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
- Update your internal UNSCR 1267 list with the eight new notes dated May-June 2011.
- Screen all new account openings against the updated consolidated list before onboarding.
- 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.
Who it affects
All Primary (Urban) Co-operative Banks, Compliance Officers and Principal Officers of UCBs, Branch managers handling account opening and KYC
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.