9/11 Commission Documents Related to Insider Trading Investigation (updated 6 December 2009)

This post lists a set of documents related to the 9/11 Commission’s investigation of allegations of insider trading before the attacks of September 11. The documents have been posted at the History Commons site at Scribd. I am reading through them gradually and highlighting interesting information. This post will be updated continuously.

Records Obtained

(-) Various 9/11 Commission documents:

(1) A workplan for the commission’s investigation of insider trading allegations.

(2) Document Request Number 1 to the NSA. It asks for counterterrorism reports for specific periods, finished intelligence products about al-Qaeda, after-action reports for significant terrorist attacks, and other documents. It does not ask raw intelligence. Items 2, 5 and 6 are unredacted elsewhere.

(3) Key Questions about the financing of the 9/11 plot. It says there is a gap between what some of the hijackers spent and received.

(4) Draft document request to FBI concerning the financing of the 9/11 plot and other FBI operations against al-Qaeda financing.

(5) A later draft of the same document request.

(6) A briefing request for the CIA about al-Qaeda financing and money for the 9/11 plot.

(7) A document request for the Office of Foreign Asset Control about measures against terrorist financing.

(8) An internal memo about requests for briefings about terrorism finance by various agencies.

(9) A draft document request for the Securities and Exchange Commission. It asks for material related to insider trading allegations.

(10) A document request for FinCEN. It asks for material related to terrorist financing.

(11) A document request for the US Treasury Department.

(12) Another version of the CIA briefing request.

(13) A commission e-mail with a document request for the FBI.

(-) A letter from the Securities and Exchange Commission to the 9/11 Commission about possible insider trading related to 9/11. The SEC tells the commission it will not yet provide it with some documents the commission has requested; the documents were supplied to the SEC by foreign partners and these partners have to approve their provision to the 9/11 Commission before they can be passed on.

(-) Letter from the Securities and Exchange Commission (SEC) to the 9/11 Commission about the confidentiality of information. The letter says that the commission should remind the National Archives that documents the commission obtained from the SEC but are confidential (because, for example, they are from foreign governments with a confidentiality agreement) cannot be disclosed by the Archives, after the commission’s records are transferred there.

(-) A chart found in the 9/11 Commission’s records showing numbers of call and put options in United Airlines and American Airlines stock between August 20 and September 10, 2001.

(-) E-mail to the 9/11 Commission from Jean Cawley of the Options Clearing Corporation about the allegations of insider trading related to 9/11. Cawley says there was no significant money “left on the table” for the September 2001 expiration of options.

(-) SEC Fax to 9/11 Commission about allegations of insider trading before 9/11. The fax forwards information from the Options Clearing Corporation about trading in options for United  Airlines on September 6 and American Airlines on September 10.

(-) A letter from the Securities and Exchange Commission (SEC) to the 9/11 Commission’s counsel Daniel Marcus. The SEC says it cannot yet provide the commission with information it received about alleged 9/11 insider trading from foreign partner bodies as it does not yet have their consent to disseminate such information to the commission. It will now ask for their consent to do so.

(-) A letter from the 9/11 Commission to the Securities and Exchange Commission about allegations of insider trading related to 9/11. The letter says that the SEC’s reasons for withholding documents about the allegations provided to it by foreign partner bodies are spurious. The SEC’s interpretation of documents it claims prevent it from sharing the information from its foreign partners is called “wooden and restrictive.”

(-) Questions drafted by the 9/11 Commission about allegations of insider trading related to 9/11. The questions are about how the investigation was conducted by the SEC and FBI.

Withdrawal Notices

(-) A withdrawal notice for a chronology of US and foreign markets between September 17, 2001 and October 20, 2001. The document was part of the 9/11 Commission’s archives and presumably relates to allegations of insider trading related to the attacks.

(-) A Withdrawal notice for 9/11 Commission document, related to “suspicious financial transactions.”

(-) A withdrawal notice for a 38-page document about the 9/11 insider trading allegations.

(-) A withdrawal notice for 23-page FBI 302 about allegations of insider trading related to the 9/11 attacks. The document was part of the 9/11 Commission’s files.

(-) A withdrawal notice for 20-page FBI 302 about allegations of insider trading related to the 9/11 attacks. The document was part of the 9/11 Commission’s files.

(-) A withdrawal notice for 129-page FBI 302 about allegations of insider trading related to the 9/11 attacks. The document comprises reports on trading activity designed to profit or avoid loss from 911 and was part of the 9/11 Commission’s files.

(-) Withdrawal notice for 16 pages of 9/11 Commission notes on a meeting with Joseph Cella about the investigation into allegations of insider trading related to 9/11.

(-) Withdrawal notice for a 3-page document from the 9/11 Commission’s files containing a table of foreign regulators related to the commission’s allegations of insider trading.

The masterlist for all documents the History Commons has obtained and is analysing can be found here.