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UNSC 1267 Terror List Updates: Banks Must Screen Accounts

Current · Source: Reserve Bank of India · RBI/2009-10/217 · issued 11 Nov 2009 · ~1 min read
Quick answerRBI directs banks to update their consolidated list of UNSC 1267-designated terrorist individuals/entities following amendments from the UN 1267 Committee. Banks must screen new and existing accounts against this list and comply with UAPA freezing procedures.
Sanctions-list safety note. This circular refers to a specific UN Security Council / UAPA designated-entities list update as it stood on the date above — sanctions lists change often, and a newer update almost certainly exists today. Never use this page, or any single dated circular, as your current screening list. Always screen against the live, current list at the official UAPA proscribed-organisations list and the UN Consolidated List, and confirm the obligations for your bank on the official rbi.org.in source below.
The rule, in the simplest words
How it plays out — a real example

A KYC & compliance officer in Indore is opening a new account for a customer. Before approving, she checks the customer's name against the updated UNSC 1267 list her bank just received. The name is not there, so she proceeds. Later, she also runs a scan of all existing loan accounts and finds one linked to a newly added entry; she immediately freezes that account and follows the UAPA freezing steps.

What changed

RBI received updated UNSC 1267 Committee notes from September-October 2009, with amendments to the Consolidated List of Al-Qaida/Taliban-linked individuals and entities. Changes include deletions and modifications (strike-through/underline) to entries across three annexes. Banks must update their internal lists accordingly.

What it means for you

Banks must immediately update their customer screening databases with the revised UNSC 1267 list. Failure to identify and freeze accounts of designated entities could lead to regulatory action. This reinforces the government's commitment to combating terrorist financing under UAPA.

What you must do

Who it affects

All Scheduled Commercial Banks (excluding RRBs), Local Area Banks, Financial Institutions

❓ Common questions

What is the source of the updated list?

The updates come from notes dated September 3, 23, and October 22, 2009, from the Chairman of the UN Security Council's 1267 Committee, forwarded by the Ministry of External Affairs.

What actions are required for existing accounts?

Banks must scan all existing accounts to ensure no account is held by or linked to any entity or individual in the updated list. If found, freezing of funds and assets must follow the UAPA Order procedures.

Where can the full consolidated list be accessed?

The complete consolidated list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml.

📜 Read the original circular — full text as issued by RBI
RBI/2009-10/217 DBOD. AML. No. 8299 /14.06.057/2009-10 November 11, 2009 The Chairman / CEOs of all Scheduled Commercial Banks (Excluding RRBs)/ Local Area Banks / Financial Institutions Dear Sir, List of Terrorist Individuals/Organisations - under UNSCR 1267(1999) and 1822(2008) on Taliban/Al-Qaida Organsaition Please refer to our circular letter DBOD. AML.No.6106/14.06.055/2009-10 dated October 6, 2009.  We have since received from Government of India (Ministry of External Affairs) copies of notes dated September 3, 2009; September 23, 2009 and October 22, 2009 from the Chairman of UN Security Council's 1267 Committee regarding changes made in the Consolidated List of Individuals and entities linked to Al-Qaida and Taliban as specified below: Amendments specified with strike –through and underline in the four entries to the Consolidated List  and an update of the review of names  of the Consolidated List as per Annex-I Amendments made through deletion of one entry  and amendment specified with strike –through and underline in the two entries to the Consolidated List and an update of the review of names  of the Consolidated List as per Annex-II Amendments made through deletion of the four entries specified from its Consolidated List and an update of the review of names  of the Consolidated List as per Annex- III 2. Banks/Financial Institutions are required to update the consolidated list of individuals/entities as circulated by Reserve Bank and before opening any new account, it should be ensured that the name/s of the proposed customer does not appear in the list. Further, banks should scan all existing accounts to ensure that no account is held by or linked to any of the entities or individuals included in the list. 3. Banks are advised to strictly follow the procedure laid down in the  UAPA Order dated August 27, 2009 enclosed to our circular DBOD.AML.BC. No. 44/14.01.001/2009-10 dated September 17, 2009 and ensure meticulous compliance to the Order issued by the Government. 4.  As far as freezing of funds, financial assets or economic resources or related services held in the form of bank accounts of the designated individuals/entities are concerned, action should  be taken as detailed in paragraph  6 of the circular dated September 17, 2009, mentioned above. 5.  The complete details of the said consolidated list are available on the UN website:                 http://www.un.org/sc/committees/1267/consolist.shtml 6  Compliance Officer/Principal Officer should acknowledge receipt of this circular letter. Yours faithfully, (P. K. Das) Deputy General Manager Encl: As above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2009-10/217 · issued 11 Nov 2009. The plain-English explanation above is BankPulse’s own independent summary.
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Who does what — compliance checklist
🏦 Branch Manager
  • Screen all new account applications against the updated list before account opening.
📜 Compliance
  • Update the consolidated list of terrorist individuals/entities as per the three annexes provided in the circular.
  • Scan all existing accounts to identify any links to newly added or modified entries.
  • Follow the freezing procedures outlined in the UAPA Order dated August 27, 2009, and RBI circular of September 17, 2009.
  • Ensure Compliance Officer/Principal Officer acknowledges receipt of this circular.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template

Example: if you are a Compliance officer at a bank this circular applies to (All Scheduled Commercial Banks (excluding RRBs), Local Area Banks, Financial Institutions), your first concrete step on “UNSC 1267 Terror List Updates: Banks Must Screen Accounts” is: “Update the consolidated list of terrorist individuals/entities as per the three annexes provided in the circular.” (RBI issued this 11 Nov 2009).

  1. Circular: RBI/2009-10/217 -- UNSC 1267 Terror List Updates: Banks Must Screen Accounts
  2. Issued: 11 Nov 2009
  3. Action required: Update the consolidated list of terrorist individuals/entities as per the three annexes provided in the circular.
  4. Action required: Screen all new account applications against the updated list before account opening.
  5. Action required: Scan all existing accounts to identify any links to newly added or modified entries.
  6. Action required: Follow the freezing procedures outlined in the UAPA Order dated August 27, 2009, and RBI circular of September 17, 2009.
  7. Action required: Ensure Compliance Officer/Principal Officer acknowledges receipt of this circular.
  8. Owner: ____________ Target date: ____________
  9. Board/committee approval needed? Y / N
  10. Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=5361&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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