What changed
RBI received eight UN Security Council notes (dated Aug 6 to Dec 17, 2010) with changes to the consolidated list of individuals/entities linked to Al-Qaida and Taliban. Banks must incorporate these updates into their screening processes immediately.
What it means for you
Banks face heightened compliance risk—any failure to screen new or existing accounts against the updated list could lead to regulatory action. Freezing of funds must follow the detailed steps in RBI's September 17, 2009 circular. This is a recurring obligation; expect periodic list updates.
What you must do
- Update your internal sanctions list with the eight new UN notes (Annex I–VIII) from the circular.
- Screen all new account applications against the updated list before onboarding.
- Run a one-time scan of all existing accounts to identify any matches with the list.
- For any matched accounts, freeze funds/assets as per paragraph 6 of the September 17, 2009 circular.
- Ensure your Compliance Officer/Principal Officer acknowledges receipt of this circular to RBI.
Who it affects
All Scheduled Commercial Banks (excluding RRBs), Local Area Banks, All India Financial Institutions
What is the source of the updated list?
The list comes from UN Security Council Resolution 1267 (1999) and 1822 (2008) via the Government of India (Ministry of External Affairs). RBI has forwarded eight notes from the UN 1267 Committee with changes.
Do I need to freeze accounts immediately if a match is found?
Yes, but follow the specific procedure in paragraph 6 of RBI's circular dated September 17, 2009 (DBOD.AML.BC. No. 44/14.01.001/2009-10), which details freezing of funds, financial assets, or economic resources.
How often will this list be updated?
The circular covers eight updates from August to December 2010. RBI will continue to forward changes from the UN 1267 Committee as received from the Government of India.