What changed
RBI issued a circular on September 6, 2012, updating the Al-Qaida sanctions list based on UN Security Council changes from June-July 2012. It requires PSOs to update their records and ensure no new or existing accounts are linked to listed individuals or entities.
What it means for you
Banks and payment operators must integrate this updated list into their customer onboarding and ongoing monitoring processes. Non-compliance could lead to regulatory action, as the directive ties into the UAPA, 1967, and RBI's AML framework.
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.
- Scan all existing customer accounts to identify and flag any matches with the list.
- Follow the freezing procedures outlined in paragraph 6 of RBI circular DBOD.AML.BC. No. 44/14.01.001/2009-10 for any matches.
- 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 the UN Security Council's 1267/1989 Committee's Al-Qaida Sanctions List, updated as of June-July 2012, and forwarded by the Ministry of External Affairs.
What actions are required for existing accounts?
PSOs must scan all existing accounts to ensure none are held by or linked to individuals or entities on the updated list, and freeze any such accounts as per the 2009 circular's paragraph 6.
Where can I find 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.