What changed
The UNSC Security Council Committee amended two entries on its ISIL (Da'esh) and Al-Qaida Sanctions List on July 21, 2023. The changes involve Yazid Sufaat (Malaysian, founding member of Jemaah Islamiyah) and Faysal Ahmad Bin Ali Al-Zahrani (Saudi, lead oil and gas division official of ISIL, reportedly deceased). RBI has communicated these amendments to all regulated entities, referencing the Master Direction on KYC dated February 25, 2016 as amended on May 04, 2023.
What it means for you
Banks and other regulated entities must immediately update their internal sanctions screening systems to reflect these two amended entries. Any accounts or transactions linked to these individuals must be frozen and reported to FIU-IND. Failure to comply could lead to regulatory action.
What you must do
- Update your UNSC sanctions screening database with the amended details for Yazid Sufaat and Faysal Ahmad Bin Ali Al-Zahrani.
- Conduct a retrospective review of all existing accounts and transactions to identify any matches with these individuals.
- Freeze any identified assets or accounts immediately and file a Suspicious Transaction Report (STR) with FIU-IND.
- Ensure compliance with Section 51A of UAPA, 1967, and the Master Direction on KYC dated February 25, 2016 as amended on May 04, 2023, and maintain records of screening actions.
- Communicate this update to all relevant branches and departments handling KYC/AML compliance.
Who it affects
All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, Other regulated entities under RBI's purview
What is the legal basis for this notification?
This notification is issued under Section 51A of the Unlawful Activities (Prevention) Act, 1967, and the RBI Master Direction on KYC dated February 25, 2016 as amended on May 04, 2023. It requires regulated entities to ensure no accounts are held by individuals/entities on the UNSC sanctions list.
What should I do if I find a match with the amended entries?
Immediately freeze the account or asset, file a Suspicious Transaction Report (STR) with FIU-IND, and follow the procedure as laid down in the UAPA Order dated February 02, 2021 (amended on March 15, 2023). Do not inform the customer about the freezing action.
Are these amendments retroactive?
The UNSC press release is dated July 21, 2023, and the amendments were enacted on that date. You must review all existing accounts and transactions for potential matches, not just new ones.