What changed
RBI has forwarded three UN Security Council 1267 Committee notes (dated September 3, 23, and October 22, 2009) containing amendments to the consolidated list of individuals/entities linked to Al-Qaida and Taliban. The amendments include deletions of entries, strike-through/underline changes, and an updated review of names, detailed in three annexes. Banks must now incorporate these changes into their screening processes.
What it means for you
Urban Co-operative Banks must immediately update their internal sanctions lists to reflect the latest UNSC amendments, ensuring no new accounts are opened for listed entities and existing accounts are scanned for matches. Non-compliance with the UAPA Order and RBI's freezing instructions could lead to regulatory action. This reinforces the ongoing obligation to maintain robust KYC/AML controls.
What you must do
- Update your bank's consolidated list of terrorist individuals/entities with the amendments in Annex I, II, and III of this circular.
- Screen all new account applications against the updated list before onboarding.
- Scan all existing accounts to identify any linked to or held by listed individuals/entities.
- Strictly follow the UAPA Order dated August 27, 2009, and the freezing procedures outlined in paragraph 6 of the November 16, 2009 circular.
- Acknowledge receipt of this circular to your respective RBI Regional Office via the Compliance Officer/Principal Officer.
Who it affects
All Primary (Urban) Co-operative Banks, Compliance Officers and Principal Officers of UCBs, KYC/AML teams in UCBs
What specific changes are being made to the terrorist list?
The circular includes three sets of amendments: (1) strike-through and underline changes to four entries plus a review update (Annex I); (2) deletion of one entry and changes to two entries plus a review update (Annex II); (3) deletion of four entries plus a review update (Annex III). Banks must refer to the annexes for exact details.
Do we need to freeze accounts immediately if a match is found?
Yes, but follow the specific freezing procedures detailed in paragraph 6 of RBI circular dated November 16, 2009 (UBD.CO.BPD.PCB.Cir.No.21/12.05.001/2009-10). This includes freezing funds, financial assets, or economic resources of designated individuals/entities.
Where can we find the full consolidated list?
The complete consolidated list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml. Banks should cross-reference this with the amendments provided by RBI.