What changed
The UN Security Council split its consolidated sanctions list into two: the Al-Qaida Sanctions List (maintained by the 1267/1989 Committee) and the 1988 Sanctions List (for Taliban-associated entities). RRBs must now check both lists separately when implementing Section 51A of UAPA, 1967.
What it means for you
RRBs face increased screening burden as they must cross-check customers against two distinct lists instead of one. Non-compliance risks penalties under UAPA. The circular reinforces existing obligations from the 2009 UAPA order, with no new procedural changes beyond the list split.
What you must do
- Update your internal sanctions database to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.
- Screen all new account applicants against both lists before account opening.
- Conduct a one-time scan of all existing accounts to identify any matches with either list.
- Ensure compliance with the UAPA Order dated August 27, 2009, as per earlier RBI circular.
- Have Compliance Officer/Principal Officer acknowledge receipt of this circular to the concerned RBI Regional Office.
Who it affects
All Regional Rural Banks (RRBs), Compliance Officers/Principal Officers of RRBs, Branch staff handling account opening and KYC
Why did the UN split the sanctions list?
The UN Security Council adopted Resolutions 1988 (2011) and 1989 (2011) to separate Taliban-related sanctions from Al-Qaida-related sanctions for clearer targeting.
Do we need to check only new accounts?
No, you must screen both new accounts before opening and all existing accounts to ensure no account is linked to any entity on either list.
What action is required if we find a match?
Follow the freezing procedure detailed in paragraph 6 of RBI circular RPCD.CO.RRB.No.39/03.05.33(E)/2009-10 dated November 5, 2009, as per the UAPA Order.