The OFAC notice which appeared last week, covering the retirement of specific independent data files and their consolidation, should serve as a timely reminder of a problem with certain Palestinian PEPs who pose a unique compliance burden; they are not SDNs, but you are nevertheless prohibited from dealing with them, as all "transactions involving these individuals must be rejected."
Known as the NS-PLC list, it consists of the names of members of the Palestinian Legislative Council who were elected on the political party slate of Hamas, or another sanctioned entity, but do not appear on the SDN list. If you are foolish enough to limit your query to the Specially Designated Nationals, or SDN, list, you will not find these individuals, and you may erroneously permit a transaction.
if you are not familiar with the PLC list, and you are banking Palestinians, it is suggested that you download the list, and keep it for future reference by your compliance staff. it can be accessed here.
There has not been an election for the members of the PLC since 2006, due to the split between Hamas, ruling in the Gaza Strip, and the PA/Fatah, governing in the West Bank; the listed members continue to serve, albeit in a dysfunctional government.
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Note: NS stands for "Non-Specially Designated National."
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