Case Explained: JOSEPH PAUL ENGLEHARDT AND YVONNE DORA WADE v. TODD BLANCHE

Court: United States Court of Appeals for the District of Columbia Circuit Filed: 2026-08-04 The dc-circuit reversed the district court’s grant of summary judgment for the Department of Justice, holding that the Justice for United States Victims of State Sponsored Terrorism Act (VSST Act) requires all proceeds from British American Tobacco’s criminal penalties and forfeitures to be deposited into the United States Victims of State Sponsored Terrorism Fund. The court interpreted 34 U.S.C. § 20144(e)(2)(A)(i), which mandates that funds from violations of the International Emergency Economic Powers Act (IEEPA) or Trading with the Enemy Act (TWEA), as well as related criminal conspiracies arising from actions by a state sponsor of terrorism, be deposited into the Fund. The court determined that the statute creates two distinct categories: IEEPA and TWEA violations require no nexus to a state sponsor of terrorism, while “related” offenses do. Because British American Tobacco’s IEEPA conspiracy was charged as a violation of an IEEPA order, all proceeds from it must go into the Fund. Regarding the bank fraud conspiracy, the court held that because the offense originated while North Korea was designated as a state sponsor of terrorism, the entire conspiracy “arose from” doing business with a state sponsor of terrorism, requiring all proceeds from that single offense to be deposited into the Fund rather than only those tracing to transactions during the designation period. The case is remanded with instructions to enter summary judgment for the plaintiffs. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.