What changed
RBI has circulated the latest changes to the UN Security Council's Al-Qaida Sanctions List, as notified by the Ministry of External Affairs. Banks must update their records with this revised list and ensure compliance with the UAPA Order of August 27, 2009.
What it means for you
Banks must immediately update their internal databases with the new list of sanctioned individuals and entities linked to Al-Qaida. All new account openings must be screened against this list, and existing accounts must be reviewed to identify any matches. For any matches, banks must freeze funds and assets as per the September 2009 circular's paragraph 6.
What you must do
- Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.
- Screen all new account applications against the updated list before onboarding.
- Scan all existing accounts to identify any linked to listed individuals or entities.
- Freeze funds and assets of any matched accounts following the procedure in the September 17, 2009 circular.
- Ensure the 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 the UN Security Council's 1267/1989 Committee's Al-Qaida Sanctions List, available on the UN website.
What action is required for existing accounts?
Banks must scan all existing accounts to ensure none are held by or linked to any individual or entity on the updated list.
What should we do 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.