Introduction
As the BCCI scandal has unfolded, Mohammed Hammoud has emerged as a shadowy
figure with close ties to a number of powerful American political and government
figures.
During the 1980's, Hammoud acted as a front-man or nominee for BCCI, became
an owner of BCCI and of CCAH, the holding company for First American, borrowed
over $110 million from BCCI, much of which he failed to make interest payments
on, and made numerous investments in the United States with funds provided him
by BCCI, and in one case, backed up by guarantees from First American.
During the same period, Hammoud, a little known Lebanese merchant, also
purchased the shares in First American held by Clark Clifford and Robert Altman;
had his U.S. real estate investments managed by the current U.S. Ambassador to
Bahrain, Charles W. Hostler; had contact with officials from the State
Department concerning the release of U.S. hostages from Beirut and other issues
pertaining to Lebanon, and developed a personal and business relationship with
Michael Pillsbury, a former assistant Undersecretary of Defense and Senate staff
assistant.
After BCCI's indictment in October, 1988 by the U.S. Attorney in Tampa, Hammoud also worked closely with BCCI's
criminal defense team in Washington to determine whether it would be possible
to "reverse Tampa" by meeting with higher-level federal officials in Washington.
In the fall of 1989, Hammoud actually met with high-ranking officials at
Treasury and Justice concerning the BCCI case, and had ongoing contact with
Senate staffer Pillsbury seeking to assist BCCI in defending itself against its
criminal case.(1)
Hammoud's multiple roles in connection with BCCI continued until his sudden
death on May 3, 1990, at the very time that investigations of BCCI were
intensifying. After his death, press accounts raised questions as to whether his
death was real or staged, and law enforcement indictments have described
Hammoud's current status as "reportedly dead."(2)
Who is Mohammed Hammoud?
Little is known of Hammoud's background, although Abdur Sakhia, the former
general manager for BCCI N.Y., described Hammoud as a merchant who at one time
operated a stall in one of Beirut's open-air markets:
My memory goes back about 27 or 28 years when I went first to Beirut. He was a small time money changer.(3)
In interviews with Subcommittee staff, Nazir Chinoy, the BCCI general manager
in Paris, remembered Hammoud as:
A short man, not a very impressive personality. . . My impression of Hammoud,
to me Hammoud was not rich. Pharoan had physical power from his bearing his
confidence. Hammoud was a slimey sort of a chap, not a forceful personality.
Would Hammoud understand foreign policy? I do not think so. He was not a worldly
man. Pharoan yes. Hammoud no.(4)
In testimony before the Subcommittee in 1991, Massihur Rahman, BCCI's former
chief financial officer, described Hammoud as "a medium sized businessman."
BCCI's files indicate that Hammoud's wealth grew exponentially, and
inexplicably, during the 1980's, at a clip of almost $5 million a year. By 1989
he is listed as owning assets in excess of $35 million.(5)
Nevertheless, according to Chinoy, Hammoud did not give "the impression of being
an extremely rich man from his clothes and general behavior."(6)
At some point during the 1970's Hammoud became very close to the top
management at BCCI. Naqvi had worked in Lebanon and BCCI had branches there, but
the Subcommittee has been unable to determine who originally introduced Hammoud
to BCCI. Hammoud is described in a 1983 BCCI memorandum as "a very good customer
of the BCC Group," who "possesses large means."(7)
By the time of his death in 1990, Hammoud was a major shareholder in the bank,
owning 2,646,184 shares, according to a February, 1990 report by BCCI's outside
auditors, Price Waterhouse.
According to Rahman, "[h]e seemed to be very close to some of our executives.
And he has been used obviously for taking loans and doing things."(8)
Later in his testimony Rahman characterized Hammoud as the most flexible of
BCCI's nominees.
Chinoy echoed the testimony of Rahman, stating that Hammoud had "a very
special relationship" with the bank. Chinoy recalled how Hammoud had borrowed
about $100,000 from the Paris branch and was not servicing the loan. When Chinoy
wrote Hammoud asking that the loan be repaid, Chinoy was rebuked by his
superiors in London and told he "should not write abusive letters to good
clients who had helped the bank." Chinoy explained that he later wrote the loan
off in three separate installments.(9)
The loan to Hammoud by BCCI's Paris branch pales in comparison to the massive
loans Hammoud received from BCCI elsewhere. As of April 1990, Hammoud owed over
$110 million dollars to BCCI and its affiliate, ICIC, Grand Caymans, As Price
Waterhouse concluded in the report, "there remain too many unanswered questions
about Mr. Hammoud [including] his connection with delinquent accounts of BCCI."
At the time, Price Waterhouse expressed its concern about the lack of evidence
at BCCI that Hammoud owned "any of the companies" he claimed to own in
connection with BCCI lending.
(10)
Hammoud's Real Estate Investments
Hammoud made real estate investments in the United States through a series of
companies: Linden Investments, Copperwood, N.V., Marmaris investments, N.V.,
Eastward, N.V. and Carlson Farms, Ltd. Ambassador Charles Hostler, who advised
Hammoud on his US investments, referred to these companies as "holding
companies" for the properties.
Documents obtained by the Subcommittee indicate that all of the companies
were probably front companies which Hammoud established on behalf of BCCI. For
instance in November, 1978, Hammoud wrote to ICIC, BCCI's "bank within a bank":
I have to request you to arrange on my behalf for the incorporation of a
company in Cayman Islands with an authorized capital of US$900,000.00 and Issued
and Paid-up capital of $US100,000.00. This company to be incorporated with the
name and style of "Linden Investments Company Limited" is to have as its
principle objects investments in immovable properties in the U.S.A. and other
places, either directly or through any of its subsidiaries to be incorporated in
such countries where maximum tax benefits would be available for such property
investments, and with such other objects as are usable and necessary for such
investment companies, including borrowing powers.
You may appoint your own nominee directors for the said Linden Investment Co.
Ltd. and transfer to their names such shares as may be necessary according to
the legal requirements. The remaining shares may be held by you in your
name or in the name of any other company as your nominee.
I hereby authorize you to appoint any agents for the aforesaid purpose and to
do, execute and perform or cause to be done, executed and performed all acts,
deeds and things that may be required or necessary in a fiduciary capacity for
the aforesaid purpose and to give any other authority or writing that you may
require or deem necessary for this purpose.(11)
Hammoud's real estate investments include property he purchased from a church
in Alexandria, Virginia, an office building in New York, a building in Boston
adjacent to Boston Symphony Hall, and a development in the small town of
Sherman, Connecticut. All of these investments were financed by BCCI and none of
the loans was ever serviced. Carlson Farms, for instance, received a $1 million
letter of credit from BCCI secured by only the guarantee of Linden Investments,
which apparently held no other properties.(12)
In his Senate testimony, Sakhia described the Hammoud's real estate holdings
in the US with which he was familiar. According to Sakhia:
We did a loan to him from BCCI in New York, which we were told from London to
give that loan in the first place.
In the second instance, when we had acquired the property and we wanted to
develop a property in Washington, he contacted us to make a construction loan--
which we refused to do because we were not equipped to handle constructions
loans."(13)
Sakhia testified that he "completely refused to do the second transaction,"
but that the Central Credit Division in London ordered him to the first
transaction, which wound up being "110% of the loan". Sakhia acknowledged that
the loan did not make business sense.
(14)
After Sakhia refused to do the construction loan, the Central Credit
Committee in London told its New York regional manager "[W]hy don't you
introduce him to First American, because the property is in Washington. First
American is located in Washington and First American is big in real estate
loans." First American subsequently issued a $4 million letter of credit to
Hammoud.(15)
Senator Kerry was struck by the fact that Hammoud needed an introduction to
First American after Hammoud had become a shareholder of First American, having
purchased his shares in First American/CCAH from First American's chairman and
president, Clark Clifford and Robert Altman. Sakhia testified that he too was
baffled by the events:
It's [First American] not like a big corporation with hundreds of
shareholders. The handful of shareholders -- [Hammmoud] directly bought the
shares from the Chairman and the President. And he wants me to introduce the
officers of First American. It didn't make any sense to me.(16)
In 1990, the U.S. General Manager of BCCI, in an effort to avoid the scrutiny
of bank regulators, recommended "immediate transfer" of Hammoud's assets "to an
off shore unit."
Holdings of CCAH Stock
Hammoud's investment in First American Bank came about as a result of his
acquisition of stock throughout the 1980s through BCCI, and in fact, as a
nominee for BCCI. In 1986, Hammoud first began acquiring stock at $2,200 a share
as BCCI's nominee. By 1990, Hammoud had acquired 6% of the shares of the bank on
BCCI's behalf.
In March 1988, Hammoud bought stock from Clifford and Altman, the Chairman
and President of First American, for a whopping $6,800 a share -- the highest
price ever paid for First American stock. Hammoud's $25 million purchase of
First American shares was bankrolled by BCCI, although in testimony before the
Subcommittee, Altman stated that:
[M]r. Hammoud was one of the individuals not listed by the Federal Reserve as
a nominee in their notice of charges. He was in their category of bona fide
shareholder.(17)
Altman added that after Hammoud's death in the spring of 1990, "we had been
contacted by Hammoud's estate." According to Altman:
His estate believes that the stock is stock that belonged to Mr. Hammoud and
now belongs to his heirs. They certainly take the position that Mr. Hammoud was
no nominee. He was a bona fide shareholder. And they had asked that the stock be
transferred into the names of the heirs. And we were seeking certain
documentation in that regard before the transfer could be lawfully effected.(18)
Altman's representations before the Subcommittee regarding the bona fides of
Mohammed Hammoud were recently challenged in the indictment of Clifford and
Altman by the Manhattan District Attorney. The indictment charged that:
As part of the business of the corrupt enterprise, assets were purchased with
depositors' funds, but were falsely maintained as ostensibly separate from the
BCC group. These assets were purchased in the names of, among others
....Mohammed M. Hammoud, a Lebanese businessman who reportedly died in 1990.
Moreover, Masihur Rahman, BCCI's chief financial officer, provided detail on
the mechanism that Hammoud employed to mask the sham transactions involving CCAH
stock. Rahman testified that Hammoud used two front companies, Mid-Gulf and
Rubstone, to purchase the shares. According to Rahman, after Price Waterhouse
raised concerns about BCCI and the bank began an internal investigation, Rahman
confronted Hammoud: "He [Hammoud] was first denying, but finally it was accepted
that both of them belonged to Hammoud."(19)
Rahman did not know what the companies did, "except that they had some loans
[from BCCI] for CCAH." According to Rahman, the amount loaned to Rubstone to
purchase First American shares was around $14 million and the amount loaned to
Mid-Gulf to purchase First American shares was $44 million."(20)
The Subcommittee has obtained an undated letter of instruction from Hammoud
to the Manager of BCCI, Overseas, Grand Cayman, which support Rahman's
testimony. The letter specifically states:
With reference to the loan advanced by you on my recommendation to Mssrs.
Rubstone Trading, of amount up to $US 12 million, I hereby authorize you to hold
my shares in Credit and Commerce American Holdings N.V., as security to cover
the outstanding balance of the loan.(21)
By April 1990, as the auditors scrutinized BCCI and its CCAH loans, Hammoud
informed BCCI that he did "not hold any shares" in either Midgulf or Rubstone.(22)
Apparently, both Hammoud and BCCI had decided that it was not in their interest
to have Hammoud seen as a nominee for BCCI holding CCAH shares. This, of course,
was during the period that Price Waterhouse was uncovering massive fraud and
deception at BCCI, and just weeks before Hammoud's sudden death.
Altman and Hammoud
Documents obtained by the Subcommittee from BCCI's liquidators show that
Robert Altman, who was also BCCI's U.S. attorney, held a power of attorney for
Hammoud, giving Altman the right to dispose of Hammoud's stock in CCAH at any
time as Hammoud's agent. Altman testified he was unaware that he had such a
power of attorney and when shown the document by Senator Kerry, he expressed
profound shock:
[T]his gives an authority to sell shares, and that is something that to the
best of my recollection, I'd never seen before. I do not know how to explain it.
I don't know where it came from, but I don't believe it was ever in our files.(23)
Thus, Altman, who sold his stock to Hammoud for three times what Altman paid
for the stock, had the ability through the power of attorney also to buy and
sell shares of CCAH to and from Hammoud in any case.
Altman testified that he never met Hammoud. This statement seems odd given
that Hammoud was in Washington on a number of occasions, and was ostensibly a
major shareholder of First American, on whose behalf Altman was running the
bank. On the other hand, there was really no reason for Altman to have met
Hammoud if Hammoud was the flexible front man that he has been portrayed to have
been. It is entirely possible that Hammoud was not even aware of his holdings in
First American: the loans were arranged by BCCI; the purchase and sale may have
been arranged by Altman using the power of attorney.
Hammoud and Ambassador Hostler
Hammoud also had contacts with US Ambassador to Bahrain Charles Hostler. As a
businessman in Beirut in the 1960's, Hammoud met Hostler when Hostler was a
young U.S. Air Force officer, attached to Lebanon, Jordan and Cyprus, and based
in Beirut, Lebanon. Hammoud's wife taught Arabic to the young Mr. Hostler, and
the Hammouds and Hostler became good friends.
(24) Later, Hostler returned to Beirut as the manager of the
Douglas Aircraft Company in Lebanon from 1965 to 1967, before accepting a
position with McDonnell Douglas in the U.S. As the report to the Foreign
Relations Committee on Hostler described his career:
Mr. Hostler served at the United States Department of Commerce as Deputy
Assistant Secretary of International Commerce from 1974 to 1976, where he was
responsible for establishing and managing the nation's export expansion program.
From 1963 to 1969 he worked in numerous capacities for McDonnell Douglas
Corporation including Director of International Operations for the Middle East
and North Africa. . . and Manager of International Marketing for Missiles and
Space.(25)
According to the Wall Street Journal, Ambassador Hostler stated that he has from time to time given financial advice to Hammoud. Hostler told the Subcommittee that he advised Hammoud on three properties: "vacant land" in Sherman Connecticut, an "old building" in Boston, Massachusetts and a "tear-down" in New York City.(26)
Curtis Hagen, a real estate broker, also worked with Hammoud on the three
properties referenced by the Ambassador in his affidavit.
Concerning the tear-down in New York City, Hagen told the Subcommittee:
In NYC I engineered a joint venture between BCCI and Skanska with an agreed
to land evaluation of 5 million (BCCI purchased it at $1.1 million) In the midst
of contract negotiation between the two law firms representing each entity. In
the meantime I turned down an offer of 4 million in cash by Paul Milstein,
because the tax burden was too severe. However, he eventually built the project,
although the chain of title after Hammoud came on the scene with Hostler is
unclear to me.(27)
Concerning the "old building" in Boston, Hagen told the Subcommittee:
I arranged a zoning change from a two story Taxpayer to a 17 story and lower
condominium residential & commercial building with on-parking premises. This
process, as you know, was extremely complex and took 2 and 1/2 years to bring to
a point, where only a very routine submission of a detail was needed to
finalize. BSO now has ownership. Hostler arranged the sale to BSO for Hammoud,
however I do not know what consideration BSO gave to Hammoud/Hostler.(28)
Concerning the "vacant land" in Sherman, Connecticut, Hagen told the
Subcommittee:
After 6 tons of papers, maps, demographics, etc. the final subdivision was
approved and I negotiated the required road bond.(29)
In short, the vacant land, the old building and the tear down were
substantial properties with real value.
In his affidavit to the Subcommittee, Ambassador Hostler stated that "He
[Hammoud] considered me expert in real estate matters, since he lived abroad and
was then largely unacquainted with US real estate practices."(30)
However, Hagen, the New York real estate broker, didn't think Hostler knew much
about real estate: "[H]ostler, the real estate typhoon, knew as much about real
estate as my Aunt Matilda knew in 1860 about building a space shuttle."(31)
It appears that Hagen did the lion's share of work to make Hammoud's various
real estate investments marketable and saleable. The question arises as to what
Hostler's role was and what compensation he was received.
According to the Ambassador:
"His inquiries and my advisory activities for him were intermittent and
limited. I would estimate that they involved perhaps an average of several hours
a month in the period between 1982 and 1988."(32)
Hostler claims that he "received no salary, gifts or other gratuities or
compensation from Hammoud, though I was reimbursed for my direct, nominal,
actual receipted expenses."(33)
Hagen, however, recalls a meeting at the Pierre Hotel in Hammoud's suite on
July 16, 1982 between Hammoud, Hostler, Pisani [an architect] Milne [a Utah real
estate developer] and Hagen and his daughter. According to Hagen, "It was either
at that meeting or a few days before wherein Hammoud placed both hands on
Hostler's shoulders and said: "there will be a Cadillac in your driveway,
tomorrow morning."(34)
The Subcommittee has been unable to ascertain whether or not Ambassador
Hostler received the Cadillac. However, it is certainly unusual for anyone to
provide business services to someone else for several hours a month for six
years without receiving any form of compensation for it in return. Hence,
Ambassador Hostler's described willingness to work for Hammoud for nothing for
this lengthy period raises the question of why Ambassador Hostler did perform
these services.
Hammoud and Pillsbury
Michael Pillsbury is a former Senate staffer. He was formerly an Assistant Secretary of Defense. According to the Washington Post, Pillsbury was "a member of the top-secret "208 Committee," the interagency group that oversees Central Intelligence Agency covert operations for the President and meets in the situation room and room 208 of the Old Executive Office Building."
Pillsbury has told Subcommittee staff that he initially met Hammoud in the
context of his work in the Senate when a real estate developer, Earl Milne,
introduced him in 1981 or 1982. According to Pillsbury, Hammoud was "unusual"
because he was a wealthy, Lebanese shi'ite. Pillsbury subsequently developed a
personal relationship with Hammoud and over the course of the decade met him
"ten to twenty" times in several cities around the world, including Washington,
London, Geneva, Beirut, Damascus and "possibly Paris". According to Pillsbury,
Hammoud provided him with intelligence related information concerning U.S.
hostages held in Lebanon, which Pillsbury then passed on to US government
agencies. As a letter to Subcommittee staff from Pillsbury's attorney, former
Watergate prosecutor Seymour Glanzer, states:
Mr. Pillsbury has never said that he is "withholding important information"
[from the Subcommittee]. What he did say was that he was reticent about
disclosing inflrmation that might be needed about Mr. Hammoud's purported
assistance to the United States Government. That was because he was alluding to
two State Depeartment communications which may be "classified" and which can be
obtained from the State Department. Thus, he does not believe he is at liberty
to disclose their contents. One of these communications is a cable from the
American Ambassador in Beirut in approximately November 1983, and the other is a
cable from the American Ambassador in Damascus in approximately April 1989.
Therefore, Mr. Pillsbury believes it is appropriate that disclosure be taken up
with the State Department.(35)
Following receipt of the letter from Glanzer, Senator Kerry asked the State Department to retrieve the documents described. Unfortunately, the State Department was not able to locate the 1983 cable. It was able to locate the second cable and that cable remains classified. At the time of the second cable, Edward Derejian was U.S. Ambassador to Syria, and since that time has been appointed Assistant Secretary of State for Middle Eastern Affairs. Contemporaneous notes from BCCI's attorneys show that Pillsbury was contending that Hammoud was directly involved in assisting the U.S. on negotiations concerning the release of the U.S. hostages held in Lebanon as of the fall of 1989.(36)
In the early-1980's Pillsbury moved from the Senate to become the assistant undersecretary for Defense. In that position he championed the provision of advanced weapon systems, notably stinger missiles, to anti-communist insurgencies around the world, including Savimbi's UNITA forces in Angola and the Mujahadin in Afghanistan. Pillsbury is known to have made frequent trips to both countries.
The Task Force on Terrorism and Unconventional Warfare -- House Republican
Research Committee claims that Hammoud was an arms merchant:
In order to insert large quantities of explosive and related equipment into
target countries, the Hizballah established a web of import-export companies in
Western Europe as part of its dormant network. Lebanon's leading shi'ite
businessmen, including Mohammed Hammoud, who would later become a key financier
of BCCI, provided crucial expertise, organizational and financial assistance
without which projects could not have been undertaken.
Pillsbury has denied that he ever used Hammoud or BCCI either to arrange or
to finance the provision of sophisticated weapons to anti-communist
insurgencies.
In fact, Pillsbury has stated that his contact with Hammoud, aside from the
information he provided on the US hostages held in Lebanon, was in the context
of a book that they were writing together about the Shi'ites of Lebanon.
According to Pillsbury, Hammoud paid him an advance to coauthor a scholarly
text about the Shi'ites and Pillsbury had completed some 200 pages of this book
by the time of Hammoud's death. Pillsbury told the Subcommittee that he
disclosed the book deal to the Senate Ethics Committee. However, Pillsbury
refused to disclose the amount he had been paid by Hammoud, and when the payment
was made. Pillsbury argued that these facts were irrelevant since he ultimately
returned the money, although he refused to specify when that occurred. Pillsbury
stated that his expenses had never been paid by either Hammoud or BCCI. However,
these statements are contradicted by notes taken by BCCI's lawyers in October,
l989 state that Pillsbury travelled to Europe on several occasions on tips paid
for by Hammoud, raising in their minds concerns about whether Pillsbury's trips
were actually being paid for by BCCI. Both BCCI officials and Pillsbury denied
BCCI's involvement in the payments. However, given Hammoud's $110 million debt
to BCCI at the time, and his frequent front-man status for BCCI, the distinction
between Hammoud's activities and BCCI's activities does not seem to be very
clear.(37)
Subcommittee staff have seen a law enforcement document which alleges that
after Hammoud's death, Pillsbury travelled to Geneva to identify the body.
Pillsbury denies the allegation. Pillsbury may or may not have identified the
body, but after Hammoud's alleged death Pillsbury maintained a close
relationship with Hammoud's family. The Subcommittee has been provided a
document which appears to show that after the death of Hammoud, Pillsbury met in
New York with Robert Altman, one of BCCI's lawyers, and with Hammoud's son, to
discuss settlement of the elder Hammoud's estate. Pillsbury has told the
Subcommittee that he only met Altman only twice -- both times in the context of
Senate business.
Hammoud and BCCI's Criminal Defense
In the fall of 1989, Hammoud began to take an active interest in BCCI's legal
problems in the United States as a result of its indictment for drug money
laundering in Tampa, Florida. He met with Pillsbury on a number of occasions
concerning these problems. Pillsbury in turn identified key Treasury and Justice
Department officials in Washington who in Pillsbury's view would be key to
assisting BCCI if they determined that the sting operation against BCCI were
improper. Hammoud met with some, unidentified, officials from both Treasury and
Justice, as well as with BCCI's criminal defense team in Washington. Available
documentation concerning Hammoud's activities in this period suggests he may
have undertaken other steps in connection with assisting BCCI with its criminal
defense, but information on this point is, unfortunately, inadequate to
determine precisely what.(38)
Hammoud's Death
Hammoud, unfortunately, cannot shed any light on his political or government
connections because he is, as prosecutors describe his status, "reportedly
dead."(39)
He allegedly died in Geneva in 1990 while visiting his doctor and he is buried
in Beirut. However, insurance companies have reportedly refused to pay out on
the life policy because Hammoud's corpse was found to be several inches shorter
than the height recorded at his last medical examination. Several former BCCI
officials who have testified before the Subcommittee have testified that they do
not believe Hammoud is dead.
Hammoud was reportedly buried in Beirut and his family provided his London lawyers with a video of the funeral which allegedly shows high ranking Syrian intelligence officials in attendance. In its August 10, 1992 edition, Newsweek reports:
Intelligence officials now say that Mohammed Hammoud, an alleged BCCI front
man, was taped saying over the telephone, "If anybody knew how dirty the
Americans are in this BCCI business, they'd be surprised -- they're dirtier than
the Pakistanis." He then said he was about to tell someone about the American
role. Eight hours later he was found dead.(40)
Much about Mohammed Hammoud's life, business with BCCI, and alleged death remains a mystery to the Subcommittee. He clearly had very close ties not only to BCCI, but also to several US political and government officials as well as to various intelligence agencies.
1. An account of these meetings is contained in the chapter concerning BCCI's lawyers and their contacts with Hammoud and Michael Pillsbury.
2. See e.g. indictment, People v. Abedi, New York Supreme Court, County of New York, July 29, 1992.
3. S. Hrg. 102-350. pt. 2, p.612. In an interview with
staff prior to his testimony Sakhia stated, "I went to Beirut to a seminar at
American University in 1960. Hammoud used to have an office, a storefront the
size of this sofa. His store was three feet deep and eight feet wide."
4. Staff interview, Nazir Chinoy, March 9, 1992.
5. BCCI memorandum, Central Credit Division, re:Congressional Place Ltd./M M Hammoud. March 30, 1989.
6. S. Hrg. 102-350, Pt.4 p. 374.
7. BCCI memorandum, reprinted in S. Hrg. 102-350, pt.4, p.762.
8. S. Hrg. 102-350. Pt.1, p.534.
9. Id. p.374.
10. See documents at S. Hrg. 102-350, Pt. 1 pp. 356-358.
11. Letter to ICIC from Mohammed Hammoud, November 1, 1978, reprinted in S. Hrg. 102-350, pt. 4. p.740.
12. BCCI Memorandum, reprinted in S. Hrg. 102-350, pt.4, p.762.
13. pt. 2, p.612.
14. Id.
15. Id. Sakhia explained in his interview with staff, "This transaction was done by First American not directly secured by the assets of Hammoud, but by a counter guarantee of First American. BCCI issued the guarantee which was confirmed by First American."
16. Id. p.614. In his interview with staff prior to his testimony Sakhia asked rhetorically, "If he had bought and sold shares from Clifford & Altman, why would he want my introduction? -- Since he didn't put a cent of his own into First American, he didn't feel like he owned it."
17. Id. p.176.
18. Id. p.176
19. pt. 1, p.534.
20. Id. p. 535.
21. Letter to "the Manager" from Mohammad M. Hammoud, reprinted in S. Hrg. 102-350, pt. 4.p 782.
22. Letter to BCCI, London, from i.H. Ansari, dated 4.4.90.
23. S. Hrg. pt.3, p.195.
24. See Hostler Affidavit, S. Hrg. 102-350 Pt. 4 p. 768, Hostler Resume, submitted to Foreign Relations Committee as part of confirmation process.
25. Report for the Committee on Foreign Relations, U.S. Senate, Ambassadorial Nomination for State of Bahrain, Charles Warren Hostler.
26. S. Hrg. 102-350 Pt. 4 pp. 769-771.
27. Letter to Jonathan Winer from Curtis Hagen, February 10, 1992, reprinted in S. Hrg. 102-350, pt. 4, p.765.
28. Id.
29. Id.
30. Id. pt.4., p.770.
31. Id.
32. Affidavit of Ambassador Hostler, reprinted in S. Hrg. 102-350, Pt.4, p.771.
33. Id. p.771.
34. Id. 766.
35. Seymour Glanzer to David S. McKean, July 31, 1992, concerning Michael Pillsbury.
36. Staff interviews with Pillsbury, March-July, 1992; see also attorney notes of interviews with Pillsbury, October, l989, provided to Subcommittee by BCCI attorney Raymond Banoun on September 3, l992.
37. Documentation on this issues is provided in a series of memoranda created by BCCI's criminal defense team and provided to the Subcommittee on September 3, 1992 by former BCCI lawyer Raymond Banoun and by the law firm of Janis, Schuelke and Wechsler on behalf of Lawrence Wechsler.
38. The fullest account of Hammoud's activities on BCCI's behalf in connection with its criminal defense appears in notes taken by BCCI's lawyers in the U.S. and provided to the Subcommittee on September 3, 1992 by Raymond Banoun and Lawrence Wechsler. These documents form the basis for the information set forth concerning this section.
39. People v. Abedi, New York Supreme Court, New York County, July 29, 1992.
40. Newsweek, August 10, 1992,