What changed
RBI has circulated eleven update notes from the UN Security Council's 1267/1989 Committee, dated between January 15 and March 25, 2013, along with a consolidated list as of April 8, 2013. Banks must update their internal lists and ensure compliance with the UAPA Order of August 27, 2009.
What it means for you
Banks must immediately update their customer screening databases with the latest UN sanctions list to avoid onboarding or maintaining accounts for designated terrorists or entities. Non-compliance could lead to regulatory action and reputational risk. The circular reinforces the need for rigorous AML/KYC checks.
What you must do
- Update your internal sanctions list with the eleven update notes and consolidated list provided by RBI.
- Screen all new account applications against the updated list before opening accounts.
- Scan all existing accounts to identify and freeze any linked to listed individuals or entities.
- Follow the freezing procedures outlined in paragraph 6 of the September 17, 2009 circular.
- Ensure the Compliance Officer acknowledges receipt of this circular.
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.
What action is required for existing accounts?
Banks must scan all existing accounts to ensure no account is held by or linked to any entity or individual on the updated list.
Where can I find the complete list?
The complete list is available on the UN website at the URLs provided in the circular.