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UNSC 1267/1822 Terror List Update: Compliance Mandate for Banks

Current · Source: Reserve Bank of India · RBI/2009-10/373 · issued 31 Mar 2010 · ~2 min read
Quick answerRBI mandates banks to update the UNSC 1267/1822 consolidated list of terrorist individuals/entities, screen new and existing accounts against it, and follow UAPA Order procedures for freezing assets. Compliance Officer must acknowledge receipt.
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 KYC & compliance officer in Indore receives this RBI circular. She immediately updates her bank's internal terrorist list with the new UN changes. Before approving a new gold loan, she screens the applicant's name against the list and finds no match. She also runs a scan of all existing gold-loan accounts and finds one linked to a listed entity, so she freezes that account following the September 2009 procedures.

What changed

RBI forwarded a March 25, 2010 UN Security Council 1267 Committee note with changes to the consolidated list of Al-Qaida/Taliban-linked individuals and entities. Banks must update their records from the previous circular (March 18, 2010) and ensure no account is linked to the revised list.

What it means for you

Banks must immediately update their internal sanctions lists with the latest UNSC changes and screen all new account openings against it. Existing accounts must be scanned to identify and report any matches. Freezing of funds and assets must follow the procedures in the September 17, 2009 circular, ensuring strict compliance with the UAPA Order.

What you must do

Who it affects

All Scheduled Commercial Banks (excluding RRBs), Local Area Banks, All India Financial Institutions

❓ Common questions

What is the source of the updated list?

The list is from the UN Security Council's 1267 Committee, forwarded by the Ministry of External Affairs via a note dated March 25, 2010. The full list is on the UN website.

What actions are required for existing accounts?

Banks must scan all existing accounts to ensure none are held by or linked to any entity or individual on the updated consolidated list.

What is the procedure for freezing assets?

Freezing of funds, financial assets, or economic resources must follow the steps in paragraph 6 of RBI's September 17, 2009 circular, which implements the UAPA Order.

📜 Read the original circular — full text as issued by RBI
RBI/2009-10/373 DBOD. AML.No.16740/14.06.064/2009-10 March 31, 2010 The Chairmen / CEOs of all Scheduled Commercial Banks (Excluding RRBs)/ Local Area Banks / All India Financial Institutions Dear Sir, List of Terrorist Individuals/ Organisations - under UNSCR 1267(1999) and 1822(2008) on Taliban/Al-Qaida Organisation Please refer to our circular letter DBOD. AML.No.16000/14.06.063/2009-10 dated March 18, 2010.  We have since received from Government of India (Ministry of External Affairs) copy of note dated March 25, 2010 (copy enclosed) 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. 2. Banks/All India 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 DBOD.AML.BC. No. 44/14.01.001/2009-10 dated September 17, 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 September 17, 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. Compliance Officer/Principal Officer should acknowledge receipt of this circular letter. Yours faithfully, (Vinay Baijal) Chief General Manager Encl: As above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2009-10/373 · issued 31 Mar 2010. 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 internal consolidated list of terrorist individuals/entities with the latest UNSC 1267 Committee changes from the March 25, 2010 note.
  • Scan all existing accounts to identify any linked to listed individuals/entities and report findings.
  • Follow the freezing procedures detailed in paragraph 6 of the September 17, 2009 circular for any matched accounts.
  • Ensure Compliance Officer/Principal Officer acknowledges receipt of this circular.
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 Scheduled Commercial Banks (excluding RRBs), Local Area Banks, All India Financial Institutions), your first concrete step on “UNSC 1267/1822 Terror List Update: Compliance Mandate for Banks” is: “Update your internal consolidated list of terrorist individuals/entities with the latest UNSC 1267 Committee changes from the March 25, 2010 note.” (RBI issued this 31 Mar 2010).

  1. Circular: RBI/2009-10/373 -- UNSC 1267/1822 Terror List Update: Compliance Mandate for Banks
  2. Issued: 31 Mar 2010
  3. Action required: Update your internal consolidated list of terrorist individuals/entities with the latest UNSC 1267 Committee changes from the March 25, 2010 note.
  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 and report findings.
  6. Action required: Follow the freezing procedures detailed in paragraph 6 of the September 17, 2009 circular for any matched accounts.
  7. Action required: Ensure Compliance Officer/Principal Officer acknowledges receipt of this circular.
  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=5559&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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