What changed
RBI circulated eight UN Security Council notes from August to December 2010 detailing changes to the consolidated list of individuals and entities linked to Al-Qaida and Taliban. Payment system operators must now update their internal lists and screen all new and existing customers against this updated list.
What it means for you
Payment system operators must integrate these UN list updates into their KYC and AML checks immediately. Non-compliance could lead to regulatory action, and the circular reinforces the need for rigorous ongoing due diligence on all accounts, not just new ones.
What you must do
- Update your internal consolidated list of designated individuals/entities with the eight UN notes provided.
- Screen all new customers against the updated list before opening accounts or offering services.
- Scan all existing accounts to identify and freeze any linked to listed entities, following the UAPA Order procedure.
- Ensure your Nodal Officer/Principal Officer acknowledges receipt of this circular.
- Refer to the UN website for the complete and latest consolidated list.
Who it affects
All authorised payment system operators in India, Banks offering payment services, Non-bank payment service providers, Compliance and AML teams
What is the source of the updated list I need to use?
The list is based on eight notes from the UN Security Council's 1267 Committee, forwarded by the Ministry of External Affairs. The full consolidated list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml.
Do I only need to check new customers, or also existing ones?
Both. You must screen new customers before onboarding and also scan all existing accounts to ensure none are held by or linked to any entity or individual on the updated list.
What action should I take if I find a match in an existing account?
Follow the procedure laid out in the UAPA Order dated August 27, 2009, and detailed in paragraph 6 of RBI circular DBOD.AML.BC. No. 44/14.01.001/2009-10 dated September 17, 2009, which includes freezing funds and financial assets.