It's been more than 21 years since the former Luxembourg-based Bank of Credit and Commerce International engineered an illegal takeover of a Washington bank company.

And eight years have elapsed since the infamous BCCI collapsed in the face of an investigation into the matter.

Still, after all those years, the BCCI affair continues to play out in the courts, with no apparent end in sight. We may be well into the next millennium before the final chapter in the BCCI scandal is written.

A federal judge's ruling last week, ordering a BCCI figure to pay a $1.2 billion fine on fraud and racketeering charges, is but the latest in a protracted effort to clean up the BCCI mess.

Through the years, the term "scandal" has become shorthand for describing the unlawful actions of those who were responsible for the takeover of what was then Financial General Bankshares Inc.

The real scandal in this debacle is the extent to which U.S. banking authorities and the courts either ignored the telltale signs of an illegal takeover or were completely fooled by those who masterminded BCCI's stealth acquisition of what later became First American Bankshares Inc.

Even though BCCI collapsed and federal regulators have since seized First American and sold it, U.S. officials still have egg on their faces, having fallen asleep at the switch. That's the scandal that ought to come to mind whenever anyone mentions BCCI.

But that's hardly the case as the stench from the BCCI mess slowly dissipates. With the passage of time it has become little more than a minor curiosity.

Take the recently completed case of Abdul Raouf Khalil, a Saudi investor, who was charged with fraud and racketeering in connection with the BCCI investigation. Testimony in the case was occasionally marked by levity, according to published accounts of the proceedings.

In the end there was nothing funny about a federal judge's decision to fine the defendant, Khalil, $1.2 billion.

Nothing about the BCCI scandal can be called amusing or lighthearted.

The deception and fraud that led to BCCI's takeover of First American, and ultimately the seizure and sale of First American by federal regulators, constitute an American business tragedy.

Moreover, the sale of First American to Charlotte's First Union Corp. in 1993 was a personal tragedy for the hundreds of employees who lost their jobs as a result.

BCCI's illegal acquisition of First American not only destroyed a bank but also "destroyed people with real lives and real jobs," a source close to the local company said ruefully as First Union announced plans to lay off as many as 1,100 First American employees.

Who knows? The relative positions of First Union and other out-of-state banking giants operating in the Washington area might have been decidedly different had BCCI not carried out its scheme to gain control of First American.

Riggs National Bank and the former American Security Bank were much bigger than First American's predecessor when BCCI began making its move on Financial General in late 1977 and early 1978.

Financial General had only $2.3 billion in assets at the time. But it also had something that few U.S. bank companies enjoyed: the benefit of a grandfather clause that allowed it to own or control banks in several states. Strict federal banking laws prohibited interstate banking until the 1980s. But Financial General controlled banks in the District, Maryland, Virginia, New York, Georgia and Tennessee.

Given Financial General's franchise and what occurred in the banking industry once interstate banking was approved, it's fair to say that under more astute management, Financial General would have been a key player in the wave of mergers across state lines after 1985.

By 1989, First American's assets had grown to more than $10 billion, making it the largest bank holding company in the District.

Certainly it would not have been possible -- without the seizure of First American by federal officials -- for First Union to buy the First American banks in the District, Maryland and Virginia for a mere $453 million six years ago.

By then First American had sold its banks in Georgia, New York and Tennessee. But BCCI was already firmly in control.

Financial General's management announced in February 1978 that a foreign bank had bought a fair amount of stock and may have been attempting to gain control of the company. Financial General subsequently filed a lawsuit alleging that BCCI and a group of Middle East investors had engaged in a conspiracy to acquire the company illegally.

Indeed, the Securities and Exchange Commission later accused BCCI, among others, of violating the agency's rules requiring individuals and institutions to report purchases of 5 percent or more of a company's stock within 10 days.

But the defendants were given a slap on the wrist and the Middle East investors, all clients of BCCI, were granted permission by regulators and the courts to make a cash tender offer for all of Financial General's stock.

That more than anything is the BCCI scandal.