What changed
The UN Security Council removed one individual (Lionel Dumont) from its ISIL & Al-Qaida sanctions list effective February 21, 2025. Consequently, the asset freeze, travel ban, and arms embargo no longer apply to this entry. RBI has communicated this change to all regulated entities via a circular dated February 27, 2025.
What it means for you
Banks and other regulated entities must promptly update their internal sanctions screening databases to reflect this delisting. While this specific entry no longer requires freezing, entities must continue to strictly comply with UAPA Section 51A and the KYC Master Direction for all other listed individuals and entities. Any de-listing requests received from customers must be forwarded to MHA as per existing instructions.
What you must do
- Update your UNSC sanctions list records to remove Lionel Dumont (QDi.095) from your screening database.
- Ensure no new freezing actions are taken against this individual; release any frozen assets if applicable, subject to legal advice.
- Continue to monitor the UNSC sanctions list website for future updates and implement changes promptly.
- Forward any de-listing requests from customers to Joint Secretary (CTCR), Ministry of Home Affairs, as per MHA instructions.
Who it affects
All regulated entities (banks, NBFCs, payment system operators, etc.), Compliance and AML/KYC teams, Branch staff handling account opening and transaction monitoring
What is the significance of this UNSC list update for my bank?
It means you must remove the delisted individual from your internal sanctions watchlist and stop applying asset freeze measures to that person. However, you must continue to screen against the full updated list for all other entries.
How do I handle a customer who claims they were wrongly listed and now want their account unfrozen?
If the customer is not on the current UNSC list, you can unfreeze the account after verifying the updated list. For any de-listing requests, forward them electronically to Joint Secretary (CTCR), Ministry of Home Affairs, as per MHA instructions.
Where can I find the latest UNSC sanctions list?
The updated ISIL & Al-Qaida sanctions list is available at www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list. The Taliban list is at www.un.org/securitycouncil/sanctions/1988/materials.