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UCBs: Update UN Terrorist List for Account Screening

Current · Source: Reserve Bank of India · RBI/2009-10/259 · issued 17 Dec 2009 · ~2 min read
Quick answerRBI directs all Primary Urban Co-operative Banks to update the UNSC 1267/1822 consolidated list of terrorist individuals/entities. Banks must screen new and existing accounts against this list and comply with UAPA freezing orders.
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

Priya, a compliance officer at a primary urban co-operative bank in Pune, receives this RBI circular. She immediately updates the bank's internal database with the latest UN terrorist list. Later that day, when a new customer applies for a savings account, Priya screens the name against the updated list and finds no match, so she approves the account opening. She also runs a scan of all existing accounts and finds one account linked to a newly listed entity; she promptly freezes the funds in that account as per the UAPA procedures.

What changed

RBI has forwarded a fresh update from the UN Security Council's 1267 Committee (dated December 3, 2009) to the consolidated list of individuals and entities linked to Al-Qaida and Taliban. This supersedes the previous circular of December 16, 2009, and requires banks to incorporate the latest changes into their screening process.

What it means for you

UCBs must immediately update their internal databases with the revised UN list to ensure no new account is opened for a listed entity or individual. Existing accounts must be scanned for matches, and if found, banks must freeze funds and assets as per the UAPA Order procedures outlined in earlier RBI circulars. Non-compliance could lead to regulatory action.

What you must do

Who it affects

All Primary (Urban) Co-operative Banks, Compliance Officers and Principal Officers of UCBs, Branch managers handling account opening and KYC

❓ Common questions

What is the source of the updated list?

The list is the Consolidated List of individuals and entities linked to Al-Qaida and Taliban, maintained by the UN Security Council's 1267 Committee. The latest changes were communicated via a note dated December 3, 2009, from the Chairman of that committee.

What action is required if an existing account matches the list?

Banks must freeze the funds, financial assets, or economic resources held in such accounts, following the procedure detailed in paragraph 6 of RBI circular UBD.CO.BPD.PCB.Cir.No.21/12.05.001/2009-10 dated November 16, 2009.

Where can we access the full consolidated list?

The complete list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml. Banks should refer to this for the most current version.

📜 Read the original circular — full text as issued by RBI
RBI/2009-10/259 UBD (PCB) CO.BPD. Cir. No.32 /14.01.062/2009-10 December 17, 2009 The Chief Executive Officers of All Primary (Urban) Co-operative Banks Dear Sir / Madam, List of Terrorist individuals/organizations –under UNSCR 1267 (1999) and 1822 (2008) on Taliban/Al-Qaida organisation Please refer to our circular UBD (PCB) CO.BPD.Cir.No.31/14.01.062/2009-10 dated December 16, 2009 on the above subject. We have since received from Government of India (Ministry of External Affairs) copy of note dated December 3, 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 (copy enclosed). 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 UBD.CO.BPD.PCB.Cir.No.21/12.05.001/2009-10 dated November 16, 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 November 16, 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.  The Compliance Officer / Principal Officer of the bank should acknowledge receipt of this circular to our Regional Office concerned. Yours faithfully (Monisha Chakraborty) Deputy General Manager Encl: As above.
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2009-10/259 · issued 17 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 your bank's consolidated list of terrorist individuals/entities with the latest UNSC 1267 Committee changes (December 3, 2009).
  • Scan all existing accounts to identify any linked to listed individuals/entities.
  • Freeze funds, financial assets, or economic resources of matched accounts as per paragraph 6 of the November 16, 2009 circular.
  • Acknowledge receipt of this circular to your respective RBI Regional Office through the Compliance/Principal 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 (All Primary (Urban) Co-operative Banks, Compliance Officers and Principal Officers of UCBs, Branch managers handling account opening and KYC), your first concrete step on “UCBs: Update UN Terrorist List for Account Screening” is: “Update your bank's consolidated list of terrorist individuals/entities with the latest UNSC 1267 Committee changes (December 3, 2009).” (RBI issued this 17 Dec 2009).

  1. Circular: RBI/2009-10/259 -- UCBs: Update UN Terrorist List for Account Screening
  2. Issued: 17 Dec 2009
  3. Action required: Update your bank's consolidated list of terrorist individuals/entities with the latest UNSC 1267 Committee changes (December 3, 2009).
  4. Action required: Screen all new account applications against the updated list before opening accounts.
  5. Action required: Scan all existing accounts to identify any linked to listed individuals/entities.
  6. Action required: Freeze funds, financial assets, or economic resources of matched accounts as per paragraph 6 of the November 16, 2009 circular.
  7. Action required: Acknowledge receipt of this circular to your respective RBI Regional Office through the Compliance/Principal 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.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=5422&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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