Did you know that there are two sanctions lists on the OFAC website? Most of us know about the SDN (Specially Designated Nationals) List, but usually not so much about the NS-PLC List (more on why in a second).
NS = Non-SDN
PLC – Palestinian Legislative Council
The Palestinian Legislative Council is the legislative body (like a Parliament) which makes legislative decisions for the West Bank and Gaza. actually has not (according to Wikipedia) been able to meet for a while due to the imprisonment of some of its members by the Israelis. But, Mr. Watchlist digresses.
The PLC consists of people elected under the West Bank-based Fatah slate, and under the Gaza-based Hamas slate. A person who was elected under the Hamas slate, and is not already on the SDN list, goes on the NS-PLC List.
Because, if you get a match to someone on the NS-PLC List, you reject the transaction instead of blocking the funds. The US wants to show its disapproval of Hamas in general, but has insufficient evidence on these individuals to hold their assets.
So, why don’t most of us know about this list? Well, from a purely mechanical standpoint, it’s still a list of names you have to match against. So, data providers combine the two lists, and expect compliance officers to know the difference. Not unreasonable actually – it beats doing two matching passes (one for the NS-PLC List, one for the OFAC List).
So, now you know.