What changed
RBI has forwarded four new UN Security Council 1267 Committee notes (dated May 4, 11, 16, and 27, 2011) that update the consolidated list of individuals and entities linked to Al-Qaida and Taliban. Banks must incorporate these changes into their existing screening lists and ensure compliance with the UAPA Order of August 27, 2009.
What it means for you
Banks must immediately update their internal databases with the revised UN sanctions list to avoid onboarding or servicing prohibited entities. Failure to screen accounts properly could lead to regulatory action and reputational risk. The circular reinforces the need for strict adherence to anti-money laundering and counter-terrorism financing protocols.
What you must do
- Update the consolidated list of terrorist individuals/entities with the four new UN notes received from the Ministry of External Affairs.
- Screen all new account applications against the updated list before opening accounts.
- Scan all existing accounts to identify and freeze any accounts linked to newly listed individuals/entities.
- Follow the freezing procedures outlined in paragraph 6 of the September 17, 2009 circular and the UAPA Order dated August 27, 2009.
- Ensure the 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
What is the source of the updated list?
The updates come from four notes issued by the UN Security Council's 1267 Committee in May 2011, forwarded by the Government of India's Ministry of External Affairs.
Do we need to freeze accounts immediately?
Yes, if any existing account is found linked to a newly designated individual or entity, you must freeze funds, financial assets, or economic resources as per the procedure in paragraph 6 of the September 17, 2009 circular.
Where can we find the complete consolidated list?
The full list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml.