What changed
The UNSC Committee under resolution 1718 amended one entry on its sanctions list for DPRK, with changes shown via strikethrough/underline. RBI circular communicates this amendment, updating the designated list referenced in the September 1, 2023 Order under Section 12A of the WMD Act.
What it means for you
Banks must immediately incorporate the amended UNSC 1718 sanctions list into their daily screening processes. Failure to align with the updated list could lead to non-compliance with the WMD Act and KYC Master Direction, exposing institutions to regulatory action.
What you must do
- Update your sanctions screening systems with the latest UNSC 1718 list amendments for DPRK as enclosed in the circular.
- Ensure daily verification of the UNSC 1718 Sanctions List from MEA's website and UN Security Council's site.
- Review and align your internal compliance procedures with the amended designated list under Section 12A of the WMD Act.
- Communicate the changes to your AML/KYC compliance teams and relevant business units.
Who it affects
All regulated entities (banks, NBFCs, payment systems, etc.), AML/KYC compliance teams, Sanctions screening operations, Risk management departments
What is the source of the updated sanctions list?
The UNSC Committee established under resolution 1718 amended its sanctions list for DPRK. The Ministry of External Affairs communicated these changes to RBI, which then issued this circular.
How often should we check the sanctions list?
As per Section 53 of the KYC Master Direction, regulated entities must verify the UNSCR 1718 Sanctions List every day to account for any additions, deletions, or other changes.
What happens if we don't comply?
Non-compliance with the WMD Act and KYC Master Direction can lead to regulatory penalties, including fines or restrictions on operations. Meticulous compliance is mandatory.