--- alias: - CCAH - Credit and Commerce American Holdings, N.V. category: BCCI Scandal created: 2026-09-23 location: Netherlands Antilles relations: - fn: 1 reverse: true role: secret controlling owner through nominees type: owned with: '[[Bank of Credit and Commerce International]]' - fn: 1 role: holding company type: owned with: '[[First American Bank]]' - fn: 5 start: 1987-08-19 type: owned with: '[[National Bank of Georgia]]' - end: 1998 fn: 2 reverse: true start: 1991 type: investigated with: '[[Federal Reserve Board]]' start: 1978 summary: Netherlands Antilles holding company formed by BCCI in 1978 through which nominee shareholders held First American Bankshares, the Washington bank BCCI secretly controlled. tags: - Organization - BCCI - FirstAmerican - HoldingCompany - NetherlandsAntilles updated: 2026-09-23 --- Credit and Commerce American Holdings, N.V. (CCAH) was a holding company incorporated in the Netherlands Antilles and formed in the summer of 1978 by the [Bank of Credit and Commerce International](/organizations/bank-of-credit-and-commerce-international/) (BCCI), "ostensibly on behalf of the Middle Eastern investors," with a Dutch subsidiary, Credit and Commerce American Investment, B.V., as the vehicles for acquiring shares of [Financial General Bankshares](/organizations/financial-general-bankshares/). After the [Federal Reserve](/organizations/federal-reserve-board/) approved its application on August 25, 1981, CCAH became the registered bank holding company of Financial General, renamed First American and later [First American Bankshares, Inc.](/organizations/first-american-bank/), of [Washington, D.C.](/places/washington-dc/) In statements to the [Securities and Exchange Commission](/organizations/securities-and-exchange-commission/) BCCI, [Agha Hasan Abedi](/people/agha-hasan-abedi/) and the four named investors stated that BCCI would have no interest in CCAH; the Federal Reserve found in 1991 that BCCI had controlled it through nominees from the start.[^1][^2] ### Formation and Approval The four original investors were [Kamal Adham](/people/kamal-adham/), [Faisal Saud al-Fulaij](/people/faisal-saud-al-fulaij/), Sheikh [Sultan bin Zayed Al Nahyan](/people/sultan-bin-zayed-al-nahyan/), and Abdullah Darwaish, acting for Sheikh Mohammed bin Zayed; an Iranian, Mohammed Rahim Motaghi Irvani, the partner of the former [CIA](/organizations/central-intelligence-agency/) director [Richard Helms](/people/richard-helms/) in his consulting firm, was listed in the original SEC filing as a 5 percent shareholder and was, in the words of the [Kerry-Brown Senate Report](/events/bcci-kerry-brown-senate-report/), "BCCI's lead front-man in the original takeover."[^3][^4] The application was opposed by the Virginia bank regulator Sidney A. Bailey, who told the Federal Reserve that "the proposed acquisition will be inimical to the convenience and needs of the community" and later testified that he had been given nothing but assurances: "Take me at my word. Believe me. Have I ever lied to you?" At a hearing convened on April 23, 1981, by the Federal Reserve's associate counsel, Robert Mannion, Adham, Fulaij, [Abdul Raouf Khalil](/people/a-r-abdul-raouf-khalil/) and El Sayed El Gohary gave assurances that any future relationship with BCCI would be "decided by the new management." The Federal Reserve approved the application on August 25, 1981, and at [Robert Altman](/people/robert-altman/)'s request of June 2, 1981, sealed portions of the hearing transcript, "preventing anyone outside the Federal Reserve from learning the identities of several of the shareholders."[^1] The Federal Reserve later found that all four Middle Easterners who had appeared in person, Adham, Fulaij, Khalil, and Sayed Jawhary, were nominees for BCCI, as were "Sheikh Naomi," ruler of Ajman, a corporation owned by Sheikh Hamad bin Mohammed Al Sharqi, ruler of Fujairah, and a government official of the [United Arab Emirates](/places/united-arab-emirates/), Sheikh Shorafa. BCCI financed CCAH's start-up costs, and a 50 million dollar loan to First American nominally from an outside bank, the [Banque Arabe et Internationale d'Investissement](/organizations/banque-arabe-et-internationale-dinvestissement/), which had interlocking directors with BCCI. "In short," the Senate report concluded, "BCCI, Kamal Adham, Faisal al Fulaij, A.R.K. Khalil, and the other Middle Eastern nominees had secretly done precisely what the Federal Reserve had sought to assure they would not do."[^1] After the purchase BCCI added 30 million dollars in capital to First American and CCAH, partly from deposits of the Crown Prince of [Abu Dhabi](/places/abu-dhabi/) and partly from BCCI loans to its nominees Fulaij, Khalil and Shorafa.[^5] ### Management and Shares [Clark Clifford](/people/clark-clifford/) and Robert Altman, BCCI's American counsel, served as directors of CCAH and as chairman and president of First American; Clifford said he was paid 50,000 dollars a year as chairman.[^2][^6][^7] BCCI installed its own officers, K.K. Elley and Aijaz Afridi, at First American's New York bank.[^5] In December 1986 BCCI caused CCAH to agree to buy the [National Bank of Georgia](/organizations/national-bank-of-georgia/) from [Ghaith R. Pharaon](/people/ghaith-r-pharaon/) for 220 million dollars; the purchase closed on August 19, 1987.[^5] In a rights offering, a BCCI nominee called Masriq waived its rights so that Clifford and Altman could buy CCAH shares at book value, 2,216 dollars a share, one day after Masriq had bought other CCAH shares at 4,044.20 dollars. In 1988 the two men sold their CCAH stock to the BCCI nominee [Mohammed Hammoud](/people/mohammed-hammoud/) at 6,800 dollars a share, "the highest price ever paid for CCAH stock," for a combined gross profit of 9.5 million dollars.[^6] ### Enforcement On July 29, 1991, the Federal Reserve assessed a fine of 200 million dollars against BCCI, 37 million dollars against Pharaon and 20 million dollars against the BCCI official Kemal Shoaib, and on July 29, 1992, it opened a civil enforcement action against Clifford and Altman as "institution-affiliated parties" of CCAH. Its Second Amended Notice of Intent to Prohibit, issued on January 14, 1997, charged that they had caused CCAH to borrow from BCCI beyond the acquisition debt permitted by the 1981 order, that Altman had structured the National Bank of Georgia purchase to conceal BCCI's role, and that both had accepted compensation from BCCI in the form of preferential loans and profits on their CCAH stock. Under a consent order dated effective February 1998 the two men relinquished 1,802 and 895 CCAH shares, respectively, to the court-appointed trustee of First American or the court-appointed fiduciaries of BCCI; the order stated that these "are not fines or civil money penalties."[^2][^7][^8] [^1]: Kerry, Senator John, and Senator Hank Brown. *The BCCI Affair: A Report to the Committee on Foreign Relations, United States Senate.* December 1992, ch. 6, "BCCI in the United States: Initial Entry." https://irp.fas.org/congress/1992_rpt/bcci/06early.htm [^2]: Board of Governors of the Federal Reserve System, *In the Matter of Clark M. Clifford and Robert A. Altman, Institution-Affiliated Parties of Credit and Commerce American Holdings, N.V.,* Docket Nos. 92-080-E-I1, 92-080-B-I1, 92-080-CMP-I1, 92-080-E-I2, 92-080-B-I2, 92-080-CMP-I2, consent order, effective February 1998, with the Second Amended Notice of January 14, 1997. https://www.federalreserve.gov/boarddocs/press/enforcement/1998/19980203/Attachment.pdf [^3]: Kerry and Brown, *The BCCI Affair,* ch. 14, "Abu Dhabi: BCCI's Founding and Majority Stockholders" (quoting the Price Waterhouse section 41 report of June 1991 on "the four investors [Kamal Adham, Faisal al Fulaij, Sheikh Sultan Bin Zayed and Abdullah Darweish on behalf of Sheikh Mohammed Bin Zayed]"). https://irp.fas.org/congress/1992_rpt/bcci/14abudhabi.htm [^4]: Kerry and Brown, *The BCCI Affair,* ch. 11, "BCCI, the CIA and Foreign Intelligence." https://irp.fas.org/congress/1992_rpt/bcci/11intel.htm [^5]: Kerry and Brown, *The BCCI Affair,* ch. 7, "BCCI in the United States: Later Acquisitions." https://irp.fas.org/congress/1992_rpt/bcci/07later.htm [^6]: Kerry and Brown, *The BCCI Affair,* ch. 13, "Clark Clifford and Robert Altman." https://irp.fas.org/congress/1992_rpt/bcci/13clifford.htm [^7]: Kerry and Brown, *The BCCI Affair,* ch. 12, "BCCI and the Regulators." https://irp.fas.org/congress/1992_rpt/bcci/12reg.htm [^8]: "Clifford, Altman indicted in BCCI bank fraud," United Press International, July 29, 1992. https://www.upi.com/Archives/1992/07/29/Clifford-Altman-indicted-in-BCCI-bank-fraud/5122712382400/