BCCI has been set up deliberately to avoid consolidated supervision and operated in bank secrecy jurisdiction. BCCI was chartered in Luxembourg and the Grand Caymans, but neither its holding company nor the subsidiaries has conducted any banking activities there. Thus, Luxembourg did not regulate it. Its real home which was BCCI’s headquarter and where most of the operations were carried out was actually in the UK. Because it was chartered in Luxembourg and Grand Caymans, Bank of England (BOE) thus thought itself as a secondary role in supervising BCCI, thereby reducing the level of scrutiny imposed on BCCI. In addition, BCCI has an uncommon auditing system. Price Waterhouse (PW) was the accountants for BCCI overseas, while Ernst & Whitney in charged of BCCI holdings. Two sets of auditors being used was to avoid them from publishing a meaningful consolidated accounts and make sure neither of the audit team had full jurisdiction over it.
BCCI’s founder, Abedi and his assistant, Naqvi were the critical leader of its rapid growth and a guarantee of its final collapse. By fracturing its corporate structure and record keeping, the complex BCCI group was able to avoid regulation on the transfer of capitals and goods between its internal banks.