Robert A. Stanford and Susan Stanford - Page 3

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          banks and related companies in Montserrat.                                  
               Under the laws of Montserrat, petitioner in 1985, 1986, and            
          1987, respectively, formed Guardian International Bank Ltd.                 
          (Guardian Bank), Guardian International Investment Services Ltd.            
          (Guardian Services), and Stanford Financial Group Inc. (Stanford            
          Financial), as controlled foreign corporations for the purposes             
          of engaging in offshore banking and other activities.                       
               By 1990, petitioner owned 95 percent of the shares of stock            
          in Stanford Financial.  Stanford Financial, in turn, owned nearly           
          100 percent of the shares of stock in Guardian Bank and Guardian            
          Services.  Thus, by 1990, Guardian Bank and Guardian Services               
          were brother/sister subsidiary corporations owned by Stanford               
          Financial as the parent corporation.                                        
               More specifically, on December 12, 1985, petitioner formed             
          Guardian Bank as a Montserrat corporation for the purpose of                
          engaging in certain offshore banking activities.  Upon its                  
          formation, petitioner and petitioner’s father each owned 50                 
          percent of the shares of stock in Guardian Bank.                            
               In its articles of association or charter, Guardian Bank's             
          stated business purpose to engage in the business of banking was            
          defined broadly and included administrative, management, and                
          marketing functions relating to the business of banking, as                 

               (1)  To carry on the business of Banking in all its branches           
               and to transact and do all matters and things incidental               

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