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Hiya - let’s talk about Aramco...Volume I of III

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Posted on November 10 2019


Just a quick note from me to you:

My deepest apologies for my protracted absence. As some of you may know I had a tiny medical emergency in early October. At the time, I did not have Emergency GI surgery on my bingo card. Understandably this sidelined me for much longer than I expected. Notwithstanding I am probably the worst patient, ever...the unexpected post surgical complications, resulted in a slower than expected recovery.. Setting aside the various setbacks, I am in fact, albeit slowly getting back to my old self. This comes at much needed relief  to my clients, family and friends. Again I’m sorry I went MIA but I’m back.



Saudi Arabia Prince Bone-Saw & Kushner

Just two young men using each other to prop the other one up...Kushner giving MbS-Bone-Saw our Intelligence to wit he imprisoned, tortured & murdered other members of the Saudi Royal Family. Kushner’s 666 Fifth Ave property suddenly flush with cash...I’m certain there’s nothing there - there. Right?



2018 Primer- Khashoggi & MbS


In the Fall of 2018, shortly after the public reporting of the barbaric and pre-meditated murder of Washington Post Journalist Mr. Jamal Khashoggi - like many i was horrified. As new details emerged my horror turned to outright anger. Because the details reported by the Washington Post (and other reputable news organization) of just how much Donald Trump and Jared Kushner gave Saudi Arabia “cover” that’s the precise moment I decided to channel my rage into something quasi-productive. You might find this Saudi Arabia FARA write up helpful. 

In the aftermath of Mr. Khashoggi’s murder, those of us in DC started to genuinely question the Trump Administration and specifically Jared Kushner - potential failure to adhere to the:


Intelligence Community Directive 191: Duty to Warn, July 21, 2015


“...will provide warning regarding threats to specific individuals or groups of intentional killing, serious bodily injury, and kidnapping..”


It is still largely unclear if the Trump Administration ever followed this Directive. However on October 8, 2018 the Washington Post, reported that our Intelligence Community had intercepts


Before Khashoggi’s disappearance, U.S. intelligence intercepted communications of Saudi officials discussing a plan to capture him, according to a person familiar with the information. The Saudis wanted to lure Khashoggi back to Saudi Arabia and lay hands on him there, this person said. It was not clear whether the Saudis intended to arrest and interrogate Khashoggi or to kill him, or if the United States warned Khashoggi that he was a target, this person said.”



We also know that almost immediately after the public reporting of Mr. Khashoggi’s disappearance and probable murder,  on October 12, 2018  the following joint statement from Smith, Engel, and Schiff - Demanding Action on the Disappearance of Saudi Journalist Jamal Khashoggi. The same day Representatives Royce and Engel sent a bipartisan letter to the White House


“Mr. President, we value our relations with Saudi Arabia. Yet murder and other blatant violations of international norms and agreements cannot be done with impunity. We look forward to hearing from you about any investigation on this matter and potential consequences.


To date it remains unclear that the Trump Administration adhered to the IC Directive 191- Duty to Warn. The Administration’s pernicious failure to provide the most basic information to Congress. And absolute refusal to provide theAmerican people a fulsome and transparent answer to that specific question is deeply problematic. This link will take you to a “search” of the House Foreign Relations Committee concerning the events in the immediate aftermath and recent legislation. We still deserve an answer from the Administration.


This becomes especially concerning given Spector’s November 4, 2019 Report, as Cockburn notes “of true...could be deadly for Jared Kushner” the vacuum Cockburn’s article it is not intellectually honest to believe the Trump-GOP narrative that there’s “nothing to see here” do so, would be at the peril of our Democracy and equally important our Country’s National Security. Again as Cockburn notes:


“A second source tells Cockburn that this is true and adds a crucial twist to the story. This source claims that Turkish intelligence obtained an intercept of the call between Kushner and MBS. And President Erdogan used it to get Trump to roll over and pull American troops out of northern Syria before the Turks invaded,”


If you view this in a much broader context. Meaning take your foot off the gas pedal and pull way back to Kushner’s October 2017 “off book” secret rendezvous with becomes increasingly clear that Congress needs to know exactly what did Kushner give MbS-Bone-Saw. Given that Kushner flew to Saudi Arabia via a commercial flight, thereby “slipping” his protective security detail. What promises were made, what was given, what was agreed to - on our Country’s behalf. Also not that this matters but this datapoint is consistently overlooked: the October 2017 “secret trip” was Kushner third trip to Saudi Arabia since January 20, 2017.


“The Senior Advisor to the President, the Deputy National Security Advisor for Strategy, and the Special Representative for International Negotiations recently returned from Saudi Arabia," a White House official told Politico in a statement. "The Senior Advisor has also been in frequent contact with officials from Israel, the Palestinian Authority, Egypt, United Arab Emirates, Jordan and Saudi Arabia."


More over Kushner’s October 2017 trip came just days before (then) Special Counsel Mueller unsealed the first Indictments - charging Paul Manafort, Rick Gates and George Papadopoulos...Why does this matter?  It’s the timing and subsequent sequence of actions taken by Trump Administration and Saudi Arabia. Kushner purportedly caught a commercial flight on Wednesday October 25, 2017 and returned to Washington DC on Saturday October 29, 2017. 

As a reminder, on October 30, 2017, note this was the day after Kushner returned from his “secret” Saudi Arabia Trip - the Special Counsel’s Office unsealed the following Indictments, charging Paul Manafort, Richard Gates and George Papadopoulos 



U.S. v. Paul J. Manafort, Jr. (1:17-cr-201, District of Columbia)

Paul J. Manafort, Jr., of Alexandria, Va., pleaded guilty on September 14, 2018, to a superseding criminal information filed today in the District of Columbia, which includes conspiracy against the United States (conspiracy to commit money laundering, tax fraud, failing to file Foreign Bank Account Reports and Violating the Foreign Agents Registration Act, and lying and misrepresenting to the Department of Justice) and conspiracy to obstruct justice (witness tampering). On March 13, 2019, Manafort was sentenced to serve 73 months in prison, with 30 months to run concurrent with his sentence in the Eastern District of Virginia.

Superseding Criminal Information 


Plea Agreement

Statement of the Offense


U.S. v. Richard W. Gates III (1:17-cr-201, District of Columbia)

Richard W. Gates III of Richmond, Va., pleaded guilty on Feb. 23, 2018, to a superseding criminal information that includes: count one of the indictment, which charges conspiracy against the United States, in violation of 18 U.S.C. 371 (which includes conspiracy to violate 26 U.S.C. 7206(1), 31 U.S.C. 5312 and 5322(b), and 22 U.S.C. 612, 618(a)(1), and 618(a)(2)), and a charge of making false statements to the Special Counsel’s Office and FBI agents, in violation of 18 U.S.C. 1001.

Superseding Criminal Information

Plea Agreement

Statement of the Offense


U.S. v. George Papadopoulos (1:17-cr-182, District of Columbia)

George Papadopoulos, of Chicago, Illinois, pleaded guilty on Oct. 5, 2017, to making false statements to FBI agents, in violation of 18 U.S.C. 1001. The case was unsealed on Oct. 30, 2017. On Sept. 7, 2018, Papadopoulos was sentenced to serve 14 days in prison, pay a $9,500 fine, and complete 200 hours of community service.

Criminal Information

Plea Agreement

Statement of the Offense



Incidentally shortly after Kushner returned to DC, on November 4, 2017 the Washington Post David Ignatius reported the following tidbit:


“The two princes are said to have stayed up until nearly 4 a.m. several nights, swapping stories and planning strategy,” 


What is also overlooked is this random November 4, 2017 Tweet by our esteemed Commander-in-Chief. Again note the date and content of his tweet, it is important and I’ll address this datapoint further in this entry. For now it’s a place maker:



Of the copious tweets, I find it intriguing that Trump has only tweeted about Saudi’s Aramco ONCE, see his twitter archive, found here





Subsequently thereafter, in the early Spring of 2018, MbS-Bone-Saw began his Public Relations tour of America (as previously detailed here). New details emerged as to the “closeness” of the relationship between a murderous thug and our little boy-wonder Jared Kushner. Apparently the two enjoy long late night conversations, slow walks on the beach and holding hands watching the sunset. I’m actually kidding. There’s ample public reporting that MbS-Bone-Saw and Jared Kushner regularly communicate via WhatsApp. That there’s a fondness between both men. What is actually pretty clear is  - in the after Mr. Khashoggi’s barbaric murder Kushner was MbS-Bone-Saw de-facto Crisis and Public Relations advisor.

Perhaps if Jared Kushner had the actual balls to listen to the audio tapes of MbS-Bone-Saw’s assassin-crew dismember Mr. Khashoggi body, he might rethink his cozy-best-friends-forever “Friendship” with MbS-Bone-Saw. In fact Trump and his cabal of “strong and very powerful” men lacked the intestinal fortitude to listen the the audio, instead they demurred and sent CIA Gina Haspel. Think about that, for a man who’s obsessed with his image of being “strong and powerful” Trump (Kushner, Pompeo, Bolton) none of them had the guts to listen to that grisly audio.

Moreover MbS has bragged about “having Kushner in his pocket” - this matters for a variety of reasons. In February of 2018 Kushner had his security clearance down graded. The following March 22, 2018 CBS News Segment highlights the numerous areas of concern.  



I’ve repeatedly stated that if anyone of us had amended our SF86 as many times as Jared Kushner and Ivanka Trump have - no ambiguity - we would be in jail, facing a multi-count Criminal Indictment and our clearance would be immediately suspended. The reality is— Trump has turned our Department of Justice into - any criminal referrals of Jared Kushner and Ivanka Trump will go no where. Based on the preponderance of evidence in the public domain, it is absolutely clear that Roy Cohn 2.0 continues to enable Trump’s lawlessness.


I can not emphasize enough how much of a National Security risk Jared Kushner and Ivanka Trump are. Moreover the “transactional” nature that is the Trump foreign and Domestic Policy Doctrine has set asunder America’s “leadership” & harmed our Global-Moral Authority. Trump’s entire presidency has been a complex gambit of “how to get rich” and laughing all the way to the bank. Which now brings us to the ugly underbelly of the Aramco IPO and crossing the streams of FARA, unjust enrichment and who exactly is Trump governing for...



Saudi - Aramco IPO and FARAs


As widely reported on Saturday November 9, 2019 Saudi’s Aramco published its prospectus for their IPO. This is the general landing page, you’ll note that there’s a pull down window, if you are in America - do NOT select the United States otherwise you get the following “pop-up”




Or you can simply click on this Aramco link, to download the 600+ page prospectus. When reviewing any prospectus I tend to focus in on the litigation disclosures, projected market capitalization and other acquisitions. Case in point I found pages 105 and 106, respectively - a pretty interesting read:


“The Company has been subject to significant litigation, primarily in the United States and the Kingdom. Some of the most significant U.S. litigation involved allegations of violations of antitrust laws arising, in part, from the Kingdom’s membership and participation in OPEC....”



Foreign Sovereign Immunities Act - Sidebar:

To be fair Aramco has been largely successful in their arguments - specifically using Foreign Sovereign Immunities Act FSIA, codified at Title 28, §§ 1330, 1332, 1391(f), 1441(d),and 1602–1611. This link will take you to the aforementioned statutes, specifically 90 Stat. 2891 (statues at large)


United States Statutes at Large, Volume 90, 94th Congress, 2nd Session; Foreign Sovereign Immunities Act; A bill to define the jurisdiction of U.S. courts in suits against foreign states, the circumstances in which foreign states are immune from suit and in which execution may not be levied on their property, and for other purposes; Public Law 94-583


As the FSIA explains, there are actually three objectives; “1) to transfer responsibility for immunity determinations from the Department of State to the judiciary; 2) to define and codify the "restrictive" theory of immunity; and 3) to provide a comprehensive, uniform regime for litigation against foreign states and governmental agencies”

Notable FSIA Cases


During the course of our country’s vast judicial history, the following are considered as “notable” FISA cases:


Samantar v.Yousuf 560 U.S. 305 (2010)


Question(s) before SCOTUS:

1) Does a foreign state's FSIA immunity from suit extend to an individual acting in his official capacity on behalf of the foreign state?

2) Does an individual who is no longer a government official of a foreign state at the time suit is filed retain FSIA immunity for acts taken in that individual's former capacity as a government official acting on behalf of a foreign state?

 In an unanimous decision, SCOTUS held:

No. No. The Supreme Court held that the FSIA does not govern Mr. Samantar's claim of immunity. With Justice John Paul Stevens writing for the majority, the Court reasoned that there is nothing to suggest that "foreign state" within the FSIA should be read to include an official acting on behalf of that state. The Court further reasoned that the FSIA's legislative history did not indicate that Congress intended to codify official immunity within the FSIA.


Doe v. Holy See, 557 F.3d 1066 (9th Cir. 2009)

Questions before the Court:

The Foreign Sovereign Immunities Act of 1976 (FSIA), 28 U.S.C. 1330, 1602 et seq., establishes that foreign sovereigns are presumptively immune from suit in United States courts, 28 U.S.C. 1604, unless a claim falls within one of the exceptions to immunity enumer- ated in 28 U.S.C. 1605 and 1607. The tort exception to immunity permits claims against a foreign state based on “the tortious act or omission of that foreign state or of any official or employee of that foreign state while acting within the scope of his office or employment.” 28 U.S.C. 1605(a)(5).

The question presented is whether Section 1605(a)(5) authorizes a court to exercise jurisdiction over respondent’s vicarious liability claim against petitioner, the Holy See, for a priest’s sexual abuse committed in Ore- gon, where sexual abuse is outside the scope of the priest’s employment as a matter of Oregon law.


In short the Vatican requested that the 9thCCOAs and subsequent SCOTUS to stop an Oregon Lawsuit. The lawsuit accused the Vatican of intentionally transferring a priest from city to city in an attempt to shield the priest from criminal and civil actions. The evidence adduced during the district court case, particularized the Vatican’s actions even in the face of repeated sexual abuse accusations. The appeal by the Vatican, focused on testing whether it (as an entity) is immune to damages awarded in various lawsuits for the sexual abuse of minors by priests in the U.S in which the DOJ filed an Amici 


Federal Insurance v. Kingdom of Saudi Arabia

 In short after the 9/11 terror attacks numerous (and i mean dozens of) parties filed suit against the Kingdom of Saudi Arabia, see original complaint here. Accordingly the DOJ also filed an Amici in the above entitled case, found here, and while some might disagree with my position, the fact remains that 15 of the 9/11 hijackers were Saudi Nationals. This assertion was confirmed after the Senate Intelligence Committee released (their long awaited) Report, found here. After the protracted litigation (by all sides) SCOTUS held that some of the Saudia Arabian Defendants were immune, specifically under FSIA, see 2009 Reuter’s Article, found here.

If you’re somewhat confused, I get it. Remember that there were/are multiple lawsuits, but it’s important to remember once Justice Against Sponsors of Terrorism Act (JASTA) was codified this law afforded 9/11 victims families and -some- insurance companies to sue The Kingdom of Saudi Arabia for actual damages suffered as a result of the 9/11 attacks. It should be noted that in late October of 2019 in a stunning reversal the 2ndCCOAs breathed new life in to one particular case: Underwriting Members of Lloyd's Syndicate 2 v. Al Rajhi Bank, see 2ndCCOAs Order here.

To be clear there are hundreds if not thousands of cases currently working their way through our judicial system. So yes when I saw Aramco’s FSIA disclosure it kind of reset the narrative and made me curious to research what kind of financial impact this could have on the Kingdom of Saudi Arabia and Aramco especially as detailed on pages 297 and 298 of Aramco’s Prospectus



More on Aramco’s IPO 

With respect to Aramco’s prospectus they specifically address the US House of Representatives February 2019 Bill(s) - a cursory search of

...I was able to drill down on the following House and Senate Bills; 

H.R.948 - NOPEC and S370 - “No Oil Producing and Exporting Cartels Act of 2019’’ or ‘‘NOPEC’’...To amend the Sherman Act to make oil-producing and exporting cartels illegal” I could be wrong but I believe this particular section of the bill is what Aramco is most concerned about:

—It shall be illegal and a violation of this Act for any foreign state, or any instrumentality or agent of any foreign state, to act collectively or in combination with any other foreign state, any instrumentality or agent of any other foreign state, or any other person, whether by cartel or any other association or form of cooperation or joint action— 


In non-legalese and policy speak - this bill seeks to close the loophole within FSIA, specific to oil companies/conglomerates. Other notable (and arguably important) subsections of Aramco’s Prospectus - See Pages 34 thru 48 - this is why I specifically pointed out Trump’s November 4, 2017 tweet - because if you read the supporting materials of the prospectus you’ll note that a majority of the money backers - especially US based banks fell in to line shortly after Trump’s tweet...I am certain that’s just a random coincidence, right?



This is why it’s important to read a prospectus, as well as the supporting documents, And I might be in a bit of trouble - either way I uploaded their November 3, 2019 “floating notice” to my public drive, found here.

This is why you should read ALL the materials, for example I found this disclosure slightly eyebrow raising - mainly when you know that Aramco’s Market Cap is projected at >$1T as in Trillion to see the following disclosure is akin to the horrid OIL Too Big Too Fail.


Higher operating cash flow, Free Cash Flow, EBIT, EBITDA and Return on Average Capital Employed (“ROACE”) than each of the five major international oil companies (collectively, the “Five Major IOCs”, comprising ExxonMobil, Shell, Chevron, Total and BP)


Moreover Aramco states in their Upstream Competitive Strength

- Unique ability to capture value through active management of the world’s largest conventional hydrocarbons reserves base
-Unique operational flexibility to respond to changes in supply and demand
- Multiple crude grades and global crude oil delivery points
- Extensive high-quality gas reserves with exclusive access to the large and growing domestic marketplace





And lastly if you’ve made it this far in to the entry, quick question: how many FARA numbers do you think Aramco has?

Do you think it’s 5? NOPE

Do you think it’s 10? NOPE

Tomorrow I’ll publish a follow up to this entry. Given there’s a lot of ground to cover and it might be a bit of information overload. Notwithstanding I am presently downloading hundreds of filings and of course reading each one takes a bit of time. At any rate apologies for my long absence.  After all what else would I do now that I’m back on mandatory bed rest. Apparently when a surgical incision (8+ inches long) becomes infected, not once but twice the end result means is a slow recovery, more stitches and installing of “drain ports” all of which I resisted because I’m a type A personality and super stubborn so that’s the current state of play.

-SpicyFiles Out (but back, for now)


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1 comment

  • Lori: November 16, 2019

    So happy to see you back. I was worried that you had somehow been silenced. Best wishes for a permanent recovery.

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