What changed
RBI received from the Government of India, Ministry of External Affairs, UNP Division, copies of notes dated March 6, 12, 14, 21, and April 2, 13, 2012, from the Chairman of the UN Security Council's 1267/1989 Committee regarding changes to the Al-Qaida Sanctions List. Payment System Operators must now incorporate these changes into their customer screening processes.
What it means for you
Banks and payment operators must cross-check every new account opening against the updated list and review all existing accounts for any matches. Non-compliance with the UAPA 1967 and RBI's 2009 circular could lead to regulatory action. This reinforces the government's commitment to counter-terrorism financing.
What you must do
- Update your internal sanctions list with the latest UN Al-Qaida list from the provided UN website.
- Screen all new account applications against the updated list before opening accounts.
- Conduct a one-time review of all existing accounts to identify and freeze any linked to listed individuals or entities.
- Follow the freezing procedures outlined in paragraph 6 of RBI circular DBOD.AML.BC. No. 44/14.01.001/2009-09 dated September 17, 2009.
- Ensure your nodal officer acknowledges receipt of this circular to RBI.
Who it affects
All Payment System Operators authorized under PSS Act, 2007, Banks offering payment services, Compliance and AML teams at financial institutions
What is the source of the updated sanctions list?
The list is maintained by the UN Security Council's 1267/1989 Committee and is available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
What should we do if we find an existing account linked to a listed entity?
You must freeze the funds, financial assets, or economic resources in that account as per the procedures detailed in paragraph 6 of RBI's circular dated September 17, 2009.
Is this a one-time requirement or ongoing?
This is an ongoing obligation. You must update your lists whenever RBI circulates changes and screen new accounts continuously. The current circular requires an immediate update based on the latest UN changes.