What changed
The UNSC Committee under resolution 1718 amended certain entries on its Sanctions List of individuals and entities, with changes marked by strikethrough and underline. RBI has communicated these amendments to the designated list previously notified in its July 4, 2023 circular, requiring regulated entities to update their records accordingly.
What it means for you
Banks and other regulated entities must immediately incorporate the latest UNSC sanctions amendments into their KYC and screening processes to avoid non-compliance with the WMD Act. Failure to align with these updates could lead to regulatory penalties and reputational risk, as the list is part of the statutory framework under Section 12A.
What you must do
- Update your internal designated list with the amendments enclosed with this circular, including strikethrough and underline changes.
- Verify the latest UNSCR 1718 Sanctions List on DPRK daily from the MEA and UN websites provided.
- Ensure your KYC and transaction screening systems reflect the revised entries to maintain compliance with the WMD Act.
- Document all updates and verification steps for audit and regulatory review.
Who it affects
All regulated entities under RBI (banks, NBFCs, payment systems, etc.), Compliance and AML/KYC teams, Risk management departments
What is the source of the updated designated list?
The amendments come from the UNSC Committee established under resolution 1718, communicated via the Ministry of External Affairs. RBI has enclosed the changes with this circular.
How often must we check the sanctions list?
Per RBI's Master Direction on KYC, regulated entities must verify the UNSCR 1718 Sanctions List daily to account for any additions, deletions, or changes.
What happens if we don't update our list?
Non-compliance with Section 12A of the WMD Act can lead to regulatory action, including penalties, as the list is part of the statutory compliance framework.