What changed
The UN Security Council's 1267 Committee consolidated list of individuals and entities linked to Al-Qaida and Taliban has been split into two distinct lists: the 'Al-Qaida Sanctions List' (maintained by the 1267/1989 Committee) and the '1988 Sanctions List' (maintained by the 1988 Committee). Banks must now refer to both separate lists for compliance under Section 51A of UAPA, 1967, instead of the earlier single consolidated list.
What it means for you
Banks and financial institutions must update their screening databases to include both new lists separately. Before opening any new account, customer names must be verified against both the Al-Qaida and Taliban sanctions lists. Existing accounts must also be scanned to ensure no account is linked to any entity or individual on either list. Failure to comply could lead to regulatory action under UAPA.
What you must do
- Update your AML/KYC screening systems to include both the 'Al-Qaida Sanctions List' and the '1988 Sanctions List' as separate reference lists.
- Before opening any new account, verify the proposed customer's name against both lists.
- Conduct a one-time scan of all existing accounts to identify any matches with either list.
- Ensure your compliance officer acknowledges receipt of this circular and maintains records of compliance.
- Strictly follow the procedure laid down in the UAPA Order dated August 27, 2009, as referenced in earlier RBI circulars.
Who it affects
All Scheduled Commercial Banks (excluding RRBs), Local Area Banks, All India Financial Institutions, Compliance Officers and Principal Officers of banks, AML/KYC teams
What are the two new lists I need to check against?
The first is the 'Al-Qaida Sanctions List' maintained by the 1267/1989 Committee, and the second is the '1988 Sanctions List' maintained by the 1988 Committee. Both are available on the UN website at the URLs provided in the circular.
Do I need to check existing accounts as well?
Yes, the circular explicitly requires banks to scan all existing accounts to ensure no account is held by or linked to any entity or individual included in either of the two lists.
What action should I take if I find a match?
You must follow the freezing procedure detailed in paragraph 6 of RBI circular DBOD.AML.BC. No. 44/14.01.001/2009-10 dated September 17, 2009, which includes freezing funds, financial assets, or economic resources held in bank accounts of designated individuals/entities.