LYNCH, Circuit Judge.
This case raises a novel issue of the proper construction of 18 U.S.C. § 981(k), a civil forfeiture provision concerned with interbank accounts of foreign banks, which was added as part of the USA PATRIOT Act, Pub.L. No. 107-56, § 319(a), 115 Stat. 272, 311-12 (2001).
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