PolicyBrief
S. 198
119th CongressJan 22nd 2025
PLO and PA Terror Payments Accountability Act of 2025
IN COMMITTEE

The PLO and PA Terror Payments Accountability Act of 2025 mandates sanctions on foreign individuals, entities, and financial institutions that support the PLO and PA's system of compensation for acts of terrorism, and requires the President to impose these sanctions. The act will be terminated if the Secretary of State certifies that the PLO and PA have stopped providing payments to terrorists and their families.

Tom Cotton
R

Tom Cotton

Senator

AR

LEGISLATION

New Bill Mandates Sanctions Over PLO and PA Payments to Terrorists and Families: Banks Could Face Restrictions

The "PLO and PA Terror Payments Accountability Act of 2025" aims to cut off financial support for terrorism by imposing strict sanctions on individuals, entities, and even banks involved in making or facilitating payments to terrorists and their families by the Palestinian Liberation Organization (PLO) and Palestinian Authority (PA). This isn't just about government officials; the bill casts a wide net, targeting anyone from former PLO representatives to employees and even those providing "material support" (Section 4(a)(4)).

Targeting the Money Flow

The core of the bill focuses on hitting the PLO and PA where it hurts: their finances. It mandates the President to freeze assets and block transactions of anyone found to be involved in the "system of compensation" that the U.S. sees as incentivizing terrorism (Section 2). This includes not just those directly authorizing payments, but also organizations that manage or facilitate them, like the Commission of Prisoners and Released Prisoners and the Palestine National Fund (Section 4(a)(3)). Think of it like this: if you're a farmer receiving aid, and that aid is somehow linked to these payments, even indirectly, you could be impacted. The definition of "material support" is broad, and that's a potential red flag.

Banking on Compliance

Beyond individuals and organizations, the bill targets banks. Any foreign financial institution found to be processing or even just facilitating transactions related to these payments faces severe restrictions on their ability to do business with the U.S. (Section 5). This means any bank, anywhere in the world, that handles money connected to the PLO/PA's compensation system could find itself locked out of the American financial system. The bill uses the terms "knowingly" and "should have known" (Section 3), which means a bank could be penalized even if they weren't directly aware that a transaction was linked to these payments, but should have reasonably known. This could lead to banks being overly cautious, potentially cutting off legitimate financial flows to Palestinian territories to avoid any risk.

The Termination Clause (and a Catch)

The bill does include a way out. If the Secretary of State certifies that the PLO and PA have stopped these payments, the sanctions are lifted (Section 6). However, given the findings section of the bill (Section 2), which references the 2018 Taylor Force Act and claims payments have continued despite it, achieving this certification might be a high bar. This bill essentially puts a financial chokehold on the PLO and PA, and potentially anyone connected to them, until they demonstrably change their policies. The broad definitions and potential for overreach, especially concerning financial institutions and the concept of "material support", could have significant, and possibly unintended, consequences for ordinary people and humanitarian efforts.