What changed
RBI issued this circular to communicate the 22nd update of the UNSCR 1267/1989 Al-Qaida Sanctions List, which includes deletions of certain individuals and entities. UCBs must now incorporate these deletions into their internal lists and ensure compliance with the UAPA Order of August 27, 2009.
What it means for you
UCBs must promptly update their sanctions screening databases to reflect the latest UN deletions, preventing any inadvertent freezing of accounts linked to delisted entities. This ensures alignment with international sanctions and avoids legal or regulatory penalties. Banks should also reinforce their KYC and account monitoring processes to maintain compliance.
What you must do
- Update the internal list of designated individuals/entities with the 22nd UN Al-Qaida Sanctions List deletions.
- Screen all new account openings against the updated list before onboarding customers.
- Scan all existing accounts to identify and report any links to listed entities or individuals.
- Follow the freezing procedures outlined in paragraph 7 of the November 16, 2009 circular for any accounts linked to designated entities.
- Acknowledge receipt of this circular to the concerned RBI Regional Office via the Compliance Officer/Principal Officer.
Who it affects
Primary (Urban) Co-operative Banks (UCBs), Compliance Officers and Principal Officers of UCBs, KYC and account opening teams at UCBs
What is the 22nd update of the UN Al-Qaida Sanctions List?
It is a list of deletions of individuals and entities previously sanctioned under UNSCR 1267/1989, communicated by the UN Security Council's committee. UCBs must remove these entries from their internal sanctions lists.
What should we do if we find an existing account linked to a newly deleted entity?
Since the entity has been deleted from the sanctions list, you should no longer freeze or restrict the account based on this list. However, ensure you follow the UAPA Order and RBI guidelines for any other compliance requirements.
Where can we access the full updated sanctions list?
The complete list is available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml. RBI also circulates updates via its circulars.