What changed
The UN Security Council removed 5 individuals from its ISIL (Da'esh) and Al-Qaida Sanctions List effective January 4, 2022. RBI has communicated this deletion to all regulated entities, advising them to update their records and ensure ongoing compliance with the asset freeze, travel ban, and arms embargo.
What it means for you
Banks and other regulated entities must promptly update their customer screening systems to remove these 5 names from their watchlists. This does not change the overall obligation to screen against the UNSC sanctions list; entities must continue to check all accounts and transactions against the current list. Failure to update could lead to unnecessary freezes or compliance gaps.
What you must do
- Update your AML/KYC screening databases to remove the 5 deleted entries (Mevlüt Kar, Denis Mamadou Gerhard Cuspert, Nayef Salam Muhammad Ujaym Al-Hababi, Turki Mubarak Abdullah Ahmad Al-Binali, Tuah Febriwansyah).
- Verify that your internal sanctions screening processes reference the latest UNSC list available at www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list.
- Remind staff that any delisting requests from customers must be forwarded to the Joint Secretary (CTCR), Ministry of Home Affairs.
- Document the update and maintain an audit trail for 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 AML/KYC Master Direction
Do we need to unfreeze accounts of these 5 individuals immediately?
Yes, since the UNSC has deleted these entries, you should remove any freeze or restriction placed solely based on this listing. However, ensure no other legal or regulatory obligation prevents unfreezing.
How often should we update our sanctions list?
RBI expects you to monitor UNSC updates continuously. This circular is a specific notification; you should regularly check the UNSC website for any changes and update your systems promptly.
What if a customer claims they were wrongly listed and wants delisting?
Forward such requests electronically to the Joint Secretary (CTCR), Ministry of Home Affairs. Also inform the customer they can approach the UN Ombudsperson for delisting.