What changed
The Ministry of External Affairs informed RBI about UNSC press release SC/15556 dated January 05, 2024 amending 7 entries on the ISIL (Da'esh) and Al-Qaida Sanctions List. The amendments include updates to names, aliases, dates of birth, passport details, and other identifying information for listed individuals and entities.
What it means for you
Banks and other regulated entities must cross-check their customer database against the updated list and freeze/report any matching accounts immediately. Non-compliance with UAPA Section 51A can lead to regulatory action. The list now includes updated details for individuals like Hafiz Saeed and Habib Al-Loubiri, requiring re-screening even if previously cleared.
What you must do
- Immediately update your AML/KYC screening systems with the amended UNSC sanctions list entries (7 individuals and entities).
- Re-run sanctions screening on all existing customers.
- Freeze and report any matching accounts to the RBI within the prescribed timeline.
- Ensure compliance with Section 51A of UAPA, 1967 as per Master Direction on KYC (Feb 25, 2016, amended Jan 4, 2024).
- Document the screening process and maintain records for regulatory inspection.
Who it affects
All scheduled commercial banks, All non-banking financial companies (NBFCs), All cooperative banks, All payment system operators, All other regulated entities under RBI's purview
What is the deadline for implementing these changes?
The circular is dated January 6, 2024. Regulated entities must act immediately to update screening systems and freeze any matching accounts without delay.
Do I need to re-screen all customers or only new ones?
You must re-screen existing customers as well, because the amendments include updated identifiers (e.g., new aliases, passport numbers) that may not have matched during earlier screening.
What happens if we find a match?
You must immediately freeze the account and inform the RBI's concerned regional office. Do not allow any transactions.