This section will examine in greater detail the role of the United States in the events preceding BCCI’s closure in July 1991, including the regulatory, prosecutorial and political dimensions of the increasingly hostile environment surrounding BCCI in the United States.
The analysis will refer briefly to the Tampa money-laundering proceedings, including the circumstances of the undercover operation, allegations of inducement or entrapment, and the later prosecution of General Manuel Noriega. These matters are examined separately in greater detail. The principal focus here will instead be on the increasing regulatory, political and prosecutorial pressure on BCCI’s presence in the United States, and on communications between American and British authorities in the period leading to closure.
The section will also consider the wider political and intelligence dimension, including documented and alleged connections between BCCI, the CIA and other intelligence agencies, and the apparent contradiction between later portrayals of BCCI as an unacceptable international financial institution and evidence that Western intelligence and government agencies had themselves used, encountered or maintained relationships with the Bank in connection with sensitive international activities.
These issues require careful distinction between established documentary evidence, official findings, contemporary allegations and subsequent interpretation.
Particular attention will also be given to BCCI’s relationships with influential US political figures and whether the Bank’s political associations affected the way it was viewed after changes in the political environment. This includes examination of whether support or relationships developed with figures associated with one side of American politics became a liability when political influence shifted following presidential elections.
The section will also consider the BCCI-related evidence arising from the prosecution of General Manuel Noriega, including the political circumstances surrounding his removal from power in Panama and subsequent prosecution in the United States. The purpose will not be to repeat the detailed criminal proceedings, but to examine how allegations concerning Noriega and Panama became incorporated into the wider political and institutional narrative surrounding BCCI.
A further area requiring close examination is whether the escalating investigations into First American, congressional interest in BCCI, possible enforcement action by the Federal Reserve and other US authorities, and the prospect of further damaging disclosures created pressure upon the British authorities to act before developments in the United States placed the Bank of England in an increasingly difficult or embarrassing position.
The purpose is not to suggest that the United States alone caused BCCI’s closure, nor to advance an unsubstantiated conspiracy theory. It is to examine whether US regulatory, prosecutorial, political and intelligence considerations formed a significant part of the environment in which the Bank of England moved from supporting a restructuring process to immediate closure, and whether their influence has been sufficiently examined in established accounts of the events of 1991.
The detailed analysis will therefore concentrate on First American, the Federal Reserve and other US agencies, congressional and political pressure, intelligence-agency connections, the wider significance of the Noriega case, communications with the United Kingdom authorities, and the chronology of US actions immediately preceding 5 July 1991.
These issues are important to any objective assessment of whether developments in the United States influenced the timing, urgency or eventual course of the UK decision to close BCCI.
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