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UN Terror List Updates for Co-op Banks: Dec 2009

Current · Source: Reserve Bank of India · RBI/2009-10/255 · issued 15 Dec 2009 · ~2 min read
Quick answerRBI directs StCBs/CCBs to update their UNSCR 1267/1822 terrorist lists with three sets of amendments from the UN 1267 Committee, covering deletions and changes to entries linked to Al-Qaida and Taliban. Banks must screen new and existing accounts against the updated list.
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 payments & clearing officer in Indore, Priya, receives this RBI circular. She immediately updates her bank's terrorist list with the three UN annexes. Before approving a new gold loan for a customer, she screens the name against the updated list. She also reviews all existing gold-loan accounts and finds one linked to a newly deleted entry, so she freezes that account following the October 29 circular's procedures.

What changed

RBI forwarded three UN 1267 Committee notes (dated Sep 3, Sep 23, Oct 22, 2009) with amendments to the Consolidated List of individuals/entities linked to Al-Qaida and Taliban. The amendments include strike-through/underline changes to four entries and deletions of one or more entries, as detailed in three annexes.

What it means for you

Co-operative banks must immediately update their internal terrorist lists to reflect the latest UN sanctions. Failure to screen new accounts and review existing ones against this list could lead to regulatory action and non-compliance with UAPA orders.

What you must do

Who it affects

State Co-operative Banks (StCBs), Central Co-operative Banks (CCBs), Compliance Officers of co-operative banks, Branch managers handling account opening

❓ Common questions

What is the source of the updated list?

The updates come from the UN Security Council's 1267 Committee, forwarded by the Ministry of External Affairs. The full list is also available on the UN website.

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 none are held by or linked to listed entities.

What action is required for accounts linked to listed entities?

Freeze funds, financial assets, or economic resources in those accounts as per paragraph 6 of the October 29, 2009 circular.

📜 Read the original circular — full text as issued by RBI
RBI/2009-10/255 RPCD.CO.RF.AML.No.6638/07.02.12/2009-10 December 15, 2009 The Chairmen / CEOs of all State / Central Co-operative Banks Dear Sir, List of terrorist individuals/organisations - under UNSCR 1267(1999) and 1822 (2008) on Taliban/Al-Qaida Organisation Please refer to our letter RPCD.CO.RF.AML.No.4865/07.02.12/2009-10 dated November 9, 2009 on the captioned subject. We have since received from the Government of India (Ministry of External Affairs) copies of notes (copies enclosed) dated September 3, 2009; September 23, 2009 and October 22, 2009 from the Chairman of United Nations 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. State and Central Co-operative Banks 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 RPCD.CO.RF.AML.BC. No. 34/ 07.40.00/ 2009-10 dated October 29, 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 October 29, 2009, mentioned above. 5. The complete details of the said consolidated list are also available on the UN website: http://www.un.org/sc/committees/1267/consolist.shtml 6. Compliance Officer / Principal Officer should acknowledge receipt of this letter to our concerned Regional Office. Yours faithfully, (S.S.Sahota) Deputy General Manager Encl:  As above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2009-10/255 · issued 15 Dec 2009. The plain-English explanation above is BankPulse’s own independent summary.
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Who does what — compliance checklist
💻 IT / Systems
  • Screen all new account applications against the updated list before opening accounts.
📜 Compliance
  • Update the consolidated list of terrorist individuals/entities with the three annexes provided in this circular.
  • Scan all existing accounts to identify and freeze any linked to listed individuals/entities.
  • Follow the freezing procedures outlined in paragraph 6 of the October 29, 2009 circular.
  • Acknowledge receipt of this letter to your respective RBI Regional Office via the Compliance Officer.
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 (State Co-operative Banks (StCBs), Central Co-operative Banks (CCBs), Compliance Officers of co-operative banks, Branch managers handling account opening), your first concrete step on “UN Terror List Updates for Co-op Banks: Dec 2009” is: “Update the consolidated list of terrorist individuals/entities with the three annexes provided in this circular.” (RBI issued this 15 Dec 2009).

  1. Circular: RBI/2009-10/255 -- UN Terror List Updates for Co-op Banks: Dec 2009
  2. Issued: 15 Dec 2009
  3. Action required: Update the consolidated list of terrorist individuals/entities with the three annexes provided in this circular.
  4. Action required: Screen all new account applications against the updated list before opening accounts.
  5. Action required: Scan all existing accounts to identify and freeze any linked to listed individuals/entities.
  6. Action required: Follow the freezing procedures outlined in paragraph 6 of the October 29, 2009 circular.
  7. Action required: Acknowledge receipt of this letter to your respective RBI Regional Office via the Compliance Officer.
  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.

💬 Banker Discussion

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=5418&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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