What changed
The UNSC Security Council Committee amended entries on its ISIL (Da'esh) and Al-Qaida Sanctions List, as per press release SC/16017 dated March 12, 2025. The provided source lists amendments to 4 individuals: Aiman Muhammed Rabi Al-Zawahiri, Muhsin Fadhil Ayed Ashour Al-Fadhli, Abd Allah Mohamed Ragab Abdel Rahman, and Zaki Ezat Zaki Ahmed. These amendments include changes to names, aliases, and other identifying details. RBI has communicated these updates to all regulated entities for immediate compliance under Section 51A of UAPA, 1967.
What it means for you
Banks and other regulated entities must update their internal screening systems with the revised UNSC list to ensure no accounts or transactions are linked to the amended entries. Failure to comply could lead to regulatory action, including penalties for non-adherence to KYC/AML norms. This reinforces the government's zero-tolerance approach to terrorist financing.
What you must do
- Update your AML/KYC screening databases with the amended UNSC list entries (4 amendments as per provided source) immediately.
- Conduct a thorough review of all existing customer accounts to identify any matches with the updated list.
- Freeze and report any matched accounts to the Financial Intelligence Unit (FIU-IND) and RBI within the prescribed timeline.
- Ensure compliance teams are briefed on the specific changes, including new aliases and identifiers for listed individuals.
- Document all actions taken for audit and regulatory inspection purposes.
Who it affects
All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, Cooperative banks, All other regulated entities under RBI's purview
What is the legal basis for this circular?
It 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).
How quickly must we implement these changes?
Immediately upon receipt of the circular. The UNSC list amendments are effective from March 12, 2025, and RBI expects real-time compliance.
What happens if we find a match?
You must freeze the account immediately, stop all transactions, and report to FIU-IND and the RBI within the timeframe specified in the KYC Master Direction.