Investigators untangling the affairs of the Bank of Credit and Commerce International are beginning to find answers to one of the most tantalizing questions raised by the world's biggest banking scandal: Where did all the money go?

Hundreds of millions of dollars of BCCI's funds -- including $20 million from the BCCI account of deposed Panamanian dictator Manuel Noriega -- have been traced to a company owned in part by some of the same Middle Eastern investors involved in BCCI's secret purchase of control of First American Bankshares Inc. of Washington, according to British banking regulators and court documents.

The company, Capcom Financial Services, set up offices in Chicago and London in the mid-1980s to trade foreign currencies, government bonds, gold and other commodities.

British regulators say BCCI reported suffering massive losses on trading accounts handled by Capcom, but the regulators have yet to determine how the money was lost.

Capcom's trading practices triggered investigations by market regulators that resulted in the firm being expelled from the London futures markets in 1988 and kicked out of the Chicago futures markets a short time later.

Now, Capcom is under indictment in Tampa, along with BCCI, for allegedly laundering money for Noriega and several drug dealers, is facing multi-million-dollar civil lawsuits in Miami and London and is involved in other BCCI investigations in the United States and Britain.

Capcom, which stopped doing business in the United States in 1989 after it was expelled from the Chicago futures markets, has not responded to the criminal charges and no U.S. representative of the firm could be located.

Corporate records in London show that when Capcom was founded, its dozen shareholders included three men who U.S. bank regulators say allegedly were front men in BCCI's secret purchase of control of First American -- Kamal Adham, the former head of intelligence for Saudi Arabia; A. R. Khalil, a longtime aide to Adham; and Sayed El Jawhary, another Saudi businessman. A fourth Capcom investor was Hatton Pharaon, younger brother of Ghaith Pharaon, the Saudi financier who has been accused of helping BCCI buy two other U.S. banks.

U.S. Investors Involved As with First American, prominent Americans were involved with Middle Eastern investors in Capcom.

One of Capcom's original owners was Bob John Magness, founder and chairman of Tele-Communications Inc. (TCI) of Denver, the nation's biggest cable television company. Magness, whose 59 percent stake in TCI is estimated to be worth more than $400 million, is as well-known in the cable TV business as former First American chairman Clark M. Clifford is in Washington affairs, industry sources say. TCI Vice President Larry Romrell invested in Capcom along with Magness, the company's records in London show.

Magness and Romrell refused several requests to discuss how they came to invest in Capcom. Spokesmen for the two say they bought stock in the firm only as an investment and never had any role in Capcom's day-to-day management.

Reports filed by Capcom with British regulators listed Romrell as Capcom's chairman in 1987 and 1988 and reported Magness was one of six other board members at that time. The corporate reports show Magness and Romrell each originally purchased 250,000 shares of Capcom and that Romrell later increased his holdings to 2.75 million of the company's 15 million shares.

Both men sold their shares and resigned their posts in October 1988 after Capcom was implicated in the Florida money-laundering case.

Neither Magness nor Romrell has been questioned by federal investigators handling the Tampa money-laundering case against the company, nor have they been questioned by congressional aides who are investigating BCCI.

Magness and Romrell are not the only Americans who invested in Capcom.

A third man, Robert "Mo" Powell, who has owned and managed firms doing business with the U.S. and foreign governments since the days of the Vietnam War, when he worked for aircraft operations and maintenance firms in Vietnam and Thailand, also shows up as a Capcom shareholder.

Powell now runs a small defense contracting firm in Pacoima, Calif., and operates several enterprises in the Middle East from a pair of neighboring villas in the sultanate of Oman, where he lives most of the year.

In a telephone interview, Powell said he was not involved in Capcom's management and did no business with the company.

Powell said he has had business connections with Kamal Adham since 1968 -- when Adham was head of the Saudi intelligence agency -- and long has done business with BCCI.

Powell said he accepted an offer to invest in Capcom because "it was in my interest to please BCCI."

The offer came not from his old friend Adham, Powell said, but from the former head of the BCCI branch in Oman, Pakistani banker S.Z.A. Akbar.

Banker's Key Role Akbar is the central figure in Capcom and the person blamed by British regulators for hundreds of millions of dollars of BCCI's reported trading losses during the time he was in charge of trading at BCCI and while he was handling BCCI's trading through Capcom.

Akbar was convicted by a British court in 1989 of conspiring to launder money and served six months in jail. Last month, after he was ordered to stay in Britain as a result of a new investigation, he was arrested again in France when he stepped off a ferry while apparently trying to flee Britain under a phony passport. Akbar also is a defendant in the indictment issued last month in Tampa against BCCI and Capcom for allegedly laundering money for various drug dealers and Panamanian dictator Noriega.

Akbar and Capcom also are defendants in civil lawsuits filed in the United States and Britain by the government of Panama to recover millions of dollars that allegedly were stolen by Noriega.

The indictments and the lawsuits say $20 million of Noriega's money has been traced from BCCI's branch in Panama through banks in six countries to a trading account at Capcom.

Papers filed in the Panamanian lawsuit allege the Noriega account was part of millions of dollars of unexplained payments found by British accountants who audited Capcom's accounts for the British Association of Futures Brokers and Dealers, a regulatory agency.

Capcom officials eventually produced records showing to whom part of the money belonged. But in a report filed with British authorities, Capcom said it was "unable to provide the company's auditors with relevant supporting documents" explaining the source of almost $50 million, including $20 million in an account carrying the name Finley International Ltd., a Panamanian corporation. The audit report said Akbar himself was a director of Finley.

Noriega's money was shifted between Capcom accounts in London and New York and then vanished, according to court documents filed by Miami lawyer Robert Equels, who represents the government of Panama in the suit against Capcom, BCCI and Akbar.

Akbar, during the early 1980s, served as head of BCCI's treasury operations, in charge of investing billions of dollars of deposits. Like most big banks, BCCI traded in foreign currencies, bonds of various governments and financial futures contracts, hoping to profit from changes in interest rates or the relative values of currencies.

Trading Activities Shifted BCCI handled its own trading for a while, but later shifted much of its business to Capcom, according to British banking regulators. Capcom was not owned by BCCI, but except for the three Americans, its shareholders all had some connection with the bank and several top employees formerly worked for BCCI.

Akbar remained BCCI's top trader after Capcom was set up in 1984 and directed much of the bank's trading to the firm, British authorities said. Later he left BCCI to become the manager and one of the owners of Capcom, according to corporate records.

When British banking regulators shut down BCCI earlier this year, they disclosed that the bank had suffered some $850 million in trading losses. Most of the losses apparently occurred while Akbar was BCCI's chief trader or while he was managing BCCI's accounts at Capcom.

Despite the huge trading losses it suffered, BCCI rewarded Akbar with a $32 million bonus after he left the bank, British authorities say.

While British regulators are investigating Capcom's role in BCCI's questionable losses, the Central Intelligence Agency has suggested that at the time Capcom was handling BCCI's business, the bank also was involved in illegal currency trading.

A CIA working paper dated June 1986 said BCCI had engaged in questionable trading practices in European financial markets. "As of May 1985," the CIA reported, "BCCI was said on good authority to be manipulating to its advantage the Eurodollar certificate of deposit market." Eurodollar CDs are savings accounts deposited in European banks but in American dollars.

The CIA said BCCI was among the biggest traders in Eurodollar CDs and "the bank augments its trading strength by bribing a key firm making a market in these securities ..."

Capcom's financial affairs began to unravel in 1988 when the firm was named in a Florida money-laundering indictment as the result of the same undercover investigation that led to the indictment of BCCI and several employees of its Florida bank.

According to the indictment, an undercover U.S. Customs agent, masquerading as a middleman for drug lords, was told by two officials of BCCI Florida that Capcom could be used to launder money.

Through BCCI officials, undercover agent Robert Mazur was introduced to Akbar in London, where he explained that he needed to disguise millions of dollars of cocaine profits and opened two commodity trading accounts at Capcom to handle the cocaine cash, according to affidavits filed in Tampa.

The money-laundering charges triggered investigations by British and American financial market regulators, which led to the firm's expulsion from the London and Chicago futures markets.

After Capcom was kicked out of the London markets and fined almost $700,000 in July 1989 by the Association of Futures Brokers and Dealers, which oversees British financial markets, British regulators passed a confidential warning to their counterparts at the Commodity Futures Trading Commission in Washington.

The tip was relayed to the Chicago Board of Trade and the Chicago Mercantile Exchange, which are responsible for policing their own markets. Within months, Capcom was forced to give up its seats on both Chicago exchanges, fined more than $500,000 and permanently banned from doing business in the U.S. commodity markets, the strongest penalty that could be imposed.

Limited Jurisdiction Futures regulators say they lacked the jurisdiction to pursue the Capcom investigation beyond Capcom's activities in the market.

Investigations by the two Chicago exchanges and the National Futures Association -- the self-regulatory organization for future brokers -- all found irregularities that were serious enough to warrant expelling Capcom from the markets, but officials acknowledge they did not get to the bottom of the case.

"I don't know what they were doing," said Roger Rutz, president of the Chicago Board of Trade Clearing Corp., one of the self-regulatory organizations that looked into Capcom's operations.

"We looked into it, we didn't like what we saw and we got rid of them," said another exchange official.

The Chicago Mercantile Exchange's complaint against Capcom Futures Inc. -- the American affiliate of the London firm -- cites questionable transactions involving company insiders. Money was shuffled around among the accounts of Capcom shareholders, and investments were taken out of one account and placed in other accounts with no record of why the transfers were made, according to the complaint.

Shifting trades from one account to another is illegal because it can be used to evade taxes, create phony profits or launder money, a longtime futures market professional explained.

Among the transactions that regulators say raised their suspicions were those involving Capcom clients who put large amounts of money into futures trading accounts at Capcom and then took the money out without ever doing any trading.

When the National Futures Association (NFA) served notice that it wanted to discuss these accounts with the customers, Capcom withdrew its registration as a futures brokerage firm. Since Congress assigned NFA responsibility only for overseeing registered brokers, the NFA could not pursue the matter further.

The investigations of Capcom by the NFA and the two exchanges were closely monitored by federal officials at the Commodity Futures Trading Commission, who say they are satisfied that the internal self-regulatory system succeeded in forcing out of the market a firm that was not playing by the rules.

But the Capcom case never reached the attention of U.S. banking regulators, because futures regulators had no way of knowing that the firm they had kicked out of the Chicago market was partially owned by some of the same investors who allegedly fronted for BCCI in gaining control of Washington's biggest bank holding company.