-Caveat Lector-

Read of the Marc Rich connection to Pakastanis....and his criminal
activity.   Larry King announced his former wife may run for public
office as he gushed over her seeing the $$$$ in her eyes - money stolen
from the American People....why do they not confiscate her property
inasmuch as 34 million dollars of it was money ripped off from American
Taxpayers?

So see hoodlum Marc Rich connection here - and keep in mind the ADL took
a $250,000 bribe to get the pardon from Clinton - they refused to return
the money.

Saba

APPENDICES

Matters For Further Investigation

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 technologies.

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 further investigation.

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. financial institutions.

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 warranted.

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 intelligence operations.
]
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 be
undertaken.
WITNESSES

(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 Guatemala.
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 Exchange.
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 Paris.
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, Washington,
D.C.
James F. Dougherty, Attorney, Miami Florida. Representing Lloyds of
London in litigation concerning alleged fraud involving BCCI.
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 Florida.
Wendy Gramm, Commissioner, Commodities Futures Trading Commission.
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 Miami,
Florida.
Richard A. Lehrman, Esq., attorney, Miami, Florida. Represented Lloyds
of London in case involving BCCI commmodities fraud.
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 Enforcement
Administration.
Douglas P. Mulholland, Assistant Secretary for Intelligence and
Research, Department of State.
Robert Morgenthau, District Attorney, County of New York, 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 Insurance
Corporation.
William Taylor, Staff Director, Division of Banking Supervision and
Regulation, Federal Reserve, Washington, D.C.

WRITS AND SUBPOENAS AUTHORIZED DURING INVESTIGATION

WRITS AUTHORIZED (4)

Amjad Awan
Akbar Bilgrami
Nazir Chinoy
Ian Howard

SUBPOENAS AUTHORIZED (17)

Sani Ahmed
BCCI
Roy Carlson
Kerry Fox
Grand Hotel, Washington DC
Abol Helmy
Kissinger Associates
Office of the Comptroller of the Currency
Price Waterhouse (US)
Price Waterhouse (UK)
First American
First American Georgia
Robert Magness
David Paul
Robert Powell
Ed Rogers
Larry Romrell

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