Agha Hasan Abedi founds the Bank of Credit and Commerce International (BCCI) in Luxembourg with 25% funding from Bank of America (.5 million) and 75% from Sheikh Zayed bin Sultan Al Nahyan of Abu Dhabi. The bank is deliberately structured across Luxembourg and Cayman Islands jurisdictions with weak banking regulations to evade comprehensive oversight. Bank of America provides legitimacy and Western financial connections while Sheikh Zayed provides capital and Middle Eastern access. BCCI's corporate structure is designed from inception to avoid centralized regulatory review, operating extensively in bank secrecy jurisdictions. This deliberate regulatory arbitrage creates a template for criminal banking operations that would later facilitate CIA money laundering, drug trafficking proceeds, and arms dealing.