What changed
RBI has forwarded six UN Security Council notes (dated Oct 5, Oct 17, Nov 30, Dec 13, Dec 28, Dec 30, 2011) that update the Al-Qaida Sanctions List. All PSOs must now incorporate these changes into their customer screening processes.
What it means for you
Banks and payment operators must immediately update their internal sanctions lists with the new UN entries. They are required to check all new account openings against this list and also review existing accounts to identify any matches. Non-compliance could lead to regulatory action.
What you must do
- Update your internal sanctions database with the six UN notes attached to this circular.
- Screen all new customer applications against the updated Al-Qaida list before onboarding.
- Conduct a retrospective scan of all existing accounts to detect any linked to listed entities.
- Follow the freezing procedures outlined in RBI's September 17, 2009 circular for any matches found.
- Ensure your nodal officer acknowledges receipt of this circular.
Who it affects
All payment system operators authorized under PSS Act, 2007, Banks offering payment services, Compliance and AML teams, Nodal officers of payment entities
What is the source of the updated list?
The updates come from six official notes from the UN Security Council's 1267/1989 Committee, forwarded by the Ministry of External Affairs.
Do we need to check only new accounts?
No, you must screen both new accounts before opening and all existing accounts to ensure none are linked to the listed individuals or entities.
What action is required if a match is found?
Follow the freezing of funds and assets procedures detailed in paragraph 6 of RBI's circular dated September 17, 2009.