What changed
The UNSC updated its sanctions list with amendments (underline/strikethrough) to 6 individual entries—2 via SC/14913 and 4 via SC/14914, both dated May 27, 2022. These changes affect names, aliases, and other identifiers for listed terrorists. Regulated entities must immediately apply the updated list to their KYC and screening processes.
What it means for you
Banks and lenders must cross-check all customer accounts against the revised UNSC list and freeze any matching accounts without prior notice. Non-compliance with Section 51A of UAPA can attract regulatory action. This update reinforces India's commitment to global counter-terrorism financing measures.
What you must do
- Update your AML/KYC screening systems with the amended UNSC list entries for the 6 individuals.
- Immediately freeze all accounts and transactions linked to these individuals and report to FIU-IND.
- Review and refresh customer due diligence for any existing accounts that may match the updated identifiers.
- Ensure compliance teams are briefed on the UNSC press releases SC/14913 and SC/14914 for accurate implementation.
Who it affects
All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, All other regulated entities under RBI's AML/CFT framework
What is the legal basis for this circular?
It flows from Section 51A of the Unlawful Activities (Prevention) Act, 1967, and RBI's Master Direction on KYC dated February 25, 2016 (as amended).
How quickly must we act on these updates?
Immediately. The UNSC amendments took effect on May 27, 2022, and RBI expects regulated entities to apply them without delay to avoid sanctions.
What if we find a match after screening?
Freeze the account or transaction instantly, file a Suspicious Transaction Report (STR) with FIU-IND, and ensure no further dealings with the listed individual.