Comment on FR Doc # 2026-06271
Caleb Hayes-DeatsOpposeBusiness
Summary: Lowell & Associates, PLLC, a law firm, opposes the proposed interpretation that excludes monies collected by the U.S. Victims of State Sponsored Terrorism Fund (VSSTF) from the definition of "monetary sanctions." They argue this interpretation contradicts the plain language of 31 U.S.C. § 5323, would significantly reduce whistleblower awards, and would ultimately harm terrorism victims by decreasing the incentives for whistleblowers to report sanctions violations.
Our comments focus on one particularly important issue: the proposed interpretation of “monetary sanctions” purports to exclude “monies collected by the U.S. Victims of State Sponsored Terrorism Fund (VSSTF).” 91 Fed. Reg. at 16,333. That interpretation contradicts the plain language of 31 U.S.C. 5323 and would harm the terrorism victims that the VSSTF serves.
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