Since 11/29, when WikiLeaks director Julian Assange announced his intention to "take down" a major American bank and reveal an "ecosystem of corruption" with a cache of data from an executive’s hard drive, Bank of America's chief risk officer and a interdepartmental team of 15 to 20 top bank officials have conducted a broad internal investigation.  They've scoured thousands of documents in the event that they become public, reviewed every case where a computer has gone missing, and hunted for any sign that its systems might have been compromised. 

To help manage this review, the bank brought in consultants from Booz Allen Hamilton, and has sought advice from several top law firms about legal problems that could arise from a disclosure, including the bank’s potential liability if private information was disclosed about clients.  CEO Brian Moynihan gets regular updates.

So far, BofA's internal review reportedly has not turned up anything that would substantiate Mr. Assange's claim that he has a hard drive.  With the data trail cold, one working theory both inside and outside the bank is that internal documents in Mr. Assange’s possession, if any, probably came from the mountains of material turned over to the SEC, Congressional investigators and the NY attorney general’s office during separate investigations in 2009 and 2010 into the bank’s acquisition of Merrill Lynch.

The bank’s investigative team is trying to reconstruct the handover of materials to public agencies for a variety of inquiries, in pursuit of previously undisclosed documents that could embarrass the company, bank officials said.

In addition to the Merrill documents, the team is reviewing material on Bank of America’s disastrous acquisition in 2008 of Countrywide Financial, the subprime mortgage specialist.  The criticism of Bank of America’s foreclosure procedures centers mostly on loans it acquired in the Countrywide deal, and one possibility is that the documents could show unscrupulous or fraudulent lending practices by Countrywide.

If that is the case, it would not only reignite political pressure on Bank of America and other top mortgage servicers, but it could also strengthen the case of investors pressuring the big banks to buy back tens of billions in soured mortgages.

Bank of America has taken other steps, as well.  Last month, the bank bought up Web addresses that could prove embarrassing to the company or its top executives in the event of a large-scale public assault - although a spokesperson said the move was unrelated to any possible leak.  On 12/18, BofA said it would join other companies like MasterCard and PayPal in halting the processing of payments intended for WikiLeaks, citing the possibility the organization’s activities might be illegal. 

Despite his legal troubles, Mr. Assange’s threats have grown more credible with every release of secret documents, including those concerning the dumping of toxic waste in Africa, the treatment of prisoners held by the U.S. at Guantánamo Bay, the wars in Iraq and Afghanistan and, most recently, the trove of diplomatic cables. 

Yet, with the possibility that Mr. Assange might shift his attention to a private company - especially one as politically unpopular as Bank of America or any of its rivals - there's a new kind of corporate threat - one that combines elements of law, technology, public policy, politics and public relations.  That's not to say WikiLeaks has never taken on private companies in the past - including leaking documents from U.K.'s Barclays Bank and Switzerland's Bank Julius Baer - though neither disclosure drew nearly as much attention.

So, for now, it's "wait and see" for everyone, other than Bank of America.  For further details, go to:   [NYTimes, 1/3/11, "Facing a New Type of Threat ..."]