What changed
The UN Security Council Committee amended 29 entries on its ISIL (Da'esh) and Al-Qaida Sanctions List, as per press release SC/15190 dated February 3, 2023. RBI has communicated these changes to all regulated entities, requiring them to update their compliance checks accordingly.
What it means for you
Banks and other regulated entities must promptly incorporate these 29 amendments into their AML/KYC screening processes to avoid violating Section 51A of UAPA, 1967. Non-compliance could lead to regulatory action, including penalties, and reputational risk. Entities must also follow the delisting procedure prescribed by MHA for any requests received.
What you must do
- Update your AML screening databases with the latest UNSC sanctions list amendments (29 entries) immediately.
- Cross-check all existing and new customer accounts against the updated list and freeze any matching accounts.
- Forward any delisting requests received from customers to Joint Secretary (CTCR), Ministry of Home Affairs electronically.
- Ensure compliance with sections 51, 52, and 53 of the Master Direction on KYC and the UAPA Order dated February 2, 2021.
- Monitor the UNSC press release page and sanctions list URLs regularly for future updates.
Who it affects
All scheduled commercial banks, Cooperative banks, Non-banking financial companies (NBFCs), Payment system operators, All other regulated entities under RBI
What is the source of the updated sanctions list?
The UN Security Council Committee pursuant to resolutions 1267 (1999), 1989 (2011), and 2253 (2015) issued press release SC/15190 on February 3, 2023, amending 29 entries on its ISIL (Da'esh) and Al-Qaida Sanctions List.
How should we handle a delisting request from a customer?
As per MHA instructions, any delisting request received by a regulated entity must be forwarded electronically to Joint Secretary (CTCR), Ministry of Home Affairs. Customers can also approach the UN Ombudsperson directly via the provided URL.
What are the consequences of not updating our screening systems?
Failure to comply may result in regulatory action under UAPA, 1967 and RBI's KYC Master Direction, including penalties, as maintaining accounts or processing transactions for listed entities is prohibited.