What changed
The UNSC updated its 1267/1989 ISIL & Al-Qaida Sanctions List, amending 11 entries (10 individuals and 1 entity/group). RBI has directed all regulated entities to incorporate these changes into their compliance checks under Section 51A of UAPA, 1967.
What it means for you
Banks and other regulated entities must immediately update their customer screening databases to reflect the amended UNSC list. Failure to identify and freeze assets of these newly updated entries could lead to regulatory action. The circular also reiterates the delisting process via MHA and the UN Ombudsperson.
What you must do
- Update your AML/KYC screening systems with the amended UNSC list entries (10 individuals and 1 entity).
- Cross-check all existing customer accounts and transactions against the updated list and freeze any matches.
- Ensure your compliance team is aware of the delisting request procedure through MHA and the UN Ombudsperson.
- Document the steps taken for audit and regulatory review.
Who it affects
All scheduled commercial banks, All non-banking financial companies (NBFCs), All payment system operators, All other regulated entities under RBI's purview
What is the source of the updated list?
The UNSC Committee issued press release SC/14299 dated 10 September 2020, amending 11 entries in the ISIL & Al-Qaida Sanctions List. RBI has forwarded this to all regulated entities.
What should we do if a customer requests delisting?
Forward the request electronically to Joint Secretary (CTCR), Ministry of Home Affairs. The customer can also approach the UN Ombudsperson directly for delisting.
Does this circular replace earlier KYC master directions?
No, it supplements the existing KYC Master Direction of February 25, 2016 (as amended April 20, 2020), specifically Section 51A on UAPA compliance.