What changed
RBI forwarded a corrigendum from the Government of India (Ministry of External Affairs) regarding a technical error in the Arabic script of one name in the UN Security Council's 1267 Committee list. The error was in the entry for Al-Qaida in the Arabian Peninsula (AQAP) (QE.A.129.10) from the note dated January 19, 2010. This circular updates the previous circular UBD (PCB) CO.BPD. Cir.No. 43 /14.01.062/2009-10 dated February 9, 2010.
What it means for you
UCBs must immediately incorporate the corrected Arabic script into their screening systems to avoid misidentification or non-compliance with UN sanctions. Failure to update records could lead to regulatory action for not adhering to anti-terrorist financing measures. This is a routine but critical update to ensure accuracy in sanctions screening.
What you must do
- Update your internal terrorist list database with the corrected Arabic script for the AQAP entry.
- Re-screen existing customers and transactions against the corrected list to identify any matches.
- Ensure compliance with UNSCR 1267 and 1822 requirements by reporting any matches to the Financial Intelligence Unit (FIU-IND).
- Acknowledge receipt of this circular and confirm action taken to the concerned RBI regional office.
Who it affects
All Primary (Urban) Co-operative Banks (UCBs), Compliance and AML/KYC teams at UCBs, Branches handling international transactions or remittances
What is the significance of the Arabic script correction?
The correction fixes a technical error in the Arabic script of the name for Al-Qaida in the Arabian Peninsula (AQAP) in the UN sanctions list. Accurate script is essential for proper name matching in screening systems to avoid false positives or missed hits.
Do we need to re-screen all existing customers?
Yes, you should re-screen existing customers and transactions against the corrected list to ensure no matches were missed due to the earlier error. This is a standard precaution for sanctions compliance.
What happens if we don't update our records?
Non-compliance with UNSCR 1267 and 1822 can lead to regulatory penalties, including fines or restrictions on operations. It also increases the risk of facilitating terrorist financing.