What changed
RBI issued a circular on January 20, 2012, enclosing the Ministry of External Affairs order implementing UN Security Council Resolution 1929 (2010) on non-proliferation. Banks are now required to cross-check all new account openings and existing account transactions against the listed individuals/entities and report any matches.
What it means for you
Banks must integrate the UNSCR 1929 sanctions list into their KYC and transaction monitoring systems to identify and report matches. Non-compliance could lead to regulatory action, as this is a direct instruction from RBI and FIU-IND.
What you must do
- Cross-check all new account applications and existing account transactions against the individuals/entities listed in the Gazette of India dated November 4, 2011.
- Report any accounts resembling listed individuals/entities to RBI and Financial Intelligence Unit-India immediately.
- Ensure the Compliance Officer/Principal Officer acknowledges receipt of this circular.
- Update internal AML/sanctions screening systems to include the UNSCR 1929 list.
Who it affects
All Scheduled Commercial Banks (excluding RRBs), Local Area Banks, Financial Institutions
What is the source of the sanctions list I need to screen against?
The list is from the Ministry of External Affairs order dated November 4, 2011, published in the Gazette of India, implementing UN Security Council Resolution 1929 (2010) on non-proliferation.
What should I do if I find a match with the listed individuals/entities?
You must report those accounts to both the Reserve Bank of India and the Financial Intelligence Unit-India as per the circular.
Does this apply to existing accounts as well?
Yes, the circular requires cross-checking both new account opening applications and transactions carried out in existing accounts.