Riggs National Corporation & Subsidiaries - Page 37




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         697-ZS correctly lists Exhibit 694-ZP(5) as the December 5, 1985,            
         agent bank letter covering those interest payments.18  In contrast,          
         in connection with the various September 1985 phase II CGA payments,         
         Joint Exhibit 697-ZS correctly lists Joint Exhibit 694-ZP(6) as the          
         January 21, 1986, agent bank letter covering those September 1985            
         interest payments.  As discussed supra, by this January 21, 1986,            
         letter (which is quoted in our findings), Morgan Bank was forwarding         
         DARF’s and supporting schedules purporting to evidence the Central           
         Bank’s alleged withholding tax payments on the foreign lenders’              
         behalf for the “interest period June 28, 1985 to September 27,               
         1985".                                                                       
              Further examination of Joint Exhibit 692-ZN(23) discloses that          
         Mr. Oliveira, by his November 19, 1985, letter, was transmitting             
         DARF’s covering only the phase II CGA interest payments the Central          
         Bank had made on September 27, 1985, not the January 1985 phase II           
         CGA interest payment.  Mr. Oliveira’s letter makes no mention of any         
         January 1985 phase II CGA interest payment; the letter states only           
         that DARF’s for “withholding tax payments” effected “September /85"          
         were attached.  Joint Exhibit 692-ZN(23) also contains no Central            
         Bank schedule page covering any January 1985 phase II CGA interest           



               18   Indeed, the Dec. 5, 1985, Morgan Bank letter (in Joint            
          Exhibit 694-ZP(5)) stated DARF’s and supporting schedules were              
          enclosed covering phase II CGA interest payments made on the                
          following specified dates in 1985:  January 16; March 7; March              
          11; March 12; March 27; April 16; June 12; June 18; June 27; and            
          June 28.                                                                    





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