What changed
RBI has forwarded five new UN Security Council notes (dated September 5, 27, October 4, 5, and 18, 2012) that update the Al-Qaida Sanctions List. Banks must incorporate these changes into their screening lists immediately.
What it means for you
Banks must update their internal sanctions databases with the latest UN Al-Qaida designations to avoid onboarding or servicing prohibited entities. Non-compliance could lead to regulatory action and reputational risk. The circular reinforces the existing UAPA framework for freezing assets of listed individuals/entities.
What you must do
- Update your internal sanctions list with the new UN Al-Qaida entries from the five MEA notes received.
- Screen all new account applications against the updated list before account opening.
- Run a fresh scan of all existing accounts to identify any matches with the updated list.
- Follow the freezing procedures outlined in paragraph 6 of the September 17, 2009 circular for any matches found.
- Ensure your Compliance Officer acknowledges receipt of this circular to RBI.
Who it affects
All Scheduled Commercial Banks (excluding RRBs), Local Area Banks, All India Financial Institutions
What is the source of the updated list?
The updates come from the UN Security Council's 1267/1989 Committee's Al-Qaida Sanctions List, forwarded by the Ministry of External Affairs via five notes dated between September 5 and October 18, 2012.
Do I need to freeze accounts immediately if a match is found?
Yes. For any designated individual or entity found in your accounts, you must take action as detailed in paragraph 6 of RBI's circular dated September 17, 2009, which covers freezing of funds, financial assets, or economic resources.
Where can I 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.