What changed
RBI issued a circular on June 27, 2011, requiring PSOs to incorporate the latest UN Security Council 1267 Committee list changes into their customer screening process. This builds on a previous circular from June 22, 2011, and aligns with Government of India's communication from June 10, 2011.
What it means for you
PSOs must now proactively check all new and existing customers against the updated UN terror list. Non-compliance with the UAPA Order and RBI's AML guidelines could lead to regulatory action. This tightens the noose on financial channels used by designated terrorist entities.
What you must do
- Update your internal consolidated list of designated individuals/entities with the latest UN 1267 Committee changes.
- Screen all new customers against this list before opening accounts or offering services.
- Scan all existing accounts to identify and flag any linked to listed entities or individuals.
- Follow the freezing procedures outlined in paragraph 6 of RBI circular DBOD.AML.BC. No. 44/14.01.001/2009-10 dated September 17, 2009.
- Ensure your Nodal/Principal Officer acknowledges receipt of this circular.
Who it affects
All payment system operators authorised under the PSS Act, 2007, Compliance and AML teams at PSOs, Nodal/Principal Officers of PSOs
What is the source of the list I need to screen against?
The consolidated list is maintained by the UN Security Council's 1267 Committee and is available on their website. RBI circulates updates to PSOs based on Government of India inputs.
What actions must I take if I find a match in existing accounts?
You must follow the freezing of funds, financial assets, or economic services as detailed in paragraph 6 of RBI's September 17, 2009 circular, which implements the UAPA Order.
Does this apply only to new customers?
No, it applies to both new and existing customers. You must screen new customers before onboarding and also scan all existing accounts for any links to the listed entities.