What changed
The UN Security Council adopted Resolutions 1988 and 1989, splitting the earlier consolidated list of individuals and entities linked to Al-Qaida and Taliban into two separate lists: the 'Al-Qaida Sanctions List' and the '1988 Sanctions List'. Both lists are now relevant for implementing Section 51A of UAPA, 1967.
What it means for you
Co-operative banks must now check against two distinct UN sanctions lists instead of one consolidated list. This increases the compliance burden slightly but ensures alignment with updated international sanctions. Banks must update their internal screening databases and ensure no accounts are linked to any entity on either list.
What you must do
- Update your internal sanctions screening systems to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.
- Before opening any new account, verify the proposed customer's name against both lists.
- Scan all existing accounts to identify and freeze any accounts linked to individuals or entities on either list.
- Follow the procedure laid down in the UAPA Order dated August 27, 2009, and our earlier circular of October 29, 2009.
- Acknowledge receipt of this circular to your respective RBI Regional Office through the Compliance Officer/Principal Officer.
Who it affects
State Co-operative Banks, Central Co-operative Banks, Compliance Officers / Principal Officers of co-operative banks
What are the two new sanctions lists I need to check?
The Al-Qaida Sanctions List (maintained by the 1267/1989 Committee) and the 1988 Sanctions List (maintained by the 1988 Committee). Both are available on the UN website.
Do I need to check only new accounts or existing ones too?
Both. You must screen all new accounts before opening and also scan all existing accounts to ensure no account is held by or linked to any entity on either list.
What action should I take if I find a match?
Follow the freezing procedure detailed in paragraph 6 of our circular dated October 29, 2009, and the UAPA Order of August 27, 2009.