Joyce Aston - Page 7

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               Between 1977 and 1987, a BCCI nominee purchased the National           
          Bank of Georgia.                                                            
               Although BCCI never directly owned any U.S. banks, it                  
          controlled a number of banks in New York, Maryland, Georgia,                
          California, and Florida.                                                    
               In 1990, BCCI officials pleaded guilty to money laundering             
          charges involving wire transfers between Panama and BCCI-Panama's           
          account at FAB of New York.                                                 
          3.  Supervision of BCCI, S.A.                                               
               BCCI, S.A. was initially supervised by the Luxembourg Monetary         
          Institute.  As the bank grew--spreading to approximately 72                 
          countries--the Luxembourg authorities became concerned about their          
          ability to supervise BCCI effectively. Because of perceived                 
          irregularities in the European branches of BCCI, S.A., a "college           
          of supervisors" was established in the late 1980's.  The                    
          supervisors consisted of bank regulators from England, the Cayman           
          Islands, Luxembourg, and several other European countries.  They            
          attempted to create a consolidated and accurate picture of BCCI's           
          operations.  Bank regulators from the United States were not                
          invited to join this group.                                                 
               At the time BCCI's operating subsidiaries opened their agency          
          offices in the United States, no approval from any Federal banking          
          authority (such as the Federal Reserve Board) was required.  The            
          only approval required was a license from State banking regulators.         





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