What changed
RBI issued the 22nd update to the UNSCR 1267/1989 Al-Qaida Sanctions List, reflecting deletions made by the UN Committee. This supersedes the previous 21st update circular dated September 10, 2013. Banks must incorporate these deletions into their screening processes.
What it means for you
Banks must immediately update their internal sanctions lists to remove any individuals or entities that have been deleted from the UN list. This ensures compliance with Section 51-A of UAPA and avoids freezing accounts of delisted parties. Failure to update could lead to regulatory action or operational errors.
What you must do
- Update your sanctions screening database with the 22nd UN Al-Qaida deletions list from the UN website.
- Screen all new account applications against the updated list before onboarding.
- Review existing accounts to confirm no account is linked to any listed individual or entity.
- Follow the freezing procedures outlined in RBI circulars dated November 5, 2009 and October 29, 2009 for any designated entities.
- Compliance Officer/Principal Officer should acknowledge receipt of this circular to your respective RBI Regional Office.
Who it affects
Regional Rural Banks (RRBs), State Cooperative Banks (StCBs), Central Cooperative Banks (CCBs), Compliance Officers and Principal Officers of these banks
What is the source of the updated list?
The list is the 22nd update from the UN Security Council's 1267/1989 Al-Qaida Sanctions Committee, forwarded by the Ministry of External Affairs. It is available on the UN website at the URLs provided in the circular.
Do we need to freeze accounts of deleted entities?
No, the update only covers deletions. Freezing actions should follow the procedures in the earlier circulars for any entities that remain on the list. For deleted entries, no freezing is required.
What if we miss updating the list?
Non-compliance could result in regulatory penalties and operational risks, such as inadvertently freezing accounts of delisted parties or failing to screen against current sanctions.