What changed
RBI received a June 15, 2011 note from the UN Security Council's 1267 Committee with changes to the consolidated list of individuals and entities linked to Al-Qaida and Taliban. Banks are required to update their records with this revised list and ensure compliance with earlier circulars on account screening and asset freezing.
What it means for you
Banks must immediately update their internal databases with the latest UN consolidated list and verify that no new or existing customer matches any listed entity. Failure to comply could lead to regulatory action and reputational risk. The circular reinforces the strict procedures under the UAPA Order of August 27, 2009, particularly for freezing funds and financial assets of designated individuals.
What you must do
- Update your internal consolidated list of terrorist individuals/entities with the latest UN 1267 Committee changes.
- Screen all new account openings against the updated list before onboarding customers.
- Scan all existing accounts to identify and report any matches with the updated list.
- Freeze funds, financial assets, or economic resources of designated individuals/entities as per paragraph 6 of the September 17, 2009 circular.
- 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 list is from the UN Security Council's 1267 Committee, forwarded by the Ministry of External Affairs. The full list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml.
What action is required for existing accounts?
Banks must scan all existing accounts to ensure no account is held by or linked to any entity or individual on the updated list. If a match is found, funds and assets must be frozen as per the UAPA Order procedures.
Which earlier circulars are referenced?
This circular refers to DBOD.AML.No.19262/14.06.001/2010-11 dated June 14, 2011, and DBOD.AML.BC.No.44/14.01.001/2009-10 dated September 17, 2009, which contains the UAPA Order and freezing procedures.