What changed
The UNSC's 1267/1989 ISIL & Al-Qaida Sanctions Committee amended 92 entries in its consolidated list, as notified via MEA press release SC/14446 dated February 23, 2021. RBI circular DOR.AML.BC.No.44/14.06.001/2020-21 directs all regulated entities to incorporate these changes into their compliance checks.
What it means for you
Banks and other regulated entities must immediately update their KYC and AML screening databases to reflect the amended 92 entries, covering both individuals (QDi) and entities (QDe). Failure to comply could lead to regulatory action, as maintaining accounts for listed persons violates UAPA Section 51A. The circular also reiterates the delisting request process through MHA and the UN Ombudsperson.
What you must do
- Update your AML/KYC screening systems with the 92 amended UNSC sanctions list entries (QDi.006 to QDe.151).
- Cross-check all existing customer accounts against the updated list and freeze any matching accounts immediately.
- Ensure your compliance team is aware of the delisting request procedure: forward any such requests to Joint Secretary (CTCR), MHA electronically.
- Document the update and compliance actions for audit and regulatory review.
Who it affects
All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, Other regulated entities under RBI's AML/CFT framework
What is the source of the 92 amended entries?
The UNSC Committee established under Resolutions 1267, 1989, and 2253 issued press release SC/14446 on February 23, 2021, amending 92 entries in the ISIL (Da'esh) & Al-Qaida Sanctions List. The MEA forwarded this to RBI.
How should we handle a delisting request from a customer?
Forward the request electronically to Joint Secretary (CTCR), Ministry of Home Affairs. Alternatively, the individual/entity can approach the UN Ombudsperson directly via the UN website.
Does this circular replace earlier KYC master directions?
No, it supplements Section 51 of the Master Direction on KYC dated February 25, 2016 (as amended December 18, 2020), which already requires compliance with UNSC sanctions lists.