What changed
The UN Security Council added one individual (Emraan Ali) to its ISIL (Da'esh) & Al-Qaida Sanctions List on November 24, 2021. RBI has now communicated this update to all regulated entities, requiring them to implement the asset freeze, travel ban, and arms embargo as per Section 51A of UAPA, 1967.
What it means for you
Banks and other regulated entities must immediately screen their customer base against the updated UNSC list and freeze any accounts or assets belonging to the newly added individual. Failure to comply could lead to regulatory action. The delisting process remains available through MHA or the UN Ombudsperson.
What you must do
- Update your AML/KYC screening systems with the new UNSC list entry for Emraan Ali.
- Run a one-time check across all customer accounts, including dormant ones, for matches with this individual.
- Freeze any identified accounts/assets and report to the Financial Intelligence Unit (FIU) and MHA as per existing procedures.
- Forward any delisting requests received from customers to Joint Secretary (CTCR), MHA electronically.
- Remind compliance teams to regularly check the UNSC sanctions list URLs provided in the circular.
Who it affects
All scheduled commercial banks, All non-banking financial companies (NBFCs), All payment system operators, All other RBI-regulated entities
What is the source of this sanctions list update?
The UN Security Council Committee, via press release SC/14712 dated November 24, 2021, added one individual (Emraan Ali) to the ISIL (Da'esh) & Al-Qaida Sanctions List. RBI has forwarded this to all regulated entities.
How should we handle a delisting request from a customer?
Forward any delisting request electronically to Joint Secretary (CTCR), Ministry of Home Affairs. Customers can also approach the UN Ombudsperson directly via the URL provided in the circular.
Does this circular replace earlier KYC master directions?
No, this is an update to the existing obligations under Section 51A of UAPA, 1967, as already covered in the Master Direction on KYC dated February 25, 2016 (amended May 10, 2021). It adds one new name to the sanctions list.