+--------+---+---------------------------+--------+--------------------+---+
| # O    | # |                           |        |                    | # |
|        | # |                           |        |                    |   |
| ##     | # |                           |        |                    |   |
|        | # |                           |        |                    | # |
|        |   |                           |        |                    |   |
|        | A |                           |        |                    |   |
|        | L |                           |        |                    | # |
|        | E |                           |        |                    | # |
|        | R |                           |        |                    |   |
|        | T |                           |        |                    |   |
|        |   |                           |        |                    |   |
|        | 2 |                           |        |                    |   |
|        | 0 |                           |        |                    |   |
|        | 0 |                           |        |                    |   |
|        | 4 |                           |        |                    |   |
|        | - |                           |        |                    |   |
|        | 1 |                           |        |                    |   |
|        | 8 |                           |        |                    |   |
+--------+---+---------------------------+--------+--------------------+---+
|        | * |                           |        |                    |   |
|        | * |                           |        |                    |   |
|        | O |                           |        |                    |   |
|        | C |                           |        |                    |   |
|        | C |                           |        |                    |   |
|        | A |                           |        |                    |   |
|        | L |                           |        |                    |   |
|        | E |                           |        |                    |   |
|        | R |                           |        |                    |   |
|        | T |                           |        |                    |   |
|        | * |                           |        |                    |   |
|        | * |                           |        |                    |   |
+--------+---+---------------------------+--------+--------------------+---+
| ## Com |   |                           |        |                    |   |
| ptroll |   |                           |        |                    |   |
| er of  |   |                           |        |                    |   |
| the Cu |   |                           |        |                    |   |
| rrency |   |                           |        |                    |   |
|        |   |                           |        |                    |   |
| > A    |   |                           |        |                    |   |
| dminis |   |                           |        |                    |   |
| trator |   |                           |        |                    |   |
| > of   |   |                           |        |                    |   |
| > Na   |   |                           |        |                    |   |
| tional |   |                           |        |                    |   |
| >      |   |                           |        |                    |   |
|  Banks |   |                           |        |                    |   |
+--------+---+---------------------------+--------+--------------------+---+
| ## Su  |   | Securities Law Violations | Descri | Unregistered       |   |
| bject: |   |                           | ption: | Securities and     |   |
|        |   |                           |        | Unlicensed         |   |
|        |   |                           |        | Security Sales     |   |
+--------+---+---------------------------+--------+--------------------+---+

**TO:** Chief Executive Officers of All National Banks; All State
Banking Authorities; Chairman, Board of Governors of the Federal Reserve
System; Chairman, Federal Deposit Insurance Corporation; Conference of
State Bank Supervisors; Deputy Comptrollers (districts); Assistant
Deputy Comptrollers; District Counsel and Examining Personnel

**RE:** Architects of Wine, Grand Cayman, Cayman Islands

> The Office of the Comptroller of the Currency (OCC) has received
> information regarding enforcement actions taken by multiple state
> regulatory authorities against the above-referenced entity for the
> sale of unregistered securities using unlicensed persons. A copy of a
> recent cease-and-desist order issued by the State of Arkansas
> Securities Department is attached for your information.
>
> Be advised that banks may be approached to open a deposit account in
> which the sales proceeds of unregistered investments are deposited and
> then wired out of the country. Banks should exercise caution and
> perform appropriate due diligence prior to opening such deposit
> accounts. Be further advised that, as additional enforcement actions
> are taken against the entities involved, new company names are being
> used to engage in the same activities.
>
> To date, the following entities have been identified:
>
> Architects of Wine, Ltd, Caledonian House, 69 Dr. Roy's Drive, P.O.
> Box 1043, GT Georgetown, Grand Cayman, Cayman Islands, BWI;
>
> Seed International, Ltd., 174 South Church Street, P.O. Box 1778, GT
> Grand Cayman, Cayman Islands, BWI, formerly known as Churchill
> Associates at the same address; and,
>
> Ocean International Marketing, Ltd., De Leuve, Schiedamsedijk 42, 3011
> ED Rotterdam, The Netherlands, formerly known as Heros Global
> Marketing, Ltd., of the same address.
>
> Any information that you have concerning this matter should be brought
> to the attention of your state securities regulator or the U.S.
> Securities and Exchange Commission, as appropriate.
>
> Any questions or comments regarding this alert or information that you
> feel should be brought to the OCC's attention may be sent to:

Mail: Office of the Comptroller of the Currency

Enforcement & Compliance Division, MS 8-10

250 E Street, SW, Washington, DC 20219

Fax: (202) 874-5301

Internet: http://www.occ.treas.gov

E-mail: occalertresponses@occ.treas.gov

Brian C. McCormally

Director

Enforcement & Compliance Division

Attachment: [State of Arkansas Securities Department Cease and Desist
Order](http://www.occ.treas.gov/ftp/alert/2004-18a.pdf)

\[http://www.occ.treas.gov/ftp/alert/2004-18a.pdf\]