What changed
RBI has circulated updates to the UN Al-Qaida Sanctions List based on multiple notes from the UN Security Council's 1267/1989 Committee received between April and May 2012. Payment System Operators must now incorporate these changes into their customer screening processes.
What it means for you
Banks and payment operators must immediately update their internal sanctions lists and verify that no new or existing customer accounts are linked to the newly designated individuals or entities. Failure to comply could lead to regulatory action and reputational risk.
What you must do
- Update your internal sanctions database with the latest UN Al-Qaida Sanctions List from the UN website.
- Screen all new account applications against the updated list before opening accounts.
- Conduct a retrospective scan of all existing accounts to identify any matches with the updated list.
- Follow the freezing procedures outlined in RBI circular DBOD.AML.BC. No. 44/14.01.001/2009-10 dated September 17, 2009 for any matched accounts.
- Ensure your nodal officer acknowledges receipt of this circular.
Who it affects
All Payment System Operators authorized under the PSS Act, 2007, Banks offering payment services, Compliance and AML teams
What is the source of the updated sanctions list?
The list is the UN Al-Qaida Sanctions List maintained by the UN Security Council's 1267/1989 Committee, and the updates were communicated via notes from the Ministry of External Affairs.
What action is required if we find a match in existing accounts?
You must freeze the funds, financial assets, or economic resources of the designated individual or entity as per the procedure in paragraph 6 of RBI circular dated September 17, 2009.
Where can we access the full sanctions list?
The complete list is available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.