What changed
RBI issued a circular on February 17, 2012, requiring PSOs to update the Al-Qaida sanctions list based on a UN Security Council committee note dated January 26, 2012. This follows a prior circular from January 24, 2012, and reinforces compliance with the UAPA Order of August 27, 2009.
What it means for you
PSOs must now ensure no new account is opened for any individual or entity on the updated UN sanctions list. They must also review all existing accounts to identify and freeze any linked assets, following the procedures in the September 17, 2009 RBI circular.
What you must do
- Update your internal sanctions list with the latest UN Al-Qaida list from the UN website.
- Screen all new account applicants against the updated list before opening accounts.
- Scan all existing customer accounts to identify any matches with the sanctions list.
- Freeze funds, financial assets, or economic resources of designated individuals/entities as per paragraph 6 of the September 17, 2009 circular.
- Ensure your nodal/principal officer acknowledges receipt of this circular.
Who it affects
All Payment System Operators authorized under the PSS Act, 2007, Compliance and AML teams at PSOs, Nodal/Principal Officers of PSOs
What is the source of the updated sanctions list?
The list is from the UN Security Council's 1267/1989 Committee, available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
What action is required for existing accounts linked to the list?
PSOs must scan all existing accounts and freeze any funds, financial assets, or economic resources of designated individuals/entities, following the procedure in paragraph 6 of the September 17, 2009 RBI circular.
Which earlier circular provides the detailed procedure?
The procedure is outlined in RBI circular DBOD.AML.BC. No. 44/14.01.001/2009-10 dated September 17, 2009, which implements the UAPA Order of August 27, 2009.