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ways: (1) As a "subsidiary"; (2) as a fully insured "branch"; (3)
as an "agency"; or (4) as a "representative".
At various times during its years of operation, BCCI, S.A.
maintained agency offices in New York City, Los Angeles, and San
Francisco; BCCI Cayman Islands maintained agency offices in Miami,
Tampa, and Boca Raton. For a limited time BCCI, S.A. had a
representative office in Washington, D.C. (A representative office
is the lowest grade of banking offices. It is prohibited from
doing routine banking transactions and primarily serves a local
public relations function for the home office of the bank.) As
part of its worldwide branch2 structure, BCCI, S.A. maintained a
branch on the Isle of Man (IOMB).
BCCI, S.A.'s agency offices3 in the United States were not
permitted to exercise fiduciary or trust powers under Federal or
State law. The U.S. agency offices also were prohibited from
2 "Branch" is defined pursuant to 12 U.S.C. sec. 3101(3)
(1994), as "any office or any place of business of a foreign bank
located in any State of the United States at which deposits are
received."
3 "Agency" is defined pursuant to 12 U.S.C. sec. 3101(1)
(1994), as follows:
any office or any place of business of a
foreign bank located in any State of the
United States at which credit balances are
maintained incidental to or arising out of
the exercise of banking powers, checks are
paid, or money is lent but at which deposits
may not be accepted from citizens or
residents of the United States. * * *
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