What changed
The UNSC amended two entries on its 1267/1989 ISIL & Al-Qaida sanctions list: individual QDi.430 (Emraan Ali) with details including aliases, passport numbers, and addresses, and entity QDe.161 (ISIL-Khorasan) with additional aliases. These changes were communicated via MEA press release SC/14850 dated April 1, 2022, as per RBI circular dated April 4, 2022.
What it means for you
Banks and other regulated entities must immediately update their KYC and AML screening databases to reflect these amendments. Failure to identify and freeze accounts linked to these updated entries could lead to regulatory action under UAPA, 1967. The inclusion of ISIL-Khorasan with multiple aliases requires enhanced due diligence for transactions involving South Asian regions.
What you must do
- Update your AML screening systems with the amended UNSC sanctions list entries for Emraan Ali (QDi.430) and ISIL-Khorasan (QDe.161) as per the UNSC press release dated April 1, 2022, and RBI circular dated April 4, 2022.
- Cross-check existing customer accounts and transactions against the updated aliases, passport numbers, and addresses provided in the notification.
- Ensure compliance with Section 51A of UAPA, 1967 by freezing any accounts or assets linked to these individuals/entities and reporting to FIU-IND.
- Take note of the UNSC communication and ensure meticulous compliance as advised by RBI.
Who it affects
All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, Other regulated entities under RBI's AML/KYC framework
What is the significance of the UNSC press release SC/14850 for Indian banks?
It provides specific amendments to two sanctions list entries—an individual and an entity—which banks must incorporate into their screening processes to avoid violating UAPA, 1967.
How should banks handle the multiple aliases for ISIL-Khorasan?
Banks should ensure their screening systems can match all listed aliases (e.g., ISIS-K, IS-Khorasan) to prevent false negatives during transaction monitoring and customer due diligence.
What are the consequences of non-compliance with this update?
Non-compliance could result in regulatory penalties, including fines or restrictions, as per RBI's AML/KYC directives and the UAPA, 1967.