What changed
RBI has forwarded six new UN Security Council notes (dated Oct 5, Oct 17, Nov 30, Dec 13, Dec 28, and Dec 30, 2011) that update the Al-Qaida Sanctions List of individuals and entities. Co-operative banks must now incorporate these changes into their consolidated list and ensure compliance with the UAPA Order of August 27, 2009.
What it means for you
Co-operative banks must immediately update their internal sanctions screening systems with the latest UN list entries. Failure to identify and freeze accounts linked to designated individuals or entities could lead to regulatory action. The circular reinforces that banks must verify all new customers against the list and periodically scan existing accounts.
What you must do
- Update your consolidated sanctions list with the six UN notes (Annex I-VI) provided in the circular.
- Screen all new account openings against the updated list before onboarding.
- Scan all existing accounts to identify any links to newly added individuals or entities.
- Follow the freezing procedures outlined in paragraph 6 of RBI circular dated October 29, 2009 for any matches.
- Acknowledge receipt of this circular to your respective RBI Regional Office through your Compliance/Principal Officer.
Who it affects
State Co-operative Banks, Central Co-operative Banks, Compliance Officers and Principal Officers of co-operative banks
What is the source of the updated sanctions list?
The updates come from six notes issued by the Chairman of the UN Security Council's 1267/1989 Committee between October and December 2011, forwarded by the Ministry of External Affairs.
Do we need to check only new accounts or existing ones too?
Both. You must ensure no new account is opened for a listed entity or individual, and you must scan all existing accounts to confirm none are held by or linked to any listed party.
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 circular dated October 29, 2009, which implements the UAPA Order.