What changed
RBI forwarded three new UN notes (July 29, Aug 12, Aug 22, 2011) from the 1267 Committee that update the consolidated list of Al-Qaida/Taliban-linked individuals and entities. Banks must replace earlier lists with this updated version and ensure compliance with the UAPA Order of August 27, 2009.
What it means for you
Banks must immediately update their internal sanctions screening databases with the latest UN list. Failure to identify and freeze accounts of designated entities could lead to regulatory action. This circular reinforces the ongoing obligation to check all new and existing customers against the consolidated list.
What you must do
- Update your internal sanctions list with the three new UN notes (July 29, Aug 12, Aug 22, 2011) attached to this circular.
- Screen all new account applications against the updated consolidated list before onboarding.
- Scan all existing accounts to identify any matches with the updated list and report findings.
- Freeze funds/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
What is the source of the updated list?
The list comes from the UN Security Council's 1267 Committee, forwarded by the Ministry of External Affairs via three notes dated July 29, August 12, and August 22, 2011.
Do we need to screen only new accounts?
No. You must screen both new accounts before opening and all existing accounts to ensure none are linked to listed individuals/entities.
What action is required if we find a match?
Follow the freezing procedures detailed in paragraph 6 of RBI circular DBOD.AML.BC. No. 44/14.01.001/2009-10 dated September 17, 2009, as per the UAPA Order.