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 individuals and entities). RBI now requires all payment system operators to use both lists for compliance under Section 51A of UAPA, 1967.
What it means for you
Payment system operators must update their screening databases to include both new lists and cross-check all existing and new customers. Failure to identify a match could lead to regulatory action. The circular reinforces the government's procedure for freezing assets and reporting suspicious accounts.
What you must do
- Update your customer screening systems to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.
- Scan all existing accounts to ensure no account is held by or linked to any entity on either list.
- Before opening any new account, verify the proposed customer's name against both lists.
- Follow the freezing and reporting procedures detailed in the UAPA Order of August 27, 2009, and RBI circular of September 17, 2009.
- Ensure your nodal/principal officer acknowledges receipt of this circular.
Who it affects
All payment system operators authorized under the PSS Act, 2007, Compliance and AML teams at payment firms, Nodal officers and principal officers of PSOs
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 (for Taliban-associated individuals and entities). Both are available on the UN website.
Do I need to re-screen all existing customers?
Yes, the circular requires all payment system operators to scan all existing accounts to ensure no account is held by or linked to any entity or individual on either list.
What action should I take if I find a match?
Follow the freezing of funds and reporting procedures detailed in paragraph 6 of RBI's circular dated September 17, 2009, and the UAPA Order of August 27, 2009.