Hizballah International Financing Prevention Act of 2015, Pub. L. 114-102, 129 Stat. 2205

Date issued: Dec. 18 2015

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TURBOFAC Commentary (450 words)

Notes:

1) Read in conjunction with the Hizballah International Financing Prevention Amendments Act of 2018 [Selected provisions], and comments thereto.

2) The Hizballah International Financing Prevention Act of 2015 (HIFPA), as originally enacted, is largely irrelevant for ordinary sanctions compliance purposes, with the exception of Sec. 102 of the act. That section provides for CISADA-style, correspondent account or a payable-through account restrictions for foreign financial institutions that knowingly facilitate a significant transaction or transactions for Hizballah; knowingly facilitate a significant transaction or transactions of a person identified on the SDN list for acting on behalf of or at the direction of, or being owned or controlled by, Hizballah; or knowingly facilitate a significant transaction or transactions or provides significant financial services to carry out an activity described above. There is also a "money laundering" provision of less interest to those concerned with...