The AWC alleges that the significant potential risks posed by using mortgage proceeds to make securities investments and the high concentration level in the VUL investment, rendered the transaction unsuitable.
The net cash proceeds are prior to any adjustment for potential tax liabilities which are likely to arise from the sale of spectrum assets even after utilizing the existing net operating losses.
The problem has become so vexing that the Treasury Department issued a rare advisory last year that warned American banks about "a dramatic increase in the smuggling of bulk cash proceeds from the sale of narcotics" and the"potential misuse of relationships with U.S. financial institutions by certain Mexican financial institutions, including Mexican casas de cambio, " or currency exchange houses (see diagram).