What changed
RBI has circulated seven UN Security Council notes updating the 1988 Sanctions List of Taliban-linked individuals and entities. Banks must now incorporate these updates into their screening processes and ensure no accounts are held by or linked to any newly listed names.
What it means for you
Banks must immediately update their internal sanctions lists with the seven annexes provided and screen all new and existing accounts. Failure to comply could lead to regulatory action, as the UAPA order requires meticulous adherence. This reinforces the need for robust AML/KYC frameworks to prevent terrorist financing.
What you must do
- Update your internal sanctions list with the seven annexes from the UNSCR 1988 Committee notes dated July 2011 to January 2012.
- Screen all new account applications against the updated list before opening accounts.
- Conduct a retrospective scan of all existing accounts to identify any matches with the updated list.
- Follow the freezing procedures outlined in paragraph 6 of the September 17, 2009 circular for any matched accounts.
- Ensure your Compliance 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 sanctions list?
The list is from the UN Security Council's 1988 Committee, covering Taliban-linked individuals and entities, as communicated by the Ministry of External Affairs.
Do we need to check only new accounts or existing ones too?
Both. You must screen new accounts before opening and scan all existing accounts to ensure no account is linked to any listed entity or individual.
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.