Cyprus Records Shed Light on Libya's Hidden Millions

Newly leaked records from Cyprus show how a Gaddafi-era pro­cure­ment offi­cial who stole mil­lions from his coun­try’s gov­ern­ment used off­shore com­pa­nies and mul­ti­ple bank accounts to chan­nel and laun­der the pro­ceeds abroad.

A for­mer head of Libya’s state con­tract­ing office who served under the country’s for­mer dic­ta­tor Muammar Gaddafi is being inves­ti­gat­ed because he is believed to have stolen 20 per­cent of the val­ue of the con­tracts his office handled.

Now, a new doc­u­ment leak reveals that the for­mer offi­cial may have used at least 16 bank accounts and sev­en com­pa­nies in Cyprus in the alleged crimes. The new­ly revealed mech­a­nisms form just part of his hid­den glob­al empire of more than 100 com­pa­nies, lux­u­ry real estate hold­ings, and oth­er assets.

From 1989 until 2011, Ali Ibrahim Dabaiba, once may­or of the coastal city of Misrata, con­trolled the Organization for Development of Administrative Centers (ODAC), a major pub­lic agency tasked with devel­op­ing the country’s infra­struc­ture. During his tenure as its direc­tor, Dabaiba award­ed 3,091 con­tracts with a total val­ue of 45.4 bil­lion Libyan dinars (US$ 33 bil­lion). In an inter­view to the Oxford Business Group, Dabaiba said that ODAC’s bud­get in 2008 was $6.8 billion.

The Tripoli-based Libyan author­i­ties believe that Dabaiba may have mis­ap­pro­pri­at­ed between $6 and $7 bil­lion of that amount using such tech­niques as charg­ing exces­sive “com­mis­sions” and award­ing ten­ders to com­pa­nies that were linked to him or that he secret­ly owned out­right. In 2013, they launched a crim­i­nal inves­ti­ga­tion into his activ­i­ties, as well as those of his broth­er Yusef Ibrahim Dabaiba and his sons Ibrahim Ali Dabaiba and Osama Dabaiba. They have also enlist­ed inter­na­tion­al inves­ti­ga­tors to try to recov­er the ille­gal­ly obtained assets, even offer­ing a per­cent­age of the funds as a finder’s reward.

In the run-up to the fall of the Gaddafi regime in 2011, Dabaiba knew a los­er when he saw one, and switched his alle­giance to the rebels. As Libya descend­ed into a bru­tal civ­il war that claimed the lives of thou­sands of his coun­try­men, his off­shore empire was ready to serve him well for a life in exile. (Dabaiba is now believed to be liv­ing in Istanbul.)

Ali Ibrahim Dabaiba, for­mer­ly may­or of Misrata and head of major Libyan state pro­cure­ment agency ODAC under the Gaddafi regime. Credit: Al-Mostakbal

The new trove of finan­cial doc­u­ments leaked to reporters, as well as inter­views with Libyan offi­cials inves­ti­gat­ing Dabaiba and files from that inves­ti­ga­tion, reveal more about how his schemes worked.

Just some of the Libyan official’s deal­ings involved Cyprus. But Dabaiba’s use of the country’s finan­cial ser­vices is par­tic­u­lar­ly sen­si­tive giv­en its recent efforts to clean up its image as a haven for mon­ey laun­der­ers and oth­er criminals.

Reporters for the Investigative Reporting Project Italy (IRPI) and an inde­pen­dent reporter work­ing for OCCRP in Cyprus have spent the last six months trac­ing where some of that miss­ing mon­ey may have end­ed up — and to what purpose.

Public Procurement, Personal Profit

Ali Ibrahim Dabaiba’s rise was as rapid as it was lucra­tive. Most like­ly born in 1945, the for­mer geog­ra­phy teacher became may­or of the key coastal city of Misrata not long after Gaddafi seized pow­er in 1969. In 1983, Dabaiba start­ed work­ing at ODAC, going on to serve as its direc­tor from 1989 to 2011.

Interpol Red Notice issued for Ali Ibrahim Dabaiba (since retract­ed). Credit: WayBack Machine Internet Archive

ODAC’s pur­pose was to use some of Libya’s con­sid­er­able oil wealth to devel­op the country’s pub­lic infra­struc­ture. As its head, Dabaiba played a deci­sive role, nego­ti­at­ing con­tracts and over­see­ing pay­ments to sup­pli­ers. But he also had oth­er loy­al­ties; doc­u­ments show that while on ODAC’s pay­roll, he ran sev­er­al com­pa­nies abroad that ben­e­fit­ed from his lead­ing role at the agency.

Dabaiba’s embez­zle­ment of ODAC funds did not go unno­ticed even dur­ing Gaddafi’s rule, accord­ing to a 2016 book on the Panama Papers leak by two of the jour­nal­ists who worked on it. The book notes that an advi­sor to the dic­ta­tor told Libyan inves­ti­ga­tors that dis­crep­an­cies in ODAC’s book­keep­ing had been noticed very ear­ly on, but were nev­er explored as Gaddafi and his sons were also involved in the agency’s management.

The country’s new rulers proved less will­ing to turn a blind eye, and Dabaiba’s for­tunes changed. In 2012, along with oth­er Libyans hold­ing alleged­ly stolen assets, he was black­list­ed by the Tripoli-based National Transitional Council, the country’s new gov­ern­ing body.

By this point, Dabaiba had fled Libya.

The author­i­ties request­ed an Interpol red notice in an attempt to appre­hend him on charges of embez­zle­ment of pub­lic funds, mon­ey laun­der­ing, abuse of pow­er and cor­rup­tion, but the doc­u­ment is no longer in force. According to a Libyan news site which cit­ed social media, the Interpol war­rant led to his arrest in September 2014. (Interpol would not com­ment on the rea­son for its with­draw­al, refer­ring reporters back to Libyan author­i­ties, who have also not replied to requests for comment.)

Among the doc­u­ments obtained by reporters are dozens of invoic­es issued to ODAC by var­i­ous com­pa­nies under Dabaiba’s over­sight, show­ing how he either award­ed con­tracts to those he was affil­i­at­ed with or might have charged com­mis­sions of up to 20 per­cent on gov­ern­ment con­tracts he negotiated.

The leaked files also con­tain dig­i­tal records of at least 16 per­son­al bank accounts Dabaiba held in Cyprus with both Cypriot and for­eign banks. They show a port­fo­lio of invest­ments worth mil­lions of US dol­lars, an amount that is hard to square with what Libyan inves­ti­ga­tors have said was his offi­cial ODAC salary — just £12,000 ($15,600) per year.

In total, the Libyan inves­ti­ga­tors are look­ing into more than 100 com­pa­nies around the world relat­ed to Dabaiba, includ­ing 65 in the UK, 16 in the British Virgin Islands, 22 in Malta, six in India, and three in Liechtenstein. Libyan author­i­ties have asked law enforce­ment agen­cies in all of these juris­dic­tions for assis­tance in the investigation.

But it all start­ed in the east­ern Mediterranean, in the island nation of Cyprus, where Dabaiba once lived.

Women cel­e­brate the over­throw of the Gaddafi regime in Misrata, Libya. Credit: Youssef Boudlal / Reuters

Employer and Employee

Cyprus would have been an attrac­tive loca­tion for a Libyan offi­cial to set up off­shore com­pa­nies while his own coun­try was under UN sanc­tions for its role in the 1988 Pan Am bomb­ing. After all, the island offered con­fi­den­tial­i­ty in bank­ing ser­vices, had no anti-mon­ey laun­der­ing frame­work, and enjoyed a low cor­po­rate tax rate.

Dabaiba appears to have used at least sev­en com­pa­nies on Cyprus, as well as two in Canada and three in Liechtenstein, to invoice ODAC and to move and invest the stolen funds.

Dabaiba either worked for or owned some of these com­pa­nies, all of which were linked to an old friend of his who proved a use­ful part­ner in crime.

A Libyan busi­ness­man named Ahmed Lamlum, an old acquain­tance who died in 2014, had helped Dabaiba set up and main­tain his off­shore empire (as well as shar­ing in the spoils).

The close­ness of their rela­tion­ship is evinced by the trust Dabaiba appears to have placed in his friend. As Lamlum’s chief accoun­tant once wrote in a 2000 let­ter to his Credit Suisse bank man­ag­er, the Libyan held pow­er of attor­ney to rep­re­sent Dabaiba “in his bank accounts” at the Swiss bank.

An exam­ple of how ODAC helped embez­zle Libyan pub­lic funds for pri­vate prof­it: in a series of trans­ac­tions in 1997–1998, Dabaiba-linked con­trac­tors invoiced the pro­cure­ment agency for ever larg­er amounts of mon­ey — all for the pur­chase of one vehi­cle. Click to enlarge. Credit: Edin Pasovic / OCCRP

Dabaiba and Lamlum shopped for prop­er­ties in Switzerland togeth­er, work­ing with the same real estate agent to pur­chase two neigh­bor­ing flats in Montreux on Lake Geneva and even used the same dec­o­ra­tor in 1995. In addi­tion to their busi­ness part­ner­ship, the two even devel­oped fam­i­ly ties. In 1998, Dabaiba’s daugh­ter Amna mar­ried Lamlum’s nephew Hani Lamlum.

One of the com­pa­nies the two men made use of togeth­er — per­haps the most impor­tant in their schemes — is the Cyprus-based Fabulon Investments, lat­er renamed to Global Business Network International.

According to its web­site, this com­pa­ny today spe­cial­izes in office equip­ment, office automa­tion, and sta­tionery. But Fabulon was much more than that, play­ing a key role in the theft of Libyan state funds from ODAC. In addi­tion to receiv­ing a large por­tion of the mon­ey itself, the com­pa­ny act­ed as the phys­i­cal head­quar­ters for some of Dabaiba’s oth­er companies.

Lamlum was reg­is­tered as Fabulon’s ben­e­fi­cial own­er, mean­ing that the company’s prof­its ulti­mate­ly accrued to him, at least on paper. As for Dabaiba’s role, the leaked doc­u­ments var­i­ous­ly refer to him as Fabulon’s employ­ee, its head, and also “the sole sig­na­to­ry for most of the company’s bank accounts in Cyprus, Switzerland and England.” A doc­u­ment relat­ing to Fabulon’s bank account at the Cyprus branch of Hellenic Bank gives Dabaiba’s posi­tion as the company’s man­ag­ing director.

Between August 1997 and September 1998, the com­pa­ny sub­mit­ted at least nine invoic­es to the Libyan agency for sub­stan­tial orders of con­struc­tion mate­ri­als and fur­nish­ings. The total invoiced amount was in excess of $5.4 million.

In 1994, he claimed to be a busi­ness con­sul­tant of Nuvest Consultancy, anoth­er Cyprus-based company.

It’s not known what pro­por­tion of these funds may have found their way into Dabaiba’s per­son­al accounts, or whether he received any kick­backs for the ODAC con­tracts he steered towards Fabulon. (It is known that, even as he earned £12,000 per year from the Libyan agency, he was also pulling at $90,000 from the com­pa­ny as an annu­al salary.)

The Elias Neocleous & Co. tow­er in Limassol, Cyprus. Credit: Stelios Orphanides / Sara Farolfi

Our Man in Cyprus

In addi­tion to Fabulon — which remains active to this day under the name Global Business Network International — Dabaiba and Lamlum used sev­er­al oth­er Cypriot com­pa­nies to obtain and han­dle their mon­ey.
These include Midcon Ltd., Berk Holding Ltd., Olexo Ltd., and Murhead Ltd, all of which either had trans­ac­tions with ODAC, hid the alleged stolen assets, or both.

One of these com­pa­nies, Olexo, was used to man­age Dabaiba’s assets in real estate, rent­ing out one prop­er­ty in the British coun­ty of Surrey for £3,000 per month in 2006. Another prop­er­ty in Surrey gen­er­at­ed Berk Holding £3,500 a month. (The prop­er­ties, which were worth £2 mil­lion in 2014, were owned by anoth­er Dabaiba-linked offshore).

Documents relat­ing to Olexo pro­vide firm evi­dence of the close busi­ness rela­tion­ship between Lamlum and Dabaiba — and of the work of the Cypriot agent who helped them make the scheme possible.

On May 27, 2004, Lamlum and his wife, who at that point were Olexo’s ulti­mate ben­e­fi­cia­ries, instruct­ed a local law firm to trans­fer the 25,000 shares they each held in the com­pa­ny to “Ali Ibrahim Dabaiba or any nom­i­nee des­ig­nat­ed by him.”

Andreas Neocleous & Co, the firm that car­ried out this ser­vice, is one of the largest legal and cor­po­rate ser­vices providers in Cyprus. Its wealthy, promi­nent clients have includ­ed Dmitry Rybolovlev, a Russian oli­garch who had invest­ed heav­i­ly in the country’s bank­ing sector.

Andreas Neocleous & Co has a check­ered rep­u­ta­tion. Its founder, Andreas Neocleous, with­drew from active ser­vice after the firm and one of his sons were con­vict­ed last year of brib­ing the country’s Deputy Attorney General, Rikkos Erotokritou, in an unre­lat­ed high-pro­file cor­rup­tion case. The inci­dent rocked the island’s polit­i­cal estab­lish­ment, and the firm was replaced by a firm called Elias Neocleous & Co, named after Andreas’s oth­er son.

But the firm had no prob­lem oblig­ing the Lamlums’ request in 2004, trans­fer­ring their 50,000 Olexa shares to Dabaiba just as request­ed, which made him the company’s ulti­mate beneficiary.

Documents in the leak con­firm Lamlum’s com­mu­ni­ca­tions with Neocleous & Co, show­ing that he had paid the firm for its ser­vices and acknowl­edged receipt of doc­u­ments relat­ing to the transfer.

The firm also seems to have dealt with Dabaiba himself.

Olexo’s two nom­i­nee share­hold­ers remained the same for six years after the share trans­fer, show­ing that Neocleous & Co most like­ly con­tin­ued to pro­vide cor­po­rate ser­vices to the com­pa­ny under Dabaiba’s ownership.

Neocleous & Co and affil­i­at­ed com­pa­nies also appear to have pro­vid­ed nom­i­nee direc­tors and share­hold­ers to the oth­er Dabaiba-linked com­pa­nies in Cyprus. The com­pa­nies shared the law firm’s head­quar­ters in Limassol — the Neocleous House — as their postal address. And until he stepped down last November, Andreas Neocleous him­self served as the nom­i­nee direc­tor of Fabulon (now GBNI).

Despite all of the above, when approached by reporters for com­ment, Kyriaki Stinga, the com­pli­ance offi­cer of Elias Neocleous & Co, who also spoke on behalf of the law firm’s pre­de­ces­sor, strong­ly denied any rela­tion­ship with Dabaiba.

She flat­ly denied that it had ever had Ali Ibrahim Dabaiba as a client, but acknowl­edged that it had offered ser­vices to GBNI. She also said that the firm had no record of GBNI being linked to Dabaiba — this despite the fact that he was not only on the company’s pay­roll, but had access to its cor­po­rate account at Hellenic Bank.

In an emailed state­ment, lawyer Andreas Neocleous said that the law firm he found­ed had no involve­ment in the day-to-day run­ning of its clients’ com­pa­nies nor in their com­mer­cial activ­i­ties. “We should not have expect­ed to be aware of the details of its com­mer­cial oper­a­tions or its trad­ing part­ners unless there was a legal issue relat­ing to them, such as a bad debt,” he concluded.

Andreas Neocleous added that he could not com­ment on spe­cif­ic mat­ters relat­ed to his clien­tele, cit­ing the Cypriot advo­cates’ law, which bans lawyers from shar­ing con­fi­den­tial information.

However, he did stress that his firm had “act­ed pro­fes­sion­al­ly” and that “noth­ing came to [its] atten­tion that would have raised any sus­pi­cion in the mind of a rea­son­able per­son regard­ing the com­pa­nies and their stake­hold­ers.” Neocleous added that at the time of most of these com­pa­nies’ incor­po­ra­tion, today’s know-your-cus­tomer and due dili­gence stan­dards “did not apply.”

Had our client accep­tance pro­ce­dures dis­closed any issues that would have pre­clud­ed us from act­ing, we should have declined to act,” he said.

The GBNI offices in Limassol, Cyprus. Credit: Stelios Orphanides / Sara Farolfi

A Friend in Need

But let’s not for­get Dabaiba’s close friend Ahmed Lamlum — after all, Dabaiba cer­tain­ly didn’t.

After Gaddafi was killed and his regime over­thrown in 2011, the two men’s pre­vi­ous schemes were no longer pos­si­ble — Dabaiba was on the run and no longer in a posi­tion to secure lucra­tive con­tracts. But there is evi­dence that, in at least one case, Lamlum man­aged to con­tin­ue mak­ing lucra­tive deals at the expense of the Libyan state. In 2013, a com­pa­ny under his con­trol sold shelv­ing to a state tele­com provider for about €182,000 with the help of a “mid­dle­man” who pock­et­ed a 10 per­cent com­mis­sion with­out actu­al­ly par­tic­i­pat­ing in the trans­ac­tion. Internal cor­re­spon­dence seen by reporters attests to the fact that the price had been arti­fi­cial­ly inflat­ed to account for the commission.

After Lamlum died in September 2014, Cypriot tax author­i­ties asked the admin­is­tra­tors of his prop­er­ty, the Andreas Neocleous & Co’s lawyer Christos Vezouvios and Lamlum’s son Samy, to explain ori­gins of the $2.6 mil­lion wired through his bank accounts at two banks on the island between 2008 and 2013.

As a Cyprus tax res­i­dent, [he] is taxed for his glob­al income,” tax offi­cer Tasos Constantinou wrote to Vezouvios and Samy Lamlum in a 2015 let­ter. “The income of €40,000 to €45,000 per year is insuf­fi­cient in my view to cov­er the sig­nif­i­cant liv­ing expens­es of the fam­i­ly and the main­te­nance of the house.”

The house in ques­tion may refer to a house Ahmed Lamlum’s wid­ow, Munira Gadour, rents from Dabaiba-linked com­pa­nies near Limassol. This is con­firmed by the source of the leaked doc­u­ments. It boasts six bed­rooms, sev­en bath­rooms, a maid’s quar­ters, fire­places, a home cin­e­ma, a sauna, a Jacuzzi, heat­ed floors, a gym, a sea view, and a swim­ming pool. At the time of Constantinou’s let­ter, it was worth an esti­mat­ed €3.5 million.

 Where The Money Went

Dabaiba and Lamlum may have exploit­ed the finan­cial sys­tem of Cyprus to get the funds out of Libya. But that’s not where they spent most of it.

As it turns out, through their net­work of shell com­pa­nies around the world, the duo invest­ed in prop­er­ties from Canada to Scotland to main­land Europe.

In Canada, Dabaiba and Lamlum set up at least two com­pa­nies, includ­ing the cur­rent­ly inac­tive Weylands International Trading Inc., estab­lished in December 1995.

This com­pa­ny appears to have been a way for the duo to fun­nel their Libyan mon­ey into Canada. Weylands, which was chaired by Lamlum and vice-chaired by Dabaiba, received a CA$ 1 mil­lion loan from Transinfo, anoth­er Dabaiba com­pa­ny in Liechtenstein that trans­act­ed with ODAC. Essentially, he was lend­ing mon­ey to him­self — and then using it the fol­low­ing year to acquire a CA$ 4.5 mil­lion prop­er­ty in Montreal.

Along with his wife, Ali Ibrahim Dabaiba also owns a Montreal flat worth CA$ 628,000 in 2017.

(Weyland paid off in anoth­er way, too: In 1997 and 1998, the com­pa­ny invoiced ODAC on sev­er­al occa­sions for the sale of tires, med­ical equip­ment, and office fur­ni­ture for over US$ 2.3 million.)

The Dabaiba funds even made their way to the Scottish Highlands. Taymouth Castle is one of Scotland’s most impres­sive build­ings: a neo-Gothic edi­fice Queen Victoria once visited.

With its own 18-hole golf course, the cas­tle lies on an estate of over 450 acres. Built in 1552, the build­ing, which is regard­ed as the most impor­tant Scottish cas­tle in pri­vate hands, stands vacant.

A bill­board just out­side the front entrance alerts vis­i­tors that improve­ments are on the way, but locals are skeptical.

The cas­tle is a des­ti­na­tion for tourists who stroll around the tidy main street and pleas­ant hol­i­day vil­lage of near­by Kenmore. But rather than being admired for its mag­nif­i­cence, it is instead dis­cussed as the “mys­te­ri­ous prop­er­ty at the cen­ter of a Libyan mon­ey-laun­der­ing intrigue,” as one tourist recent­ly told reporters.

Taymouth Castle, Scotland, is just one UK prop­er­ty which is appears linked to Dabaiba’s off­shore empire. Credit: Sara Farolfi

Sadly, this is no fairy tale. Along with sev­er­al oth­er high-end prop­er­ties in the United Kingdom, Taymouth Castle is sus­pect­ed to have been among an intri­cate web of Scottish com­pa­nies that Dabaiba alleged­ly used to laun­der his illic­it proceeds.

The alle­ga­tion, made by the Libyan attor­ney gen­er­al, is includ­ed in a con­fi­den­tial request for legal assis­tance sent to the UK author­i­ties in 2014.

The cas­tle may not be the full extent of Dabaiba’s prop­er­ty empire in the United Kingdom.

As report­ed by the Guardian, com­pa­nies that appear to be con­trolled by Dabaiba, his two sons, and his broth­er have invest­ed in at least six pres­ti­gious English prop­er­ties that have a cur­rent val­ue of over £25 mil­lion. Furthermore, the Sunday Times recent­ly report­ed that Ali Dabaiba has amassed a £3 mil­lion prop­er­ty empire in Edinburgh.

The asset recov­ery team work­ing along­side Libyan inves­ti­ga­tors have also found two high-end German prop­er­ties in Brandenburg and Berlin that belong to the Dabaibas. Their val­ue is unknown.

These exten­sive list of prop­er­ties around the world sug­gests not only that Ali Ibrahim Dabaiba’s real estate port­fo­lio has con­tin­ued to thrive since he fled Libya, but that the Lamlum fam­i­ly con­tin­ues to ben­e­fit finan­cial­ly from their long-stand­ing relationship.

Comments And No Comments

The rev­e­la­tions about the Dabaibas’ and Lamlums’ oper­a­tions in Cyprus come at a time when the island is try­ing to improve an inter­na­tion­al rep­u­ta­tion tar­nished by reports of mon­ey laun­der­ing by Eastern European oli­garchs. They appear more than five years after Cyprus agreed, as part of its 2013 bailout agree­ment with the European Commission, the ECB, and IMF, to intro­duce stricter anti-mon­ey laun­der­ing legislation.

MOKAS, the anti-mon­ey laun­der­ing unit of the Law Office of the Cyprus Attorney General, said via email that Cypriot author­i­ties can­not dis­close infor­ma­tion about pos­si­ble sus­pi­cious activ­i­ties report­ed to them or requests received from third coun­tries, but did add that “fur­ther actions are tak­en,” includ­ing liais­ing with the police, when deemed necessary.

A spokesper­son for Hellenic Bank, the local lender with which Dabaiba and Lamlum held both per­son­al and cor­po­rate accounts, said that while the bank’s pol­i­cy bans it from com­ment­ing on spe­cif­ic cus­tomer trans­ac­tions, this does not pre­vent it from tak­ing “the appro­pri­ate and nec­es­sary action” when there “is even the slight­est sus­pi­cion regard­ing mon­ey laun­der­ing issues.”

The spokesper­son added that the lender was coop­er­at­ing with both reg­u­la­tors and super­vi­sors to min­imise the risk of mon­ey laundering.

Credit Suisse, where Lamlum had pow­er of attor­ney to rep­re­sent Dabaiba, said that it is “com­mit­ted to oper­at­ing its busi­ness in strict com­pli­ance with all the applic­a­ble laws, rules and reg­u­la­tions in the mar­kets in which it operates.”

In addi­tion, Andreas Neocleous said that the Central Bank of Cyprus, which was charged with approv­ing for­eign invest­ment on the island before it became an EU mem­ber, had employed “exten­sive vet­ting and enquiries” in all of the invest­ments it had approved, which would have includ­ed Dabaiba’s.

In addi­tion,” he con­tin­ued, “the approval of the coun­cil of min­is­ters was required to under­take cer­tain cat­e­gories of busi­ness and buy premis­es at the time, and the com­pa­nies suc­ceed­ed in obtain­ing this. Their rela­tions with the rel­e­vant gov­ern­ment depart­ments were excellent.”

The Lamlums, con­tact­ed via GBNI’s gen­er­al email account and the Neocleous law firm, did not respond to requests for com­ment. Dabaiba could not be reached for comment.

Family mem­bers of the late Ahmed Lamlum still live in Cyprus to this day.

Reporters tried to reach Dabaiba for com­ment on this sto­ry, but were unable to do so.

Cyprus Records Shed Light on Libya’s Hidden Millions

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