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UCBs Must Screen Accounts Against Updated UN Terror List

Current · Source: Reserve Bank of India · RBI/2011-12/109 · issued 07 Jul 2011 · ~1 min read
Quick answerRBI has forwarded UN updates to the Al-Qaida/Taliban sanctions list. Urban co-operative banks must screen new and existing accounts against this list, freeze assets of designated entities per UAPA rules, and confirm receipt to their regional office.
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 co-operative bank branch officer in Indore, Priya, receives the updated UN list from RBI. Before approving a new gold loan for a customer, she checks the customer's name against the list. She also runs a scan of all existing loan accounts and finds one linked to a newly listed entity. She immediately freezes that account, following the UAPA freezing procedure, and then sends an acknowledgment to her RBI regional office.

What changed

RBI circulated eight new UN notes (May-June 2011) updating the consolidated list of individuals and entities linked to Al-Qaida and Taliban under UNSCR 1267/1822. This updates the list referenced in the May 11, 2011 circular. Banks must now use this updated list for all customer screening.

What it means for you

UCBs face heightened compliance burden to ensure no account is linked to newly added terrorist entities. Failure to screen or freeze assets could lead to regulatory action. The circular reinforces that existing account scanning is mandatory, not optional, and must follow the UAPA Order dated August 27, 2009.

What you must do

Who it affects

All Primary (Urban) Co-operative Banks, Compliance Officers and Principal Officers of UCBs, Branch managers handling account opening and KYC

❓ Common questions

What is the source of the updated list?

The list comes from UN Security Council Committee 1267, forwarded via Government of India Ministry of External Affairs notifications dated May-June 2011.

Do we need to freeze accounts immediately?

Yes, for any designated individual/entity found in your records, you must freeze funds and assets as per the procedure in paragraph 6 of the November 16, 2009 circular.

Where can we find the full consolidated list?

The complete list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml.

📜 Read the original circular — full text as issued by RBI
RBI/2011-12/109 UBD.CO.BPD (PCB) Cir.No.1/14.01.062/2011-12 July 07, 2011 The Chief Executive Officer of All Primary (Urban) Co-operative Banks Madam/Dear Sir, List of Terrorist Individuals /Organisations under UNSCR 1267 (1999) and 1822 (2008) on Taliban/Al-Qaida Organisation Please refer to our circular UBD.CO. BPD (PCB).Cir.No.48/14.01.062/2010-11 dated May 11, 2011 . We enclose, as detailed below, copies of notification (received from Government of India – Ministry of External Affairs) of 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: Note dated May 04, 2011 Note dated May 11, 2011 Note dated May 16, 2011 Note dated May 27, 2011 Note dated June 10, 2011 Note dated June 15, 2011 Note dated June 16, 2011 Note dated June 23, 2011 2. Urban Co-operative Banks are required to update the consolidated list of individuals/entities as circulated by the 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. Urban Co-operative Banks are advised to strictly follow the procedure laid down in the UAPA Order dated August 27, 2009 enclosed to our circular UBD.CO.BPD. PCB.Cir. No. 21/12.05.001/2009-10 dated November 16, 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 November 16, 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. The Compliance Officer/Principal Officer of the Urban Co-operative Bank should acknowledge receipt of this circular to our Regional Office. Yours faithfully, (L. M. Kamble) General Manager Encl: As above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/109 · issued 07 Jul 2011. The plain-English explanation above is BankPulse’s own independent summary.
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Who does what — compliance checklist
🏦 Branch Manager
  • Screen all new account openings against the updated consolidated list before onboarding.
📜 Compliance
  • Update your internal UNSCR 1267 list with the eight new notes dated May-June 2011.
  • Scan all existing accounts to identify and freeze any linked to newly listed individuals/entities.
  • Follow the freezing procedure detailed in paragraph 6 of the November 16, 2009 circular.
  • Acknowledge receipt of this circular to your RBI Regional Office via the Compliance/Principal Officer.
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 Primary (Urban) Co-operative Banks, Compliance Officers and Principal Officers of UCBs, Branch managers handling account opening and KYC), your first concrete step on “UCBs Must Screen Accounts Against Updated UN Terror List” is: “Update your internal UNSCR 1267 list with the eight new notes dated May-June 2011.” (RBI issued this 07 Jul 2011).

  1. Circular: RBI/2011-12/109 -- UCBs Must Screen Accounts Against Updated UN Terror List
  2. Issued: 07 Jul 2011
  3. Action required: Update your internal UNSCR 1267 list with the eight new notes dated May-June 2011.
  4. Action required: Screen all new account openings against the updated consolidated list before onboarding.
  5. Action required: Scan all existing accounts to identify and freeze any linked to newly listed individuals/entities.
  6. Action required: Follow the freezing procedure detailed in paragraph 6 of the November 16, 2009 circular.
  7. Action required: Acknowledge receipt of this circular to your RBI Regional Office via the Compliance/Principal Officer.
  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=6605&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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