against any of the LCB 

Principals (as defined below) based on (i) any conduct by LCB; and (ii) any conduct by an LCB 

Principal in his capacity as an LCB shareholder, Board Member, Chairman-General Manager, 

and/or General Manager. 

9 




13. Nothing in this Stipulation and Order is intended to limit any claims by the United 

States based on facts other than the Alleged Scheme, any in rem claims against property other 

than the Defendant Property arising out of the Alleged Scheme, or any in personam claims 

arising out of the Alleged Scheme against any LCB Principal based on such LCB Principal's 

conduct, if any, in his individual capacity outside ofhis duties or responsibilities at LCB. 

14. The United States acknowledges that the Amended Complaint does not assert any 

claims against the LCB Shareholders, Board Members, the Chairman General Manager, and the 

General Manager, whose names are listed in Schedule A attached to this Stipulation and Order 

(the "LCB Principals"). 

15. Subject to compliance with Lebanese law generally and in particular with 

Lebanon's Banking Secrecy Law and Law No. 318 of April 20, 2001, LCB agrees to provide the 

United States with access to all documents, records, and information in its possession or which 

LCB has rights to access under the terms of the Sale and Purchase Agreement, including all 

records and information pertaining to assets, liabilities, accounts, and account holders at LCB 

and/or transferred to SGBL. SGBL shall take no action of any kind which would prevent, 

obstruct, impede, delay, or otherwise interfere with the release of this information by LCB. 

16. Subject to compliance with Lebanese law generally and in particular with 

Lebanon's Banking Secrecy Law and Law No. 318 of April 20, 2001, SGBL agrees to provide 

the United States with access to all documents, records, and information transferred to or 

reviewed by and in the possession of SGBL in connection with the Sale and Purchase 

Agreement, including all records and information in its possession, pertaining to assets, 

liabilities, accounts, and account holders acquired by SGBL pursuant to the Sale and Purchase 

Agreement; and all documents, records, and information relating to assets, liabilities, accounts, 

10 




and account holders reviewed by and in the possession of SGBL in connection with the Sale and 

Purchase Agreement but not acquired by SGBL. LCB shall take no action of any kind which 

would prevent, obstruct, impede, delay, or otherwise interfere with the release of this information 

bySGBL. 

17. Provided it does not violate any Lebanese law, freeze order from the Special 

Investigation Commission of the Central Bank of Lebanon ("SIC"), or order or decision by a 

court of competent jurisdiction in Lebanon, SGBL shall, upon written authorization and 

instructions from a SGBL client, including a complete release and waiver, release funds held by 

SGBL on behalf of that client to the United States. Should written authorization not be provided 

by a client, then and in that event, SGBL shall release client funds to the United States upon due 

notification and receipt of a binding and final legal order or decision authorizing the release of 

funds by a court of competent jurisdiction in Lebanon and if applicable, a decision from the SIC 

lifting any freeze over the client's account and SGBL shall not be required or bound to release 

client funds to the United States absent such court order or decision. SGBL shall not contest or 

otherwise seek to prevent the issuance of such an order by a court of competent jurisdiction in 

Lebanon. 

18. Provided it does not violate any Lebanese law. freeze order from the SIC, or order 

or decision by a court of competent jurisdiction in Lebanon, LCB shall, upon written 

authorization and instructions from a LCB client, including a complete release and waiver, 

release funds held by LCB on behalf of that client to the United States. Should written 

authorization not be provided by a client, then and in that event, LCB shall release client funds to 

the United States upon due notification and receipt of a binding and final legal order or decision 

authorizing the release of funds by a court of competent jurisdiction in Lebanon and if 

11 




applicable, a decision from the SIC lifting any freeze over the client's account and LCB shall not 

be required or bound to release client funds to the United States absent such court order or 

decision. LCB shall not contest or otherwise seek to prevent the issuance of such an order by a 

court ofcompetent jurisdiction in Lebanon. 

19. LCB and SGBL are hereby barred from asserting any claims against the United 

States or any of its agents and employees (including, without limitation, the Drug Enforcement 

Administration ("DEA") and the United States Attorney's Office for the Southern District of 

New York ("USAO-SDNY") in connection with or arising out of the United States' seizure, 

restraint, and/or constructive possession of the Defendant Property, including the Seized Funds; 

including, without limitation, any claim that the United States did not have probable cause to 

seize, restrain, and/or forfeit the Defendant Property, that LCB or SGBL is a prevailing party, or 

that LCB or SGBL is entitled to attorneys' fees or any award of interest. 

20. LCB represents that with the exception of the claims set forth in this action by 

SGBL, it is the sole legal owner of the Defendant Property. SGBL represents that with the 

exception of the claims set forth in this action by LCB, it is the sole legal owner of the Claimed 

Funds. LCB agrees to hold harmless the United States and any and all of its agents and 

employees (including, without limitation, the DEA and the USAO-SDNY) from any and all 

claims (including, without limitation, third-party claims, with the exception of the claims 

asserted by SGBL) in connection with or arising out of the United States' seizure, restraint, 

and/or constructive possession of the Defendant Property, including the Seized Funds. SGBL 

agrees to hold harmless the United States and any and all of its agents and employees (including, 

without limitation, the DEA and the USAO-SDNY) from any and all claims (including, without 

limitation, third-party claims, with the exception of the claims asserted by LCB) in connection 

12 




with or arising out of the United States' seizure, restraint, and/or constructive possession of the 

Claimed Funds. 

21. LCB represents and warrants that this Stipulation and Order has been duly 

authorized by its Oeneral Assemblies of 9 April, 3 June and 18 June 2013 and constitutes valid 

corporate action pursuant to the laws and regulations of Lebanon. 

22. SOBL represents and warrants that this Stipulation and Order is duly authorized 

by SOBt's Bylaws and other corporate documents, notably by a meeting of SOBt's board of 

directors held on 21 June 2011 approving the execution of the Sale and Purchase Agreement, and 

constitutes valid corporate action pursuant to the laws and regulations of Lebanon. 

23. Each party waives all rights to appeal or to otherwise challenge or contest the 

validity of this Stipulation and Order. 

24. Each party shall bear its own costs and attorneys' fees. 

25. The Court shall retain jurisdiction over this Stipulation and Order and over any 

action to interpret or enforce its terms. The signing of this Stipulation and Settlement Order does 

not constitute consent by LCB or SOBL to personal jurisdiction over LCB or SOBL, other than 

for the purpose of enforcing this Stipulation and Order. 

13 




26. The signature pages of this Stipulation and Order may be executed in one or more 

counterparts, each of which will be deemed an original but all of which together will constitute 

one and the same instrument. Signature pages may be by fax or by pdf and such signatures shall 

be deemed as valid originals. 

AGREED AND CONSENTED TO: 

PREET BHARARA 
United States Attorney for the 
Southern District ofNew York 

-
___________ ~'(2.{ fLOt s 

DATE 
Jason H. Cowleyl Alexander Wilson 
Assistant United States Attorneys 
One St. Andrew's Plaza 
New York, New York 10007 
(212) 637-2200 

By~:~____~~~~~. 
aron Cohen LevinIMichael D. Lockard 

[ADDITIONAL SIGNATURES ON FOLLOWING PAGE] 


14 




LEBANESE CANAD~,-S:A.L.. 

\ \ ' '"

. L __gR ---) J., 0/t; {2f) 13By: #J . "" 
George Zard Abou Jaoude DATE 
Liquidator 
Lebanese Canadian Bank SAL 

-JJ1:.;«-==-:'~
By:---7 7- ,~o /)(j)o(J 

Mohamad Ibrahim Hamdoun DATE 

Liquidatol', 

Lebanese Canadian Bank SAL 


BY:~~ to/t. tJ/JJ 
Evan T. Barr, Esq. DATE ' 

Steptoe & Johnson LLP 

1114 Avenue of the Americas 

New York, NY 10036 

(212) 506-3900 
COllnseljol' Lebane.re Canadian Btmk SAL 

By;~__~~~~~______________ 
John M. Hillebl'echt, Esq. DATE 
DLA Piper 
1251 Avenue of the Americas 
New York, New York 10020-1104 
(212) 335-4590 

Counsel for Lebanese Canadian Bank SAL 


[ADDITIONAL SIGNATURES ON FOLLOWING PAGE] 

15 

http:Lebane.re


JON 21,2013 06:26A 7188525184 page 1 

UJDANESE C~\NAI.)!i\N BA"NK, SAL...\. ",
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0>':__...__ __~._~..!;xl~:?! j. 
(lcurg!! 1.''''1'.:1 Abou Jaolldi 

Liquida!or 

1.~I,;lIlC!!e Canaditm Bank SAL 


.,1_./' .-.. " 
By:~-:' -~~'~..~ .......... ' .. 

Mahamad Ibmhim Hnmdolll) 
U4lUidltlUr, 

1,el)M~l\!i' Cani,dinl1 Bllilk SAL 


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Cm/l1$(1}/m' i/lb.znBxlI ("mlll.:Ii'm 1l(1l7k SAL 

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(212) JJ5·4SI)O 
CI)JtlbCll()f L::bllm:lic Ctlnooian Bank SAL 

[ADDITIONAl SI<iNATURE.q ON FOLJ.OWIN(l PAGt::J 

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http:Amcric.ls


SOCIETE GBNBR.A.LE DB BANQUE AU LlBAN S.AL. 

~~~~~~/--~---~--'---------­
Amoun Sehnaoui 
Chairman and Gmera1 Manapr 
Soci6tt ~ de Banque au Liban S.A.L. 

By: '­
~~~~~--~I~----~--------­

Chief'Oparating Officer 
~G6n6rale de Banque au Uban SAL. 

SOORDBRED: 

!:o~J~=YER 

UNITED STATES DISTRICT JUDGE 

16 

,,6 - tu - 13 
DATE 

, 

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DATE 

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DATE ~ 

DATE 


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SCHEDULE A - Ustof LCBPRIN(:IPALS: February 2011-J!Jne 18,2013 

Otherc:,
Names ofShareholdel'J 

ardMemDenl ~alnna~_~G~ GM DGM 
__,~.__-,,",,~,___' __~m""'~_""""'""_"'''''''_'~''_"~~'''_''''''''''_'''_________' ~~~-..-"""--" 

Leader Invest (Holding) SAL I , ./ 
-""""'''-~ 

Hamdoun Mohamad Ibrahim ./ ./ 

Ne~lan Lca ~~~__~~,_~_~_,__.~~_"'_~ ./ 

Zard Abou Jaoude Georges Edward 
. ',,,,­

./ ./ 

Perpetual (H"olding) SAL ./
--------" "" .,-,-",--" ~,,-----

,~uryn~rr.!e_l~ldl~L~~,__ ,,,,, __,,,,,,~._,,,,,_~__,,.,_,_,_,".,,,_,,,' ,'-"'­ _"~'~~""~'''~_C__~'' 

Nasrallah Wadih Adel--_. ~__''''''''''''~~'_M'''''~N~_____''''''''_.~~mq.____ _w ¥_-.----­
Wan Invest SA ./ 

Nest Investments Holding Lebanon SAL ./ .__..,~u ",._­

Trust International Insurance and Reinsurance Co. (Trust Re) • 
'" 

Jordanian Expatriates Invest. Holding Co. ./ 
.....~~----"--, ,---­ 1-­

Qatar General Insurance and Reinsurance Company S.A.Q " II ,-_.",,--,­ ;..-"'''----­

Abu Nahl Ghazi Kamel Abdul Rahman ,,--­ ~----".----~--~---. 

Abu Nahl Jamal Kamel Abdul Rahman 
I 

Compass Insurance SAL 
,,~--- " 

!:~~!,~nte~~!~':!.!llnSura~_~£.<>,,~e~_~YJ£.'iPEus) L~~~t:c!,__, __ ,_~"" 
" 

AI Thani Nasser Ali Saoud Thanl 

Abu Nahl Fad! Ghazi~~~~N~"_____~__________ 

Abu Nahl Hamad Ghazi 
,,, 

Abu Nahl Kamel Ghazi - ". 
Zard Abou Jaoude Edward Jerjes ./ 

Dlab Ray",u"... Nasri I 
./ 

............ 
" 

Makari Makarem Nabil ./
,---­ "~~~,--------

Abou Jaoude Carlos Antoine 
~w_~~~____._____w"""'___~"~'~"""'N~~' ••••,_ -,-
Kapital (Holding) SAL_~__~_'""'__'"_"____,~'''''_~,, 

Gretta Ibrahim Ghafari ./ 
__~ ......""""_~___n~__¥.N'~'__'_,__._,__,,__~_ 

"'~--,---, ~~~..,.,..,..~-,-" ~---..--
Ghassan Wadih Haikal ./ 

Total 11 1 1 . Z 
_.~_,___~~,_·____""""'~_~__·_~~".'~__'~r __•••'"~_"_~_~n'_""""_¥~N_'~'" .. ,-~-

I/r In April 20.1.2, the shareholder "Trust International Insurance and Reinsurance Company (Trust Re)" trans/erred all its shares 

(6,240,000 shares) to another shareholder 0/ the group, namely Nest Investments Holding Lebanon SAL

USD(" SOY\, 

UNITED STATES DISTRICT COURT DOCUl\J[\T 

SOUTHERN DISTRICT OF NEW YORK ELECTRO\IC\LLY HI FJ) 
DOC #:._____.....,-_ 

--------------------------------------------------------------x DATE FILED:j ()e; {(~ 

UNITED STATES OF AMERICA, S 

Plaintiff, 

- v. ­

LEBANESE CANADIAN BANK SAL et aI., 

Defendants, 

ALL ASSETS OF LEBANESE CANADIAN 
BANK SAL OR ASSETS TRACEABLE 
THERETO, et al., 

Defendants in rem. 

--------------------------------------------------------------x 

WHEREAS, on or about December 15, 2011, a Verified Complaint, 11 Civ. 9186 

(RJH) (the "Complaint") was filed in the United States District Court for the Southern District of 

New York seeking the forfeiture of certain properties pursuant to Title 18, United States Code, 

Section 98I(a)(l)(A) and (a)(l)(C), and seeking civil money laundering penalties pursuant to 

Title 18, United States Code, Section 1956 against certain parties; 

WHEREAS, on or about October 26,2012, the United States filed a Verified First 

Amended Complaint (the "Amended Complaint"); 

WHEREAS, the Defendants in rem in this action include all assets of Lebanese 

Canadian Bank SAL ("LCB") and assets traceable thereto (the "Defendant Property"); 

WHEREAS, the Amended Complaint alleges that the Defendant Property 

(a) constitutes or was derived from proceeds traceable to violations of executive orders and 

regulations issued pursuant to the International Emergency Economic Powers Act of 1977 

OF SETTLEMENT REGARDING 
LEBANESE CANADIAN BANK 
AND SOCIETE GENERALE 
DE BANQUE AU LIDAN S.A.L. 

11 Civ. 9186 (PAE) 



("IEEPA"), codified at 50 U.S.C. §§ 1701-1705; and (b) constitutes property involved in money 

laundering transactions in violation of Title 18, United States Code, Sections 1956 and 1957; 

WHEREAS, the Amended Complaint also seeks a civil money laundering penalty 

from LCB in the amount of approximately $230,000,000 pursuant to Title 18, United States 

Code, Section 1956(b); 

WHEREAS, on or about December 15, 2011, the Court issued a post-complaint 

restraining order pursuant to 18 U.S.C. § 9830)(1) and Rule 0(7) of the Supplemental Rules for 

Admiralty or Maritime Claims and Asset Forfeiture, prohibiting the transfer or dissipation of the 

Defendant Property (the "Restraining Order"); 

WHEREAS, on or about February 10,2011, the United States Department of the 

Treasury, Financial Crimes Enforcement Network ("FinCEN") issued a Notice of Finding, 

finding that reasonable grounds exist for concluding that LCB was a "financial institution of 

primary money laundering concern" pursuant to Title 31, United States Code, Section 5318A; 

and further issued a Notice of Proposed Rule Making giving notice of FinCEN's proposal to 

issue a rule prohibiting, inter alia, all covered financial institutions from establishing, 

maintaining, administering, or managing a correspondent or payable-through account in the 

United States for, or on behalf of LCB; 

WHEREAS, LCB asserts that, through counsel, it promptly engaged in meetings 

with the United States Treasury Department and that it committed to taking necessary steps to 

address the concerns raised in the Notice of Finding and Notice of Proposed Rule Making; 

WHEREAS LCB asserts that on March 3, 2011, after having received and 

reviewed offers from several banks, and pursuant to the provisions of Article 10 of Lebanese 

Law 192, dated 4 January 1993 (on facilitating bank mergers) ("Law 192/93") and in 

2 




accordance with reVIew and approval of the Central Bank of Lebanon, LCB's Board of 

Directors, for commercial reasons, resolved to sell all of its assets, liabilities, rights and 

obligations to Societe Generale de Banque au Liban S.A.L. ("SGBL"); 

WHEREAS, pursuant to an agreement dated June 22, 2011 (the "Sale and 

Purchase Agreement") between LCB and SGBL, SGBL agreed to acquire substantially all of the 

assets of LCB, in exchange for the payment of a purchase price of $580 million (the "Purchase 

Price") subject to the final review and approval of the Central Bank of Lebanon; 

WHEREAS, on September 7, 2011, the Central Council of the Central Bank of 

Lebanon issued its decision number 1/27/11 by virtue of which it granted its final approval of the 

acquisition by SGBL of the assets and liabilities of LCB pursuant to the provisions of Articles 

(2-3) and (10) of Law 192/93; 

WHEREAS, LCB maintains that subsequent to the execution of the Sale and 

Purchase Agreement, LCB for commercial reasons ceased its banking activities, placed itself 

under liquidation, and, consequently, requested to strike its banking license off of the bank list, 

which request was consented to by the Central Bank of Lebanon pursuant to Decision no. 10799 

all in accordance with the provisions of Article (l0) Law 192/93; 

WHEREAS, pursuant to an agreement dated September 8, 2011 (the "Escrow 

Agreement") between LCB, SGBL, and a Lebanese bank acting as escrow agent (the "Escrow 

Agent"), $150 million of the Purchase Price (the "Escrow Funds") was to be held in escrow by 

the Escrow Agent pending the satisfaction of certain conditions pursuant to the Sale and 

Purchase Agreement; 

3 




WHEREAS, pursuant to the terms of the Sale and Purchase Agreement and the 

Escrow Agreement, the proceedings concerning the release and distribution of the Escrow Funds 

between SGBL and LCB are currently pending in Lebanon; 

WHEREAS, pursuant to Title 18, United States Code, Section 981 (k), the Escrow 

Funds are deemed to have been deposited into the interbank account in the United States of the 

Escrow Agent; 

WHEREAS, the United States has seized, pursuant to Title 18, United States 

Code, 981(k), $150 million from an interbank account of the Escrow Agent (the "Seized 

Funds"); 

WHEREAS, SGBL has filed a sworn claim in this action (the "Claim") for 

$90,000,000 of Seized Funds plus interest (the "Claimed Funds"), representing claims in the 

amounts of $60,000,000 (the "First Claimed Amount"), $30,000,000 (the "Second Claimed 

Amount"), and interest on the First and Second Claimed Amounts (the "Interest Funds") from 

the Escrow Funds; 

WHEREAS, LCB agrees that SGBL is entitled to receive payment of the First 

Claimed Amount from the Escrow Funds in accordance with the terms of the Sale and Purchase 

Agreement and the terms of the Escrow Agreement, but reserves the right to contest the Second 

Claimed Amount; 

WHEREAS, LCB, SGBL, and the United States agree that the First Claimed 

Amount will be paid by (a) the release by the United States to the Escrow Agent of $48,000,000 

from the Seized Funds (the "Released Funds") and (b) LCB causing $12,000,000 to be 

transferred to the Escrow Agent (the "First Additional Funds"); 

4 




WHEREAS, SGBL agrees to credit the Released Funds and the First Additional 

Funds in full satisfaction of SGBL's First Claimed Amount and except for LCB's continued 

irrevocable and unconditional obligations pursuant to the Sale and Purchase Agreement and the 

Addendum (the "Addendum"), a copy of which shall be filed with the Court under seal, shall not 

seek a total amount relating to the Escrow Funds or the New Escrow Funds (as defined below) in 

an amount over or above the Claimed Funds and the Second Additional Funds (as defined 

below) plus any interest SGBL is entitled to under the Sale and Purchase Agreement; 

WHEREAS, LCB asserts that it had no knowledge, or reason to know, of any 

alleged unlawful activity taking place at or through the auspices of LCB prior to its designation 

as a "financial institution of primary money laundering concern" by the United States Treasury 

Department on or about February 10, 2011, including allegations of a scheme to launder 

proceeds oflEEPA violations and narcotics transactions through the U.S. used car market; 

WHEREAS, SGBL asserts it is an innocent purchaser of the assets and liabilities 

of LCB and that the transaction was subject to the review and approval of the Central Bank of 

Lebanon; 

WHEREAS, SGBL and LCB have agreed to settle this matter upon the terms and 

conditions set forth below and in accordance with the Addendum attached hereto; 

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and 

between the United States of America, through its attorney, Preet Bharara, United States 

Attorney for the Southern District of New York, Sharon Cohen Levin, Michael D. Lockard, 

Jason H. Cowley, and Alexander J. Wilson, Assistant United States Attorneys, of counsel, LCB 

and its counsel of record, Evan T. Barr, Esq., of Steptoe & Johnson LLP and John M. 

5 




Hillebrecht, Esq. of DLA Piper LLP, and SGBL and its counsel of record, Michael J. Sullivan, 

Esq., of The Ashcroft Law Firm, LLC, as follows: 

1. LeB and its respective officers, directors, shareholders, subsidiaries, and affiliates 

acknowledge that each has been made aware of allegations, as set forth in the Amended 

Complaint, of a scheme to launder the proceeds ofviolations of rEEP A and proceeds ofnarcotics 

transactions, including through the purchase of used cars in the United States; their subsequent 

shipment to West Africa for sale; the commingling of the proceeds of those sales with narcotics 

proceeds; and transportation of those funds into Lebanon; and allegations that Hizballah 

members and supporters were involved at various points in the above-described alleged money 

laundering scheme (the "Alleged Scheme"). 

2. LCB, having contested all of the allegations referred to in the Amended 

Complaint. and having consistently denied allegations of wrongdoing or management complicity 

or involvement in drugs, terrorist or money laundering activities, has agreed to settle this matter 

on such basis and solely for purposes of terminating this litigation and facilitating the completion 

of the Sale and Purchase Agreement. 

3. SGBL is aware of the allegations set forth in the Amended Complaint and 

described above in paragraph 1 and believes its officers, directors and controlling shareholders 

are also aware of these allegations. 

4. LCB, as part of the settlement set forth herein, shall forfeit to the United States for 

disposition according to law all ofLCB's right, title, and interest in the Seized Funds. 

5. Within ten business days of the entry of this Stipulation and Order of Settlement 

("Stipulation and Order"), the United States shall release the Released Funds to the Escrow 

Agent, in full satisfaction of SGBL's sworn claim in this action. 

6 




6. Within ten business days of the entry of this Stipulation and Order, SGBL and 

LCB shall cause the Central Bank of Lebanon to acknowledge and/or to authorize the entry into 

the Addendum, as applicable, and LCB shall cause (a) the First Additional Funds of $12,000,000 

and (b) an additional amount of $49,100,000 (the "Second Additional Funds," together the "New 

Escrow Funds") to be transferred to the Escrow Agent and deposited in a new or in the existing 

escrow account. The Released Funds and the New Escrow Funds shall be allocated for any final 

resolution of any and all outstanding financial obligations between LCB and SGBL pursuant to 

(i) the Sale and Purchase Agreement, (ii) the Addendum and (iii) the new or amended escrow 

agreement with the Escrow Agent. 

7. Within ten business days of the entry of this Stipulation and Order, LCB shall 

cause the Escrow Agent to release to SGBL, $60,000,000 in full satisfaction of SGBL's First 

Claimed Amount. 

8. SGBL (a) agrees that the amount of the Released Funds and the New Escrow 

Funds shall be credited towards any amount of funds to be awarded to SGBL in Lebanon in 

respect of the (i) First Claimed Amount, (ii) the Second Claimed Amount, and (iii) the other 

claims expressly set out in the Addendum; (b) expressly, specifically, and irrevocably waives its 

rights pursuant to Section 7 of the Sale and Purchase Agreement to make any additional claims 

against LCB for any additional funds relating to any purported unrecorded liabilities in an 

amount over or above the financial limit set out in the Addendum; (c) except for LCB's 

Addendum obligations, expressly, specifically, and irrevocably waives its rights pursuant to 

Section 8 of the Sale and Purchase Agreement to make any additional claims against LCB for 

any additional funds relating to any purported warranties other than those set out in the 

Addendum; (d) agrees that its claims against LCB and the New Escrow Funds, except for LCB's 

7 




Addendum obligations, shall be limited to (i) Claims not to exceed the Second Additional Funds 

and (ii) any claims in relation to LCB's agreement to indemnify SGBL in the manner described 

in the Addendum; and (e) agrees that except for LCB's obligations under Paragraph 8.d(ii) the 

Released Funds and the New Escrow Funds are subject to a final resolution of all and any 

continued irrevocable and unconditional outstanding financial obligations between LCB and 

SGBL pursuant to (i) the Sale and Purchase Agreement, (ii) the Addendum and (ii) the new or 

amended escrow agreement with the Escrow Agent. 

9. The United States shall not bring any claims against the Escrow Agent or any of 

its agents and employees in connection with the Escrow Agent's receipt of the Released Funds 

and New Escrow Funds and its lawful transfer of all or a portion of such funds to SGBL or LCB, 

pursuant to (a) this Stipulation and Order; (b) the Sale and Purchase Agreement; or (c) any other 

agreement between SGBL and LCB. The United States acknowledges that SGBL and LCB 

agree to hold the Escrow Agent harmless from and against any liability or claim arising out or in 

connection with the maintaining and release of the Released Funds and/or the New Escrow 

Funds to either LCB or SGBL. 

10. The United States shall not bring any claim against SGBL, its directors, officers, 

shareholders, agents, employees, or affiliates arising out of the lawful acquisition of LCB' s 

assets and liabilities pursuant to the Sale and Purchase Agreement, for the Alleged Scheme 

and/or under a theory of successor liability. 

11. Upon entry of this Stipulation and Order and the completion of the transfers 

described in paragraphs 5, 6 and 7 above (a) SGBL's claim in this action shall be deemed to be 

dismissed with prejudice and without leave to file any new or additional claims to the Seized 

Funds in this action; (b) the claims in the Amended Complaint for forfeiture of the Defendant 

8 




Property, including the Released Funds and the Purchase Price, shall be dismissed with 

prejudice, except with respect to $102,000,000 of the Seized Funds (the "Forfeited Funds"); (c) 

the Restraining Order shall be amended so as to no longer apply to the Defendant Property, 

including any further restraint of accounts held in the name of LCB located at various banks in 

Lebanon as specified in the sealed attachments to the Stipulation and Order between LCB and 

the United States entered on or about March 27, 2013; (d) the civil money laundering penalty 

claim pursuant to Title 18, United States Code, Section 1956(b) shall be dismissed with prejudice 

as to LCB; and (e) the Forfeited Funds shall be deemed forfeited to the United States, subject to 

the resolution of any remaining pending claims relating to them. 

12. This Stipulation and Order is intended to fully and finally resolve all pending 

claims made by the United States in this action relating to LCB and the Defendant Property. 

Specifically, it is agreed that LCB's forfeiture of all right, title, and interest in the Seized Funds 

and its compliance with its obligations as set forth in this Stipulation and Order shall constitute 

full and complete satisfaction of (a) any in rem claim by the United States arising out of the 

Alleged Scheme set forth in the Amended Complaint as against the Defendant Property, 

including funds from the Purchase Price paid or distributed to other parties in connection with 

the liquidation and winding up of LCB; (b) any in personam claim by the United States arising 

out of the Alleged Scheme set forth in the Amended Complaint for civil money laundering 

penalties or other relief against LCB; and (c) any in personam claims by the United States arising 

out of the Alleged Scheme set forth in the Amended Complaint against any of the LCB 

Principals (as defined below) based on (i) any conduct by LCB; and (ii) any conduct by an LCB 

Principal in his capacity as an LCB shareholder, Board Member, Chairman-General Manager, 

and/or General Manager. 

9 




13. Nothing in this Stipulation and Order is intended to limit any claims by the United 

States based on facts other than the Alleged Scheme, any in rem claims against property other 

than the Defendant Property arising out of the Alleged Scheme, or any in personam claims 

arising out of the Alleged Scheme against any LCB Principal based on such LCB Principal's 

conduct, if any, in his individual capacity outside ofhis duties or responsibilities at LCB. 

14. The United States acknowledges that the Amended Complaint does not assert any 

claims against the LCB Shareholders, Board Members, the Chairman General Manager, and the 

General Manager, whose names are listed in Schedule A attached to this Stipulation and Order 

(the "LCB Principals"). 

15. Subject to compliance with Lebanese law generally and in particular with 

Lebanon's Banking Secrecy Law and Law No. 318 of April 20, 2001, LCB agrees to provide the 

United States with access to all documents, records, and information in its possession or which 

LCB has rights to access under the terms of the Sale and Purchase Agreement, including all 

records and information pertaining to assets, liabilities, accounts, and account holders at LCB 

and/or transferred to SGBL. SGBL shall take no action of any kind which would prevent, 

obstruct, impede, delay, or otherwise interfere with the release of this information by LCB. 

16. Subject to compliance with Lebanese law generally and in particular with 

Lebanon's Banking Secrecy Law and Law No. 318 of April 20, 2001, SGBL agrees to provide 

the United States with access to all documents, records, and information transferred to or 

reviewed by and in the possession of SGBL in connection with the Sale and Purchase 

Agreement, including all records and information in its possession, pertaining to assets, 

liabilities, accounts, and account holders acquired by SGBL pursuant to the Sale and Purchase 

Agreement; and all documents, records, and information relating to assets, liabilities, accounts, 

10 




and account holders reviewed by and in the possession of SGBL in connection with the Sale and 

Purchase Agreement but not acquired by SGBL. LCB shall take no action of any kind which 

would prevent, obstruct, impede, delay, or otherwise interfere with the release of this information 

bySGBL. 

17. Provided it does not violate any Lebanese law, freeze order from the Special 

Investigation Commission of the Central Bank of Lebanon ("SIC"), or order or decision by a 

court of competent jurisdiction in Lebanon, SGBL shall, upon written authorization and 

instructions from a SGBL client, including a complete release and waiver, release funds held by 

SGBL on behalf of that client to the United States. Should written authorization not be provided 

by a client, then and in that event, SGBL shall release client funds to the United States upon due 

notification and receipt of a binding and final legal order or decision authorizing the release of 

funds by a court of competent jurisdiction in Lebanon and if applicable, a decision from the SIC 

lifting any freeze over the client's account and SGBL shall not be required or bound to release 

client funds to the United States absent such court order or decision. SGBL shall not contest or 

otherwise seek to prevent the issuance of such an order by a court of competent jurisdiction in 

Lebanon. 

18. Provided it does not violate any Lebanese law. freeze order from the SIC, or order 

or decision by a court of competent jurisdiction in Lebanon, LCB shall, upon written 

authorization and instructions from a LCB client, including a complete release and waiver, 

release funds held by LCB on behalf of that client to the United States. Should written 

authorization not be provided by a client, then and in that event, LCB shall release client funds to 

the United States upon due notification and receipt of a binding and final legal order or decision 

authorizing the release of funds by a court of competent jurisdiction in Lebanon and if 

11 




applicable, a decision from the SIC lifting any freeze over the client's account and LCB shall not 

be required or bound to release client funds to the United States absent such court order or 

decision. LCB shall not contest or otherwise seek to prevent the issuance of such an order by a 

court ofcompetent jurisdiction in Lebanon. 

19. LCB and SGBL are hereby barred from asserting any claims against the United 

States or any of its agents and employees (including, without limitation, the Drug Enforcement 

Administration ("DEA") and the United States Attorney's Office for the Southern District of 

New York ("USAO-SDNY") in connection with or arising out of the United States' seizure, 

restraint, and/or constructive possession of the Defendant Property, including the Seized Funds; 

including, without limitation, any claim that the United States did not have probable cause to 

seize, restrain, and/or forfeit the Defendant Property, that LCB or SGBL is a prevailing party, or 

that LCB or SGBL is entitled to attorneys' fees or any award of interest. 

20. LCB represents that with the exception of the claims set forth in this action by 

SGBL, it is the sole legal owner of the Defendant Property. SGBL represents that with the 

exception of the claims set forth in this action by LCB, it is the sole legal owner of the Claimed 

Funds. LCB agrees to hold harmless the United States and any and all of its agents and 

employees (including, without limitation, the DEA and the USAO-SDNY) from any and all 

claims (including, without limitation, third-party claims, with the exception of the claims 

asserted by SGBL) in connection with or arising out of the United States' seizure, restraint, 

and/or constructive possession of the Defendant Property, including the Seized Funds. SGBL 

agrees to hold harmless the United States and any and all of its agents and employees (including, 

without limitation, the DEA and the USAO-SDNY) from any and all claims (including, without 

limitation, third-party claims, with the exception of the claims asserted by LCB) in connection 

12 




with or arising out of the United States' seizure, restraint, and/or constructive possession of the 

Claimed Funds. 

21. LCB represents and warrants that this Stipulation and Order has been duly 

authorized by its Oeneral Assemblies of 9 April, 3 June and 18 June 2013 and constitutes valid 

corporate action pursuant to the laws and regulations of Lebanon. 

22. SOBL represents and warrants that this Stipulation and Order is duly authorized 

by SOBt's Bylaws and other corporate documents, notably by a meeting of SOBt's board of 

directors held on 21 June 2011 approving the execution of the Sale and Purchase Agreement, and 

constitutes valid corporate action pursuant to the laws and regulations of Lebanon. 

23. Each party waives all rights to appeal or to otherwise challenge or contest the 

validity of this Stipulation and Order. 

24. Each party shall bear its own costs and attorneys' fees. 

25. The Court shall retain jurisdiction over this Stipulation and Order and over any 

action to interpret or enforce its terms. The signing of this Stipulation and Settlement Order does 

not constitute consent by LCB or SOBL to personal jurisdiction over LCB or SOBL, other than 

for the purpose of enforcing this Stipulation and Order. 

13 




26. The signature pages of this Stipulation and Order may be executed in one or more 

counterparts, each of which will be deemed an original but all of which together will constitute 

one and the same instrument. Signature pages may be by fax or by pdf and such signatures shall 

be deemed as valid originals. 

AGREED AND CONSENTED TO: 

PREET BHARARA 
United States Attorney for the 
Southern District ofNew York 

-
___________ ~'(2.{ fLOt s 

DATE 
Jason H. Cowleyl Alexander Wilson 
Assistant United States Attorneys 
One St. Andrew's Plaza 
New York, New York 10007 
(212) 637-2200 

By~:~____~~~~~. 
aron Cohen LevinIMichael D. Lockard 

[ADDITIONAL SIGNATURES ON FOLLOWING PAGE] 


14 




LEBANESE CANAD~,-S:A.L.. 

\ \ ' '"

. L __gR ---) J., 0/t; {2f) 13By: #J . "" 
George Zard Abou Jaoude DATE 
Liquidator 
Lebanese Canadian Bank SAL 

-JJ1:.;«-==-:'~
By:---7 7- ,~o /)(j)o(J 

Mohamad Ibrahim Hamdoun DATE 

Liquidatol', 

Lebanese Canadian Bank SAL 


BY:~~ to/t. tJ/JJ 
Evan T. Barr, Esq. DATE ' 

Steptoe & Johnson LLP 

1114 Avenue of the Americas 

New York, NY 10036 

(212) 506-3900 
COllnseljol' Lebane.re Canadian Btmk SAL 

By;~__~~~~~______________ 
John M. Hillebl'echt, Esq. DATE 
DLA Piper 
1251 Avenue of the Americas 
New York, New York 10020-1104 
(212) 335-4590 

Counsel for Lebanese Canadian Bank SAL 


[ADDITIONAL SIGNATURES ON FOLLOWING PAGE] 

15 

http:Lebane.re


JON 21,2013 06:26A 7188525184 page 1 

UJDANESE C~\NAI.)!i\N BA"NK, SAL...\. ",
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Liquida!or 

1.~I,;lIlC!!e Canaditm Bank SAL 


.,1_./' .-.. " 
By:~-:' -~~'~..~ .......... ' .. 

Mahamad Ibmhim Hnmdolll) 
U4lUidltlUr, 

1,el)M~l\!i' Cani,dinl1 Bllilk SAL 


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[ADDITIONAl SI<iNATURE.q ON FOLJ.OWIN(l PAGt::J 

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http:Amcric.ls


SOCIETE GBNBR.A.LE DB BANQUE AU LlBAN S.AL. 

~~~~~~/--~---~--'---------­
Amoun Sehnaoui 
Chairman and Gmera1 Manapr 
Soci6tt ~ de Banque au Liban S.A.L. 

By: '­
~~~~~--~I~----~--------­

Chief'Oparating Officer 
~G6n6rale de Banque au Uban SAL. 

SOORDBRED: 

!:o~J~=YER 

UNITED STATES DISTRICT JUDGE 

16 

,,6 - tu - 13 
DATE 

, 

, (:. be . 


DATE 

f:2-Zo -13 
DATE ~ 

DATE 


http:GBNBR.A.LE


SCHEDULE A - Ustof LCBPRIN(:IPALS: February 2011-J!Jne 18,2013 

Otherc:,
Names ofShareholdel'J 

ardMemDenl ~alnna~_~G~ GM DGM 
__,~.__-,,",,~,___' __~m""'~_""""'""_"'''''''_'~''_"~~'''_''''''''''_'''_________' ~~~-..-"""--" 

Leader Invest (Holding) SAL I , ./ 
-""""'''-~ 

Hamdoun Mohamad Ibrahim ./ ./ 

Ne~lan Lca ~~~__~~,_~_~_,__.~~_"'_~ ./ 

Zard Abou Jaoude Georges Edward 
. ',,,,­

./ ./ 

Perpetual (H"olding) SAL ./
--------" "" .,-,-",--" ~,,-----

,~uryn~rr.!e_l~ldl~L~~,__ ,,,,, __,,,,,,~._,,,,,_~__,,.,_,_,_,".,,,_,,,' ,'-"'­ _"~'~~""~'''~_C__~'' 

Nasrallah Wadih Adel--_. ~__''''''''''''~~'_M'''''~N~_____''''''''_.~~mq.____ _w ¥_-.----­
Wan Invest SA ./ 

Nest Investments Holding Lebanon SAL ./ .__..,~u ",._­

Trust International Insurance and Reinsurance Co. (Trust Re) • 
'" 

Jordanian Expatriates Invest. Holding Co. ./ 
.....~~----"--, ,---­ 1-­

Qatar General Insurance and Reinsurance Company S.A.Q " II ,-_.",,--,­ ;..-"'''----­

Abu Nahl Ghazi Kamel Abdul Rahman ,,--­ ~----".----~--~---. 

Abu Nahl Jamal Kamel Abdul Rahman 
I 

Compass Insurance SAL 
,,~--- " 

!:~~!,~nte~~!~':!.!llnSura~_~£.<>,,~e~_~YJ£.'iPEus) L~~~t:c!,__, __ ,_~"" 
" 

AI Thani Nasser Ali Saoud Thanl 

Abu Nahl Fad! Ghazi~~~~N~"_____~__________ 

Abu Nahl Hamad Ghazi 
,,, 

Abu Nahl Kamel Ghazi - ". 
Zard Abou Jaoude Edward Jerjes ./ 

Dlab Ray",u"... Nasri I 
./ 

............ 
" 

Makari Makarem Nabil ./
,---­ "~~~,--------

Abou Jaoude Carlos Antoine 
~w_~~~____._____w"""'___~"~'~"""'N~~' ••••,_ -,-
Kapital (Holding) SAL_~__~_'""'__'"_"____,~'''''_~,, 

Gretta Ibrahim Ghafari ./ 
__~ ......""""_~___n~__¥.N'~'__'_,__._,__,,__~_ 

"'~--,---, ~~~..,.,..,..~-,-" ~---..--
Ghassan Wadih Haikal ./ 

Total 11 1 1 . Z 
_.~_,___~~,_·____""""'~_~__·_~~".'~__'~r __•••'"~_"_~_~n'_""""_¥~N_'~'" .. ,-~-

I/r In April 20.1.2, the shareholder "Trust International Insurance and Reinsurance Company (Trust Re)" trans/erred all its shares 

(6,240,000 shares) to another shareholder 0/ the group, namely Nest Investments Holding Lebanon SAL