9/11 – The Evidence For Insider Trading

Mark H. Gaffney | 25 May 2016

After 9/11, there were indications that traders with inside information had benefited financially from the terrorist attacks. It also appeared that the phenomenon was not limited to US markets. The list of affected nations was long and included, in addition to the US, Germany, Japan, France Luxembourg, the UK, Switzerland, Spain, and even Hong Kong.i One consultant, Jonathan Winer, told ABC, “It’s absolutely unprecedented to see cases of insider trading covering the entire world from Japan to the US to North America to Europe.”ii

Soon, independent investigations were underway on three continents, in the belief that the paper trail would lead to the terrorists. Press statements by leading figures in the international banking community left little doubt that the evidence was compelling. Ernst Welteke, President of the German Deutsche Bundesbank, told the Miami Herald that “a preliminary review by German regulators and bank researchers showed there were highly suspicious sales of shares in airlines and insurance companies, along with major trades in gold and oil markets, before September 11 that suggest … advance knowledge of the attacks. Welteke said that his researchers came across … almost irrefutable proof of insider trading.” Welteke himself was emphatic: “If you look at the movements in markets before and after the attacks, it really makes your brow furrow.… What we found makes us sure that people connected to the terrorists must have been trying to profit from this tragedy.”iii

In the UK, London City regulators investigated a flurry of suspicious sales processed just before the attack. A Financial Services Authority (FSA) spokesperson confirmed that market regulators in Germany, Japan and the US had received information about short selling of insurance company shares and airline stocks, which fell sharply as a result of the attacks. The FSA was “drawn into the investigation because it had a transaction monitoring department that checks suspicious share movements.” Richard Crossley, a London analyst, “said that he had tracked suspicious short selling and share dumping in a swath of stocks badly affected by the terrorist attacks.iv

Among the World Trade Center tenants were dozens of banks and insurance companies, including several that were now going to have to pay out billions to cover heavy losses from the attacks. Assuming nefarious individuals were armed with foreknowledge, they stood to make a windfall by dumping stock and selling competitors short, not to mention vast potential profits from last-minute electronic money laundering via computers which, the perpetrators had to know, would be destroyed within hours.

CBS also reported a sharp upsurge in purchases of put options on both United and American Airlines. A put option is a contract that allows the holder to sell a stock at a set price during a specified time period, which can reap huge profits should the stock plummet. The uptick had occurred in the days prior to 9/11.

Sources on Wall Street told CBS that they had never before seen that kind of trading imbalance. The only airlines affected were United and American, the two involved in the attack. American Airlines stock dropped 39% in a single day. United Airlines stock fell even more, a whopping 44%.v

Although many stocks tumbled, there were also big winners, especially in the military sector. Contractors like L-3 Communications, Alliant Techsystems and Northrop Grumman all reported large gains. The biggest winner, though, was Raytheon, which manufactures Tomahawk missiles. In the trading week of September 17-21, 2001, Raytheon stock climbed by an astounding 37%.vi On the day prior to 9/11, the purchase of call options for Raytheon had suspiciously surged by 600%.vii

The sale of five-year US Treasury Notes also spiked just before 9/11, as reported by the Wall Street Journal. Among the purchases was a single $5 billion transaction, which pointed to large investors: “Five-year Treasury notes are among the best investments in the event of a world crisis, especially one that hits the US. The notes are prized for their safety and their backing by the US government, and usually rally when investors flee riskier investments, such as stocks.” According to a Wall Street bond-market strategist: “If they were going to do something like this they would do it in the five-year part of the market. [Because] It’s extremely liquid, and the tracks would be hard to spot.” The article noted that the value of those notes rose sharply during the three weeks following the events of September 11.viii

The Securities and Exchange Commission led the US government probe of allegations of insider trading.ix For weeks, the SEC remained close-mouthed about the scope of its investigation; then it sent out a request to securities firms around the world for more information on trading in thirty-eight different stocks.x SEC Chairman Harvey Pitt told the House Financial Services Committee, “We will do everything in our power to track those people down and bring them to justice.”xi By this time, however, the fix was apparently in.

View the SEC’s list of 38 suspect companies here:

http://coto2.wordpress.com/2011/09/11/911-insider-trading-38-us-stocks/

The San Francisco Chronicle reported that the SEC took the unprecedented step of deputizing “hundreds, if not thousands, of key players in the private sector.” Wrote the Chronicle, “In a two-page statement issued to ‘all securities-related entities’ nationwide, the SEC asked companies to designate senior personnel who appreciate ‘the sensitive nature’ of the case and can be relied upon to ‘exercise appropriate discretion’ as ‘point’ people linking government investigators and the industry.” The requested information was to be held in strictest confidence. The SEC statement included the following passage: “We ask that you disseminate the information within your institution only on a need-to-know basis [my emphasis].”xii

In his book Crossing the Rubicon, former LAPD detective Michael Ruppert described the SEC’s move to deputize: “What happens when you deputize someone in a national security or criminal investigation is that you make it illegal for them to disclose publicly what they know … In effect, they become government agents and are controlled by government regulations rather than their own conscience. In fact, they can be thrown in jail without a hearing if they talk publicly. I have seen this implied threat time and again with federal investigations, intelligence agents, and even members of the United States Congress who are bound so tightly by secrecy oaths and agreements that they are not even able to disclose criminal activities inside the government for fear of incarceration … members of congressional intelligence committees … sign even more draconian secrecy agreements in order to get their assignments.”xiii

This surely means that Al Qaeda had nothing to do with the insider trading.xiv When the evidentiary trail led back to Wall Street, the SEC moved quickly to control the evidence and muzzle potential whistleblowers. Despite the best efforts of the SEC, however, a few details did leak to the world press. In mid-October 2001, The Independent (UK) reported, “To the embarrassment of investigators, it has … emerged that the firm used to buy many of the ‘put’ options – where a trader, in effect, bets on a share price fall – on United Airlines stock was headed until 1998 by Alvin ‘Buzzy’ Krongard, now executive director of the CIA.”xv

For the most part, the US press failed to pick up the story, which linked Wall Street and the US intelligence community to the 9/11 attacks. Indeed, even before the leak, some of the press had begun backing away from the early reports of insider trading. For example, in a story posted on October 1, 2001, the New York Times cited experts who attributed the spike in put options for United and American Airlines as most likely due to a slumping airline industry.xvi

George Tenet writes in his memoirs that in February 1998 he recruited Buzzy Krongard to become his Councilor,xvii in which capacity Krongard probably served as Tenet’s personal liaison to Wall Street. Krongard’s known ties to the CIA, however, go back at least as far as 1992.xviii In the mid-1990s Krongard served as a consultant to CIA director James Woolsey. Then he returned to finance and was named chairman of America’s oldest investment banking firm, Alex Brown and Sons, Inc., which in 1997 merged with Bankers Trust. In 1999, BT Alex Brown was in turn acquired by Deutsche Bank, the firm that placed the UAL put options.

In 1998, BT Alex Brown refused to cooperate with a Senate subcommittee that was conducting hearings on the involvement of US banks in money-laundering activities.xix At the time, BT Alex Brown, like other large US financial institutions, was in the business of private banking, meaning that it catered to unnamed wealthy clients, often for the sole purpose of setting up shell companies in foreign jurisdictions, such as on the Isle of Jersey, where effective bank regulation and oversight are nonexistent. According to Michael Ruppert, Krongard’s last job at Alex Brown was to oversee “private client relations,”xx meaning that Krongard personally arranged confidential transactions and transfers for the bank’s unnamed wealthy clientele.

Private banks typically offer a range of services to their clients for the purpose of shielding them from oversight. Private banks set up multiple offshore accounts in multiple locations under multiple names. They also facilitate the quick, confidential and hard-to-trace transfer of money across jurisdictional boundaries. In many such cases, the private banks do not even know who owns the account, which, of course, means that not even the bankers can follow the transactions with “due diligence.” Many private banks do not even try, for fear of scaring away business, especially from foreign clients. Even though private bankers are responsible for enforcing legal controls against money laundering, where such laws exist, in practice oversight is typically weak or nonexistent.

You may be surprised to learn that although it is illegal for US banks to launder ill-gotten money originating within the United States, it is perfectly legal for them to accept dirty money from elsewhere. Thus, many US banks openly solicit business from Central American drug lords, arms merchants and other shady entities.

Computer technology has also introduced a new level of anonymity, in the form of faceless transactions that do not require the intermediation of a financial institution. Internet money transfers and new payment technologies such as “e-cash,” electronic purses and other electronic payment systems have created new ways to disguise the source and ownership of illicit money, as discussed in a US Treasury report of September 2001 on money laundering.xxi

It is therefore little wonder that law enforcement has failed to stem the growing international proliferation of laundered drug money and other illicit assets over the past several decades. The failure has been truly spectacular. In 1999, a consensus of experts in Germany, Switzerland and at the US Treasury agreed that 99.9% of laundered money routinely escapes detection. The experts estimated that the annual total was between $500 billion and a trillion dollars, a mind-boggling number, about half of which is washed into the US economy, the rest into Europe.xxii

After Buzzy Krongard’s departure to the CIA, his successor at BT Alex Brown was his former deputy Mayo Shattuck III, who had worked at the bank for many years. In 1997, Shattuck helped Krongard engineer the merger with Bankers Trust, and he stayed on after Deutsche Bank acquired BT Alex Brown in 1999.xxiii

According to the New York Times, Bankers Trust was “one of the most loosely managed [banks] on Wall Street,” and during the 1990s was repeatedly rocked by scandal. In 1994, clients and regulators accused the bank “of misleading customers about its risky derivative products.” The case went viral when tape recordings were made public that showed bank salesmen snickering about ripping off naïve customers.

In 1999, BT Alex Brown pled guilty to criminal conspiracy charges, after it was revealed that top-level executives had created a slush fund out of at least $20 million in unclaimed funds.xxiv The firm had to pay a $63 million fine and would have been forced to close its doors but for the fact that it was purchased, just at this time, by Deutsche Bank, Europe’s largest. According to the New York Times, Mayo Shattuck III stayed on and was named “co-head of investment banking in January [2001], overseeing Deutsche Bank’s 400 brokers who cater to wealthy clients.”xxv Shattuck himself reportedly handled the private accounts of such dubious notables as Saudi financier Adnan Khashoggi and Seagram’s owner Edgar Bronfmann.xxvi His sudden unexplained resignation immediately after the 9/11 attacks must therefor be viewed as highly suspicious.

Shocking as all of this may sound, the CIA has a long history of quietly playing the stock market, and this may include illicit or insider trading. Such is the view of Victor Marchetti and John D. Marks, co-authors of a best-selling 1974 book, The CIA and the Cult of Intelligence. Marchetti was a former CIA analyst and Marks served at the State Department. Their well-researched book was one of the first to expose questionable CIA activities. Indeed, Langley was so threatened by the imminent release of their book that it attempted to block publication, though failed in the end, fortunately.xxvii

The authors assert that with the approval of top CIA leadership a small group of senior officers for years played the stock market using the CIA’s “employee retirement fund, certain agent and contract-personnel escrow accounts, and the CIA credit-union’s capital.” In more recent years, the assets likely included slush funds generated from the illicit sale of arms, possibly kickbacks from the drug trade, plus assets derived from a vast quantity of Japanese gold seized after World War II.

Initially, the CIA played the markets through a Boston-based brokerage house. But eventually the Agency economists, accountants, and lawyers concluded that the Boston brokers’ investment strategy was too conservative, and that they would do better on their own.

Marchetti and Marks go so far as to suggest that the CIA group may have engaged in insider trading on occasion, for example, in 1970 at the time of a major CIA covert operation in Chile to prevent the election of Salvador Allende. The CIA could easily have reaped a windfall by shorting Anaconda copper stock, which evidently tumbled as a result of the CIA’s political interference in the country. Given the Agency’s tradition of secrecy and the near total absence of fiscal accountability, certainly the potential for this kind of abuse was high, and remains so.

The CIA involvement in the stock market probably evolved over time, 9/11 being a logical outcome. No question, Marchetti and Marks’ early research bolsters the credibility of the leaked information linking the CIA’s number three executive Buzzy Krongard to the pre-9/11 insider trading scam.xxviii Was Krongard simply freelancing, or was inside trading part of a larger CIA covert operation?

The 9/11 Commission Report

Careful readers of The 9/11 Commission Report know that many of its most important details are buried in the endnotes. This is certainly true with regard to its discussion of the insider-trading flap. The text of the report itself casts no light on the subject, beyond pronouncing government investigations as “exhaustive” and exonerating of Al Qaeda (pp. 171-72):

There also have been claims that al Qaeda financed itself through manipulation of the stock market based on its advance knowledge of the 9/11 attacks. Exhaustive investigations by the Securities and Exchange Commission, FBI, and other agencies have uncovered no evidence that anyone with advance knowledge of the attacks profited through securities transactions.130

Endnote 130 is more detailed, though hardly more revealing (p. 499). It mentions that a “single U.S.-based institutional investor with no conceivable ties to Al Qaeda purchased 95 percent of the UAL puts,” a likely reference to Mayo Shattuck III:

Highly publicized allegations of insider trading in advance of 9/11 generally rest on reports of unusual pre-9/11 trading activity in companies whose stock plummeted after the attacks. Some unusual trading did in fact occur, but each such trade proved to have an innocuous explanation. For example, the volume of put options—investments that pay off only when a stock drops in price—surged in the parent companies of United Airlines on September 6 and American Airlines on September 10—highly suspicious trading on its face. Yet, further investigation has revealed that the trading had no connection with 9/11. A single U.S.-based institutional investor with no conceivable ties to al Qaeda purchased 95 percent of the UAL puts on September 6 as part of a trading strategy that also included buying 115,000 shares of American on September 10 [Commission’s emphasis]. Similarly, much of the seemingly suspicious trading in American on September 10 was traced to a specific U.S.-based options trading newsletter, faxed to its subscribers on Sunday, September 9, which recommended these trades. These examples typify the evidence examined by the investigation. The SEC and the FBI, aided by other agencies and the securities industry, devoted enormous resources to investigating this issue, including securing the cooperation of many foreign governments. These investigators have found that the apparently suspicious consistently proved innocuous [my emphasis]. Joseph Cella interview (Sept. 16, 2003; May 7, 2004; May 10-11, 2004); FBI briefing (Aug. 15, 2003); SEC memo, Division of Enforcement to SEC Chair and Commissioners, “Pre-September 11, 2001 Trading Review,” May 15, 2002; Ken Breen interview (Apr. 23, 2004); Ed G. interview (Feb. 3, 2004).

Evidently, we are supposed to presume that “American” in the above note means American Airlines. But here it could just as easily refer to American Express, which was also on the SEC’s suspect list. If the major trading of the unnamed “US-based institutional investor with no conceivable ties to al Qaeda” was truly hedged as The 9/11 Commission Report states, this would exonerate it of “informed” or insider trading. However, without more information, it is impossible to establish the facts regarding even this one particular investing institution.

As we know that thirty-eight firms were under investigation, the Commission’s token nod at the issue is unconvincing. What about the pre-9/11 surge in call options for Raytheon, for instance, or the spike in put options for the behemoth Morgan Stanley, which had offices in the South Tower? And what of the Greenberg insurance firm, Marsh & McClennan (also on the list, along with AIG), whose offices in the North Tower took the full impact of American Airlines Flight 11, and which also saw the second highest spike in pre-9/11 put option activity, second only to United Airlines?xxix One will search The 9/11 Commission Report in vain for any discussion of these or other suspect stocks. The truth, we must conclude, is to be found between the lines, in the Report’s conspicuous skirting of the whole insider-trading issue.

Three Academic Papers

The case for insider trading is strongly supported by three published scientific studies, all of which confirm an unusual volume in options trading in the days before 9/11. The first of these peer-reviewed papers was by Professor Allen Poteshman of the University of Illinois at Urbana-Champaign, and was based on trading data from the Chicago Board Option Exchange (CBOE). Poteshman’s study appeared in the respected Journal of Business, and should have been known to the 9/11 Commission because it was accepted for publication in 2004, while the official investigation was still underway. The Commission’s Final Report, however, makes no mention of it, probably because Poteshman’s conclusion that insider trading occurred, to a probability of 99%, flatly contradicts the official findings.xxx

The second study, by Professor Marc Chesney and two colleagues, one from the University of Zurich and another from the Swiss Finance Institute, examined in detail fourteen suspect corporations and found evidence of insider trading in a number of stocks, including American and United Airlines, Boeing, Merrill Lynch, J.P. Morgan, Citigroup and Bank of America.xxxi Chesney’s paper also refutes early reports that some inside traders failed to collect their winnings out of fear of exposure and subsequent arrest.xxxii On the contrary; the data shows that all of the 9/11-related put options were exercised, meaning that pay-outs occurred for each and every stock option. This was also confirmed by no less than Joseph Cella, the SEC official who headed up the SEC insider trading probe.xxxiii

Which of course means that the traders with foreknowledge of the attacks got away with their obscene winnings. The total pay out for the options studied by Chesney was an estimated $15 million. However, according to Paul Zarembka, an economics professor at the State University of New York (SUNY) at Buffalo, the total pay-out of all the options before and after 9/11 was probably on the order of $30 million.xxxiv

A third study by two Asian economists and a professor at the University of Wisconsin further embarrassed the 9/11 Commission by examining the Standard & Poor’s 500 Index, which according to the SEC and 9/11 Commission could not be investigated due to the high volume of trading.xxxv Nonetheless, when the professors did what was supposedly impossible, they found a “significant abnormal increase in the trading volume in the option market just before the 9-11 attacks.” The authors concluded there was “credible circumstantial evidence to support the insider trading claim.”xxxvi They also refuted the counter argument that the spike in options was due to a generally declining stock market. Incidentally, the SEC’s failure to investigate Standard & Poor’s fatally undermines the Commission’s description of the SEC investigation as “exhaustive.” Clearly, it was anything but.

In sum, three separate statistical studies by three academic teams all reached the same conclusion. The joint probability that all three were “nothing more than random outliers seems” in the words of economist Paul Zarembka, “astronomically low.”xxxvii Nor has anyone to date refuted any of the three important studies.

If the options trading in the days before September 11, 2001 was truly “innocuous,” as the 9/11 Commission repeatedly insists in its report, then why did the SEC muzzle potential whistleblowers by deputizing everyone involved with its investigation? The move by the SEC had the result of limiting the flow of information to those with a “need to know,” which, of course, means that only a very few participants in the SEC investigation, those at the top, had the full picture. Did the SEC judge that an open process was too risky, as it might expose the unthinkable?

This would certainly explain the SEC’s shredding of evidence. In 2009, David Callahan, executive editor of SmartCEO Magazine, submitted a Freedom of Information Act (FOIA) request to the SEC for copies of the documentary evidence of its insider trading probe. The SEC responded that it was unable to comply because “the potentially responsive records have been destroyed.”xxxviii The SEC’s response ought to have surprised no one familiar with the Commission’s long history of destroying records to cover up Wall Street crimes.xxxix

All of this hints at the likely frightening extent of criminal activity on Wall Street in the days and hours before (and during?) 9/11. The SEC was like a surgeon who opens a patient on the operating room table to remove a tumor only to sew him back up again after finding that the cancer has metastasized throughout the body.

At an early stage of its investigation, perhaps before SEC officials were fully aware of the implications, the SEC did recommend that the FBI investigate a number of suspicious transactions. We know about this thanks to a 9/11 Commission memorandum declassified in May 2009, which summarizes an August 2003 meeting at which FBI agents briefed the Commission on the insider-trading issue. The document indicates that the SEC had passed on the information about the suspicious trading to the FBI on September 21, 2001, just ten days after the attacks.xl

Although the names in the cases are censored from the declassified document, thanks to some nice detective work by Kevin Ryan we know whom (in one case) the SEC was referring to. Ryan was able to fill in the blanks because, fortunately, the government censor was not 100% efficient, and inadvertently left enough details in the document to infer the name of the suspicious trader. His identity, it turns out, is a stunner and should have been prime-time news on every television network, world-wide.xli

The trader was none other than Wirt Walker III, a distant cousin to then-President G.W. Bush. Several days before 9/11, Walker and his wife Sally purchased 56,000 shares of stock in Stratesec, one of the companies that provided security at the World Trade Center up until the day of the attacks. Notably, Stratesec also provided security at Dulles International Airport, where AA 77 took off on 9/11, and also security for United Airlines, which owned two of the other three allegedly hijacked aircraft. At the time, Walker was a director of Stratesec. You can’t get more inside than that. Incredibly, as if this were not shocking enough, president Bush’s brother Marvin also sat on the board! Walker’s investment paid off handsomely, gaining $50,000 in value in a matter of days. Given the links to the World Trade Center and the Bush family, the SEC lead should have sparked an intensive FBI investigation. Yet, in a mind-boggling display of criminal malfeasance, the FBI concluded that because Walker and his wife had “no ties to terrorism….there was no reason to pursue the investigation.” The FBI did not conduct a single interview.

The Recovered Hard Drives

The 9/11 Commission Report also fails to mention other compelling evidence for insider trading: the approximately four hundred computer hard drives found by workmen in the ruins of the World Trade Center. In December 2001, Reuters and CNN reported that US credit card, telecommunications and accounting firms had hired a German company named Convar to recoup data from the damaged hard drives. Convar got the contract because it had developed an effective method for recovering data using a cutting-edge laser scanning technology. Richard Wagner, a data-retrieval expert at Convar, told CNN that the new laser process made it “possible to read the individual drive surfaces and then create a virtual drive.” Convar had already examined thirty-nine hard drives and in most cases had succeeded in recovering 100% of the data; at least sixty-two more were in line for processing.xlii

By searching for encryption keys, indicating a financial record, Convar found evidence stored on the drives of an “unexplained surge” in large credit card transactions prior to the attacks. According to Reuters: “Unusually large sums of money, perhaps more than $100 million, were rushed through the computers as the disaster unfolded.” Evidently, the criminals wrongly assumed that it would be impossible to trace their transactions after the computers were destroyed.

Convar director Peter Henshel elaborated:

The suspicion is that insider information about the attack was used to send financial transaction commands and authorizations in the belief that amidst all the chaos the criminals would have, at the very least, a good head start … Of course, it’s possible that Americans went on an absolute shopping binge, that Tuesday morning. But at this point there are many transactions that cannot be accounted for. Not only the volume but the size of the transactions was far higher than usual for a day like that. There is a suspicion that these were possibly planned to take advantage of the chaos.xliii

Henshel was confident that those responsible would ultimately be exposed. Yet, after the initial reporting by Reuters and CNN, the issue of the WTC hard drives disappeared from the news, and nothing has been heard since. Although reports on the Internet that Kroll meanwhile purchased Convar remain unsubstantiated, it is nonetheless clear that someone made the story (and the evidence?) go away.xliv But why would anyone wish to do so unless the initial indications from Convar of insider trading were correct?

Related evidence for insider trading was also provided in chilling fashion by a Deutsche Bank New York branch employee who survived the attacks. The whistleblower, who insisted on remaining anonymous for his own protection, told Michael Ruppert that “about five minutes before the attack the entire Deutsche Bank computer system had been taken over by something external that no one in the office recognized, and every file was downloaded at lightning speed to an unknown location [my emphases].”xlv

Chilling indeed.

The second expanded/updated edition of Mark H. Gaffney’s book Black 9/11, originally published in 2012, will be released in September 2016. Mark can be reached for comment at markhgaffney@earthlink.net

Notes

i Dave Eberhart, “Still Silence From 9-11 Stock Speculation Probe”, NewsMax, June 3, 2002, http://www.newsmax.com/archives/articles/2002/6/2/62018.shtml.

ii World News Tonight, September 20, 2001.

iii William Drozdiak, “’Insider trading’ by terrorists is suspected in Europe”, Miami Herald, September 24, 2001, http://web.archive.org/web/20011109160700/www.miami.com/herald/special/news/worldtrade/digdocs/099922.htm.

iv James Doran, “Insider Trading Apparently Based on Foreknowledge of 9/11 Attacks,” London Times, September 18, 2001, archived at http://911research.wtc7.net/cache/sept11/londontimes_insidertrading.html.

v “Profiting from Disaster,” CBS Evening News, September 19, 2001, archived at http://www.cbsnews.com/stories/2001/09/19/eveningnews/main311834.shtml.

vi Less than a month after the attacks, Bloomberg News reported about suspicious imbalances in a number of sectors: “Bank of America among 38 stocks in SEC’s attack probe,” Bloomberg News, October 3, 2001, archived at http://911research.wtc7.net/cache/sept11/bloombberg_BAamong38.html. By September 2002, it was clear who the big winners were: Michelle Ciarrocca, “Post-9/11 Economic Windfalls for Arms Manufacturers,” Foreign Policy in Focus, September 2002, posted at http://old.911digitalarchive.org/objects/50.pdf.

vii “Bank of America among 38 stocks in SEC’s attack probe,” Bloomberg News, Wednesday, October 3, 2001.

viii Charles Gasparino and Gregory Zuckerman, “Treasury Bonds Enter Purview Of U.S. Inquiry Into Attack Gains,” Wall Street Journal, October 2, 2001. p. C.1.

ix According to a 9/11 Commission staff document, the SEC agreed to play the lead role at a multi-agency meeting held on September 17, 2001: John Roth, Douglas Greenburg, and Serena Wille, National Commission on Terrorist Attacks Upon the United States, Monograph on Terrorist Financing, Staff Report to the Commission. Although the document is undated, it probably was completed in 2004.

x The list included six airline stocks: American, United, Continental, Northwest, Southwest and US Airways, as well as Martin, Boeing, Lockheed Martin Corp., AIG, American Express Corp, American International Group, AMR Corporation, Axa SA, Bank of America Corp, Bank of New York Corp, Bank One Corp, Cigna Group, CNA Financial, Carnival Corp, Chubb Group, John Hancock Financial Services, Hercules Inc, L-3 Communications Holdings, Inc., LTV Corporation, Marsh & McLennan Cos. Inc., MetLife, Progressive Corp., General Motors, Raytheon, W.R. Grace, Royal Caribbean Cruises, Ltd., Lone Star Technologies, American Express, the Citigroup Inc., Royal & Sun Alliance, Lehman Brothers Holdings, Inc., Vornado Reality Trust, Morgan Stanley, Dean Witter & Co., XL Capital Ltd., and Bear Stearns; “Bank of America among 38 stocks in SEC’s attack probe,” Bloomberg News, October 3, 2001, see note 7.

xi Erin E. Arvedlund, “Follow The Money: Terrorist Conspirators Could Have Profited More From Fall Of Entire Market Than Single Stocks,” Barron’s (Dow Jones and Company), October 6, 2001.

xii Scott Winokur, “SEC wants data-sharing system,” San Francisco Chronicle, October 19, 2001, posted at http://www.sfgate.com/cgi-bin/article.cgi?file=/chronicle/archive/2001/10/19/BU142745.DTL.

xiii Michael Ruppert, Crossing the Rubicon (New Society Publishers, 2004), p. 243.

xiv Bloomberg News reportedly acknowledged the fact in a September 2003 newswire. Although the wire has since disappeared from the Internet, the text is archived at http://s15.invisionfree.com/Loose_Change_Forum/ar/t1699.htm.

xv Chris Blackhurst, “Mystery of terror ‘insider dealers’,” The Independent (UK), October 14, 2001.

xvi “Whether advance knowledge of U.S. attacks was used for profit,” New York Times, October 1, 2001, archived at http://www.hinduonnet.com/2001/10/01/stories/06010006.htm.

xvii George Tenet, At the Center of the Storm (New York: Harper Collins, 2007), p. 19.

xviii In 2014, Baltimore Magazine posted an interview with Ed Hale, chairman of the board of Baltimore Bank, who had just published a memoir, Hale Storm, in which he reveals how his Baltimore Bank, who had just published a memoir, Hale Storm, in which he reveals how his friend Buzzy Krongard recruited him in 1992 to work for the CIA. Amy Mulvihill, “Cameo: Ed Hale,” Baltimore Magazine, October 31, 2014.

xix Hearings before the Permanent Subcommittee on Investigations, 106th Congress, November 9 and 10, 1999, p. 87, posted at http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=106_senate_hearings&docid=f:61699.pdf.

xx http://www.fromthewilderness.com/free/ww3/10_09_01_krongard.html.

xxi “The 2001 National Money Laundering Strategy,” prepared by the Office of Enforcement, US Department of the Treasury, in consultation with the US Department of Justice, September 2001; p. 29 and note 19.

xxii Raymond W. Baker, “The Biggest Loophole in the Free Market System,” Washington Quarterly, Autumn 1999, p. 29, posted at (see p. 1061) http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=106_senate_hearings&docid=f:61699.pdf.

xxiii “Chief Steps Down At Alex Brown,” New York Times, September 15, 2001.

xxiv Timothy L. O’Brien, “The Deep Slush at Bankers Trust,” New York Times, May 30, 1999, posted at http://www.nytimes.com/1999/05/30/business/the-deep-slush-at-bankers-trust.html?src=pm.

xxv “Chief Steps Down At Alex Brown,” New York Times, September 15, 2001.

xxvi David Guyatt, Nexus Magazine, Vol. 10, Number 6, October-November 2003.

xxvii Victor Marchetti and John D. Marks, The CIA and the Cult of Intelligence (New York,: Dell Books, 1974), p. 55-57.

xxviii The leak connecting the pre-9/11 purchase of put options to Krongard and A.B. Brown is further supported by a 9/11 Commission document which identifies the “specific US-based options trading newsletter” that faxed its 2,000 subscribers a recommendation to buy put options on American Airlines on September 9, 2001. http://911myths.com/images/0/01/T-0148-911MFR-00139.pdf Also see Also see http://imgur.com/a/MPDpN

The newsletter was Steve Sarnoff’s Options Hotline, published by a Baltimore-based company known as Agora Financial, itself a subsidiary of a holding company also named Agora, one of whose founders, the late Gregory Barnhill, was a protege and close associate of Buzzy Krongard. (Barnhill reportedly committed suicide in 2012.) The bank A.B.Brown is also based in Baltimore.

More recently, Agora Financial has promoted the writings of economist James Rickards, who purports to be a financial adviser to the US intelligence community. In the first chapter of his 2014 book The Death of Money, Rickards absurdly argues that Al Qaeda was responsible for the pre-9/11 insider trading, an obvious and transparent attempt to divert attention from the actual insiders. http://research.agorafinancial.com/research/html/awn_bigdrop_0315/

xxix Kyle F. Hence, “Massive pre-attack ‘insider trading’ offers authorities hottest trail to accomplices,” Global Research, April 21, 2002. Posted at http://globalresearch.ca/articles/HEN204B.html

xxx Allen M. Poteshman, “Unusual Option Market Activity and the Terrorist Attacks of September 11, 2001,” Journal of Business, 2006, vol. 79, no. 4. Posted at http://www.jstor.org/stable/10.1086/503645?seq=1#page_scan_tab_contents

xxxi Chesney’s paper evolved through several drafts between 2010-2015, when the most recent peer-reviewed version was published. Marc Chesney, et al., “Detecting Informed Trading Activities in the Options Markets,” Journal of Empirical Finance, Volume 33, September 2015, pages 263–275; posted at http://www.sciencedirect.com/science/article/pii/S0927539815000262

xxxii Christian Berthelsen, Scott Winokur, “Suspicious profits sit uncollected,” San Francisco Chronicle, September 29, 2001, archived at http://www.sfgate.com/cgi-bin/article.cgi?file=/chronicle/archive/2001/09/29/MN186128.DTL.

xxxiii See the 2003 9/11 Commission interview with Cella, posted at https://cryptome.org/nara/sec/sec-03-0916.pdf

xxxiv Lars Schall, “Insight into the 9/11 Debate: Economists are scared,” Asia Times, April 27, 2012.

xxxv See the 9/11 Commission’s 2004 interview with Department of Justice official Ken Breen, posted at http://media.nara.gov/9-11/MFR/t-0148-911MFR-00074.pdf

xxxvi Wing-Keung Wong, et al, “Was there Abnormal Trading in the S&P 500 Index Options Prior to the September 11 Attacks?” Social Sciences Research Network, April 2010, http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1588523.

xxxvii Paul Zarembka, “Evidence of Insider Trading Before 9/11 Re-examined,” in The 9/11 Toronto Report, ed. James Gourley (Dallas: International Center for 9/11 Studies, 2013), p. 148.

xxxviii Email from David Callahan, July 10, 2013; also see http://www.washingtonsblog.com/2010/06/sec-government-destroyed-documents-regarding-pre-911-put-options.html

xxxix Matt Taibbi, “Is the SEC Covering Up Wall Sreet Crimes?”, Rolling Stone, August 17, 2011; posted at http://www.rollingstone.com/politics/news/is-the-sec-covering-up-wall-street-crimes-20110817

xl 9/11 Commission memorandum entitled “FBI Briefing on Trading”, prepared by Doug Greenburg, 18 August 2003, p. 4-5. Posted at http://media.nara.gov/9-11/MFR/t-0148-911MFR-00269.pdf.

xli Kevin Ryan, “Evidence for Informed Trading on the Attacks of September 11,” Foreign Policy Journal, November 18, 2010. Posted at http://www.foreignpolicyjournal.com/2010/11/18/evidence-for-informed-trading-on-the-attacks-of-september-11/all/1/

xlii Rick Perera, “Computer disk drives from WTC could yield clues,” CNN, December 20, 2001, posted at http://archives.cnn.com/2001/TECH/industry/12/20/wtc.harddrives.idg/.

xliii German firm probes final World Trade Center deals,” Reuters, December 17, 2001, posted at http://www.rediff.com/money/2001/dec/17wtc.htm.

xliv Michael Fury, “The Ghost in the Machines: Evidence of Foreknowledge in the WTC Hard Drive Recoveries,” Journal of 9/11 Studies, December 2008, posted at http://www.journalof911studies.com/volume/2008/GhostWTC.pdf.

xlv Michael Ruppert, see note 15, p. 244.

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