What changed
RBI circulated 11 update notes from the UN Security Council's 1267/1989 Committee (dated Jan 15 to Mar 25, 2013) and a consolidated list (April 8, 2013) to RRBs and co-op banks. This updates the previous circular of December 13, 2012, requiring banks to refresh their sanctions screening databases.
What it means for you
RRBs and co-op banks must immediately update their internal sanctions lists with the new UN entries to avoid onboarding or maintaining accounts of designated individuals/entities. Non-compliance with UAPA screening and freezing obligations could lead to regulatory action. This reinforces the need for robust AML/KYC systems in smaller banks.
What you must do
- Update your sanctions screening database with the 11 update notes and consolidated list from the UN website.
- Screen all new account applications against the updated list before opening accounts.
- Scan all existing accounts to identify any matches with the updated sanctions list.
- Follow UAPA freezing procedures as per RBI circulars of Oct 29, 2009 and Nov 5, 2009 for any matches.
- Acknowledge receipt of this circular to your RBI Regional Office via the Compliance Officer.
Who it affects
Regional Rural Banks (RRBs), State Co-operative Banks, Central Co-operative Banks, Compliance Officers of these banks
What lists do I need to update?
You need to incorporate 11 update notes from Jan-Mar 2013 and the consolidated list received on April 8, 2013, from the UN 1267/1989 Committee's Al-Qaida Sanctions List.
Do I need to screen existing accounts?
Yes, the circular requires scanning all existing accounts to ensure no account is linked to any individual or entity on the updated list.
What if I find a match?
Follow the freezing procedures detailed in paragraph 6 of RBI circulars dated Oct 29, 2009 and Nov 5, 2009, as per the UAPA Order of Aug 27, 2009.