The prosecution in the Roger Ng Chong Hwa fraud trial in New York in relation to the theft of billions of dollars belonging to 1MDB, rested its case on Monday (April 4).

Assistant United States attorney Alixandra Smith summed up for the government.

Below is her summation.

The defendant, Roger Ng, played a critical role in a massive bribery and money laundering scheme to steal billions of dollars from the Government of Malaysia and use it to pay bribes to powerful government officials in Malaysia and Abu Dhabi.

What was that critical role? The defendant had to convince Goldman Sachs, the New York-based bank where he worked, to sign off on three bond deals that raised money for 1MDB, a company owned and controlled by the Malaysian Government. The money that Goldman was raising was supposed to go to projects for 1MDB to develop Malaysia's economy, but the defendant knew and agreed that the money would go instead to pay off government officials in Malaysia and in Abu Dhabi who were involved with the deals. He also knew that Goldman would never do the bond deals if Goldman knew that the money would be used for bribes, so he worked with Jho Low and with Tim Leissner to bring the bond deals to Goldman and to make them look legitimate, and he worked with Leissner and others to lie to Goldman's committees to hide information from those committees so that those committees would authorize the bond deals.

Why did he do it? Simple. Glory and agreed. The defendant was making millions of dollars a year as a banker at Goldman Sachs, but that wasn't good enough for him. He wanted the glory of bringing in the biggest deals that Goldman had ever done in Asia, to move up at the bank from managing director to partner; and, most importantly, he wanted the money he had been promised if the scheme succeeded, which ultimately was $35 million. $35 million. It's an almost incomprehensible amount of money for one person; and, truly, the numbers in this case are staggering. More than a billion dollars in bribes were paid to a dozen officials in the governments of Malaysia and in Abu Dhabi, including to officials at 1MDB and IPIC, and at Aabar. Low, himself, received more than a billion dollars. The numbers are so high that they start to sound meaningless, but let's not lose track of why the numbers are so high. It's because that money was supposed to go to help the people of Malaysia on a national level — billions of dollars to build roads, to improve the country's power grids, and to better their lives — and, instead, the defendant and his co-conspirators stole that money. The defendant took it to pay bribes, to make money for Goldman, and to make money for himself.

So let me take a moment to step back and give you a sense of what you are going to hear this morning. My job is to summarize the evidence for you. I won't be able to mention every single piece of evidence, otherwise we would be here for another two months, but I will help you piece together the evidence that you have heard from the witnesses who testified and all of the documents that you've seen so that you can see the big picture, and the big picture is this: There is overwhelming evidence that the defendant agreed with others to participate in the bribery and money laundering scheme I described, and he also agreed with others to hide key information from Goldman Sachs in order to fraudulently get the bond deals approved. As a result, he is guilty of the three crimes that he has been charged with.

The first crime is conspiracy to violate the antibribery provisions of the Foreign Corrupt Practices Act — or FCPA — by paying bribes to foreign officials to get business for Goldman. And, remember, I expect Judge Brodie to instruct you that a conspiracy is just an agreement. The second crime is conspiracy to violate the internal accounting controls provisions of the FCPA by circumventing or getting around Goldman's internal accounting controls by providing false information and concealing other information in order to fraudulently get Goldman's committees to authorize the deals.

And, finally, conspiracy to commit money laundering, which makes it a crime to send money in, out, or through the United States when the money is from a crime and the purpose of the transfer is to conceal the source of the funds; to send money in, out, or through the United States in furtherance of a crime; or to spend or transfer over $10,000 in dirty money in the United States.

So just two quick notes before we start walking through the evidence itself.

First, Judge Brodie is going to instruct you on the law after all of the summations are completed, and what she tells you on the law is what controls. However, towards the end of my presentation, I am going to preview some of the legal elements that we will prove beyond a reasonable doubt for each of these three crimes.

Second, because what lawyers say is just argument, you will not be able to get a copy of what I say or of the slides that I'm going to use to help us walk through the evidence today, but I will put on those slides and try and mention exhibit numbers and transcript sites for testimony as we go along — and you can take notes, if you'd like — and I expect that Judge Brodie will instruct you that you can ask to see any of the exhibits or testimony again as you deliberate. With all of that said, we're going to start today by doing what my colleague, Mr. Wible, talked about in his opening statement way back in February, and that is to follow the money.

We're going to look at the actions of the defendant and his wife, Hwee Bin Lim, and of Tim Leissner and his wife Judy from the moment when Project Magnolia was approved by Goldman's committees until when the transfers of money from the bribery scheme hit the Silken Waters Victoria Square account in June 2012, in July 2012, and then in September of 2013; and you are going to see that all of these actions are consistent with the defendant's guilt; that is, the defendant knew that the money came from his own crimes. That's why he and Ms. Lim urgently needed to open the Silken Waters Victoria Square account to take care not to be connected to that account and to lie about where the money in that account was coming from; and I further submit that you will see that the defendant's actions are inconsistent with what Ms. Lim testified about last week regarding the money. Once we do that, we'll take a step back and take a look at the broader schemes, and then walk through the evidence start to finish starting with the development of the defendant's relationship with Low in 2008, going all the way through the criminal conspiracies, and ending with the defendant's more recent conduct, including his deletion of email accounts that were used in furtherance of the schemes in an attempt to cover up his crimes.

So, as I said, let's start by following the money. This is a timeline of the period between May 18, 2012, when Goldman's committees approved Project Magnolia through July 16th, 2012, when the second of the first two transfers hits the Silken Waters Victoria Square account. This is a timeline that Special Agent Sean Fern walked through in great detail during his testimony, and I want to walk through it again today with you with some of the other evidence that we've seen in the case, because, as I said, it is consistent with the defendant's guilt and his knowledge that the money was coming from the bribery scheme.

So we're going to start May 18th, which is when the Goldman committees approved Project Magnolia; and, like I said, I will walk through all of this evidence and we'll come back to the timeline again at the end.

So on May 18th, the Goldman committee has approved Project Magnolia, and the first date that we're going to look at is May 20th, two days later; and on May 20th, both the defendant and Tim Leissner are taking actions to prepare to receive the money from the bribery scheme that they know is coming, and they both do this in a way that separates themselves from the money that's going to come in, so they're making sure that they're setting up accounts that are not in their name, or using accounts that are not in their name, to separate themselves from the money that's going to come in.

So the first thing that happens — this is Government Exhibit 2276 — is Tim Leissner, on his personal account, emails Judy Leissner and asks her to send him the account information for two shell companies that they already had, and he wants U.S. dollar denominated accounts because he knows the money is going to come in in dollars; and he says, we should also tell the bank that we will receive a transfer. This is May 20th, 2012. They think the money is coming in right after Project Magnolia closes. So he gets the information from the Capital Place account that he's ultimately going to use to receive the money.

At the same time, the defendant's wife, Ms. Lim, places a 22-minute call to UBS banker Evelyn Teah, and this is the call where Ms. Lim is setting up the account that she will use to receive the defendant's cut of his money from the bribery scheme. So, again, at the same time, this movement by both the defendant and Mr. Leissner, to prepare to receive the money that they know is coming. One day later, on May 21st, 2012, Goldman sends the funds from the Project Magnolia to the 1MDB Energy account — almost a billion dollars get transferred. Both the defendant and Mr. Leissner are notified of this because they are on the Project Magnolia email lists, and you can see that this was a transfer that went through a correspondent bank in the United States that was processing transactions in New York, so it is also a transfer that passed through the Eastern District of New York.

So as that money is moving on May 21st, 2012, let's see what the defendant is doing. So this is the point at which Ms. Lim, having had that conversation, is ready to set up the shell company and the bank account that's going to receive the money; and if we start with the email, which is Government Exhibit 2463,

Ms. Lim says at the bottom she — she, sort of, goes through that list of shell companies that was sent to her — and we call them shelf companies, because they were shell companies that were already set up — she picks the name Silken Waters, and says at the beginning she wants to have the name changed to Victoria Square. She also says to the banker, Evelyn Teah: I am quite easy to meet her at her convenient place — and she's talking about setting up a meeting in order to get the bank account set up — and it's important to note that she says "I am quite ready to meet her" — "I" and not "we," which means that this is an account that she's setting up — and she also tells the banker that they can drop by my place, my address, not where her parents were living in Terengganu, not where KC Tan was, but it's clear from every document that you are going to see that it is an account that Ms. Lim was setting up for herself and her husband and that they fully intended to use.

The other way that we know that it's an account for Ms. Lim and for the defendant is that the name is going to be changed to Victoria Square. That's the name of the defendant's daughter, who was born shortly thereafter, and it's the same name that the defendant and Ms. Lim used for all the shell companies that they set up in 2014 — those Victoria Corp. shell companies that Ms. Lim testified about. This was always going to be the defendant's account. The other way that you know that is because there's an email address at Victoria Square investment at Gmail that gets set up on June 17th, so — sorry, May 17th, which is — sorry, June 17th, which is right after the first transfers come in, and that account is the one — that email account is the one that is used by the defendant to monitor what is going on in the Silken Waters Victoria Square account, and we are going to see that as we walk through.

And, speaking of email accounts, on the same day that Ms. Lim sets up the meeting to set up the bank account, the KC Tan email is also created on that same day and the IP address that is used to create the KC Tan account is the same IP address that the Roger Ng 1 at Gmail address logs into in the same month; and so we know that this KC Tan email address was used to set up to impersonate Ms. Lim's mother-in-law and to keep track of what was going on in and out of the account.

So let's move forward one more day to May 22nd, 2012, and this is the day when the money is diverted from 1MDB Energy to that fake Aabar account. If you remember, Aabar is the subsidiary of IPIC — that's the entity that was going to give the guarantee for the bonds — and what happened was, in order to get the money out of 1MDB for the scheme, they set up that fake Aabar account at the BSI Bank — and we'll walk through how they did that — and that's the way in which the money gets siphoned out of the scheme. So one day after almost a billion dollars hits 1MDB Energy, that money gets diverted out of the account and into the fake Aabar account, which is where it's going to be sent out to all the co-conspirators from; and you know that it's Terence Geh who directed this payment, because, as we saw, he had signatory authority from 1MDB Energy, and he sends this email on May 22nd confirming that the money has been sent out of the account, and he sends it in part to Nik Faisal at SRC at Gmail, which is one of the accounts that you heard testimony about was used both by Nik Faisal and also by Jho Low. And, once again, this transfer is a transfer that went through the United States, and it was while CHIPS was processing in New York, so it traveled through the Eastern District of New York as well.

So as this money is being diverted from 1MDB Energy to the fake Aabar account, what is the defendant doing? So we know that the very same day, there was a meeting at the defendant's house, and that meeting was to set up the bank account for Victoria Square Silken Waters. It's the, again, exact same day, but the money is being sent from 1MDB Energy to Aabar. The money is being sent to Aabar at a BSI bank account, and that's really significant, because as we can see from the UBS records here, which are Government Exhibit 305, these, sort of, account opening summary and a summary of what UBS was told about where that money was going to be coming from, it says that Madam Tan explained that they have recently taken profit on our equity investments in Switzerland totalling about $26 million. As such, they intend to transfer these funds back from BSI to Asia. That BSI reference is really significant. BSI Bank, as you heard, is located in a place called Lugano, Switzerland. It is not a big bank; it is not a bank that you would, sort of, pluck out of the air and think of for a transfer, and the reason that the bank was told that the money was going to come from BSI is because the defendant had been at that meeting in Singapore exactly a month before at which he understood that the BSI bank account would be the bank account used by fake Aabar to take money out of the scheme; and in order to make these transfers sound legitimate, he told his bank that the money was going to be coming from BSI because he expected at that point in time to get the money directly from the fake Aabar account. It is not an accident that BSI Bank just happens to show up in the UBS documents as the place that the money is going to come from.

If we can go to May 23rd, we also know that the defendant and Ms. Lim were trying to set up this account urgently, and that's right there in the email from UBS Bank, which is Government Exhibit 346. They are setting the account up urgently because they know that the money is coming soon, and they expect the money to be coming soon, and they want this account ready to go, and they put it in the name of the defendant's mother-in-law, again, to conceal their connection to the account, to keep their distance from the account, and so they put it in the name of Tan Kim Chin, but you know that all of the contact information for Tan Kim Chin always includes contact information for Ms. Lim, and sometimes the defendant. Here, they put Ms. Lim's phone number for Tan Kim Chin, and the email accounts that they used for this account are the KC Tan 9983 at Gmail, which is the account that gets created by Ms. Lim and the defendant to, sort of, impersonate their mother-in-law, and also the victoriasquareinvestment.com email, which is the email that Ms. Lim admitted that she and the defendant used, and which was used to keep track of what was going on in the account.

And then the next day on May 24th, 2012, the opening documents for the account get signed. And, again, we're using the name Tan Kim Chin, but we're using Ms. Lim's phone number on the account.

The next day, May 25th, 2012, the proceeds keep moving through that waterfall, and this time they go from Aabar — the fake Aabar account to the Blackstone Asia Real Estate Partners account, which is another account controlled by Jho Low and by Eric Tan Kim Loong, and this is where the money is going to ultimately come from to go to Capital Place. So if you keep in mind that this is May 25th, this is only four days after the money is transferred from Goldman, so this is all happening very quickly.

On May 29, 2012, just four days later, Ms. Lim receives an email to her personal email account, so the Hwee Bin Lim at Gmail account from the personal email account of the UBS banker, which is important — they're, sort of, keeping all of this correspondence off any official channels, because anything that's done officially, she generally uses either the KC Tan 9983 email or the Victoria Square email to, again, keep her distance from the account; but, here, since she's getting it from the UBS's bankers personal account, she's using her own.

And you can see that the UBS banker says to her: Hi, Hwee Bin. Below is your account name and number with us — "your account name and number," because they're not communicating on the official channels. And you can also see that she's providing Hwee Bin with a U.S. dollar remittance form, which is the form that she will need to give to another bank to receive money in U.S. dollars. So, again, they are preparing right at the outset to receive a transfer of funds. And before we move to June, I just want to take a quick look at the contacts — the phone contacts charts that Special Agent Fern walked you guys through from May of 2012. And just looking at this, there's, sort of, three things I want you to keep in mind. One is that Leissner and the defendant speak practically every day from when the committees sign off on the deal until the end of the month; second, as you heard from Special Agent Fern, there were no communications between Judy Leissner and Ms. Lim, not just in this month, but in any of the months for which we had records going back to 2008; and, number three, I want to just, again, highlight that the concealment of the source of the money starts from day one. We already saw the lie that was told to UBS bank about the reason why they were getting money, and they're concealing their involvement in these accounts by using their wives to contact the banks, and the defendant is doing an extra layer of concealment by not just using his wife to contact the bank, but by putting it in the name of his mother-in-law.

So, if we move forward to June 5th of 2012, about a week in time, Leissner testified — and we're going to talk about this at length later — that they had expected to receive the money immediately when the deal closed — that was the reason for the urgency with the accounts — and then that didn't happen, they didn't get the money immediately, and they both started to get anxious; and in order to try and get things moving with Low, Leissner, at that point, offered up Capital Place. He said, I'm happy to, sort of, take on responsibility to do some of these transfers if that can get the money into us faster; and that's when the plan changed from getting the money directly from the Low accounts and from BSI to actually having Capital Place be involved in passing on some of the transfers. And you can see here that Leissner is sending the defendant — and, again, Leissner is sending the defendant, not Judy Leissner is sending Hwee Bin Lim, but Leissner is sending the defendant the Capital Place details for the bank account that is going to make the transfer to his account; and you can see that that's both on their personal email addresses, and it's the account details, and it's the information that the defendant will need to receive the bank transfer into his account, and that's on June 5th.

If we go forward to June 11th, that's exactly what happens next. $35 million gets transferred from Blackstone to Capital Place, which is Leissner's controlled account in his wife's name, and the money is then going to be split evenly. Exactly half of it is going to go on to the Silken Waters Victoria Square account.

And, again, before we look at the transfer itself, if we look at the phone contacts for June of 2012, we can see, again, that Leissner and Roger Ng are communicating by phone every day from the 11th when the money hits Capital Place to the 14th when the transfer to Silken Waters Victoria Square is finished; and Ms. Lim is also speaking to Ms. Khng, the UBS banker, every single day until the funds come in, and then they speak at length on the date that the funds actually hit, which is June 14th.

And here we have the confirmation of that payment itself, so that $17.5 million that gets transferred from Capital Place to the Silken Waters Victoria Square account is exactly half of the $35 million that Leissner had received in the Capital Place from the scheme; and, once again — we'll talk about this a lot — the wire transfer was one that was processed by CHIPS, so it passed through the United States, and it also passed through the Eastern District of New York, because it was a day on which CHIPS was processing its transfers to New York. So that's the first payment that comes in.

A few weeks later on July 9th, Capital Place gets the next transfer of criminal proceeds from Blackstone. That's the $16.96 million on July 9th, and we can see that on Eric van Dorn's chart, which is Government Exhibit 151, and then what happens after that is, again, very critical. So the money comes in on July 9th, it gets transferred out of Capital Place to Silken Waters Victoria Square on July 16th, and that's a transfer of $6.9 million; and what we see in this email, which is Government Exhibit 2297, is that Judy Leissner is emailing herself the information for the transfer that she is going to direct out of Capital Place and into Silken Waters Victoria Square. It's an email to herself; it is not an email to a bank or to anybody else. And in that email, she writes, for her own purposes, the true purpose of the transfer; and it says right there in big letters, "for Roger," because this is a transfer that she was being directed to make by Tim Leissner to the Silken Waters Victoria Square account on behalf of the defendant, Roger Ng. We are going to see this again when we look at the transfers in July, but this is one of the best ways that you know that this is the reason why this transfer is happening.

And, in fact, the transfer gets made on July 16th; it hits the account on July 17th — this is confirmation of the payment — and, once again, the transfer is sent by wire through the United States via CHIPS, and CHIPS is processing in New York at this point, so it also travels through the Eastern District of New York. And, once again, if we go to the call calendar for July of 2012, the defendant and Leissner speak almost every day between when the money comes into Capital Place and when the money hits the Silken Waters Victoria Square account. And, if you remember from Special Agent Fern's testimony, on July 16th, that's the day that Leissner and the defendant speak and that Leissner directs Judy to make the transfer for Roger. Leissner is in the United States on that date for work, and he was speaking to the defendant from the United States.

So, again, if we go back to the timeline of this critical period, we have, starting on May 18th, the Goldman committee has approved Project Magnolia; we have all of the steps the defendant and Ms. Lim take to set up the Victoria Square Silken Waters account urgently; we have the money moving out of 1MDB into fake Aabar, and then eventually to Capital Place and on to Silken Waters; we have all of the communications between the defendant and Leissner; and we have the emails that show that the transfer was for Roger; and all of the communications that show us that, again, the defendant and Leissner were preparing to receive their cut of the criminal proceeds at this time.

So in continuing to follow the money, I want to move forward to the second set of transfers that the defendant received as kickbacks in the time period from August to September of 2013; and, again, I'm going to walk through the underlying evidence, but this is the chart that Special Agent Fern testified about, and we are going to start on August 22, 2013.

What happens first is Ms. Lim calls the cell phone of one of the UBS bankers, and then we get here that UBS sends incoming wiring instructions to the Ng email addresses. So the fake KC Tan 9983 Gmail account, the one that's being used to impersonate the defendant's mother-in-law, and then the Victoria Square Investment at Gmail account. So following the phone call, they get this email, which is attaching, again, the information for wire transfers, and it's the information they're going to need to give to Capital Place in order to get the transfer. So they know at this point on August 22, 2013, that more money is going to be coming into the account.

And I want to just take a moment and pause on the Victoria Square Investment at Gmail account. I told you before that that account was created on June 17th, 2012, so shortly after the first transfer, and we have the testimony here from Ms. Lim last week at transcript page 4700, and she said that she created this account to have access to, quote, "all of the advisory, the research papers, or anything that I need to communicate that is otherwise not specifically for the purpose of the transactions that are going to be transacted in the account," and it's really significant that this testimony — that you think about this testimony and why this testimony is not credible, because you can see — and you will see it throughout the next few emails that we're going to look at — that this email account, which Ms. Lim admitted that both she and the defendant had access to, was not used to just get random research papers from the bank, but was, in fact, used to monitor the transactions that were happening in the bank as they were happening; and so it's important to, sort of, understand that and to keep in mind that that is why the defendant was using this email address — again, an email address not with his name, but to get the information — and you will see when information comes in that's important to the transfers, he then acts on it.

So moving forward to September 5th, 2012, this is an email from capitaladvisors@ymail.com, and you heard testimony that this was an account that Leissner set up similar to the Victoria Square Investment account, an email address that doesn't have his name and that he can use to discuss money transfers related to the crimes with. And this is an email that the subject line is "for next week," and it's an email where Leissner is directing Judy Leissner what to do and what transfers to make. He says "for next week" because that's when he's finally going to transfer money from Capital Place to the defendant, as Low had directed him to do, for their second round of payments for the kickbacks from the scheme. And just to keep in mind, as we move forward, two things. One, again, that this is Leissner directing his wife and not the other way around; and then just note that both the account number there and the name are slightly off; it was an old account number, and the name says Victoria Square Investments Limited, and that will become important in a minute. In the meantime, we move forward from September 5th to September 17th, the next week, as he says, and he resends that transfer information to Judy Leissner. And this, again, is one of the most important emails in the case, because what he says — if you can look, I, sort of, have one and two on the screen so you can see which email comes first on the chain; but, first, he basically resends that transfer information to Judy Leissner, and then Judy Leissner responds, and what she says is: 11, question mark. Sending 6.5 million from MS, the rest from Capital Place.

And it's crucial because it shows that Judy is asking Leissner, what is the total money that I should be sending to the Silken Waters Victoria Square account. It is completely inconsistent with Ms. Lim's story that it was Judy that was sending the money from some investment. In fact, it is Judy that has to check with Leissner to double check that she's sending the right amount of money to Roger Ng; and if there was any question, you should look at the rest of the email chain. Leissner follows up and says — first he says: Okay, thanks. And then he says: Actually, instead of the 11 million to Roger Ng, let's send 10.7 million, and let's keep the extra $300,000 for myself and put that in my account in Singapore. So, Judy, it's not 11 the way I might have told you before, it's actually 10.7.

And let's look at the next slide, which is the record of the transfers themselves, and we see that indeed what is going to happen is that a total of 10.7 million — not 11 million — is going to be transferred from Capital Place and Judy Leissner's Morgan Stanley account into Silken Waters Victoria Square. Again, this is entirely inconsistent with this being the final payment on some investment. In that case, Tim Leissner couldn't randomly change the amount of money that was being sent. What it is consistent with, and that what you already know from the evidence, is that this is a payment that Roger Ng was receiving for his participation in the criminal scheme, and Tim Leissner was directing Judy to make that payment; and when he did that, he changed the total amount from 11 to 10.7 because he kept $300,000 for himself. I want to take a very brief look to at what happens with the transfers themselves because I think this is additional evidence of the defendant's knowledge that the transfers were coming in.

Remember how I said when we were looking at the email that Leissner got two pieces of information wrong? He used an old account number, and he had the name of Victoria Square slightly wrong. Well, as we can see from these emails, the two transfers actually bounce back; they didn't go through because they had the wrong information. And look at who gets notified of the transfer issues. Both the KC Tan fake email account and the Victoria Square Investment at Gmail account; and that's, again, the defendant keeping track of what's going on with the transfers not randomly receiving research reports into that email account.

And, again, what we can see happens is that Leissner finds out that the transfers didn't go through, and he directs Judy on what to do instead. So he says: The receiving end made two typos. It reached UBS, but we need to resend the information.

And the two emails on the right are both emails from his phone to Judy, and it's Leissner instructing Judy what to do to fix the transfers because it's Leissner sending the money to the defendant. So first he says: The girl, Fanny Khng, at the bank needs the updated SWIFT instructions, and then he sends Judy Fanny Khng's contact information because he wants Judy to be the one dealing with UBS because, again, he's keeping himself — and the defendant is keeping himself — away from the transfers. Those two transfers ultimately reach the Silken Water Victoria Square account on September 23rd and September 24th, 2013; and, again, they were for that total of $10.7 million.

And then, once again, what do we see about what the defendant and Ms. Lim tell UBS about those transfers? And this is a call log, it's Government Exhibits 362 and 362A, and it says: Source of funds. Client was in a gold PE venture with her friends which has been liquidated. And then it says: She has two different portions percentages with two friends, because she's trying to explain why she's getting payments from two accounts in the millions of dollars on the same day from two different accounts; and so the explanation is this was a gold venture, and there were two people that she was in on it with, and one person was sending her from one account and one from another. You know that's not the truth. You know that the money came from the bribery scheme, but this is what they're telling the bank, and they're doing that, again, to separate themselves from this money.

So, again, just to recap, we start on August 22nd, 2013, with the call to the UBS banker's cell phone getting that U.S. dollar denomination information for the transfers because they know the money is coming in, and then all of the steps in between until the transfer is actually coming in, including the email chain between Tim and Judy Leissner where Tim Leissner is directing Judy how much money to send and when to send it to the defendant.

And then the last thing I want to note is just looking at all four transfers into the account, you heard testimony from Eric Van Dorn that these were the only four outside transfers that this account ever received, which is further evidence that the entire purpose of setting up this account was to receive the money from the criminal scheme, and we're going to see that again and again as we walk through the evidence in this case.

So, as I said, we wanted to start by following the money, because I think it's one of the clearest indications of the defendant's knowledge and intent and guilt, but what I would like to do now is just take a step back and do a quick overview of the larger bribery money laundering and circumvention schemes because I actually think that there's a lot about these schemes that is not in dispute. What is in dispute is the defendant's knowledge of them and his participation in them, and that is what I'm going to spend the rest of the morning talking to you about, but I want to, sort of, put it in the context of the larger scheme.

So you have seen over the course of the trial this chart a number of times, Government Exhibit Number 158, which just shows you the total payments out of the bond deals to all of the government officials; to Low, and the people associated with Low; and to the Goldman bankers, Leissner and the defendant, who were involved in the scheme. All of the various bank accounts that they used to receive the funds are up on the charts over there.

And we talked a little bit about the timing of the payments; sort of, Jho Low and some of the most significant government officials who needed to be bribed to receive their money first, starting on May 22nd, but we can see, again, that Tim Leissner and Roger Ng were incredibly critical to the scheme because they received their money early and first. They received their money June 11th and June 13th, their first payments, far earlier than many of the government officials who were involved in the scheme. And I think it will not be in dispute that the government officials who received the bribes in connection with the scheme played a role in the bond deals; they were all involved in somehow either approving the bond deals, or signing off on the bond deals, or would be available if there were issues with the bond deals to, sort of, help things move along.

So the first set of officials we have is from the Government of Malaysia. We have the prime minister of Malaysia, Najib Razak, as well as his wife, Rosmah Mansoor, and his stepson, Riza Aziz, all of whom received — Razak and Aziz received funds, and you heard about the jewelry purchases that were made on behalf of Rosmah Mansoor. You saw the documents, including Government Exhibit 3208, where Prime Minister Razak was signing off as the prime minister on the 1MDB bond deals because, again, 1MDB was part of the Malaysian Government.

We also saw that a number of the officials who received bribes all worked for Prime Minister Razak as advisors. You have Amhari Nazaruddin, Azlin Alias, and Yan Yahaya; and you also saw emails between the defendant and Nazaruddin, and between the defendant and Alias, related to Goldman business; and you remember that the defendant had contact information for both Nazaruddin and Alias backed up on his iCloud.

There's also not any dispute that 1MDB was owned and controlled by the government of Malaysia which means that anyone who worked for 1MDB was a government official of Malaysia and there is actually a stipulation that is Government's Exhibit 3801 about 1MDB.

The other Malaysia government officials who worked at 1MDB who got bribes, and these names have come up a lot and will continue to come up as we talk through the evidence today: Jasmine Loo, Zahid Taib, Terence Geh, Vincent Koh and Jerome Lee.

And then if we move to the Abu Dhabi end of the deals, if you remember, the government officials in Abu Dhabi needed to receive bribes because IPIC and Aabar were going to guarantee the bonds or agree to pay the bonds back if for some reason 1MDB could not.

So this is Sheikh Mansour. He's the chairman of IPIC and you can see that his name is on the letters that were exchanged in connection with the deal. There is no money in the bribe scheme that's been directly traced to Sheikh Mansour, but you can see when we go to the next page all of the money that went to other government officials in Abu Dhabi that may have been passed on to Sheikh Mansour as well.

And, again, there's no sort of dispute that IPIC and Aabar were controlled by the government of Abu Dhabi and, therefore, were sort of, anyone who worked for IPIC and Aabar were government officials of Abu Dhabi. And, again, that's Government Exhibit 3101.

And then here are the three Abu Dhabi officials who did receive payments for the scheme who all had a role in the bond deals. Al-Otaiba was the ambassador from the UAE to the United States and you heard Tim Leissner say that he needed to get paid because of his connections, if there were any issues with the bond deals, he would be able to sort of grease the wheels and knew what was going to go on. Al-Qubaisi was the managing director of IPIC and Al-Husseiny was the CEO of Aabar, the IPIC subsidiary, and all three of them received substantial sums, in the millions and millions of dollars, from the bond deals.

The next set of individuals who got paid in connection with the scheme were Tim Leissner and the defendant Roger Ng who needed to get paid for sort of bringing Goldman to the table and getting Goldman to sign off on these deals because they needed a legitimate, respected U.S. investment bank to get these deals done and they brought them to Goldman and these two were the ones who got it done. And, again, we also have both Hwee Bin Lim and Judy Leissner up here because their wives played critical roles in getting the money in and moving the money once they received it.

And then the final group of individuals who received payments from the scheme were Jho Low and his associates Eric Tan Kim Loong and Nik Faisal. We know that their names are sort of all over the bank accounts. Eric Tan Kim Loong is the named beneficiary of many of the accounts and Nik Faisal, the NikFaisalsrc@gmail is on a lot of the accounts, used both by Jho Low and by Nik Faisal. You'll remember that e-mail address was even in the Prime Minister's bank account as someone to contact in connection with the criminal proceeds that were coming into that account.

And I think there's no dispute that Jho Low is sort of very much at the center of what was going on. He was the key decision maker for 1MDB. Behind the scenes, he sort of set up the bond deals, he directed transfers and he received more than $1 billion. But I think what's really important and what we're going to walk through is that the defendant knew who Jho Low really was. He knew about the lavish spending, he knew about the close relationships with government officials, and those are the reasons that the defendant wanted to get close to Jho Low and wanted to tap into the money and the connections bringing in business for Goldman.

As we'll talk about a lot, the money from the bribes and the kickbacks was laundered to and through the United States. Both correspondent bank accounts were used that were processed through the United States and in many cases, through the Eastern District of New York, and in addition, there were payments that went from outside the United States into the United States. For example, "The Wolf of Wall Street" movie, that bank account was located in the United States as were a number of other bank accounts and a number of the payments for purchases were made from outside the United States into the United States.

Same thing. We're going to see this chart a lot. Just as a reminder, this is a kind of habit on the screen here, it is a six page chart, and all of the wires on the chart went through the United States. The ones in green both went through the United States and went through the Eastern District of New York. And as Eric Van Dorn testified, the wires on the chart are just examples of wires that went through the United States. There are actually many more wires in the scheme that went through the U.S. but we put some number of them on the chart for you.

So that's sort of the bribery and the money laundering. The last thing I want to give you is an overview about was the circumvention conspiracy, so the conspiracy at Goldman to get Goldman's committees to authorize the bond deals even though the bribes were being paid and if the committees had known that, they wouldn't have signed off. There were actually sort of four categories of information that the defendant, Leissner and a few other people, we'll talk about who those are, lied to the committees or withheld from the committees about: First, that 1MDB was going to be making these huge payments to the fake Aabar account in addition to the warrants that IPIC was receiving; second, that the bond deals themselves, the Leissner bond deals, would be used to pay bribes and kickbacks; third, that Jho Low is the key decision maker for the deal and we're going to see that that was something that was of great concern to Goldman; and, fourth, that both Roger Ng and Tim Leissner had a personal stake in the financial outcome of the transactions because if the transactions went through, they were going to get paid those kickbacks. So all of that information, there's no dispute that that information did not get shared with the Goldman committees.

Then I think there are a number of facts about the defendant himself that are not sort of in dispute and the evidence will show this clearly. He had a long-standing relationship with Jho Low which we're going to walk through. He had personal relationships with many of the co-conspirators including Leissner, Loo, Terence Geh and Jerome Lee. There's no dispute that he worked on the bond deals at Goldman. There's no dispute that he communicated with and met with Jho Low in furtherance of the 1MDB bond deals and you are going to see those meetings and e-mails. There is no dispute that he did not disclose Low's involvement in the bond deals to Goldman Sachs. There's no dispute that criminal proceeds from the bond deals were received by Silken Waters/Victoria Square and that account was in the name of his mother-in-law. And there's no dispute that those criminal proceeds were transferred to other accounts in the name of Ng's relatives.

So what is in dispute, as I said, is the defendant's knowledge and his intent and his guilt and that is what we're going to spend the rest of this morning talking about. As I said, we're going to start from the beginning and we're going to show you the development of the relationship with Jho Low and we're going to take it all through the crimes themselves.

So if we can go to 2008. This is testimony from Tim Leissner about the reasons why the defendant and Leissner wanted to develop a relationship with Jho Low. He said: Roger agreed to try and establish a relationship with this young gentleman, Jho Low, who had just appeared on our radar screen. Roger went to establish a relationship and he was successful in doing so and then he introduced me to Jho in January of 2009.

The relationship was valuable because of Jho Low's government connections. They wanted to use those connections to bring in business from sovereign wealth funds and other places in Malaysia to Goldman and you'll see as we walk through this section on the development of the relationship that the seeds of what would become the criminal agreement are set early. So the defendant knows about Jho Low's wealth, he knows about his political connections, they are using personal e-mails, Jho Low is asking him even in this early time period to please don't talk about my connections with government officials, don't publicize them, and sort of that is all happening as the relationship is being developed.

So this is from January of 2009, specifically January 4th, and it's sort of right after that initial meeting where Roger Ng introduces Jho Low to Tim Leissner. Tim Leissner says, I like this guy very much. And at the end, they sort of discuss him and then Roger Ng says Jho Low will play ball with us, he seems to want to be associated with us, he is comfortable. And this is at the beginning of them trying to develop that relationship with Jho Low and to get business into Goldman from him. And if you remember, Roger Ng was the coverage banker for Malaysia so part of his job was to develop these relationships and Jho Low was someone both he and Leissner saw as someone who could bring business to Goldman and to make profits for Goldman and, by extension, themselves.

So, again, we kind of see in the early part of 2009 the defendant communicating with Jho Low, having meetings with Jho Low, using his personal e-mail accounts. Here it's the rogerch_ng@gmail and Jho Low is using his jholow@gmail address. We have views, in part, because they were forwarded at one point or another to his Goldman address. We'll see later on, that that happened in a different way and stopped happening regularly because, of course, the rogerch_ng@gmail account was deleted as was the jholow@gmail account, but these were some early communications about meetings in February and March of 2009.

In April and May of 2009, we see some additional communications between Jho Low and Roger Ng discussing potential business and also discussing a trip that Roger Ng is coordinating with Jho Low to Beijing where the Prime Minister of Malaysia will be there as well. That's Government Exhibit 1546 which is on the right-hand side there. You can see on the bottom e-mail, Roger Ng says, I am making reservations for Jho and others for Tuesday and Wednesday, and he's coordinating all the travel details for Jho Low. So early on in this sort of May 2009 time period, he is not only communicating with Jho Low and meeting with him, but he's actually traveling with him and traveling with him in connection with business related to government officials in Malaysia.

This is from July of 2009 and we can see, again, if it wasn't already obvious from the e-mails, this is a news article that Roger Ng forwards to himself about the inner circle of Najib Razak, the Prime Minister, and there's a section on Jho Low.

It says there: Little is known of Penang born Low who is a TIA official — if you remember, TIA was the entity, the government entity before 1MDB so sort of the precursor to 1MDB — and is said to be an advisor to Malaysia's king Sultan Mizan, and has close ties to several Middle Eastern investment fund. So it was clear early on that Roger Ng knows exactly who Jho Low is and perhaps more than that, who he is and what his connections are.

And then these two e-mails from 2009, one from August and one from October, are both instances where we see Jho Low from the very outset trying to distance himself a little bit from the 1MDB officials and the government officials that he's working with. So he wants to exploit those connections but he doesn't want to advertise them. So on the left, you have Jho Low telling a number of people: Please remove any reference to me being close to the PM, the prime minister, or an adviser to the King, just Jho Low. And the defendant responds, Oops, sorry, sorry, bro, slipped this one.

On the right you have him saying, When you communicate with the 1MDB guys, please BCC me, I want to be in the background, I am the kingmaker but I don't want to be associated with the King. And that's something Jho Low says from a very early time period and it's something that the defendant knows from a very early time period.

And then just the last e-mail I want to show you from this time period is from November 2009. It's an e-mail between Leissner and Roger Ng where Roger Ng is saying that he just met the Prime Minister's three children with Jho at Jho's apartment and he's going to work on getting them to join Goldman Sachs and he's trying to talk business and he's going to meet Jho again tomorrow. And the subject line refers to 1MDB. So this is, again, the early period, Roger Ng talking to Tim Leissner about his efforts to get Jho Low to bring government business to Goldman Sachs, and his meeting with him at Jho's apartment in New York City. And you saw from the other evidence in the case that, you know, that this meeting took place in New York from the defendant's TEEMS records.

Then in Government's Exhibits 3004 and 3005 were the rental agreement for the apartment for Jho Low in New York City during this time period in late 2009. That's where we saw Catherine Tan, his assistant, setting up the rental agreement and we saw it was a monthly rental of $110,000 a month for this apartment.

So you can imagine when Roger Ng goes to an apartment that costs $110,000 a month, he is well aware of Jho Low's wealth and his connections and his meeting the Prime Minister's children there and this, again, sort of sets the stage for everything that would come afterwards.

The next case of this we're going to talk about is sort of the Private Wealth Management client case, but I want you to just keep in mind that the e-mails I showed you about this 2009 period are just some examples of the meetings and the travel and the discussions about business with Jho Low and in this time period, the defendant is successful in getting some business from TIA to Goldman. So there is some business that Jho Low brings in to Goldman in this time period and that sort of incentivizes him to continue to work with Jho Low and see what other kind of business he can bring in.

So as part of that effort to continue to develop the relationship with Jho Low, and to sort of build on that and increase the connections between Jho Low and Goldman, Roger Ng is trying to bring, in the same time period, Jho Low on as a Private Wealth Management client. That just means that Goldman would help manage Jho Low's money which obviously brings money into Goldman because they charge fees for doing that and sort of increases the relationship between the bank and Jho Low. So this is what the defendant is trying to do and it's in the same time period of all these e-mails that I just showed you. He puts Jho Low up for Private Wealth Management client in October of 2009 which is before that meeting at Jho Low's apartment in New York with the Prime Minister's children.

We can see from the e-mail which is Government Exhibit 1564 that Roger Ng is the one that is proposing Jho Low as a Private Wealth Management client. He said, I would like to refer a client of ours, he copies Tim Leissner, for Private Wealth Management account out of Zurich. And he says, Do not hesitate to contact me or Tim for endorsing reference. So he's putting him up as a client and saying if you want a reference, come to me, I'm supporting him to be a Private Wealth Management client.

And, again, this is October of 2009. There's another e-mail as a follow-up where he's asked to give a little more information on Jho Low and he does. And he says Jho Low's, you know, a very wealthy individual and he has all these connections and close relationships including with the Abu Dhabi Royal family. So, again, it's very clear in this time period that the defendant knows exactly who Jho Low is. And you heard from two Goldman witnesses that the referral of Low was an endorsement. So not only did the e-mail, his own e-mail said come to me for endorsing reference but, in general, if a banker is going to refer a client for a Private Wealth Management account, he's saying this is someone you should give an account to. We heard that both from Patrick Kidney who is a anti-money laundering officer in the compliance division who is responsible for vetting Private Wealth Management clients and Chris French who was the head of Goldman's Private Wealth Management client business in Europe.

They both basically said if you refer someone, that's a reference and we take that reference seriously. You also heard that the referral was made in October of 2009 and it does not go smoothly. Basically once Roger Ng refers Jho Low, compliance started looking at him and they immediately see a bunch of red flags or concerns and reasons why it would be risky for the bank to take him on as a client. So, first, they couldn't validate the source of wealth. He obviously had a lot of money but they couldn't figure out where the money was coming from. And, second, it was clear that he was doing a lot of deals with government officials.

So you heard Patrick Kidney talk about those concerns and then he said, I can't think of very many that have ever come up with this amount of red flags.

So Jho Low is just — there's so many issues with him once they start digging into his background and that is very clear to the compliance division. And ultimately, in March of 2010, so five months later, the compliance department compiles a summary of all of their concerns into what they call a red flag summary. And you know that this, from Patrick Kidney, this was a really long ongoing process and clients don't usually take this much time to come on board. I think there are a couple of things that are really significant about this document which you've seen a bunch of times before. It's Government Exhibit 1601.

You know from this document that the defendant was aware of the issues because it says, in paragraph 7: When briefed on the details of the client's claims, Roger Ng advised caution in accepting the claims at face value. So that tells you that Roger Ng was told that the compliance division was having concerns and that he was briefed on what the claims were and what the concerns were and at that point, he told the compliance division, You guys should do your job, make sure, you know, you check out all of those claims, because he knew that five months into this process, if he sort of sounded like he was, a full-throated approval of Jho Low to compliance with all of these red flags, he was going to look a little odd by pushing him too hard. What he did is he not only sort of equivocated and said, Yes, you guys should go do your job and check out those red flags, he flat out lied to compliance in an attempt to distance himself from Jho Low because of all these red flags, and you can see that in two places.

In the first paragraph, it says: Goldman Sachs has not been involved in any transaction with the individual in the past. You know that's false because there was the TIA business that Jho Low brought to Goldman Sachs. And it also says: Individual is not well known to Roger Ng. And we know that is false because he has traveled to China with him, he's met him in New York, he's had multiple meetings with him and so the idea that he's not well known to Roger Ng is not true. And then most significantly, it says: Roger had not heard of the individual apart from meeting him on a single occasion when he was present at a meeting with the King of Malaysia.

And so I think it's really important to sort of understand that this was an attempt to distance himself with the compliance department from Jho Low and as a result, he lied about his relationship with Jho Low until that point. And, again, we looked at this during the trial, Government Exhibit 77. These were all of the times that Jho Low appeared at meals that were reimbursed or sought for reimbursement by Roger Ng before this presentation is made and so all of the times that you know that they were together before this, in addition to all of the e-mails that we have seen about the various meetings that took place. So all of that happened before he tells compliance, I don't really know the guys and I only met him once. And he's lying because, again, he's trying to distance himself from Jho Low to the compliance people who have concerns. And, again, just to recap, in addition to those TEEMS reimbursement forms, here are two e-mails prior to March 2010 that show other meetings. And what's significant is while he is lying to compliance and trying to distance himself, he doesn't actually say, Don't take Jho Low on as a client, because, ultimately, he would like for Goldman to do that because that would be good for him and his relationship with Jho Low and for bringing additional business to Goldman. So after the testimony of Patrick Kidney and Chris French, and the statements you should take a closer look at Jho Low, he never says, Do not take Jho Low on as a client because if he had, that would have been in the compliance presentation and it wasn't.

And in fact, there is a May 2010 call with Chris French. Remember, Chris French is sort of on the business side, not on the compliance side. So when he's talking with the business side, the head of Private Wealth Management, he continues to be supportive of Jho Low. He continues to say, You guys can make this work, we want to take him on as a client.

And then most significantly, we know that the defendant knew why Jho Low was ultimately rejected as a Private Wealth Management client by Goldman and that is because Morton Meland who is, again, one of the people trying to get Jho Low on board, e-mails Roger Ng and Tim Leissner in May of 2010, so months after the presentation, and says, This is what Patrick has come back with for AML's fifth meeting with Jho Low, JL, not looking good. This e-mail below is from Patrick Kidney reemphasizing all of those red flags: Can't figure out where this money is coming from, does all these deals with government officials, all over the press as somebody who is a playboy and we have major, major concerns about him. And this is Morton Meland telling the defendant and Tim Leissner, I don't think this is going to work out because of all of these concerns that Patrick has. And you know from Tim Leissner's testimony that it was actually Roger Ng who called Tim Leissner and said, This is ultimately a no-fly, he is not going to be brought on as a client.

So what I think is significant is, you know, he's aware of all these red flags, he's aware that Goldman doesn't want to take him on as a Private Wealth Management client, and he continues anyway to try and develop a relationship and bring additional business to Goldman.

And we're going to walk through the 2010-2011 time period in a minute, but one deal that I want to talk about in particular is a deal called Kazakh Gold because it speaks to the defendant's further knowledge of the issues with Jho Low.

The details of this deal are not important. All that is important is that you can see on the bottom e-mail, Jho Low is e-mailing the defendant at the end of 2010 and saying: There's this deal related Kazakh Goldmine. Do you want to do it? And Tim Leissner explained that the Jho Low is going to be the buyer for this deal and Roger Ng asked Tim Leissner should we go ahead and do this. Tim Leissner said sure, we might want to go show BIG first. You might remember BIG is the Business Intelligence Group and is part of compliance and they do compliance checks on deals. So Tim Leissner says this. They bring the deal to compliance. And, again, this is early 2011 so it's after Jho Low is rejected as a Private Wealth Management client and before sort of the next attempt which we're going to get to in a minute. And what happens is that the Business Intelligence Group rejects the deal for the same reasons that Low was rejected as a Private Wealth Management client, because they can't just figure out where his money is coming from. You can see that, the concerns on the source of wealth, and then they also note his government connections.

There are calls from Malaysian MPs to inquire into him, so, basically, they're calls from Malaysian government officials to investigate Jho Low, and his claimed PEP connections. We've heard that term a number of times. It means "politically exposed persons." So, again, BIG is concerned about his source of wealth and connection to government officials.

And then you can see in the e-mail on the right, that's Government Exhibit 1665 which Roger Ng and Tim Leissner received, and I should say they also received the e-mail where BIG had explained their concerns on the left, and it says: Bias is not to move ahead. And you can see Steven O'Flaherty talking about this as well and he says, and he is informed that Asia has dropped the idea since they could not clear the buyer.

So, basically, this is a deal that gets scuttled by Goldman's compliance department because they're concerned about Jho Low's source of wealth and they're concerned about his government connections and they don't want to move forward. So at this point in time, in early 2011, the defendant knows that Jho Low hasn't been made a Private Wealth Management client because of these concerns and that this deal isn't going to go forward because of these concerns. And what happens next? What happens next is that Roger Ng nevertheless supports another attempt to make Jho Low a Private Wealth Management client. And this time, instead of trying Europe where they got rejected, they're going to try in Singapore.

And you can see this. This is Government Exhibit 1679. He re-raises the idea of Jho Low as a Private Wealth Management client. The official name on the referral is Tim Leissner but you can see from the e-mail that Roger Ng is driving this process. He e-mails someone involved in the Private Wealth Management client group and says that Jho can meet for lunch and he says that the purpose of the lunch, and that's the e-mail 3 in the middle, trying to make this a little clearer to read, is: I am available. He wants to get open a PWM client here in Singapore. So Jho Low wants a Private Wealth Management account and he wants it in Singapore.

And the response from the person in the Private Wealth Management group is: I'm not sure why the Swiss team decided not to go ahead with the account with him but I can check with the Asian team. So she's basically saying I know it didn't go forward in Switzerland but I don't really know why so let me find out. And Roger Ng writes back: Thanks. He doesn't say, Oh, I know why it didn't happen in Switzerland, because they couldn't figure out where his money was coming from and he has connections to all these government officials. He just says, Thanks, because he's trying to push this process forward as well.

And we can see that when this information reached the team in Switzerland, Patrick Kidney says: As far as I was concerned, this had already been determined. It was an open and shut case. We were not bringing him on. So the fact that he was put forth again by Roger Ng was surprising and we know that Roger Ng is the one pushing it because he actually meets with Jho Low to try to get this Private Wealth Management account set up in Singapore. Then after that meeting, he gets more information: I'm not going to chase since I'm not sure we can clear because there's still concern that they bring him on board. And, again, instead of saying he understands what the concerns is, he says that Jho Low reminded me he was busy but that he would work on the docs.

So it's really, really significant to the defendant's knowledge and his intent of who Jho Low was and why it was important to hide it from Goldman. This whole sort of series of events related to the Private Wealth Management client puts him on notice of all of these red flags which he already knew about, but it puts — it really crystallizes the issues for him. And there are two separate issues — two separate times where he was rejected as a Private Wealth Management client, both in Switzerland, it doesn't happen in Singapore. Then we have the Kazakh Gold deal where Goldman Sachs says we're not going to go forward with this because we're concerned about Jho Low.

So that's sort of where we are in the 2011 time frame and I just want to talk a little bit more about the relationship in that time frame, 2010-2011, and a couple of other things that were going on.

During this time period, sort of while all this Private Wealth Management stuff and Kazakh Gold is going on, Roger Ng remains the main point of contact for Jho Low. So you can see this is from April of 2011. Roger Ng is saying I will get this material to Jho Low, we're continuing to try to do deals and have him speak to the private minister as well.

So he is the one that is contacting Jho Low. That same pattern continues throughout 2011, Roger Ng sending from his, again, personal e-mail account, the RogerNg1@gmail account which gets deleted. He is saying to Tim and Loong Kim Tan on their personal accounts, FYI from Jho, so he's communicating with Jho about deals. The e-mail on the right which is Government Exhibit 2216 is from Tim Leissner to Roger Ng's personal account and he's saying, "Roger, can you please forward to Jho."

So Roger in this time period, that is the main point of contact with Jho Low and is continuing to be sort of the one that connects with him. Now we also see in this time period that he continues to use those two e-mail accounts that get deleted but he also starts using a Queensgate Capital account. This is an e-mail, Government Exhibit 2207, from April 30, 2011, and if you remember from Special Agent Collins' testimony, it's actually the date that the Queensgate Capital e-mail account gets opened.

So the very date that the defendant opens this e-mail account, the first person he gives that e-mail account to is Jho Low and that's the deal where he had one gmail account and you know that because it's DealRainman e-mailing Queensgate first. And only after Roger gets the e-mail at that account does he forward it to Tim Leissner and say, Leissner, FY, this is me, it's Roger. Jho Low already knows that because Jho Low is the one that gets this e-mail account first and the reason that the defendant is creating an e-mail account that doesn't have his name is to deal with Jho Low and to conduct business with Jho Low offline.

So he's moved from the e-mail accounts in his own name to a Queensgate account and that happens in April of 2011, April of 2011, almost a full year before the bribery scheme kicks off. So this is all sort of in process and in place before any of that happens.

The other thing we saw about sort of this time period is that Roger Ng maintained a personal relationship with Jho Low. He traveled to Vegas to gamble with him and you know from the Venetian records that he was gambling at the same table with Jho Low and Jho Low's brother and Eric Tan Kim Loong who is involved in all of the bank accounts. One thing that Special Agent Sullivan testified about was that the defendant flew from Singapore to Vegas for this trip on Jho Low's private jet. If you look at the tail number of the jet on the bottom left which is Government Exhibit 2855, that's the currency transaction report where Roger Ng was flying into Vegas and reported that he had $14,000 in cash on him, you can see that the tail number there is N689WM. Then if we move forward to May of 2011, and you look at the top left, that's the same tail number for Jho Low's private jet. This is an instance where the defendant and Jho Low took that private jet to Nice, France, and were aboard the ALFA NERO. We saw that that was a yacht that had been rented for I believe more than a million euro. And you can also see from this trip that when the defendant traveled back to London, he listed Low's apartment on Stratton Street as his home base for the trip. And then he even filed the TEEMS receipt later using stationery from the yacht.

So you have in this time period the defendant not only did develop a business relationship with Jho Low, but also a personal relationship, the gambling, the yacht, and it shows you that, you know, in the time period where he is being told that there's unexplained sources of wealth for Jho Low, he is experiencing those firsthand. He's going to Vegas and seeing him drop an ungodly amount of money, hundreds of thousands of dollars gambling, and he's going to a yacht in Nice that was rented for more than a million euros and flying on a private jet. He's fully aware of exactly who Jho Low is and the fact that he has all of this money.

The last thing I want to talk about from this time period are side deals. You heard a lot about various other deals that were going on, particularly during the testimony of Tim Leissner, but I think what's important about the side deals is that they established the defendant's greed.

You heard Tim Leissner say that the defendant wasn't always happy with the salary at Goldman Sachs, always thought he should be making more money, was always looking to sort of make more money, and these side deals, the deals that were sort of being done offline, not for Goldman but for themselves in this time period, and they were sort of always wheeling and dealing and trying to figure out how they can make money for themselves, really do establish the record. So this Government Exhibit 2202 is a side deal that didn't directly involve Jho Low, but did involve Michael Beck which is someone else you heard about and you can just see that they're e-mailing on their personal account about these deals. The most important thing about this is Roger Ng says, you know, sort of figuring out how the deal is going to work and what the various rates are and how it's structured. Tim Leissner says that his calculations are right. And Roger Ng basically says they are right and if this works out, it will more than my bonus.

So they're really — they're always looking for wheeling and dealing, what else can we do to bring money in, and you'll see that it's always the defendant and Tim Leissner together. And in many occasions, they're also trying to bring Jho Low in because they know Jho Low has a lot of money and Jho Low is up for doing a lot of deals. This is another example of a deal that they're discussing with Michael Beck and Stephen Dattels in October of 2010 and they're talking about, What do you think for JL, what do you think for Jho Low, should we bring Jho Low in on this.

And then the last side deal that I want to look at but I think it's sort of the most important one is this e-mail from May of 2011. You can see that it's Roger Ng who's using his gmail account, and he's also using the Queensgate account, and he is e-mailing Tim Leissner and he's updating Tim Leissner on the discussion that he had with Jho Low. He's talking about a side deal that they want to work on with a company called Petronas which is a Malaysian company and Tim Leissner testified that they tried to do deals with Petronas before and with Goldman and it never worked out. So Roger discussed this with Jho Low and he reports back to Tim Leissner. The most significant part of the e-mail is that he says: We need to pay Omar so that he plays ball. And so, basically, in words to sort of get this deal through, they're going to propose to pay Omar, and that's Omar Mustafa who is on the board of the company, in order to, to sort of make this deal happen.

Mr. Leissner explained in his testimony you don't pay a sitting board member to get a deal done, that that is a bribe. So they are discussing here in May of 2011 over personal e-mail accounts a side deal in which a bribe was contemplated being paid. So I think what it shows you is that these were two people who were willing to engage in corruption to get their job done, they are comfortable of talking on personal e-mail accounts about plans to bribe someone for a deal, and a year out, almost a year out from Project Magnolia, Jho Low is important.

So I think everything that we have seen in this development of this relationship and the knowledge of the red flags and the personal relationship that the defendant had with Jho Low and these attempts at side deals, all of this lays the foundation for what happens in 2012. And what happens in 2012 with the bribery scheme does not come out of nowhere. All of these pieces that we've been talking about, the connections to government officials, the communications on personal e-mail accounts, the discussion of potentially paying bribes, trying to do side deals away from Goldman, violating Goldman's policies which we'll talk about, all of this sets the stage for what happens next. And what happens next, what we're going to focus on now is the bribery scheme itself.

This is is Government Exhibit 2226 and you can see in this e-mail and the next evident mail, Jho Low finally comes through and is going to bring the defendant and Roger Ng really big deals that they can do for Goldman. And this is an e-mail, again, all on personal e-mails between Tim Leissner's Yahoo, the DealRainman account which is Jho Low's account, and Roger Ng at his Queensgate account and they're discussing very early on in January 2012 the assets in Tanjong Energy which is the deal that eventually becomes Project Magnolia.

You can see here that they're discussing it over their personal e-mail accounts. This is a continuation of the e-mail exchange. And the defendant says to Tim Leissner: This makes the deal more real. How do you like the name Queensgate?

So, again, they're discussing it on personal e-mail accounts, they're setting the seed for what's going to become the deal and they're discussing it with Jho Low. And then the next e-mail I want to show you is Government Exhibit 228 which is from January of 2012. And if you look at the bottom e-mail which is the first e-mail in the chain, it's Jho Low at that Jho Low gmail which, again, gets deleted, and it says to Shahrol Halmi who works at 1MDB: Making an introduction to Tim and Roger's private e-mail accounts as discussed.

So they've been talking about the deal and they're getting ready to get the deal off the ground. Jho Low is going to introduce the defendant and Tim Leissner to the person at 1MDB that they need to talk to, so, again, making an introduction on their private e-mail account so we can do this off of Goldman's systems. Then he says, Please exclude me from the e-mail going forward, because he wants to be separate from 1MDB and he's pulling the strings behind the scenes but he doesn't actually want to be involved even on these private e-mail accounts. You can see the defendant writes back, Works for me and we'll get a meeting set up, and that's in January of 2012.

So what we're going to do next is sort of walk through the four critical meetings that we talked about a number of times during the trial related to the bribery scheme starting with the London meeting in February 26 of 2012 and before we do that, I just want to take a moment here to talk about Tim Leissner because we're going to start with Tim Leissner's testimony about what happened at the London scheme. So as you know, Tim Leissner has pled guilty to violating the FPCA and money laundering and he testified here under a cooperation agreement. As my colleague Mr. Wible told you at the outset and I'm going to tell you now, you should scrutinize this testimony closely. I submit that when you do, you'll find that what he told you about the crimes that he committed with the defendant and others is backed up by and consistent with the other evidence in the case. That is, Leissner didn't tell you anything you don't already know from e-mails and the phone logs and the bank records and the travel documents for the defendant and their co-conspirators. It is all right there in black and white in the documents. Leissner's testimony is helpful because it gives you color and context for the events surrounding the crimes and it gives you an inside look into the conspiracies, but I submit that you already know that the defendant is guilty from the other evidence in the case. That's been true of everything that I walked you through so far and that's going be true of everything that we walk through from this moment forward.

So keeping that in mind, we're going to start with Leissner's testimony about the London meeting. He explained to you that they traveled to London to sort of discuss the Goldman Sachs side of the deal. So they knew this deal was in the works, we saw the e-mails where they were sort of setting things up, but now they have to do the structure because it's a $1.5 billion fundraising and that doesn't just happen. You have to have — there's a lot of paperwork, there are — all the financial structures have to be in place and it is a lot of work to put together.

So they went to Jho Low's residence in London to sort of figure out what was happening and how to put this together and how they were going to make this deal come to fruition. And when they were at the meeting, what Jho Low said to them was to get this deal done, we are going to have to pay off a lot of people in Malaysia and Abu Dhabi. And so Jho Low walked them through who is going to have to get paid to get this enormous deal done especially in a time frame that they wanted to get it done which is quickly. So he said — Leissner testified that the defendant was there and on Jho Low's side, he had himself, Jasmine Loo who is the general counsel of 1MDB, and then also Nik Faisal who is the CEO of the subsidiary of 1MDB and also the person who is on that e-mail account that he and Jho Low both used.

Then Leissner walked you through who Jho Low said was going to have to be bribed to get this done. It's sort of the same cast of characters that you see up here that you saw in the bank accounts receiving the money from Malaysia and from Abu Dhabi and then obviously Jho himself. So you have Najib Razak, the Prime Minister of Malaysia who winds up getting almost $700 million. You have Rosmah Mansoor, his wife. 1MDB officials which are going to include Jasmine Loo and Terence Geh. Then on the Abu Dhabi side, you have Sheikh Mansour who we talked about who was the chairman of IPIC. You are going to have Al-Qubaisi and Al-Husseiny who work at IPIC and Aabar, IPIC, in general, and then Yousef Al-Otaiba who is the ambassador who can kind of be there if necessary. And they also discussed at the meeting, well, the money to pay all these people, we're raising $1.5 billion, we'll take the money for the bribes out of that raise.

So that is what's discussed at the London meeting. They go in there to discuss the structure and in order to get it done, we're going to have to pay the bribes. We know from the travel records, which you have all seen, that both the defendant, Roger Ng, and Jho Low were all in London at the time of the London meeting on February 26.

We also know that Jasmine Loo was at the meeting. As you can see, she sends this e-mail on February 27 where she says the next day: I'm still in London and running meetings. We know that Terence Geh was there too. We saw the chat where he talked being at Jho Low's apartment. We see this e-mail where Jasmine Loo adds Terence Geh to the deal team the day after the London meeting, and Roger Ng says to Terence Geh: Welcome to the deal team. Then he says: You will not regret it. Boy, does Terence Geh not regret it. He ends up getting millions of dollars for his role in this scheme.

What else do we know about what happened at the London meeting. We know that the structure of the deal and how it was getting done is what was discussed. The first thing that Jasmine Loo does the same day of meeting, is e-mail Tim Leissner and Roger Ng a chart showing the structure for the deal and everything that needs to get done on the Goldman side in order for the deal to more forward. You can see at this point there is a payment from 1MDB to the Aabar SPV, a subsidiary of Aabar. That's the way the money is ultimately taken out of the 1MDB deal and used to pay the bribes.

This, as you know, changes. That payment is no longer — later it's taken out, and Goldman is told they are not going to get paid they are just going to get the warrants. At this point, this is the structure that they are talking about.

What everybody does from the London meeting forward and what you're going to see, is they work on two things. They work on getting the deal done. There is a lot of work to be done to get the deal finalized and the paperwork done, and all the financial analysis and getting approved at Goldman. And then they are going to get on board all the parties that they need to get on board. And everybody needs to agree to get bribed. And this is how they are going to do it from this point forward.

One other thing about the chart. What happens with the chart, so Jasmine Loo e-mails it to Roger Ng and Tim Leissner. Two days later, Roger Ng e-mails it from his Goldman account to his personal gmail account, the RogerNg1@gmail account that gets deleted at the end of the conspiracy. This is the beginning of a pattern of e-mails where you can see the defendant e-mailing stuff to his personal e-mail account and communicating to his personal e-mail, taking that information about the deal and filtering it back to Goldman.

He and Tim Leissner are talking to Jho Low — and we'll later see them talking to Jasmine Loo over the personal e-mail account — discussing the structure, what they need to do to get things done, various things that need to be delivered. Then they come back to the Goldman accounts and do it officially. This is a pattern that repeats through this whole time period of getting the deals done, you can see the defendant communicating with Jho Low on his personal accounts.

We walked through some of these during the testimony of Special Agent Ryan Collins. But just as an example, if you compare Government's Exhibit 1764 to Government's Exhibit 1758, these are both from March 1st, 2012, so right after the London meeting. The one on the left is from the RogerNg1@gmail, so the gmail account that gets deleted, to Roger Ng's personal Goldman account. That e-mail says: Please have your team update and resend ASAP word doc for. And it has at the bottom: Other comments coming. Send back ASAP.

So it is clear this is an e-mail being forwarded from the gmail account to the Goldman account and it came from somewhere else. Because someone is asking Roger Ng to update the document and someone is saying other docs are coming. I submit to you, this is clear this is Jho Low who he's communicating with or someone working for Jho Low. What is really significant is when this e-mail gets sent to Andy Tai at Goldman. You remember Andy Tai, the first witness in the case. He came in and testified he was very junior on the deal team at the time, and he did not about Jho Low's involvement. You have Roger Ng taking that e-mail, putting it into a Goldman e-mail, taking out the: Please have your team update and the other comments. So it looks like these comments are coming from him, when in fact, they are coming from Jho Low.

He says: Andy, some comments. And he puts the comments in. And he takes out the parts of the email that would show that it came from somebody else. Let's look at another example, because there are a number of these. Government's Exhibit 1767 is on the left, Government's Exhibit 1766 is on the right. And this is one that we actually talked about with Andy Tai. He obviously had never seen the one on the left, but he had seen the one on the right. The left is the RogerNg1@gmail that gets deleted and goes to Roger Ng's Goldman account. And this one can you see is a forward forward, so it is being forwarded from somewhere but it's not clear where.

Again, it includes a whole bunch of comments — this is March 2nd the next day — a whole bunch of comments about the deal, how to update deal paperwork. In the e-mail it says: As per discussed, you make all these changes. You can see on the bottom, again, it had been forwarded twice, but he's removed where it's coming from. On the right, he forwards the e-mail to Andy Tai and says: Please find additional comments. Doesn't actually say where they are coming from. Andy Tai testified he couldn't figure out where the forward was coming from. He's passing along the input from Jho Low and others working from Jho Low on the deal as the deal is happening. He's doing this offline with the personal e-mail accounts.

Just as a third example, again in the same time period March 2. On the left is Government's Exhibit 1768, on the right is Government's Exhibit 2251. This is Roger Ng. This time the information is going from his Goldman account to the RogerNg1 gmail account that gets deleted. This time he's forwarding a copy of the presentation that Andy Tai put together, and he's forwarding it from his Goldman account to his personal account. There is no reason, as Caroline Fraser, who came and talked to you about all of these at policies at Goldman would say, no reason for him to be forwarding Goldman documents to his personal account; particularly, in a case like this where it's a significant deal. It's private, it's not public. There is no reason for him to be forwarding this Goldman document to himself.

But what happens with the document? And keep in mind again the RogerNg1@gmail account gets deleted and the dealrainman1@gmail gets deleted. The only reason we have these emails is because the one on the left got forwarded from Goldman; and the one on the right, as you saw the stipulation, Husseiny's lawyer provided those documents to the Government. We don't have the e-mails in between RogerNg1@gmail and Deal Rainman, because those got deleted. What we can see is that the Roger Ng gmail account gets this presentation, and then four days later the Deal Rainman account forwards this presentation to Husseiny with slight changes, but the same set of documents.

If we look at the next slide, those are the two attachments for those two emails. The one on the left is the one that Roger Ng forwarded himself; the one on the right is the one that Deal Rainman forwards on to Al-Husseiny. They are not exactly the same, but it's the same Goldman document. We see some information has been changed on the second slide when it comes from Deal Rainman, but this is what is happening. Roger Ng is communicating with Jho Low offline on personal accounts. They show back up in the Goldman system with comments that he wants. He gets those comments. Then he forwards the completed Goldman documents back to Jho Low to use as he needs in connection with the deals. And all of this happening in a week or two after the London meeting.

The next meeting is the Abu Dhabi meeting, March 3rd and 4th of 2012, only about a week after the London meeting. At this point the plan is in motion. They are working on the structure at Goldman. They are communicating with Jho Low offline. And now they are going to go to Abu Dhabi and they are going to convince IPIC and Aabar to get on board. We know that Jho Low and Roger Ng and Tim Leissner were all in Abu Dhabi for this meeting. We know they have a meeting at Emirates Palace, where Tim Leissner was staying from the TEAMS records. This is Roger Ng updating another Goldman banker, Toby Watson, who we'll talk about later. And explaining the purpose of the meeting was to get IPIC and Aabar on board. He said to Toby Watson: Did Andrea — talking about Andrea Vella — post you. Toby Watson said: No, how did it go. He says: CEO IPIC and CEO Aabar have in principle agreed. PM Malaysia will also be speaking with Ruler/Emir of Abu Dhabi.

The plan is in motion. They are making sure that IPIC and Aabar will be providing the guarantee. And he knows that this is the Prime Minister of Malaysia and the Ruler of Emirates of Abu Dhabi are getting on the same page as well. I think we'll talk about this a little more later, Toby Watson is one of the inner group of people who knows about Jho Low but doesn't know about the bribes. So Roger is updating him on what is going on with this aspect, but he's not in the actual inner circle, which is just Roger Ng and Tim Leissner who know that bribes are going to get paid. In the same time period, while in Abu Dhabi on March 4, Roger Ng is once again sending Goldman documents he put together for the deal from his Goldman account, sending them to his gmail account. This happens all the way through as the deal is progressing. He's continuing to send stuff to himself.

What happens next, and there is a lot of testimony about this, is Leissner delivers the letter for Sheikh Mansour to Al-Husseiny in Abu Dhabi. This is in line with what the defendant just talked about, that they need to get IPIC and Aabar on board and make sure that Abu Dhabi and Malaysia are coordinating.

We saw the e-mail from Jho Low, the Deal Rainman account, saying: Please do not respond to this e-mail, sending it to Husseiny. Asking for the contact point for the delivery of the letter. We also see Tim Leissner, he was just in Abu Dhabi, he's going back to Abu Dhabi a few days later to make sure this letter gets delivered.

That brings us to the Los Angeles and New York meetings in March 25 to 27 of 2012. We see meetings. Obviously they talk about the structure, who needs to be bribed. We saw meetings to get IPIC and Aabar on board. And now we see a series of meetings to talk about the MNA portion of the transaction, the actual assets that will be sold as part of the bond deal, and referred to as one point as Project Turin. This is what the meeting in Los Angeles and New York is about.

If we start with Government's Exhibit 805, you can see that the meeting — this is an e-mail from the defendant, Roger Ng. The meeting was originally scheduled to take place in New York and it was going to be with Ananda Krishnan Christian, who was the owner of the Tanjong Energy Assets for Project Magnolia. And Roger is asking his assistant: Can you book me to get to New York by Sunday evening. He asked to stay at the Sofitel New York, because he's going to stay at the same hotels with Tim Leissner, that way we can be with the client. The purpose of the trip is to meet Ananda Krishnan regarding Project Magnolia with Tim Leissner.

This is the original plan for the trip. They are going to meet in New York. They are going to talk about Project Magnolia. They are going to meet with Ananda Krishnan, and it's going to be Tim Leissner and Roger Ng. Then what happens is that March 23 Roger Ng gets a call from Jho Low and the New York meeting is going to be moving to L.A. So instead of meeting in New York they will meet at L.A. at a L'Ermitage. The L'Ermitage was owned by Jho Low. So he asked ask that his travel plans get changed and also to get approval to stay at L'Ermitage, which is owned by a related client on the deal. He doesn't say Jho Low. He's not talking about Jho Low. But he wants to stay the L'Ermitage for that reason.

What happens next is that we know that Jho Low and Tim Leissner and Roger Ng all meet at the L'Ermitage, March 25 to 26, and discuss Project Magnolia. Jho Low says to Tim Leissner: See you at 6:00 p.m. at L'Ermitage. Tell Roger. You can see that Tim Leissner is having his documents sent there and Roger Ng stays there. So all three of them were at this meeting.

What happens next is that Tim Leissner travels with Jho Low onto New York to meet with Ananda Krishnan as originally planned. So you can see that Tim Leissner takes Jho Low's private jet from L.A. to Teterboro in New Jersey. They go from Teterboro to Manhattan you heard a lot about the waters passing through the Eastern District of New York to get to Manhattan. And he stays at Sofitel where Roger Ng was going to stay. This is the meeting they planned with Ananda Krishnan. You know that Ananda Krishnan doesn't go to L.A. but winds up going to New York as originally planned, and that's where Tim Leissner meets him. That's Defense Exhibit 2219.

They talk about having dinner Monday night, which is after Roger Ng goes from L.A. back to Asia. And Tim Leissner and Jho Low go to New York. They meet up in New York to discuss Project Magnolia.

We also see both from the text records and from Tim Leissner's own flight records that they have a meeting in New York. They stayed at Sofitel. Then they left from New York from J.F.K. Airport in Queens.

Then in the same time period, again this is another example of communications offline, Government's Exhibit 2266 and Government's Exhibit 1812, if you compare the two of them, another example of Tim Leissner, Jasmine Loo using the Project Dodobird e-mail address and Roger Ng using RogerNg1@gmail account, which gets deleted, discussing Project Magnolia. And Tim Leissner says to Jasmine Loo: Could I trouble you to forward this to our GS account, then I can handle officially. Sorry for that.

This is March 28, 2012; so right in between the L.A. New York meeting and the next meeting we're going to talk about. And what does Jasmine Loo do? She forwards this e-mail that Tim put together as if she came up with it herself. She forwards it officially to the defendant and to Tim Leissner's Goldman Sachs account. And Roger Ng says: Yeah, I'll take care of this. As if this had not been already discussed on the side on their personal e-mail addresses. During this whole time period, this is happening offline on the personal e-mail accounts.

Then the final key meeting that I want to talk about is the meeting in Singapore with BSI on April 21, 2012. If you look at the defendants TEEMS records and e-mails, tons of meeting all over the place during this time period for Project Magnolia. We're highlighting the top four, but throughout he's consistently working on these deals.

The Singapore meeting on April 21, 2012. We've got the structure down, they have the deal, they got all the officials on board. Now we need to figure out how we're going to get the money, how 1MDB will be used for bribes. For the Singapore meeting, again, there are records showing everyone who was there. You have Jho Low's landing card for Singapore. Roger Ng says he's there to meet was client for 1MDB and for Project Magnolia. Tim Leissner's hotel records as well. So they are all in Singapore for this April 21 meeting.

What do we know about the meeting itself? So Leissner told when you he testified, this is transcript page 943 and 945, that Jho Low and Roger organized the lunch and it was to tell BSI about the bond raise, to give them comfort that Goldman Sachs did the work, to give them comfort. And prior to the meeting, the defendant, Tim Leissner and Jho Low met in a separate room, at the same restaurant but a private room, discussed the game plan. And then they went into meet with the BSI bankers, which included Yak Yew Chee, who was Jho Low's private banker.

The idea was that BSI bank was going to get money out of the transaction and Jho Low wanted the defendant and Tim Leissner to go to the BSI bankers and make them comfortable that this was a legitimate transaction. So that was the purpose of the Singapore meeting. That took place in on April 21 with the BSI bankers.

(Court breaks for 15 minutes)

We left off with the Singapore meeting in April 21, 2012. And when left off, we were talking about Leissner's testimony about the purpose of the meeting and the fact that they went to the restaurant to meet with the BSI bankers. And Tim Leissner and Roger Ng met with Jho Low in a separate room within the restaurant first, and then had the meeting with the bankers.

You know that this meeting happened, in part, because we have an e-mail from BSI about the meeting itself where BSI is saying: We understand that we've been invited to a closed-door presentation by Goldman Sachs on the bonds to be issued by 1MDB tomorrow afternoon. The e-mail is dated April 20. It says: The presentation is conducted by Goldman Sachs. And then it also says that: I understand another client, Low, will be present at the meeting.

So this is an e-mail from within BSI talking about the meeting that is going to happen the next day. That's Government's Exhibit 2269.

Then you heard from Kevin Swampilai, the BSI banker who came from Singapore to testify during the trial. And he corroborated Tim Leissner.

He said — it's not on the screen, but it's transcript page 3237 — that his understanding from Yak Yew Chee was that Jho Low was there and in a different room. And that at the meeting itself he was expecting sort of a presentation from Goldman explaining the deals and the due diligence they had done; but in fact what Tim Leissner did, was said, we're doing these deals. He didn't give a presentation. He blew off any discussion of due diligence. The reason you know that this happened, is because Tim Leissner and Roger Ng thought that this was sort of just a meet-and-greet, that BSI with Yak Yew Chee was Low's personal banker, BSI was on board. They were there was to provide legitimacy that the deals were happening. They didn't intend to get into any of the details of the deals themselves. The meeting happens. Tim Leissner, Roger Ng talk to Jho Low about the need for this account at BSI and its getting set up. We know that's where the money from 1MDB actually winds up.

Then when they meet with the bankers themselves, they assure BSI that the transactions are happening but they don't talk about anything related to due diligence. Because it's a meeting for show. It's a meeting so BSI knows the bond deals are actually happening. No one is going to be able to give assurances about the legitimacy of what money is coming into the BSI bank, because it's going to wind up being criminal proceeds. And you know that Tim Leissner had to leave the meeting early because he had to be somewhere else, and that Roger Ng stayed behind.

And Kevin Swampilai testified that he left the meeting relatively early. And that Yak Yew Chee and the defendant Roger Ng were still in the meeting when he left. So that's the April 21, 2012 meeting in Singapore. And again, if you think back to what we discussed at the beginning of my presentation, that's exactly one month before Roger Ng and Hwee Bin Lim tell their bank that they are getting money from BSI.

So ultimately the Project Magnolia closes and we're going to talk at a later point about what the defendant and Tim Leissner were doing at Goldman Sachs to ensure that would happen.

This is a copy of the SWIFT payment. We heard about SWIFT payments, it's a message indicating that a wire transfer has gone through. It's the transfer of funds after the close of the Project Magnolia, and that happens on May 21, 2012. Then you heard testimony from Tim Leissner, pages 981 and 995, about the payment of the bribes and kickbacks after Project Magnolia closes.

Earlier this morning I talked about how Tim Leissner volunteered to use Capital Place because the payments out of Project Magnolia for the bribes and the kickbacks were delayed. The defendant and Tim Leissner expected the money much sooner than they got it; so they had a discussion when the money wasn't forthcoming to determine how to get Jho Low to move the payments along. Tim Leissner and Roger Ng discuss that Tim Leissner could use a company he already had set up, Capital Place, to take in and disburse some of the funds if Jho Low needed that additional help. That's the testimony that you heard from Leissner about what was going on during that time period.

He also testified that a number of people were complaining because they also had not been paid. One of the people who said he was complaining was Jasmine Loo. She had an account at Credit Suisse and she was waiting for her payment as well.

We know from Tim Leissner's testimony that he did not actually see bank account records from this case at all. This is Government's Exhibit 151. If you remember, he didn't have access to Capital One bank account. He had everything from that account from Judy.

Here's the money flow from Project Magnolia that forensic accountant Eric Van Dorn walked you through. The money flow itself is corroborating Leissner's testimony about the payments of the bribes and the kickbacks out of Project Magnolia.

Who gets paid first? The most important people to the deal, so that's Jho Low, that's Prime Minister Razak, Qubaisi, Hussainy. Then we get to Roger Ng and Tim Leissner. We know that Jasmine Loo got paid next. And that the Heartland Global account that she gets paid into, is a Credit Suisse account. These are the people that get paid relatively soon after Project Magnolia closes, not as soon as the defendant wanted. And then you get a payment to Yahaya in August. But everybody else involved in the deal has to wait. They don't get paid out right away.

You hear Tim Leissner says that Terence Geh is complaining that those people don't wind up getting paid until later. The money flow confirmed that the most important people get paid first, that included the Goldman bankers. They needed Goldman to get the deal done. They had to wait for the other payments to go through. One of the reasons that Goldman gets paid first is, again, they needed Goldman to get the deal done.

Then what happened after Project Magnolia? Project Maximus.

And the numbers are staggering. They raised $1.5 billion for Project Magnolia. And what do they want to do? Another deal for another $1.5 billion right away. Tim Leissner testified that he had discussions with Jho Low and the defendant, and that Jho Low wanted to do another deal because he thought the scheme had worked well and there was more money to be made in a similar scheme. He wanted to do it very quickly.

Also at this part, the hard part is done. They've come up with the structure. They've gotten everybody on board. They figured out who they have to pay. The bank accounts are set up. So it's very easy for them to cut and paste the deal that was Project Magnolia into the deal that is Project Maximus. That is what in fact happens.

We know that the defendant worked on Project Maximus as well. He's on the committee memos. We saw e-mails connected to his work on Project Maximus. I want to show this e-mail, Government's Exhibit 1878. It shows that the use of the personal e-mails continued through Project Maximus. This is a little bit hard to follow, it's a long e-mail chain. But there is an e-mail on the bottom that's related to Project Maximus, which ultimately gets forwarded to Jasmine Loo who then forwards it to Tim Leissner and then the Queensgait Capital e-mail address and Andy Tai.

If you remember, Andy Tai testified that he didn't know who Queensgait Capital was. This is in the Project Maximus time period, and can you see the bottom e-mail from Jasmine Loo she says: Okay, thanks. She realized that she copied Queensgait improperly. I accidently copied an e-mail to a wrong individual, so please reply in a new e-mail. Andy Tai doesn't know about Jho Low, doesn't know about the Queensgait e-mail address. And Jasmine Loo accidently included him on an e-mail that she had sent to Tim Leissner and Andy Tai.

So we know during this time period, the defendant and Tim Leissner are still communicating offline with Jho Low and with Jasmine Loo about the deals as they are doing Project Maximus. We know that the defendant is invited to the committee meetings for Project Maximus, and we'll talk about those in a bit.

This is Government's Exhibit 1873. We also know that the defendant attends the Project Maximus closing dinner. Project Maximus closes in October of 2012, so it's really fast. We have Magnolia closing in May. Then this cut and paste job for another 1.5 billion that closes in October.

The defendant attends this closing dinner. And Andy Tai talked about a dinner to celebrate a deal, you meet with client. And that happened in Hong Kong. On the right-hand side of your screen Government's Exhibit 1885, November 12, 2012.

We know from the defendant's own records that the defendant had a dinner with Tim Leissner and Jasmine Loo the night before that closing dinner, the three of them. We also know that was the exact same time that the invoices get filed for Jasmine Loo's purchase of diamonds and also the purchase of diamonds that the defendant's wife makes from Karen Collection. We'll go back to that later on. But we know that as he's working again on Project Maximus, he's continuing to use the defendant and Jasmine Loo, and he's using money from the Silken Waters Victoria Square account. The money gets paid in September, but they are making purchases of diamonds in the same time in Hong Kong as Project Maximus is closing.

Back to Tim Leissner's testimony again. He was asked whether he got his kickback from Project Maximus right after that deal closing. He said it took longer than that. The reason for the delay was that people had been promised money out of Magnolia and they didn't get paid out of Magnolia.

When you look at the waterfall for Project Magnolia, we know that people like Terence Geh and Vincent Koh didn't get paid out of the Project Magnolia funds. They were so busy taking money out for all these people, they just didn't pay everybody with that initial set of money, so their payments actually got delayed. So Leissner said that his payment and Roger Ng's payment for Project Maximus didn't come right away because Jho Low needed to pay out everybody else. He also said that this is where he begins to use Capital Place to make payments at Jho Low's direction to other participants in the scheme.

So he originally used it to pay Roger Ng and is now being asked by Jho Low to pay a bunch of other people. You remember the e-mails that we saw where Jho Low or Eric Tan is directing Tim Leissner to make payments to a bunch of different shell accounts. And Tim Leissner testified that his understanding was those individuals were participants in the scheme. He gets the instructions; he makes the payments.

If we look at Government's Exhibit 152, that is exactly what we see actually happening. So this is the money flow from Project Maximus, all of these people who didn't get paid the first time around, get paid now. So you've got Terence Geh, Koh, Jerome Lee, they get their first payments out of the Project Maximus money. You can see that Capital Place is now playing a bigger role and making some of those payments at Low's direction.

Then because Jho Low's reed knows no bounds, they do Project Catalyze, the final deal, $3 billion fundraising that happens in March of 2013.

Again, this is the Capital committee memo for that, the same process at Goldman. Tim Leissner worked directly on this deal. The defendant did not work on this deal directly; but he did, as we'll see as part of his role in the securities division, he did sell the bonds for Project Catalyze. Remember these are all debt transactions. So Goldman buys the bonds first then they sell them to other people.

So the defendant was involved in selling the bonds for Project Catalyze. And you can see that when they have issues selling the bonds, he and Tim Leissner go back to Jho Low for help to figure out who can buy them; because they had done so many raises so quickly that they were having trouble selling some of the bonds.

And so Jho Low at Deal Rainman address, is connecting Tim Leissner with somebody in Malaysia who might be interested in buying some of the bonds. And that then gets forwarded to Roger Ng.

Again, third deal still communicating on personal e-mail addresses, the Rainman address for Jho Low that gets deleted, and the RogerNg1 gmail address that gets deleted. You can see that they are discussing the global bonds from the Project Catalyze deal.

Then finally if we look at the transfers in the Project Catalyze time frame, this is when Tim Leissner and Roger Ng get the final transfers that I talked about earlier this morning. We can see that in this time frame, some of the money for these transfers actually does come from Project Maximus. If you look at the payment out of the fake Aabar account there with the asterisk, Eric Van Dorn testified that money was left over from Project Maximus. And then there was other money in the mix in these accounts that came from Project Catalyze.

It also shows you that Leissner testified to what he knew. His understanding from Jho Low was that they were getting paid out from Maximus. They wouldn't get a separate payment from Catalyze. And the money they were going to get, was coming from Maximus or somewhere else. He didn't actually know because he didn't look at the bank records that that money was traceable to Catalyze. He thought it was coming from somewhere else. But it's entirely consistent with his testimony that all of these people were still waiting for the second payment out of Project Maximus and that money came later in time.

You can see that here because people like Vincent Koh, Jerome Lee, Terence Geh get the second payments in this time period, as does Tim Leissner, and as does the defendant. I want to talk next about the second conspiracy that the defendant is charged with, which is the circumvention of Goldman's internal accounting controls. I want to look at what the defendant and Tim Leissner were doing to push the deals through at Goldman.

What they did was to lie to the Goldman committees and to conceal information from the Goldman committees to get them to sign off. They obtained the authorization for the deals by fraud. What I'm going to walk you through is basically the four things that they did not disclose to the committee.

Again, that there were bribes that were going to get paid out of the money. That the fake Aabar account would receive payments from 1MDB, and that really went to the structure of the deal, right, the money goes into 1MDB then gets pulled out to go to the fake Aabar account. That Low was actually the key decision-maker behind the deals pulling the strings. And that Roger Ng and Tim Leissner were going to be receiving kickbacks from the deals, so they had a personal financial interest.

That is what was not told to the committees. That is what, had the committees known, they would not have approved the deals.

To start, you heard testimony from a number of committee members throughout the trial. One was Stephen O'Flaherty, who is in the business intelligence group. They said that committee members need accurate information to inform their decision. If they are going to make a decision to commit Goldman's money to a deal, they need to have full information about what is going on with the deal in order to approve it. He also said that a deal wouldn't go forward if they knew that bribes were being paid. And a deal wouldn't go forward if there was a substantial payment that wasn't disclosed. That it is important to Goldman to understand all of the financial aspects of the deal in order to sign off on them.

You heard similar testimony from Robert Mass and Craig Broderick, other committee members, who talked about they would want to know of any third-party, intermediaries involved. They want to know if anybody on the deal team has a personal conflict. These are all things that the committees need to know before they approve a deal.

You heard testimony from Leissner about what the agreement was with him and the defendant and a few others about what to tell Goldman about Jho Low. The question he was asked was basically, Jho Low had now rejected a bunch of times private wealth management clients, rejected in 2010 in Switzerland, 2011 in Singapore, you got the Kazak Gold rejection. Why are you guys working with him for these, why were you working with Jho Low for these deals? And the answer is because Jho Low is the one that brought the deals to the table. They are working with Jho Low because they had to. They wanted to get the business in and they didn't want Goldman to know that. So they needed to work with him, but they needed Goldman not to know that is sort of the crux of what is going on in this part of the conspiracy. He talked to you about how they made a decision to keep the information from the control functions. And that the defendant and Tim Leissner, along with a couple of other people, Andre Vella, Toby Watson and Jonathan Dunne knew that Jho Low was involved.

Again, there is a distinction. The defendant and Tim Leissner knew about the bribes; the other people knew that Jho Low was on the edges. They are all business people. They know Jho Low is involved. They make a decision, we want to get these deals done, if Goldman knows that Jho Low is involved it's not going to happen, so we're going to agree that we're not going to talk about Jho Low on Goldman e-mails, keep it off of the system. We're not going to mention to the committee that Jho Low is involved, that's how we're going to get the deals done. That's exactly what you see happening. We walked through all the e-mails where Tim Leissner and the defendant are e-mailing with Jho Low not on Goldman e-mails to keep him out of the mix. And we're going to see all the ways in which they also didn't disclose him to the committees.

One point here is about Andy Tai, the junior banker who you heard from in the beginning of the trial. This is testimony from him about how he didn't know Jho Low was involved. And he is working 80- to 90-hour weeks with the defendant and Tim Leissner on these deals to get them done. You see him all over the official Goldman e-mails related to the deals. He's working on the committee memos. He didn'tknow that Jho Low is involved. That's really significant, because the defendant and Tim Leissner are keeping this information close. They are keeping it close. Andrea Vella Toby Watson, a couple of people know, but most do not, including the people working constantly on these deals like Andy Tai.

The reason why they needed to keep the information so close is because they could not risk Goldman knowing that Jho Low was involved. And they certainly couldn't risk Goldman knowing that the money was going to get paid to bribes and to kickbacks.

You heard Andy Tai say that he did talk to the defendant about Jho Low at some point and the only thing the defendant said about Jho Low was that he was a boy from Penang. Keep that in mind. The defendant is traveling with Jho Low, e-mailing with Jho Low, gambling with Jho Low. And all he says to Andy Tai is he's a boy from Penang.

The bond deals were debt transactions. That means that Goldman is using its own money to buy the bonds in the first instance. You see that in Government's Exhibit 53A, Goldman's role is that they would purchase the bonds first.

Then this is also testimony from Broderick and Tai about how for the bond deals Goldman used its own money. The reason that that matters is because if Goldman is using its own money for a deal, they need to get authorization from the Capital committee and Suitability committee in order for the deal to proceed. If Goldman is going to spend its own money it wants to vet everything, make sure everything is okay, before it commits to involving its own money into something. So you heard testimony from Broderick and O'Flaherty that Firmwide Capital and the Suitability committee reviewed these deals for Goldman for Project Magnolia, Project Maximus and Project Catalyze.

You saw the Firmwide Capital Committee Charter which talks about having oversight of debt-related transactions. You also heard testimony from Robert Mass an Andy Tai who said these deals don't go through without the committee approval.

We also know that the committees' authorization was an internal accounting control. We saw these printouts, what they call the inside database. And you heard testimony, which I'll show you in a minute, from Sal Fortunato that these were controls over financial reporting. And the risk is they need to make sure that deals that go forward are authorized by the committees.

This is Government's Exhibit 952. Then Sal Fortunato testified that the inside database, where the internal controls over financial reporting and making sure that debt-related transactions received approval was in fact one of those internal accounting controls.

So what Tim Leissner told you, and what is clear from everybody else's testimony at Goldman, the only way they were going to get authorization for these deals where billions of bribes were being paid, was to lie to the committee. The only way to get authorization is to obtain it by fraud.

They knew they couldn't tell Goldman the truth about any of four things: The fact that bribes were going to get paid. The fact that Roger Ng and Tim Leissner were going to get paid. The fact that money was going to go from 1MDB to Aabar. And the fact that Jho Low was in fact the decision-maker behind the deal. None of that could be known to Goldman. So they obtained the committee's authorization by lying to them.

We know that the defendant knew that it was important to be honest and to provide material information to the committee. We know that because every committee member came in here and told what you the expectations were of Goldman employees, that they would be honest and they would provide accurate information about any deal before the committee to Goldman.

This is Robert Mass providing that testimony, because they wanted to kick the tires on every corner of every transaction. It's important that the deal team members disclose everything.

You heard it from Andy Tai. As he sits here today, he is now a managing director at Goldman Sachs. He said as a managing director, if he knew that false information was being provided he had a responsibility to speak up. He knows he can't lie to the committees. He knows he can't conceal things to the committee.

You know that the defendant, who was a managing director at the time, knew that as well. And you also knew that the defendant knew that Goldman committees will focus on concerns about the risk of government corruption generally and about Jho Low in particular.

These are the committee memos. This is an example, Government Exhibit 803. In the committee memos themselves they talk about concerns, deals property and government cronies. This is something that they're worried about, is a risk factor for the deal, and Roger Ng knew that he needed to tell Goldman that he knew something about this. He knew that someone was going to get paid out of the deal. And we know Roger Ng worked on these committees memos because he would — Andy Tai testified that all the deal team members contributed information and reviewed them, Andy Tai is the junior guy who is assembling them, but Roger Ng knew that this is what the committees were looking at.

And if it wasn't clear from the memos, it was also clear from the testimony that you heard. So, Stephen O'Flaherty testified that at the committee meeting he raised the question of Jho Low, and Tim Leissner lied to him. And so the defendant, who we know was on all of those committee meetings — and we'll see those invites in a minute — knew that not only were they worried about government corruption generally, but they were worried about Jho Low in particular and there were specific questions asked at the committee meetings about Jho Low

You also heard that testimony from Andy Tai. He said his memory was that the question was that Jho Low was involved in the transaction and Tim Leissner responded and said — answered no, and that nobody else spoke up and said, actually, Jho Low is involved.

And we know at the time of these committee meetings — the first one is in April, the second one is in May, there is an Asia Pacific meeting at the end of March — the defendant is e-mailing constantly with Jho Low offline. He's going — April 21st, he's going to a meeting with BSI Bank with Jho Low aside in a separate private room. He knows Jho Low is involved because he's dealing with him all the time and he does not say anything.

We also saw an e-mail, which is Government Exhibit 1974, where Andy Tai responded in connection with Project Maximus to a specific question about whether Jho Low was involved in the deal from the compliance team. If you remember, it is a really long e-mail chain which at some point gets forwarded to the defendant. And you can see that Andy Tai, based on the information he has from the deal team which includes the defendant, has no idea that Jho Low is involved and that is an e-mail that the defendant ultimately receives himself.

And then I'm just going to walk through this quickly. You know from Special Agent Cohen's testimony that the defendant not only received but accepted invites to all the committee meetings for Project Magnolia. This is the suitability committee meeting, this is the Firmwide Capital Committee meeting; and then there was another call, I think later in May, with a separate capital committee meeting. And then we know from Tim Leissner's testimony, but also from looking at the committee memos for Maximus and Catalyze, that the same thing happened with the other two deals. None of that information is in the committee memos, none of that information gets disclosed to the committees. So for all three deals, the committees' approvals were obtained by fraud.

I want to move on quickly to the money laundering conspiracy. As I said at the outset, you know, for money laundering — the Judge is going to explain to you the elements and I am going to go through them a little bit more in a minute — but basically, you know, if you send — there's sort of three ways in which money laundering is charged here: One is sending money into, out of or through the United States when it's from a crime and the purpose of the transfer is to conceal the fact that the money is from a crime; if you send money in, out or through the United States in furtherance of a crime, which is called promoting a crime; or, if you spend or transfer over $10,000 in dirty money in the United States. So at a very high level sort of, we know that this bribery and money laundering conspiracy, at every stage money is either being transferred to conceal the source of the funds in furtherance of the bribery scheme or to spend in excess of $10,000, and we see that sort of all the way through the transaction. The whole money flow, each one of these is a separate money laundering transaction, and we've talked about how many of these wires went through the United States because they were U.S. correspondent bank wires.

And you heard testimony from Roberto Amenta from the Fed about how these money transfers happened instantaneously and that any money transfers in U.S. dollars that's handled by Fedwire or CHIPS must go through the United States — and we walked you guys through that diagram — and that's true for all of those wires.

He also told you — and this is important to keep in mind — that the reason that people like to do U.S. dollar denominated transactions is they like to use the U.S. monetary system. The U.S. dollar is stable, the U.S. monetary system is well established, and it's a way in which you can transact business and know that your transactions are going to go through and be secure, and so there is a reason why people come to the U.S. and use the U.S. financial system. And they're doing that in this case because they want their transactions to be secure and they're use Fedwire and CHIPS which go through the U.S. And again, this chart, which is multiple pages and lists many of the transactions for the case, not only did all of these wires go through the U.S. that's on this chart, but many of them also passed through the Eastern District of New York either because CHIPS was processing in New York or because they're Fedwire banks which have their major accounts in New York.

And then we also see many wires. This is Government Exhibit 154, which is the chart related to the defendant's use of funds, which we're going to walk through right now. But all of these transfers are money laundering transfers as well. And so just at a high level, the money laundering conspiracy evidence that I want to sort of walk you through are the defendant's efforts to conceal the receipt of the criminal funds and the transfers of those criminal proceeds and so he uses a British Virgin Islands shell company and nominee director, they use Tan Kim Chin's name, they use those e-mail accounts that we talked about, they make false statements about the source of the funds and then there's the attempt to destroy the mail and shut down Silken Waters Victoria Square once it's received all of the monies from the crimes. We also saw that the defendant himself controlled the funds in those accounts and also once they were transferred out, and we also saw transactions in excess of $10,000 in the United States by the defendant.

And so let's just walk through some of this quickly. Again, you've got the use of the kctan9983 Gmail account and the Victoria Square e-mail account. And this, you know, these are discussions of some of the money transfers.

The top e-mail, 2479, is a discussion of investments that were going to be made out of the account. If you remember that one is signed "R," which is a way a lot of the defendant's e-mails in other accounts were signed.

And then if you look at the bottom, you can see the use of the kctan e-mail account to talk about — Ms. Lim writes "need to make my payment for my bling bling purchase," and that's a reference to the use of the money from Silken Waters/Victoria Square, which, again, is all proceeds from the bribery scheme to purchase the diamonds from Karen Collection.

So again, you can see that the defendant is directing investments and Ms. Lim is the one who is directing payments out of the Silken Waters account. And again, I think this puts the lie to Ms. Lim's testimony that the Victoria Square Investment e-mail address was only being used for receiving research reports from UBS when, in fact, what it's being used by is the defendant to monitor and direct investments in and out of this account.

We also know about the false statements to conceal the source of the funds, so they lie to UBS and say the first transfer is from equity investments. And then the second two transfers, the lie is that it's a gold venture and it's actually coming from two different people, that's why it's coming from two different accounts, when we, in fact, know that both of those transfers were coming from Judy Leissner.

And then again we see that the defendant and his wife used the money from the account to make purchases and investments. We talked about the Karen Collection jewelry, the bling bling purchase. We talked about Roger Ng directing investments out of the account. And then we also have this hourglass from Rose Trading. Ms. Lim's own testimony was that she wanted to buy the hourglass for the longest time. And at the end, once the money comes in from the crime, she gets to use the money to buy the hourglass. These are purchases that Ms. Lim and the defendant are making for themselves out of this account. And then Special Agent Fern also walked you through a lot of evidence about they intended to use funds from the account to purchase real estate in London. They didn't actually wind up doing that, but again, all those e-mails show the intention to control the funds in the account.

We also talked here about — this is Government Exhibit 359-T. That's one of the recorded calls that you heard from a bank. And this is the call where Ms. Lim and Fanny Khng discuss destroying the mail for Silken Waters/Victoria Square. And Fanny Khng says the mails can't be destroyed because you're using this nominee service and they're being held in the British Virgin Islands. And Ms. Lim says I want the mail to stop with you guys. And she asks whether the mail will continue to be held overseas even if she dissolves the company, and that's Silken Waters/Victoria Square. And that's because she did not want records from UBS related to this account sitting overseas somewhere else for five years where someone can access them. She wants that information to stay with the bank only and she doesn't want it sort of out there. And we know that that is the reason why she ultimately dissolves the company and asks them to stop the mail. It's not because, as she testified, that it was too expensive, because she could have switched to a different service. And, in fact, she opened a shell company several weeks later at the same time and put a mail hold on that one.

So it wasn't about the cost. It was about right here; I want the mail destroyed and I'm upset that they're going to hold onto it even if I dissolve the company.

And if we look, as Ms. Lim testified, they had this phone call and then she goes ahead and just dissolves the company immediately. Within a couple of weeks, they dissolve the company. And you can see from a note in UBS that they do this at a meeting that — surprise-surprise — the defendant and his wife attend and they proceed to transfer all of the money out of Silken Waters into another account in the name of the mother-in-law because they don't want any connection to the stolen money. It's come in — right? All of the transfers in the account came in from the crime and they're done and they want to move and put further distance between them and that original account.

And then if we look at sort of the waterfall down from Silken Waters where all the other places the defendant and Ms. Lim moved the money, we can see that they controlled those accounts as well, even the ones that were in the name of Tan Kim Chin, the defendant's mother-in-law. So, River Blue is the clearest one. We saw that the defendant gets his name out of River Blue as an authorized user on July 1st, 2014, just about four days after the last money from the criminal scheme gets moved into that account. We also see that the Tan Kim Chin account at UBS, there's a note in that account that that account is actively managed by Ms. Lim and by Roger Ng. And then if you look again at the money that gets transferred from the — between the two OCBC accounts — and those were two accounts that were in the name of Ms. Lim and also in the name of Tan Kim Chin — we see that Ms. Lim and the defendant controlled the money in those accounts as well.

So, this is an example. This is that transfer of $4.1 million between the two accounts that happened in October of 2013. If you look at Government Exhibit 397, that's the authorization for the movement. And Ms. Lim writes that the reason that the money is being moved is to purchase land in Johor, which is an area of Malaysia, and at the same day there is an e-mail where the defendant is looking at investment properties in Johor.

And so we know that it's not just the money in Silken Waters/Victoria Square that they control, but every time they move it out, even if it's in Tan Kim Chin's name or somewhere else, they're controlling that money.

And then again, we've seen this a number of times, many of these transactions both coming into the account and going out of the account pass through the United States and many of them also pass through the Eastern District of New York.

And then finally, there are transactions in excess of $10,000 in the United States because the shares of Bristol-Meyers Squibb — it's a U.S. company that they were investing in — the Karen Collection and the Rose Trading Limited purchases were all transactions that went through U.S. correspondent banks and through the Eastern District of New York.

I want to take a minute here to talk about some additional knowledge and intent on behalf of the defendant. I want to look at two categories of evidence. One is sort of the 2015 to 2018 time period and then I also want to talk about Goldman's policies and procedures. And this evidence is really about the defendant's knowledge and intent generally.

It goes to all three of the criminal schemes and it really ties in with a lot of what we've been seeing already from the evidence that happened during the conspiracy time periods.

So you all know in 2015, you heard a ton of testimony, that news reports about corruption at 1MDB sort of increased and there was this Sarawak Report that was put out in February 2012, and I think you heard testimony from Kevin Swampillai that this was really big news. Ms. Lim herself said everyone in Malaysia was following what was going on.

And so those news reports...

(Pause in proceedings.)

Sorry, I said February 2012. It's not in February 2012, it's in 2015, so I apologize.

So February 2015, after the conspiracy then, the news reports about corruption at 1MDB increased. We had seen news reports earlier; we will look at those later. But they really pick up the pace at this point, and that's the point at which the defendant and his wife delete four e-mail accounts related to the criminal scheme. The Victoria Square account gets deleted in February of 2015 and then Queens Gate and those two Roger Ng personal accounts that we saw all over the Goldman documents and all over the e-mails with Jho Low are deleted in March of 2015. At the same time, the text records show that Jho Low, who also deletes a lot of accounts — and we're going to talk about those in a bit — stops traveling to the United States, as does Roger Ng. So the text records that we looked at, the last flights for both of them into the United States, are in March and July of 2015. And you heard testimony from Tim Leissner that Jho Low told him and the defendant stop going to the U.S., you know, stay clear.

Leissner didn't follow those instructions; he wound up getting a subpoena and then arrested. But there was this caution to sort of stay out of the U.S. because things are heating up.

And we know in the same time period in 2015 that Roger Ng is questioned for the first time by Malaysian authorities in connection with the transfers.

So then we get to 2016 and the pressure continues to build. As I said, Leissner didn't stop traveling, he winds up getting subpoenaed. We know that Leissner and Roger Ng then discuss that subpoena immediately afterwards in Hong Kong and there are travel records showing that they're both there at the same time.

And then in 2017, Roger Ng is detained in Singapore and law enforcement asks Ms. Lim about transfers from Capital Place. Ms. Lim testified that was the first time she had heard of Capital Place. I submit that that doesn't make any sense because the bank records themselves, which she did receive the bank statements, you know, that you get on a monthly basis, said that the transfers, the first two transfers and one of the two second set of transfers were coming from Capital Place. She said that's the first time she heard of Capital Place. And what happens when the defendant is detained in Singapore is really significant because the defendant's detention is big news for Jho Low and for Tim Leissner because they are concerned that these investigations are starting to come closer to them.

And so I want to take a look at what happens when sort of the defendant gets detained. These are sort of messages that were from the defendant's — sorry, from Tim Leissner's phone. And he testified that these Super Energizer Bunzzz address was Jho Low and his address is this Forza address.

And so what happens in November of 2017 is Jho Low contacts Tim Leissner and sends him this article about Roger Ng's detention and there are a couple of things I just want to highlight from it. It basically says that Roger Ng is being held in Singapore and at the same point he was in a meeting with BSI with Yak Yew Chee, Tim Leissner, and Jho Low for discussions on Aabar. We know that that was, you know, that meeting you heard testimony about. And then it says: Looks like SG is still going full force. Not sure if as a result of AG statement that 1MDB investigation is ongoing. So basically what's happening is Jho Low is updating Tim Leissner on what's going on with the defendant's detention in Singapore. And you can see that Tim Leissner gets this and then he and Jho Low have a four-minute conversation the same day and Tim Leissner testified that was to discuss this update.

And then what happens next? So two weeks later, on November 16th, you can see what's on the left are phone logs and what's on the right are text messages. These came from the iPhone that Tim Leissner had on him when he was arrested.

The text messages and the phone calls are in different parts of the phone report, so we've put them together on the same page here. But you can see that Tim Leissner gets a sixteen-minute phone call from Jho Low on November 16th, which is the defendant discusses — Tim Leissner said that they discussed the defendant's detention. And then if you look on the right, you can see shortly thereafter, the next day, the defendant — sorry, Tim Leissner, who is Forza, reaches out to Morning Dew, which is Ms. Lim, and says heard the great news.

And the response is: Thank you. Can you speak? Leissner responds: I can. And Ms. Lim says: Call you. And "heard the great news" is that Jho Low had told Leissner that the defendant was going to be released from Singapore and that is the great news that Tim Leissner is then talking to Ms. Lim about. And once they exchange these text messages, they then speak; there's a thirty-second call and then a two-minute call. And the significance of this is that as the pressure is building and as the investigations are tightening and the circle is tightening, the people who are leaning on each other and communicating about what's going on and concerned about what's going on are Jho Low, Tim Leissner, and the defendant.

And then that pressure only increases in 2018. So, we know from Ms. Lim's testimony that there was a June 2018 news report that was published that Roger Ng and Jho Low might be arrested. And we know that Ms. Lim testified that she was warned by a friend who was connected to Jho Low that Leissner might be compromised. And we all know what compromised means; it means he might be cooperating. And that's a problem for them because they're all coconspirators and they're all in this together. And so Ms. Lim testified that she has a video call with Tim Leissner with the defendant present because she said she showed Tim Leissner the defendant on the call and relays that concern that Tim Leissner might be compromised.

And it's after that that there's a news report that Tim Leissner is cooperating, and then Ms. Lim and Roger Ng began to meet with Malaysian law enforcement. So all of this in the sort of post-conspiracy time period, you know, the circle is tightening, the investigations are coming closer, and the people that are keeping in contact with each other about what's going on and concerned about it are Jho Low, the defendant, and Tim Leissner.

The other sort of category of evidence that I wanted to just talk about that was general were the Goldman policies.

The Judge gave you an instruction that violating a policy isn't itself a violation of law; and that's right, but what it is is evidence of the defendant's knowledge and intent. And I think Mr. Agnifilo said in opening that the defendant was a process guy, and everything that you have seen so far today shows that he was not because, in fact, all of his various activities connected to these conspiracies were in violation of Goldman's policies. And that's important only because he knew there were policies in place and he chose to violate them because he was hiding things from Goldman and he was hiding the crimes that he was committing, and all of that is clear when we look at what he was doing.

So the first is the Goldman policy on the use of personal e-mail accounts. And you know that this gets violated from day one with Jho Low. He's using Queens Gate Capital, he's using Roger CH Ng, and he's using rogerng1@gmail to communicate with Jho Low many times offline from Goldman.

You also know that he violated Goldman's policies on private investments and outside activities. So we know that he received kickbacks, obviously, from the 1MDB bond deals.

Those were not disclosed either upfront during the committee process or at any other point. But we know from Ms. Lim's testimony that he had a bunch of other shell companies, some of which were created before the defendant left Goldman, so that was the Queens Gate Capital and the Kingfischer company.

We know that he was working out all of these side deals. And Ms. Fraser from Goldman testified that she went back and looked and none of these were ever disclosed to Goldman. And you know that this is similar to Leissner, who also never disclosed Capital Place or Kingsway or anything else to Goldman either.

You also know that Roger Ng was familiar with Goldman's anti money laundering policies. And Ms. Fraser explained those policies to you and said that everybody got training and she had checked and that Roger Ng got training.

And those policies talk about the same red flags that were raised in the PWM process for Jho Low and in the Kazakh gold transaction, talking about overly complex transactions, unclear source of wealth, operations which touch higher risk jurisdictions for bribery and corruption. Everything that Jho Low — you would be concerned about with Jho Low, unexplained wealth, government connections, all of these were red flags that the defendant knew were red flags because he sat through all of Goldman's trainings on anti money laundering. And you also heard testimony from Ms. Fraser that she had checked her records and that the trainings he had received covered anti money laundering but also covered discussion of the antibribery provisions of the FCPA and the internal accounting controls provisions of the FCPA. And that's at transcript page 4087.

So there are sort of two more things I want to do with you briefly. And the first is, as I said, I just want to walk you through some of the legal elements of the crimes that the defendant's been charged with. Again, whatever Judge Brodie says controls. This is just meant to sort of give you a preview and to talk about a couple of the key terms that you might hear.

The first crime, Count One, is conspiracy to violate the FCPA's antibribery provisions. And the elements are that there has to be an agreement to pay a bribe to a foreign government official to obtain or retain business, that the defendant knowingly and willfully became a member of the conspiracy, and that any one of the coconspirators committed at least one overt act during the conspiracy. And we'll talk about overt acts in a minute, but I submit to you that all of the evidence that you've seen so far clearly shows that the defendant agreed with Leissner and Low and others to pay government officials bribes, to obtain or retain business, and that he knowingly and willfully became a member. And we're going to walk through some of the overt acts or the specific actions that were taken in furtherance of the conspiracy.

This count has two objects, which just means two different ways that the crime can be committed. One, you can violate the FCPA as an officer, director, employee, or agent of an issuer, which we'll talk about in a minute, or as a stockholder acting on behalf of an issuer. That's one way you can violate the antibribery provisions. And the other way is called a territorial prong, which just means you're violating the provisions while you're in the territory of the United States.

And so just to go through a few sort of technical terms that you will hear in connection with the antibribery provisions.

The first is "instrumentality," which is just an entity that's controlled by the government. And we actually — you saw stipulations that 1MDB, IPIC, and Aabar are all instrumentalities under the FCPA, which just means they're government-owned entities, which makes anyone who works at those entities a government official. So someone like Jasmine Loo, because she works at 1MDB, is a government official of Malaysia.

The other term that you're going to hear, which I just read, is "issuer." And that just means a company that issues stock in the United States. And the Goldman Sachs Group — you heard testimony from Vikram Sarker's and Andy Tai and lots of other people that Goldman Sachs issues stocks in the United States and therefore is an issuer under the FCPA.

And that's the Goldman Sachs Group that's the public company headquartered at 200 West in Manhattan that everybody works for.

Two other terms are just a stockholder of an issuer, which just means someone who owns stock. And, as you know, Roger Ng was a stockholder of Goldman. We saw in his bonus performance that every year as part of his bonus he would get issued stock by Goldman. You know, we saw that in 2012 that stock was worth about $1.23 million. And we know from Vikram Sarker's testimony that the bond deals made money for Goldman and that that money was allocated among all the various subsidiaries and then that money was sort of rolled up into the public company's names. So when the defendant was acting on behalf of Goldman for the bond deals, he was acting as a stockholder of Goldman to benefit the public company.

And the same thing with employee or agent. We know that Roger Ng was an employee of Goldman between June of 2005 — and actually, that's the wrong thing that's highlighted, it's May of 2014, and that he was employed by Goldman that entire time. You saw some subsidiaries that he was employed at in Malaysia and Singapore and we know a subsidiary is just sort of a company underneath the parent company. And Vikram Sarker testified that all of the subsidiaries he worked for all received money from the bond deals as well. And so, you know, Roger Ng is employed by Goldman, the issuer, and he's working on behalf of that issuer even at the sublevel because it all winds up being work for Goldman, the company.

And then the final requirement is an overt act by Roger Ng or any coconspirator. And the Judge will instruct you that the overt acts do not need to be criminal in and of themselves but they're just an act or a step that's taken in furtherance of the conspiracy. So those could be meetings, they could be committee memos, money transfers, e-mails, phone calls, any of those could be an overt act. You will see, when you get the jury instructions, that there are some specific overt acts listed. You can find one of those acts or you can all find another act as well.

Count Two is conspiracy to circumvent Goldman's internal accounting controls. And the elements for that are just an agreement or understanding to circumvent or to avoid the internal accounting controls that Goldman puts in place to make sure that the money that it spends is adequately controlled so that its assets — and again, the debt transactions are where they were spending their own money — are safeguarded. And that's because they're a public company, people have invested in them, and they can't just be spending their money on something that's risky and they're going to lose money for the public company. And so all of those internal controls are designed to make sure that the money that's spent from Goldman is spent with the proper authorization. And we know here that there was a conspiracy to get that authorization by fraud to circumvent the controls that were in place to make sure that Goldman's money wasn't spent on things like bribes and that Roger Ng knowingly and willfully became a member of that conspiracy.

And again, for this count, needs to show an overt act. So you have seen this before. This is Government Exhibit 952, that the committee's authorization suitability committee, capital committee was an internal accounting control at Goldman. And then again, any of these things, meetings, information committee memos, approval by committees, statement to committee members, anything that's sort of taken in furtherance of the committee could be an — furtherance of the conspiracy could be an overt act; e-mails, phone calls.

And then finally, Count Three is the money laundering conspiracy. And we talked about that a lot, so I will be fast. But it's an agreement or understanding to violate a law of the United States and that the defendant knowingly and willingly became a member of the conspiracy.

Excuse me.

For the money laundering conspiracy there is no overt act requirement. So for Counts One and Two, we have to show an overt act. For Count Three, we don't. It's just sort of the way that the law is written.

For Count Three, there are three objects, which I talked about before, which are just three different ways that you can carry out the conspiracy.

One is the transfer of funds to, from, or through the U.S. to promote a specified unlawful activity. A specified unlawful activity is just a crime, and we'll talk about which ones there are. And then to promote is just to cause.

The second object is to transport funds to, from, or through the United States to conceal or disguise the origin of the funds. And this is, you know, sort of everything we talked about; all of the coconspirators, including the defendant, trying to hide where the funds are coming from, their connection to the funds, their connections to the accounts.

And then the third is a monetary transaction in interstate commerce with criminal proceeds from a specified unlawful activity that had a value of over $10,000. So again, spending more than $10,000 on a transaction of dirty money in the United States.

And then for the money laundering conspiracy, these are the four crimes that are sort of the specified unlawful activity, the source of the dirty money. So violations of antibribery provisions, which is the bribery conspiracy in Count One, violations of internal controls, which is the circumvention conspiracy in Count Two. Violations of Malaysian law, as well, qualifies. So there are two types of violations of Malaysian law. The Malaysians also have a law against bribery of a public official. And then Malaysian law also has a law against misappropriating public funds for the benefit of a public official. So stealing money from 1MDB, for example, to pay to a public official is a violation of the law in Malaysia. So any of these four can be the crimes that are the source of sort of the dirty money.

And then the last legal requirement I want to talk about is venue, and venue is a different standard. Everything else, it's the government's burden to prove beyond a reasonable doubt. Venue is a preponderance, and the Judge will explain that that is a lower standard than reasonable doubt. And basically what it is, is it means anything for each of these three conspiracies, there needs to be something that happened, an act by the defendant or any coconspirator, if reasonably foreseeable to the defendant, that happened or was caused by the defendant in the Eastern District of New York. And so that's going to be defined for you to include Brooklyn, Queens, Staten Island, Long Island, and then the water surrounding Manhattan and the Bronx and the water surrounding the island of Manhattan. And you will hear that conduct to and through the District is sufficient, including electronic impulses like e-mails, bank transfers, and telephonic communications.

And so very quickly, because we've been through this a lot before, travel to, from, and through the Eastern District of New York in furtherance of a conspiracy would all qualify for venue. We know that Tim Leissner traveled through the Eastern District of New York in March, on March 26th, for that meeting with Ananda Krishnan on Project Magnolia and that Roger Ng had originally been scheduled to attend that as well and to stay at the same hotel. And we know that Leissner and Low traveled to Teterboro and into Manhattan for the meeting and then Leissner traveled outside from Manhattan to JFK and then out from JFK on both ends passing through the Eastern District of New York.

Sorry, we have to change the battery on this. One second.

(Pause in proceedings.)

So, in addition, we saw actually the Defendant Exhibit 3. If you remember, that was the TEEMs charts and it had a lot of Tim Leissner's TEEMs on it and there were a bunch of meeting in New York. The chart was inaccurate in some way, and one way is that it missed a meeting in New York, but there were listed a number of meetings in New York in connection with 1MDB business, all which happened in Manhattan, which requires travel through the Eastern District of New York, and there are four that are listed there. And then we know that Roger Ng also made multiple trips to New York to meet with Jho Low, including the meeting in the Prime Minister — the meeting with the Prime Minister's children in Jho Low's apartment.

We also heard testimony from Mr. Harris, who worked for Goldman, about the data pads for Goldman phone calls and e-mails. Goldman's headquarters is located in Manhattan and there are four data pads on and off down in Manhattan, all of which pass through the Eastern District of New York, and so any e-mails or phone calls with Goldman employees in New York would have passed through the Eastern District of New York.

And we know that all of the committee meetings were based in New York and involved individuals based in New York and that many of the people who worked on the deals, some of them were in New York at various points or worked in New York as well.

We also know that the money transfer wires in furtherance of the conspiracies passed to and through the EDNY. We know the CHIPS wires were processing in New York on certain days. And we also know for Fedwire, that when the wires were Fedwire, that sometimes the banks, the major banks had their headquarters in Manhattan and communicate with the data servers in Texas or New Jersey as well every time that there was a wire transfer. And again, Government Exhibit 159, many of the wires in there which are sort of denoted by the green checkmark all passed through the Eastern District of New York.

And then finally, for certain of the purchases to promote or to launder money took place in New York.

You got the artwork that was purchased from Christie's.

You got the Lorraine Schwartz jewelry that was purchased in New York.

And then the Samilor Enterprises, that was Ms. Belkin who testified about those $130,000 Hermes bags that were purchased. She testified that her bank account was located in Syosset, New York. And remember when Roberto Amenta testified that the wire would have gone from outside the U.S. into the U.S., but the name on the actual wire transfer listed her business address, not her bank. She testified that her bank was located on Long Island.

And then we also know that the jewelry purchases and the hourglass purchase also were transfers that went through the Eastern District of New York because those were both CHIPS wire transfers that were processing here.

So the last thing I want to talk to you about — and like I said, I promised ten minutes and keep an eye on the clock — is the defendant's behavior and how it was coordinated with all of the other coconspirators in the case.

The defendant is up here on this board with everybody else who received funds from these criminal schemes and he's up here because he also received funds from the criminal schemes. And the defendant would have you believe that he is the only one up there who didn't receive them because he knew what was going on, that he accidentally received those, and I think all of the evidence you've already seen makes it clear that that is not what happened.

But what I want to do is walk you through some additional evidence, some of which you've seen before, some of which I'm sort of putting together in a different way that shows everything that the defendant did was in line with what all of the coconspirators were doing and that they all participated in the schemes together.

So, you'll see that they worked together on the 1MDB bond deals and other business deals; they all sought to conceal Low's connections with 1MDB; they had friendships with each other outside of business dealings; they used shell companies to conceal criminal proceeds — you've got the names of all of those up there — they created bank accounts shortly before receiving criminal proceeds; they lied about the purpose of the funds transfers; they used family members and associates to conceal the connection to the accounts; they purchased luxury items with the criminal proceeds; they created e-mail accounts to communicate about business, including 1MDB, to communicate about transfers about criminal proceeds, to impersonate other people to further distance themselves from the conspiracies, and they all deleted conspiracy-involved e-mail accounts in 2015. So again, the defendant worked with the co conspirators, all of whom received criminal proceeds on the 1MDB bond deals. You've seen that on the e-mails and the documents involving the deals.

He also worked with many of the co conspirators on other business deals. So the top left we have Roger Ng e-mailing with Yak Yew Chee and Terence Geh about another business deal related to SRC, which is another 1MDB deal.

We've got e-mails with the defendant and Low and some of these people and the side deals that we talked about, Stephen Dattels' other deals. And we know that Larry Low, who is the defendant's — sorry, who is Jho Low's father, was e-mailing in December of 2013 — that's Government Exhibit 2420 — about how Roger Ng was going to help him, talking about bridging a loan for a project. So these are people who are not only working together on these deals, the very deals from which the criminal proceeds come from, but on a bunch of other deals as well all in the same time frame.

We know from Leissner that Low was very particular about concealing his connections to 1MDB. He wanted to be the man behind the scenes. He often said don't use names, don't connect me. And we saw that already in a lot of the e-mails that the defendant himself received from Jho Low. So, you know, don't connect me to anybody, the king, don't connect me to 1MDB, do not state names, exclude me from this e-mail going forward. The defendant was aware of this and all of the participants in the scheme worked to keep Jho Low's name from being connected to 1MDB.

The defendant and Ms. Lim had personal relationships with the co-conspirators. We saw that the defendant and Terence Geh often emailed about personal stuff.

The defendant RSVP'd to Jerome Lee's wedding with his wife, Hwee Bin; and there was a discussion about also the jewelry purchases with Jasmine Loo and how Ms. Lim — they would bump into each other in the neighborhood, so they had connections separate and apart from 1MDB also.

We know that the defendant and Ms. Lim had many of the co-conspirators in their contacts. These are, again, for the defendant because he deleted his email account, these were the contacts that were backed up to his iCloud. You've got Terence Geh, you've got Azlin Alias, you've got Vincent Koh, you've got Amhari Nazaruddin; and then you've got — in the defendant's contacts, you've got the Deal Rainman emails as well.

We also know that the defendant's information was in Catherine Tan's contacts, and that's — Catherine Tan is Jho Low's assistant who set up $110,000-a-month apartments and a yacht; and we know that it was the defendant's email information and phone number in Catherine Tan's contacts and not Tim Leissner's.

We know that the defendant and co-conspirators created bank accounts shortly before receiving money from the crimes, so we already looked at the Silken Waters account needing to be opened urgently right before the money comes in.

There is a similar email from the Nik Faisal email account, which is Government Exhibit 2259 where he's asking BSI to open an account for him urgently in, again, less than two months before the money actually comes in. And then you've got Terence Geh and Jasmine Loo also opening their bank accounts less than a month before they received their payments out of Project Maximus. So it was a pattern; everyone knows the money is coming in; they need to open clean bank accounts that are going to receive the criminal proceeds.

We know the defendant and his wife lied multiple times about the money that was coming in. Got the excuse about the equity investment and the gold investment. Well, everybody else was lying about that, too. So you see that Jerome Lee on the right there said that he expected the money in the account to be employment income, which it was not; it was money from the scheme.

And then on the left, you can see that Terence Geh is getting asked questions from his bank about what the money from Capital Place was for, and he says it was a loan on personal capacity, and you know that's not true. You know that the money that Terence Geh received was money from the scheme.

We know that a lot of the co-conspirators used family members and others to conceal their connections to the account. So you've got the Eric Tan Kim Loong for Jho Low; you've got Jude Leissner for Tim Leissner; Ms. Lim and Tan Kim Chin for the defendant. Other people also used their wives or their business associates.

They all purchased luxury items with the money from the crimes. We saw the Karen Collection, the Rose Trading for the defendant, and we've looked at these, sort of — the Christie's, the Rose Trading, Lorraine Schwartz, Samilor Enterprises for other co-conspirators.

The email addresses that were created to communicate about business, so you have got Queensgait Capital for the defendant, and then you've got for Jho Low the Project Lionfish and the Deal Rainman emails. And, again, this is Government's Exhibit 2555-E, and this is one of the contact cards that the defendant had backed up to his iCloud with all of Jho Low's created email accounts that were used to communicate about business related to 1MDB. And then we also saw Project Dodobird for Jasmine Loo. We saw Jwo Gekko for Jerome Lee.

The co-conspirators also created email accounts for the transfers of money, so we've got the Victoria Square account, the Capital Advisors account for Tim Leissner. And then you can see for erictan.omc, he creates a special email account just for that Alsen Chance shell company that winds up sending a lot of the money; and they created email accounts to impersonate others. So, you know, we know that the KC Tan 9983 account was created to act as if they were Tan Kim Chin when they were dealing with the bank. And we see the same thing with — excuse me — we see the same thing with the Nik Faisal SRC at Gmail address where Jho Low is using Nik Faisal's name to talk to other people.

We also know the that co-conspirators destroyed evidence of communications. We had the whole discussion about Ms. Lim trying to destroy mail related to Silken Waters; and you see the chat between Terence Geh and Jho Low, destroy all chase — traits, shred. Nik Faisal emailed telling Terence Geh, delete this from your inbox from BBM, and we know that Ms. Lim destroyed evidence of communications as well. So when Special Agent Fern testified there were only three emails left in the account, and the emails that were deleted were emails like the email of Evelyn Teah setting up the account, or the email with the Karen Collection invoices, we only have those emails because we did search warrants on other accounts, and Ms. Lim deleted those emails.

And then we know — and you've seen this chart a number of times — Government Exhibit 72 — that Roger Ng and Ms. Lim weren't the only ones who deleted email accounts in 2015. We have all of the emails related to the defendants and Ms. Lim, and then also to Jho Low, and Nik Faisal, and Eric Tan Kim Loong, and Jerome Lee, and Jasmine Loo. They were all deleted between February 2015 and July of 2015, and they were deleted in their entirety.

And I know you have seen this a lot before, so I'm going to do this very quickly.

There were news reports before the deletions about concerns about 1MDB and Jho Low's connection. You saw that in 2013. In 2014, even in the news report about the defendant leaving Goldman Sachs, it talked about concerns about why 1MDB needed to raise money so quickly. And then we see the first deletion date is February 2015, and then there's a rash of deletions in March to July. And we know that this is around the time that the Sarawak Report gets published and that there are other emails about concerns at 1MDB and the concerns that stuff had been deleted at 1MDB, and we know that the defendant was following it because his iCloud showed that he had bookmarks for all of these various news sources. And we also know it because he had — Ms. Lim said it was the biggest story in Malaysia; everybody was following it, and that's when the email accounts get deleted. The email accounts you guys have seen time and time again today, throughout the course of the trial — the Jho Low email account, the Deal Rainman email account, the defendants four email accounts — they all get deleted in 2014 because they are covering up the evidence of the crimes that they committed together.

I want to thank you for your patience, and for your close attention, and for letting me run ten minutes over. I promise I am about to sit down.

The evidence that we just walked through — the testimony from the witnesses, the bank records, the emails — is overwhelming. It proves beyond a reasonable doubt that the defendant received more than $35 million in secret kickbacks for his role in this brazen bribery and money laundering scheme, and it further proves beyond a reasonable doubt that the defendant hid information from Goldman in order to get the committee approvals he needed for the deals.

The defendant and his co-conspirators committed serious federal crimes, and it is important to keep in mind that what he did caused real harm. Foreign corruption undermines the public's confidence in international markets and institutions, it destroys people's faith in their leaders, and it is deeply unfair to everybody else who plays by the rules; and when, as here, foreign corruption is undertaken by the defendant and others working for an American bank operating overseas, it impacts the confidence and trust in American businesses worldwide.

Most significantly, the harm to the people of Malaysia is immeasurable. Of the $6 billion raised for the three bond deals, almost half of that was stolen by the defendant and his co-conspirators and spent on bribes, kickbacks, and luxury goods instead of being used to improve roads, electric grids, and otherwise make life better for the people of Malaysia. It is for these reasons that the defendant must be held accountable for his actions.

The only verdict that is consistent with the law, the overwhelming evidence, and your common sense, is that the defendant is guilty on all counts.

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