What changed
RBI issued a circular on June 22, 2011, updating the consolidated list of individuals and entities linked to Al-Qaida and Taliban based on four new notes from the UN Security Council's 1267 Committee. PSOs must now incorporate these changes into their screening processes.
What it means for you
Banks and payment operators must immediately update their sanctions screening databases with the latest UN list to avoid onboarding or servicing prohibited entities. Non-compliance could lead to regulatory action and reputational risk, as the circular mandates strict adherence to UAPA freezing orders.
What you must do
- Update your internal sanctions list with the four new annexes from the UN 1267 Committee.
- Screen all new customers against the updated list before opening accounts or offering services.
- Scan existing accounts to identify and freeze any linked to listed individuals or entities.
- Ensure compliance with the UAPA Order of August 27, 2009, and RBI's September 17, 2009 circular on freezing procedures.
- Have your Nodal Officer/Principal Officer acknowledge receipt of this circular.
Who it affects
All Payment System Operators (PSOs) authorized under the PSS Act, 2007 (including banks that are PSOs), Compliance and AML teams
What is the source of the updated list?
The list comes from four notes issued by the UN Security Council's 1267 Committee in May 2011, forwarded by the Ministry of External Affairs.
What action is required for existing accounts?
PSOs must scan all existing accounts to ensure none are held by or linked to any entity or individual on the updated list.
Where can I find the full consolidated list?
The complete list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml.