The Non-SDN Palestinian Legislative Council (NS-PLC) List is a sanctions roster maintained by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) that identifies members of the Palestinian Legislative Council (PLC) who were elected on the slate of a Foreign Terrorist Organization (FTO) or Specially Designated Terrorist (SDT)—principally Hamas's "Change and Reform" list—in the January 2006 Palestinian legislative elections. The list operationalizes restrictions flowing from the Anti-Terrorism Act, the International Emergency Economic Powers Act (IEEPA), and Executive Order 13224 of September 23, 2001, which targets persons committing or supporting acts of terrorism. Crucially, listed individuals are not designated as Specially Designated Nationals (SDNs); their property is not blocked under the 50 percent rule. The NS-PLC List is a distinct compliance regime sitting alongside, but separate from, the SDN List and the Sectoral Sanctions Identifications (SSI) List.
The procedural mechanics turn on a narrow but absolute prohibition. U.S. financial institutions and other U.S. persons are barred from maintaining accounts for, or transacting with, NS-PLC listees in their capacity as PLC members—meaning transactions involving their official salaries, allowances, or other emoluments derived from their legislative office. OFAC's guidance instructs that a U.S. bank receiving a wire that references NS-PLC parliamentary remuneration must reject (not block) the transaction and file a rejection report within ten business days, consistent with 31 C.F.R. § 501.604. Because the property is not blocked, funds are returned to the originator rather than placed in an interest-bearing blocked account. Screening obligations extend to correspondent banking relationships, money services businesses, and any U.S.-nexus payment processor.
A defining feature of the NS-PLC regime is its bifurcated treatment of the same individual. Personal, non-official transactions by a listee—for instance, a private remittance from a family member abroad unrelated to PLC functions—are not categorically prohibited, although institutions exercise heightened due diligence. Where a listee is independently designated under EO 13224 or another authority, those broader blocking sanctions supersede the narrower NS-PLC restriction. OFAC has on multiple occasions migrated NS-PLC entries to the SDN List when additional derogatory information warranted full blocking. The list is updated through OFAC Recent Actions notices, published in the Federal Register, and disseminated via the consolidated screening files (SDN.XML, CONS_PRIM.CSV) that compliance vendors ingest daily.
Contemporary application centers on the West Bank and Gaza payment corridors. Following Hamas's 2006 electoral victory and its June 2007 takeover of the Gaza Strip, the Quartet (United States, European Union, Russia, United Nations) conditioned engagement on Hamas's renunciation of violence, recognition of Israel, and acceptance of prior agreements—conditions Hamas did not meet. Treasury issued the NS-PLC List shortly thereafter. Named listees have historically included senior Hamas political figures such as Ismail Haniyeh (who served as PLC member and prime minister before later SDN designation) and Mahmoud al-Zahhar. Following the October 7, 2023 Hamas attacks on Israel, OFAC accelerated targeted designations of Hamas financial facilitators, and Treasury actions in late 2023 and 2024 moved additional Hamas-affiliated individuals from peripheral status to full SDN blocking under EO 13224.
The NS-PLC List should not be conflated with the SDN List, the Foreign Terrorist Organization (FTO) designation maintained by the State Department under Section 219 of the Immigration and Nationality Act, or the Specially Designated Global Terrorist (SDGT) category under EO 13224. The SDN List triggers full asset blocking and an absolute transaction prohibition; the FTO list criminalizes material support under 18 U.S.C. § 2339B; the NS-PLC List, by contrast, is a surgical instrument that prevents U.S. persons from financially sustaining the parliamentary apparatus of an organization the United States deems terrorist, without imposing the full apparatus of blocking sanctions on individuals who might otherwise lack independent grounds for designation. The list is conceptually analogous to the Non-SDN Menu-Based Sanctions List (NS-MBS) and the Non-SDN Iranian Sanctions Act List (NS-ISA) in its "list-without-blocking" architecture.
Edge cases generate persistent compliance friction. The PLC has not convened in functional session since 2007, and President Mahmoud Abbas dissolved it by decree in December 2018—a measure Hamas rejected as ultra vires. The legal status of "PLC membership" has consequently become contested, but OFAC continues to maintain the list, treating the 2006 electoral mandate as the operative trigger. Humanitarian payment channels, including those authorized under General Licenses issued after October 2023 to facilitate Gaza relief, must screen against NS-PLC entries even where the underlying activity is humanitarian. Dual nationals—particularly listees holding Jordanian documents—create know-your-customer complications for Gulf and European correspondent banks with U.S. dollar clearing exposure.
For the working practitioner, the NS-PLC List exemplifies the granularity of modern U.S. sanctions architecture and the importance of distinguishing among OFAC's multiple non-SDN regimes. Compliance officers at correspondent banks, NGOs operating in the West Bank and Gaza, and diplomatic missions facilitating donor coordination must screen counterparties against the consolidated non-SDN files, not merely the SDN List. For desk officers and policy researchers, the list serves as a barometer of U.S. posture toward Palestinian political institutions: its persistence through three U.S. administrations, multiple Gaza conflicts, and the post-October 2023 environment signals continuity in the legal demarcation between engaging the Palestinian Authority and isolating Hamas-aligned political infrastructure.
Example
In March 2024, a U.S. correspondent bank rejected and reported a euro-denominated wire originating from a Beirut institution that referenced salary disbursement to an NS-PLC-listed Hamas parliamentarian, consistent with OFAC's 31 C.F.R. § 501.604 obligations.