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Fe d e r a l R e s e r v e
B a n k o f N e w Yo r k
N E W Y O R K , N. Y. 1 0 0 4 5
A R E A C O D E 212 7 2 0 - 5 5 4 5
Fr
e d e r ic k
C. S
chadrack
E x e c u t iv e V ice Pr e s id e n t
May 23, 1989
To the Chief Executive Officers of State Member Banks, Bank
Holding Companies, Edge Act and Agreement Corporations,
New York Branches and Agencies of Foreign Banks, and
Others Concerned in the Second Federal Reserve District:
The purpose of this letter is to alert you to
certain developments in the area of suspicious currency
transactions and in the area of unauthorized banking of which
you should be aware.
Suspicious Currency Transactions
As you know, Criminal Referral Forms relating to
suspected currency violations - e.g., violations of the
provisions of Title 31 of the United States Code requiring
the filing of currency transaction reports, and making
illegal the structuring of a transaction to evade the
reporting requirements ("Bank Secrecy Act Violations") - are
presently filed by the financial institution making the
referral with the local offices of the Federal Bureau of
Investigation and the U.S. Attorney, as well as with this
Reserve Bank.
A copy of the referral is then sent by the
Reserve Bank to the Enforcement Section of the Board of
Governors, which in turn forwards it to the main office of
t he I n t e r n a l Revenue S e r v ic e in W ashington.
In order to expedite processing of these referrals,
this Reserve Bank has agreed to forward copies of your
referrals regarding Bank Secrecy Act Violations directly to
the appropriate local office of the Internal Revenue Service
as soon as they are received by us (in addition to forwarding
them to the Board of Governors).
The referral filing procedures that you follow will
not change.
However, we encourage you to contact your local
IRS office should you wish to discuss Bank Secrecy Act
referrals or related matters (in addition to following
existing referral procedures).
In addition, you may refer
questions regarding procedures to be followed for suspected
Bank Secrecy Act Violations to the Compliance Examinations
Division of this Reserve Bank at 212-720-6369.
2
Possible Unauthorized Banking
The Office of the Comptroller of the Currency
("OCC") has advised that certain entities may be conducting a
banking business in the United States illegally or without
authorization.
A list of those entities is enclosed.
In
addition, the OCC has identified certain other entities that
have issued direct obligations, including checks and drafts,
that have not been honored.
Those entities are also set
forth on the enclosed list.
Any proposed transactions
involving any of the listed entities should be viewed with
caution.
If you have any information regarding any of the
entities identified on the enclosed list, please contact
Thomas McQueeney, Assistant Chief Examiner, at 212-720-7934.
Sincerely,
Frederick C. Schadrack
Executive Vice President
Enclosure
Entitles Identified by the Comptroller of the Currency
The Comptroller of the Currency has advised that the following
entities may be conducting a banking business in the United States
illegally or without authorization:
Banco Commercial Arabe, S.A.
Los Angeles, California
Gibraltar Overseas Bank, Ltd.
Plymouth, Montserrat
Bangue Commerciale D'Haiti
Jamaica, New York
Gilbraltar Overseas Bank, Ltd.
Rosemont, Illinois
British Bank of Commerce, Ltd.
Plymouth, Montserrat
Manufacturers International Bank, Lt
Tampa, Florida
British Bank of Commerce, Ltd.
Reno, Nevada
Midcontinental Bank & Trust (W.I.)
McLean, Virginia
Cayman Overseas Bank & Trust
Company, Ltd.
Georgetown, Grand Cayman
Midcontinental Bank & Trust (W.I.)
Atlanta, Georgia
Churchill International Bank
Beverly Hills, California
Northern International Bank, Ltd.
Sparks, Nevada
European Industrial Development
Bank, Ltd.
Los Angeles, California
Northern International Bank, Ltd.
Reno, Nevada
European Industrial Development
Bank, Ltd.
Plymouth, Montserrat
Plymouth International Bank, Ltd.
Plymouth, Montserrat
First Integrity Bank Limited
San Francisco, California
Plymouth International Bank, Ltd.
Lake Havasu City, Arizona
First International Bank
& Trust, Ltd.
San Diego, California
Regal Bank of Montserrat, Ltd.
Plymouth, Montserrat
First Morgan Bank Limited
Colony of Montserrat
Union Commercial Bank
New York, New York
First Morgan Bank Limited
Columbia, South Carolina
United Bancorp International
Miami, Florida
(OVER)
United Bancorp of Minnesota
Minneapolis, Minnesota
Western Pacific Overseas Bank, Limited
Los Angeles, California
United Security Bank, Ltd.
Elmhurst, Illinois
Western Pacific Overseas Bank, Ltd.
Colony of Montserrat
United Security Bank, Ltd.
Plymouth, Montserrat
World Arbitrage Bank, Ltd.
New York, New York
Wellington International Bank
& Trust Company, Ltd.
Montserrat
World Arbitrage Bank, Ltd.
Atlanta, Georgia
Wellington International Bank
& Trust Company, Ltd.
Coral Gables, Florida
The Comptroller of the Currency has advised that certain direct
obligations, including checks and drafts, issued by the following
entities have been dishonored:
Caribbean Bankers Trust NV
Philipsburg, Saint Maarten
Internationale Financial Trust NT & SA
Acapulco, Mexico
Citizens Bank & Trust (W.I.)
Ltd .
Anguilla, West Indies
Lux International Bancorp SA
Plymouth, Montserrat
Crown International Bank, Ltd.
Plymouth, Montserrat
Union Bank of Commerce
Plymouth, Montserrat
Global Credit Reserve
Acapulco, Mexico
Union Commercial Bank
Plymouth, Montserrat
Industrial Trade Bank
Plymouth, Montserrat
Windward Island Credit Exchange
Philipsburg, Saint Maarten
@FedFRASER