What changed
RBI issued a circular on July 6, 2012, requiring all authorized payment system operators to update the UN Al-Qaida sanctions list based on a Government of India notification. Operators must ensure no new accounts are opened for listed individuals/entities and scan existing accounts for matches.
What it means for you
Banks and payment operators must integrate these sanctions lists into their account opening and monitoring processes to comply with anti-terror financing laws. Non-compliance could lead to regulatory action, and operators need to align with the UAPA Order of August 27, 2009, for freezing assets.
What you must do
- Update your internal sanctions list with the latest UN Al-Qaida list from the UN website.
- Screen all new account applications against the updated list before opening accounts.
- Review all existing accounts to identify any linked to listed individuals or entities.
- Freeze funds and assets of matched accounts as per paragraph 6 of the September 17, 2009 circular.
- Ensure nodal officer acknowledges receipt of this circular.
Who it affects
All payment system operators authorized under PSS Act, 2007, Banks offering payment services, Compliance and AML teams
What is the source of the sanctions list I need to use?
The list is the UN Security Council's Al-Qaida Sanctions List, available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
What action should I take if I find a match in existing accounts?
You must freeze the funds, financial assets, or economic resources of the matched account, following the procedure in paragraph 6 of RBI circular DBOD.AML.BC. No. 44/14.01.001/2009-10 dated September 17, 2009.
Does this circular replace earlier instructions?
No, it updates the list referenced in circular DPSS.CO.AD.No. 2218 /02.27.005/2011-12 dated June 7, 2012, and reinforces compliance with the UAPA Order of August 27, 2009.