COMPLIANCE ALERT: AVOID STATE OF PALESTINE PASSPORTS TO BE ISSUED IN 2016

Current PA passports

The Palestinian Authority, which has administrative control over portions of Judea and Samaria, formerly known as the West Bank, when Jordan annexed it, and controlled it from 1948 to 1967, has advised that it will, beginning in 2016, issue passports entitled "State of Palestine," to its residents.  Ignoring politics, the compliance ramifications of accepting this passport, for any purpose, are extremely dangerous.

If you know your history, you know these passports represent a problem. Arabs residing in Judea & Samaria do not have "Palestinian" citizenship, because there is not an independent, sovereign state, nor has there ever been one. Most of them hold Jordanian passports, or have the ability to acquire one, but such documents do not confer either nationality nor the right of residence in Jordan, which is 60-80% Palestinian, according to most estimates. Jordan was 77% of the original British Mandate of Palestine, until the UK severed it, placing a Hashemite ruler upon the throne. These Jordanian passports held by Palestinians are, however, recognized in many countries as acceptable travel documents.

History aside, the massive level of corruption in the Palestinian Authority means that literally anyone who has sufficient cash will be able, one way or another, to secure one of these new passports. this means members of Specially Designated Global Terrorist (SDGT) organizations could show up at your bank to open an account relationship, meaning you could be banking a member of Hamas, Palestinian Islamic Jihad, or some other sanctioned group. There are also Palestinians fighting in Syria with Hezbollah, who could acquire them.

Trust me, there will be no due diligence performed in Ramallah, the administrative capital of the PA, when these passports are issued. Accepting any of them, for customer identification purposes, is inconsistent with any risk-based compliance program. While some EU banks may deem it politically correct to do so, they could be exposing themselves to a charge of Providing Material Support to a Terrorist Organization, in the United States, as US Dollars always seem to figure into terrorist financing operations.