What changed
RBI forwarded a January 26, 2010 note from the UN Security Council's 1267 Committee with changes to the consolidated list of individuals and entities linked to Al-Qaida and Taliban. This supersedes the previous lists circulated via circulars dated February 9 and 10, 2010.
What it means for you
UCBs must immediately update their internal sanctions screening databases with the revised UN list. Failure to identify and freeze accounts of designated entities could lead to regulatory action and reputational risk. The circular reinforces the mandatory compliance with the UAPA Order of August 27, 2009.
What you must do
- Update your internal consolidated list of UNSCR 1267/1822 designated individuals/entities with the latest changes from the UN website.
- Screen all new account openings against the updated list before onboarding any customer.
- Conduct a fresh scan of all existing accounts to identify any matches with the revised list.
- Freeze funds, financial assets, or economic resources of any 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 Officer/Principal Officer.
Who it affects
All Primary (Urban) Co-operative Banks, Compliance Officers and Principal Officers of UCBs, Branch managers handling account opening and KYC
Where can I find the latest consolidated list?
The complete consolidated list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml. RBI has also enclosed a copy of the UN note with changes dated January 26, 2010.
What action is required if we find a match in an existing account?
You must immediately freeze the funds, financial assets, or economic resources held in that account, 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.
Do we need to acknowledge receipt of this circular?
Yes, the Compliance Officer or Principal Officer of the bank must acknowledge receipt of this circular to the concerned RBI Regional Office.