There have been a number of matters which the Subcommittee
has received some information on, but has not been able to
investigate adequately, due such factors as lack of resources,
lack of time, documents being withheld by foreign governments,
and limited evidentiary sources or witnesses. Some of the main
areas which deserve further investigation include:
1. The extent of BCCI's involvement in Pakistan's nuclear
program. As set forth in the chapter on BCCI in foreign
countries, there is good reason to conclude that BCCI did finance
Pakistan's nuclear program through the BCCI Foundation in
Pakistan, as well as through BCCI-Canada in the Parvez case.
However, details on BCCI's involvement remain unavailable.
Further investigation is needed to understand the extent to which
BCCI and Pakistan were able to evade U.S. and international
nuclear non-proliferation regimes to acquire nuclear
2. BCCI's manipulation of commodities and securities markets
in Europe and Canada. The Subcommittee has received information
that remains not fully substantiated that BCCI defrauded
investors, as well as some major U.S. and European financial
firms, through manipulating commodities and securities markets,
especially in Canada, the Netherlands, and Luxembourg. This
alleged fraud requires further investigation in those countries.
3. BCCI's activities in India, including its relationship
with the business empire of the Hinduja family. The Subcommittee
has not had access to BCCI records regarding India. The
substantial lending by BCCI to the Indian industrialist family,
the Hindujas, reported in press accounts, deserves further
scrutiny, as do the press reports concerning alleged kick-backs
and bribes to Indian officials.
4. BCCI's relationships with convicted Iraqi arms dealer
Sarkis Soghanalian, Syrian drug trafficker, terrorist, and arms
trafficker Monzer Al-Kassar, and other major arms dealers.
Sarkenalian was a principal seller of arms to Iraq. Monzer Al-Kassar has been implicated in terrorist bombings in connection
with terrorist organizations such as the Popular Front for the
Liberation of Palestine. Other arms dealers, including some who
provided machine guns and trained Medellin cartel death squads,
also used BCCI. Tracing their assets through the bank would
likely lead to important information concerning international
terrorist and arms trafficker networks.
5. The use of BCCI by central figures in arms sales to Iran
during the 1980's. The late Cyrus Hashemi, a key figure in
allegations concerning an alleged deal involving the return of
U.S. hostages from Iran in 1980, banked at BCCI London. His
records have been withheld from disclosure to the Subcommittee by
a British judge. Their release might aid in reaching judgments
concerning Hashemi's activities in 1980, with the CIA under
President Carter and allegedly with William Casey.
6. BCCI's activities with the Central Bank of Syria and with
the Foreign Trade Mission of the Soviet Union in London. BCCI was
used by both the Syrian and Soviet governments in the period in
which each was involved in supporting activities hostile to the
United States. Obtaining the records of those financial
transactions would be critical to understanding what the Soviet
Union under Brezhnev, Chernenko, and Andropov was doing in the
West; and might document the nature and extent of Syria's support
for international terrorism.
7. BCCI's involvement with foreign intelligence agencies. A
British source has told the Bank of England and British
investigators that BCCI was used by numerous foreign intelligence
agencies in the United Kingdom. The British intelligence service,
the MI-5, has sealed documents from BCCI's records in the UK
which could shed light on this allegation.
8. The financial dealings of BCCI directors with Charles
Keating and several Keating affiliates and front-companies,
including the possibility that BCCI related entities may have
laundered funds for Keating to move them outside the United
States. The Subcommittee found numerous connections among Keating
and BCCI-related persons and entities, such as BCCI director
Alfred Hartman; CenTrust chief David Paul and CenTrust itself;
Capcom front-man Lawrence Romrell; BCCI shipping affiliate, the
Gokal group and the Gokal family; and possibly Ghaith Pharaon.
The ties between BCCI and Keating's financial empire require
9. BCCI's financing of commodities and other business
dealings of international criminal financier Marc Rich. Marc Rich
remains the most important figure in the international
commodities markets, and remains a fugitive from the United
States following his indictment on securities fraud. BCCI lending
to Rich in the 1980's amounted to tens of millions of dollars.
Moreover, Rich's commodities firms were used by BCCI in
connection with BCCI's involving in U.S. guarantee programs
through the Department of Agriculture. The nature and extent of
Rich's relationship with BCCI requires further investigation.
10. The nature, extent and meaning of the ownership of
shares of other U.S. financial institutions by Middle Eastern
political figures. Political figures and members of the ruling
family of various Middle Eastern countries have very substantial
investments in the United States, in some cases, owning
substantial shares of major U.S. banks. Given BCCI's routine use
of nominees from the Middle East, and the pervasive practice of
using nominees within the Middle East, further investigation may
be warranted of Middle Eastern ownership of domestic U.S.
11. The nature, extent, and meaning of real estate and
financial investments in the United States by major shareholders
of BCCI. BCCI's shareholders and front-men have made substantial
investments in real estate throughout the United States, owning
major office buildings in such key cities as New York and
Washington, D.C. Given BCCI's pervasiveness criminality, and the
role of these shareholders and front-men in the BCCI affair, a
complete review of their holdings in the United States is
12. BCCI's collusion in Savings & Loan fraud in the U.S. The
Subcommittee found ties between BCCI and two failed Savings and
Loan institutions, CenTrust, which BCCI came to have a
controlling interest in, and Caprock Savings and Loan in Texas,
and as noted above, the involvement of BCCI figures with Charles
Keating and his business empire. In each case, BCCI's involvement
cost the U. S. taxpayers money. A comprehensive review of BCCI's
account holders in the U.S. and globally might well reveal
additional such cases. In addition, the issue of whether David
Paul and CenTrust's political relationships were used by Paul on
behalf of BCCI merits further investigation.
13. The sale of BCCI affiliate Banque de Commerce et de Placements (BCP) in Geneva, to the Cukorova Group of Turkey, which owned an entity involved in the BNL Iraqi arms sales, among others. Given BNL's links to BCCI, and Cukorova Groups' involvement through its subsidiary, Entrade, with BNL in the sales to Iraq, the swift sale of BCP to Cukorova just weeks after BCCI's closure -- prior to due diligence being conducted -- raises questions as to whether a prior relationship existed between BCCI and Cukorova, and Cukorova's intentions in making the purchase. Within the past year, Cukorova also applied to purchase a New York bank. Cukorova's actions pertaining to BCP require further investigation in Switzerland by Swiss authorities, and by the Federal Reserve New York.
14. BCCI's role in China. As noted in the chapter on BCCI's
activities in foreign countries, BCCI had extensive activity in
China, and the Chinese government allegedly lost $500 million
when BCCI closed, mostly from government accounts. While there
have been allegations that bribes and pay-offs were involved,
these allegations require further investigation and detail to
determine what actually happened, and who was involved.
15. The relationship between Capcom and BCCI, between Capcom
and the intelligence community, and between Capcom's shareholders
and U.S. telecommunications industry figures. The Subcommittee
was able to interview people and review documents concerning
Capcom that no other investigators had to date interviewed or
reviewed. Much more needs to be done to understand what Capcom
was doing in the United States, the United Kingdom, Egypt, Oman,
and the Middle East, including whether the firm was, as has been
alleged but not proven, used by the intelligence community to
move funds for intelligence operations; and whether any person
involved with Capcom was seeking secretly to acquire interests in
the U.S. telecommunications industry.
16. The relationship of important BCCI figures and important
intelligence figures to the collapse of the Hong Kong Deposit and
Guaranty Bank and Tetra Finance (HK) in 1983. The circumstances
surrounding the collpase of these two Hong Kong banks; the Hong
Kong banks' practices of using nominees, front-companies, and
back-to-back financial transactions; the Hong Banks' directors
having included several important BCCI figures, including Ghanim
Al Mazrui, and a close associate of then CIA director William
Casey; all raise the question of whether there was a relationship
between these two institutions and BCCI-Hong Kong, and whether
the two Hong Kong institutions were used for domestic or foreign
17. BCCI's activities in Atlanta and its acquisition of the
National Bank of Georgia through First American. Although the
Justice Department indictments of Clark Clifford and Robert
Altman cover portions of how BCCI acquired National Bank of
Georgia, other important allegations regarding the possible
involvement of political figures in Georgia in BCCI's activities
there remain outside the indictment. These allegations, as well
as the underlying facts regarding BCCI's activities in Georgia,
require further investigation.
18. The relationship between BCCI and the Banca Nazionale
del Lavoro. BCCI and the Atlanta Branch of BNL had an extensive
relationship in the United States, with the Atlanta Branch of BNL
having a substantial number of accounts in BCCI's Miami offices.
BNL was, according to federal indictments, a significant
financial conduit for weapons to Iraq. BCCI also made loans to
Iraq, although of a substantially smaller nature. Given the
criminality of both institutions, and their interlocking
activities, further investigation of the relationship could
produce further understanding of Saddam Hussein's international
network for acquiring weapons, and how Iraq evaded governmental
restrictions on such weapons acquisitions.
19. The alleged relationship between the late CIA director
William Casey and BCCI. As set forth in the chapter on
intelligence, numerous trails lead from BCCI to Casey, and from
Casey to BCCI, and the investigation has been unable to follow
any of them to the end to determine whether there was indeed a
relationship, and if there was, its nature and extent. If any
such relationship existed, it could have a significant impact on
the findings and conclusions concerning the CIA and BCCI's role
in U.S. foreign policy and intelligence operations during the
Casey era. The investigation's work detailing the ties of BCCI to
the intelligence community generally also remains far from
complete, and much about these ties remains obscure and in need
of further investigation.
20. Money laundering by other major international banks.
Numerous BCCI officials told the Subcommittee that BCCI's money
laundering was no different from activities they observed at
other international banks, and provided the names of a number of
prominent U.S. and European banks which they alleged engaged in
money laundering. There is no question that BCCI's laundering of
drug money, while pervading the institution, constituted a small
component of the total money laundering taking place in
international banking. Further investigation to determine which
international banks are soliciting and handling drug money should
(All witnesses testified in public session or in published
depositions printed by the Subcommittee, except witnesses with *,
who testified at hearing conducted within Subcommittee on
Consumer and Regulatory Affairs of Senate Committee on Banking,
Housing and Urban Affairs in coordination with this
investigation, May 23, 1991.)
Robert A. Altman, former president, First American
Bankshares and attorney for BCCI.
Fausto Alvarado, Member, Peruvian House of Deputies.
Fernando Ramon Marin Amaya. Investigator retained by
Attorney General of Guatemala to investigate BCCI's activities in
Amjad Awan, federal prisoner, former BCCI official who
handled accounts of Panamanian General Manuel Noriega.
Sidney Bailey, Virginia Commissioner of Financial
Institutions, Richmond, Virginia.*
Robert R. Bench, Partner, Price Waterhouse, Former Deputy
Comptroller for International Relations and Financial Evaluation.
Gerald Beyer, Executive Vice President, Chicago Merchantile
Akbar Bilgrami, federal prisoner, former head of Latin
American and Caribbean Regional Office, BCCI, Miami.
Jack Blum. A private attorney at the firm of Novins, Lamont
& Flug. Formerly special counsel to the Foreign Relations
Committee for the investigation of the Subcommittee on Narcotics,
Terrorism, and International Operations into Drugs, Law
Enforcement, and Foreign Policy, 1987-1988.
Parker W. Borg. Deputy Assistant Secretary of the Bureau of
International Narcotics Matters at the Department of State.
James Bruton, Acting Assistant Attorney General, Tax
Divisin, Department of Justice.
A. Peter Burleigh, Coordinator for Counter-Terrorism at the
Department of State.
Jorge Del Castillo, Member, Peruvian House of Delegates.
Pedro Cateriano, Member, Peruvian House of Deputies.
Nazir Chinoy, federal prisoner, former General Manager, BCCI
Clark M. Clifford, formerly, chairman of First American
Bankshares and attorney for BCCI.
Andrea Cocoran, Director of Planning and Compliance,
Commodities Futures Trading Commission.
Michael Crystal, Queen's Counsel, representing English
court-appointed liquidators of BCCI.
George Davis, President and CEO, First American Bankshares,
James F. Dougherty, Attorney, Miami Florida. Representing
Lloyds of London in litigation concerning alleged fraud involving
Scott M. Early, General Counsel, Chicago Board of Trade.
Lourdes Flores, Member, Peruvian House of Deputies.
Robert Genzman, U.S. Attorney for the Middle District of
Wendy Gramm, Commissioner, Commodities Futures Trading
John Heimann, former New York State Bank Supervisor and
Comptroller of the Currency.*
Mark Jackowski, Assistant U.S. Attorney for the Middle
District of Florida.
Nicholas de B. Katzenbach, Chairman, First American
Bankshares, Washington, D.C.
Gregory Kehoe, First Assistant U.S. Attorney, Criminal
Division, for the Middle District of Florida.
Richard Kerr, Acting Director, Central Intelligence Agency.
Alan J. Kreczko. Deputy Legal Advisor at the U.S. Department of State.
T. Bertram Lance, Former Director of the Office of
Management and Budget.
Dexter Lehtinen, Former U.S. Attorney, Southern District of
Richard A. Lehrman, Esq., attorney, Miami, Florida.
Represented Lloyds of London in case involving BCCI commmodities
Ricardo Llaque, Deputy Director of Exchange Operations,
Federal Reserve Bank of Peru.
Paul Maloney, Deputy Assistant Attorney General for Criminal
Division, U.S. Department of Justice, Washington, D.C.*
Virgil Mattingly, General Counsel, Board of Governors,
Federal Reserve System.
Robert Mazur, Undercover Agent for Operation C-Chase, Drug
Douglas P. Mulholland, Assistant Secretary for Intelligence
and Research, Department of State.
Robert Morgenthau, District Attorney, County of New York,
Robert S. Mueller, III, Assistant Attorney General,
Department of Justice, Washington, D.C.
Fernando Olivera, Member, Peruvian House of Deputies.
Laurence Pope, Associate Coordinator for Counter-Terrorism,
Department of State.
William Von Raab. An attorney at the firm of William H. Bode
Associates. Formerly Commissioner of the United States Customs
Service, 1985-1989, oversaw Customs' handling of the sting
operation that targeted BCCI, Operation C-Chase.
Masihur Rahman, Former Chief Financial Officer, BCCI London.
Mark Richard, Deputy Assistant Attorney General, Criminal
Division, Department of Justice.
Edward M. Rogers, Jr., former White House aide.
Jesus Rodriguez, Member, Chamber of Deputies, Argentina.
Abdur Sakhia, former head, BCCI Miami.
Ahmed Al Sayegh, Director, Abu Dhabi National Oil Company.
Raul Alconada Sempe, former Secretary of Defense and former
Secretary for Special Projects, Foreign Ministry, Argentina.
Grant Smith, Deputy Assistant Secretary, International
Narcotics Matters, Department of State.
Brian Smouha, Court Appointed Fiduciary for BCCI Holdings
(Luxembourg) SA and Bank of Credit and Commerce International,
S.A., London, England.
John W. Stone, Chief of Enforcement, Federal Deposit
William Taylor, Staff Director, Division of Banking
Supervision and Regulation, Federal Reserve, Washington, D.C.
Grand Hotel, Washington DC
Office of the Comptroller of the Currency
Price Waterhouse (US)
Price Waterhouse (UK)
First American Georgia