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BCCI, S.A. obtained approval from banking regulators in California
and New York for the establishment of agency offices in those
States, and BCCI Cayman Islands obtained approval from the banking
regulators in Florida for the establishment of agency offices
there.
The Federal Reserve Board had limited supervisory authority
over BCCI's U.S. agency offices. It was authorized to supervise
only the U.S. activities of the agency offices. The Federal
Reserve Board did not have: (1) Access to the bank's worldwide
records; (2) authority to go outside the United States to make any
determination regarding the bank's overall structure; or (3)
authority to obtain information concerning the asset quality
capital of the bank as an entirety.
In response to the lack of Federal control over BCCI's
operations in the United States, Congress enacted the Federal
Deposit Insurance Corporation Improvement Act of 1991, Pub. L. 102-
242, sec. 202, 105 Stat. 2286. This law requires foreign banks to
obtain approval from the Federal Reserve Board before conducting
business in the United States. It also requires foreign banks to
provide Federal regulators access to information regarding their
worldwide operations.
4. Petitioner's Bank Accounts
On June 20, 1980, petitioner and her husband opened account
No. 03000571 at the IOMB of BCCI, S.A., depositing 54,125 pounds
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