Unauthorized Banking: Unauthorized Sale of Samoan Banking Licenses

On October 5, 2001, the Office of the Comptroller of the Currency (OCC) issued OCC Alert 2001-11, Joint Agency Request Relating to Information Pertaining to Terrorist Attacks. It requested your participation in a system to facilitate cooperation with law enforcement authorities in their ongoing investigation of terrorist activity. Since then, the federal financial institutions supervisory agencies have worked with law enforcement authorities to develop and implement an electronic mail system to distribute a unified list of individuals and entities identified by the FBI or other law enforcement agencies (Control List).

The OCC is expanding this email system to include the distribution of emergency communications to your institution. The source of these emergency communications may be the OCC, other federal financial institutions supervisory agencies, or law enforcement authorities. In certain cases, the OCC may be unable to send the emergency communication by email on the Internet because of security concerns. In these cases, the agency will use the Control List system to send you an email message on the Internet informing you that sensitive emergency information is available on the OCC's National BankNet. It will prompt you to access BankNet to obtain the information. BankNet is a secure system that requires you to enter your user name and password.

If your institution is not yet a BankNet member, the OCC strongly encourages you to sign up. Access to BankNet is free of charge, and signing up will ensure your ability to obtain important information during emergencies. To gain access to BankNet, your institution must appoint a BankNet agent to be the OCC's principal point of contact and its representative to manage access to the National BankNet for bank employees. To sign up for BankNet, your designated BankNet agent must complete the certification form available on the Internet at BankNet, . After the OCC receives the form in electronic or paper form, a member of the OCC's Information Technology Services (ITS) Security Team will contact your BankNet agent to finalize your membership in BankNet.

In response to Alert 2001-11, your institution designated at least one senior-level person to serve as contact point for all communications relating to the Control List. Many institutions provided more than one contact for this purpose. These contacts will be added automatically to BankNet as your institution's emergency contacts to handle sensitive information. Since emergencies may occur during nonbusiness hours, the OCC asks you to update BankNet to include an after-hours telephone number where your emergency contacts may be reached. The BankNet agent must ensure that the emergency contacts information is complete and up to date. 

In addition, the Federal Financial Institutions Examination Council (FFIEC) has added a new instruction to the Reports of Condition and Income (call report) regarding your institution's emergency contacts information. Beginning with the September 30 call report, all national banks and federal branches are required to include their emergency contacts information in their report. Any changes to the emergency contacts information will be recorded, and OCC BankNet and the Control List system will automatically be updated through this electronic call report process. 

Thank you for your assistance and cooperation in this most important endeavor. Inquiries concerning BankNet may be directed to Gregory C. Golembe, senior advisor for Banking Relations, or Thomas Baucom, Web content analyst, Public Affairs Division by phone at (202) 874-4990. Inquiries concerning the Control List system may be directed to Brian C. McCormally, director, or Robert S. Pasley, assistant director, Enforcement and Compliance Division by phone at (202) 874-4800. 

Daniel P. Stipano 
Deputy Chief Counsel