Delegation of Functions and Authorities Under the Hizballah International Financing Prevention Act of 2015, as Amended, and the Hizballah International Financing Prevention Amendments Act of 2018

Impact dates

1. Date TBD

   Federal Register publication by Secretary of State

Key directives

• Delegate HIFPA/HIFPAA authorities to Secretary of State per sections 101(b)(2), 101(c), 102(b), 103(b-c), and 201(c)
• Delegate HIFPA/HIFPAA authorities to Secretary of the Treasury per sections 101(a), 101(b)(1), 102(a), 102(c), 103(a), 201(a-b), 204(b), 302, and HIFPAA section 301
• Delegate HIFPA/HIFPAA authorities to Director of National Intelligence per sections 202 and 204(a, c-d)
• Exercise delegated functions through National Security Presidential Memorandum-4 process
• Rescind and replace prior delegations to same officials
• Secretary of State to publish in Federal Register

Who is ordered

• Secretary of State · Department of State
• Secretary of the Treasury · Department of the Treasury
• Director of National Intelligence · Office of the Director of National Intelligence

Timeline

Risks & tensions

• Inter-agency coordination requirement via NSPM-4 may create implementation friction
• Vague 'substantially the same' future act reference creates legal uncertainty
• No specific timeline for Federal Register publication