What changed
The UNSC removed two entries (QDi.379 Abd al-Aziz Aday Zimin al-Fadhil and QDi.381 Hamad Awad Dahi Sarhan al-Shammari) from the ISIL (Da'esh) and Al-Qaida Sanctions List effective June 5, 2023. Consequently, the asset freeze, travel ban, and arms embargo under UNSC resolution 2610 (2021) no longer apply to these individuals. RBI advises all regulated entities to take appropriate action per Section 51 of the Master Direction on KYC and the UAPA Order.
What it means for you
Banks and other regulated entities must immediately update their sanctions screening systems to remove these two names from their blocked lists. Failure to do so could result in continued freezing of assets for individuals no longer sanctioned, leading to compliance and reputational risks. This circular reinforces the need for real-time synchronization with UNSC lists and adherence to MHA delisting procedures.
What you must do
- Update your sanctions screening database to remove the two delisted individuals (QDi.379 and QDi.381) from your blocked list.
- Cease applying asset freeze, travel ban, and arms embargo measures to these individuals immediately.
- Ensure your compliance team reviews the UNSC press release SC/15309 and the updated sanctions list on the UN website.
- Forward any delisting requests received from customers to Joint Secretary (CTCR), MHA electronically, as per MHA instructions.
- Maintain records of actions taken for audit and regulatory inspection purposes.
Who it affects
All scheduled commercial banks, All non-banking financial companies (NBFCs), All payment system operators, All other regulated entities under RBI's purview
What is the effective date for the removal of these two entries?
The UNSC press release SC/15309 is dated June 5, 2023, and the RBI circular was issued on June 6, 2023. Entities should act from the date of the circular.
Do we need to report the removal to RBI or any other authority?
The circular does not mandate reporting the removal itself, but you must follow the procedure in the UAPA Order dated February 2, 2021 (amended March 15, 2023) annexed to the MD on KYC. Any delisting requests from customers must be forwarded to MHA.
Where can we find the updated UNSC sanctions lists?
The updated lists are available at www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list and for Taliban at www.un.org/securitycouncil/sanctions/1988/materials.