What changed
RBI received a March 24, 2011 note from the UN Security Council's 1267 Committee with changes to the consolidated list of individuals/entities linked to Al-Qaida and Taliban. This supersedes the previous list circulated via circular dated March 11, 2011.
What it means for you
Banks must immediately update their internal screening databases with the revised UN list. Failure to identify and freeze accounts of designated entities could lead to regulatory action and reputational risk. The UAPA Order of August 27, 2009 remains the governing framework for freezing procedures.
What you must do
- Update your internal AML screening systems with the latest UN consolidated list available at the UN website.
- Screen all new account applications against the updated list before onboarding.
- Run a fresh scan of all existing accounts to identify any matches with the revised list.
- Freeze funds and assets of any matched accounts as per paragraph 6 of the September 17, 2009 circular.
- Ensure your Compliance Officer/Principal Officer acknowledges receipt of this circular.
Who it affects
All Scheduled Commercial Banks (excluding RRBs), Local Area Banks, All India Financial Institutions
Where can I find the latest consolidated list of terrorist individuals/organisations?
The complete list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml. RBI has forwarded the changes via this circular, but banks should refer to the UN site for the full updated list.
What action should we take if we find a match in an existing account?
You must immediately freeze the funds, financial assets, or economic resources held in that account, following the procedure detailed in paragraph 6 of RBI circular DBOD.AML.BC. No. 44/14.01.001/2009-10 dated September 17, 2009, which implements the UAPA Order.
Is this a one-time requirement or ongoing?
This is an ongoing obligation. Banks must continuously screen new accounts and periodically re-screen existing accounts against the UN consolidated list, which is updated by the 1267 Committee. RBI will circulate changes as received from the Government of India.