What changed
RBI forwarded a September 15, 2011 UN 1267 Committee note with changes to the consolidated list of Al-Qaida-linked individuals and entities. Banks must now incorporate these updates into their screening process.
What it means for you
Co-operative banks must immediately update their internal terror watchlists and cross-check all new and existing accounts against the revised UN list. Failure to comply with UAPA freezing orders could invite regulatory action.
What you must do
- Update your consolidated list of UNSCR 1267-designated individuals/entities with the latest changes from the UN website.
- Screen all new account applications against the updated list before onboarding.
- Scan all existing accounts to identify any matches with the revised list.
- Follow the freezing procedures outlined in the UAPA Order of August 27, 2009, as detailed in RBI's October 29, 2009 circular.
- Have your Compliance/Principal Officer acknowledge receipt of this circular to the concerned RBI Regional Office.
Who it affects
State Co-operative Banks, Central Co-operative Banks, Compliance Officers of co-operative banks, Principal Officers of co-operative banks
Where can we find the latest consolidated list?
The complete list is available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
What action is required for existing accounts that match the list?
You must freeze funds, financial assets, or economic resources as per paragraph 6 of RBI's October 29, 2009 circular, following the UAPA Order.
Do we need to acknowledge receipt of this circular?
Yes, your Compliance Officer or Principal Officer must send an acknowledgment to the concerned RBI Regional Office.