What changed
RBI circular DPSS.CO.AD.No. 604/02.27.005/2011-12 dated October 3, 2011, forwards three UN 1267 Committee notes (July 29, August 12, August 22, 2011) that update the consolidated list of Al-Qaida-linked individuals/entities. It replaces the previous list from the August 4, 2011 circular.
What it means for you
Payment system operators must immediately incorporate these new UN list updates into their customer screening processes. Failure to check both new and existing accounts against the updated list could lead to regulatory action. The circular also reinforces the freezing procedures under the UAPA Order of August 27, 2009, as detailed in RBI's September 17, 2009 circular.
What you must do
- Update your internal consolidated list of UNSCR 1267/1822 designated individuals/entities with the three new annexes from July/August 2011.
- Screen all new account openings and service registrations against the updated list before onboarding.
- Run a fresh scan of all existing customer accounts to identify any matches with the updated list.
- Follow the freezing and reporting procedures outlined in paragraph 6 of RBI circular DBOD.AML.BC. No. 44/14.01.001/2009-09 dated September 17, 2009, for any matches found.
- Ensure your Nodal Officer/Principal Officer acknowledges receipt of this circular.
Who it affects
All payment system operators authorized under the PSS Act, 2007, Banks offering payment system services, Compliance and AML teams at PSOs, Nodal Officers and Principal Officers of PSOs
What is the source of the updated list?
The updates come from three notes from the Chairman of the UN Security Council's 1267 Committee, dated July 29, August 12, and August 22, 2011, forwarded by the Ministry of External Affairs.
Do we need to check only new customers?
No. You must screen both new customers before onboarding and all existing accounts to ensure none are held by or linked to listed individuals/entities.
What action is required if we find a match?
Follow the freezing of funds, financial assets, or economic resources as detailed in paragraph 6 of RBI's September 17, 2009 circular, which implements the UAPA Order of August 27, 2009.