What changed
RBI has forwarded updates to the UN Al-Qaida Sanctions List from September 5, 27; October 4, 5, 18; November 15, 23, 26, 27; and December 5, 2012, as received from the Ministry of External Affairs. 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 screen all new and existing accounts against the revised UN list. Failure to identify and freeze assets of listed entities could lead to regulatory action under UAPA.
What you must do
- Update your internal sanctions database with the latest UN Al-Qaida list changes from September-December 2012 (specific dates: Sep 5, 27; Oct 4, 5, 18; Nov 15, 23, 26, 27; Dec 5, 2012).
- Screen all new account applications against the updated list before onboarding.
- Review all existing accounts to identify any matches with the updated list.
- Freeze funds and assets of any matched individuals/entities as per RBI's circular dated September 17, 2009.
- Ensure nodal officers acknowledge receipt of this circular.
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 from the UN Security Council's 1267/1989 Committee Al-Qaida Sanctions List, 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 listed individuals/entities, and freeze any related funds or assets.
Where can I find the complete sanctions list?
The full list is available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.