What changed
RBI forwarded two new UN 1267 Committee notes (dated July 28 and July 30, 2010) with changes to the consolidated list of terrorist individuals/entities. This updates the previous circular of July 29, 2010. Banks must now use this latest list for customer screening.
What it means for you
UCBs must immediately incorporate the updated UN sanctions list into their account opening and monitoring processes. Failure to screen and freeze accounts of designated entities could lead to regulatory action. This reinforces the government's UAPA order compliance requirements.
What you must do
- Update your internal database with the latest UN 1267 consolidated list from the UN website.
- Screen all new account applications against the updated list before opening accounts.
- Run a one-time scan of all existing accounts to identify any matches with the updated list.
- Freeze funds and financial assets of any matched individuals/entities as per the November 16, 2009 circular's paragraph 6.
- Acknowledge receipt of this circular to your respective RBI Regional Office.
Who it affects
All Primary (Urban) Co-operative Banks, Compliance Officers / Principal Officers of UCBs, Branch managers handling account opening and KYC
Where can we find the latest consolidated list?
The complete list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml.
What action is required for existing accounts that match the list?
You must freeze the funds, financial assets, or economic resources held in such accounts, following the procedure detailed in paragraph 6 of the November 16, 2009 circular.
Do we need to report compliance to RBI?
Yes, the Compliance Officer or Principal Officer must acknowledge receipt of this circular to the concerned RBI Regional Office.