Joyce Aston - Page 5

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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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