What changed
The UNSC 1267/1989 ISIL & Al-Qaida Sanctions Committee added two entries on December 29, 2021 (ASHRAF AL-QIZANI and JUND AL-KHILAFAH IN TUNISIA) and one entry on December 21, 2021 (SANAULLAH GHAFARI). RBI has now communicated these additions to all regulated entities for compliance under Section 51A of UAPA, 1967.
What it means for you
Banks and lenders must immediately update their sanctions screening systems with these three new names and freeze any linked accounts or transactions. Failure to comply could lead to regulatory action and reputational risk. The circular also reiterates the delisting process through MHA or the UN Ombudsperson.
What you must do
- Update your AML/KYC screening databases with the three new UNSC entries: ASHRAF AL-QIZANI, JUND AL-KHILAFAH IN TUNISIA, and SANAULLAH GHAFARI.
- Conduct a retrospective check on existing customers and transactions for any matches with these names.
- Freeze assets and report any matches to the Financial Intelligence Unit (FIU-IND) and the Joint Secretary (CTCR), MHA immediately.
- Ensure your compliance team is aware of the delisting request process via MHA or the UN Ombudsperson.
- Document all screening actions and maintain audit trails for regulatory inspection.
Who it affects
All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, Cooperative banks, All other RBI-regulated entities
What is the legal basis for this circular?
It is issued under Section 51A of the Unlawful Activities (Prevention) Act, 1967, read with RBI's Master Direction on KYC dated February 25, 2016 (as amended). Regulated entities must not maintain accounts for individuals or entities on the UNSC sanctions list.
How should we handle a customer who claims to be wrongly listed?
Per MHA instructions, forward any delisting request electronically to Joint Secretary (CTCR), MHA. Alternatively, the individual/entity can approach the UN Ombudsperson directly via the UN website. Do not unfreeze assets without official clearance.
Are these additions effective immediately?
Yes. The circular is dated January 3, 2022, and requires immediate compliance. The UNSC press releases for the additions were issued on December 21 and December 29, 2021, so entities should have already updated their lists.