What changed
RBI issued a circular on September 2, 2011, updating the consolidated list of individuals and entities linked to Al-Qaida under UN Security Council resolutions. Three new notes from the UN 1267 Committee (dated July 29, August 12, and August 22, 2011) were enclosed as annexes. Banks must now incorporate these changes into their screening processes.
What it means for you
Co-operative banks must immediately update their internal sanctions lists to include the newly designated individuals/entities. Failure to screen new accounts or review existing ones against this list could lead to regulatory action. The circular reinforces the existing UAPA Order of August 27, 2009, and the freezing procedures from the October 29, 2009 circular.
What you must do
- Update your consolidated list of UNSCR 1267 designated individuals/entities with the three new annexes provided.
- Screen all new account applications against the updated list before opening accounts.
- Scan all existing accounts to identify any linked to newly listed individuals/entities.
- Follow the freezing procedures outlined in paragraph 6 of the October 29, 2009 circular for any matches.
- Ensure your Compliance Officer/Principal Officer acknowledges receipt of this circular to the concerned RBI Regional Office.
Who it affects
State Co-operative Banks, Central Co-operative Banks, Compliance Officers/Principal Officers of co-operative banks
What is the source of the updated list?
The list is based on notes from the UN Security Council's 1267 Committee, forwarded by the Government of India (Ministry of External Affairs). The full consolidated list is available on the UN website.
Do we need to check only new accounts or existing ones too?
Both. The circular explicitly requires banks to ensure new account names are not on the list and to scan all existing accounts for any links to listed individuals or entities.
What action is required if we find a match?
You must follow the freezing procedures detailed in paragraph 6 of RBI's circular dated October 29, 2009, which implements the UAPA Order of August 27, 2009.