Home › Circulars › RBI/2009-10/427

NBFCs Must Screen Customers Against UN Terror List

No longer current — replaced by Revised regulatory framework for NBFCs – Directions, 2013 (updated circular replacing earlier NBFC instruction

Issued by RBI: 23 Apr 2010

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📄 Source: Reserve Bank of India · RBI/2009-10/427

Quick answerRBI directs all NBFCs and RNBCs to update their records with the UN's consolidated list of individuals/entities linked to Al-Qaida and Taliban, screen new accounts against it, and review existing accounts for matches.

What changed

RBI issued a circular on April 23, 2010, referencing a UN Security Council 1267 Committee note from January 19, 2010, that updated the consolidated list of terrorist-linked individuals and entities. NBFCs and RNBCs are now required to use this updated list for customer screening.

What it means for you

Banks and NBFCs must integrate the latest UN terror list into their KYC and AML processes to prevent accounts linked to designated terrorists. Failure to comply could lead to regulatory action and reputational risk. This reinforces the need for robust screening systems.

What you must do

Update your internal systems with the latest UN consolidated list from the provided URL.
Screen all new account applications against the updated list before opening accounts.
Conduct a retrospective review of all existing accounts to identify any matches with the list.
Ensure the Compliance Officer acknowledges receipt of this circular to the relevant DNBS Regional Office.

Who it affects

All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs), Compliance Officers and Principal Officers of NBFCs/RNBCs

Regulatory timeline

Decoded by BankPulse 2026-06-19 06:32 IST
Superseded by — Revised regulatory framework for NBFCs – Directions, 2013 (updated circular replacing earlier NBFC instruction
Status change: superseded 12 Jul 2026, 04:00 IST

Built from our lineage records — each fact carries its provenance; missing history simply is not shown (never guessed).

What is the source of the list we need to use?

The list is the UN Security Council's consolidated list of individuals and entities linked to Al-Qaida and Taliban, available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml.

Do we need to check only new accounts or also existing ones?

Both. You must ensure new accounts are not linked to listed entities, and you must scan all existing accounts to identify any matches.

Who should we inform after compliance?

The Compliance Officer or Principal Officer of your company should acknowledge receipt of this circular to the concerned Regional Office of DNBS in whose jurisdiction your NBFC/RNBC operates.

📜 Read the original circular — full text as issued by RBI

RBI/2009-10/427

 NBS(PD).CC. No 170 /03.10.42 /2009-10

 April 23, 2010

 All Non Banking Financial Companies /

 Residuary Non Banking Companies

 Dear Sir, 

 List of Terrorist Individuals / Organisations- under UNSCR 1267 (1999) and 

 1822(2008) on Taliban /Al-Qaida Organisation 

 The Chairman of UN Security Council's 1267 Committee has issued a note on January 19, 2010 regarding changes made in the Consolidated List of Individuals and entities linked to Al-Qaida and Taliban ( copy enclosed ). All NBFCs and RNBCs are accordingly advised to update the consolidated list of individuals/entities and before opening any new account, it should be ensured that the name/s of the proposed customer does not appear in the list. Further, they should scan all existing accounts to ensure that no account is held by or linked to any of the entities or individuals included in the list.

 The complete details of the said consolidated list are available on the UN website:

        http://www.un.org/sc/committees/1267/consolist.shtml 

 2. Please advise the Compliance officer/Principal Officer of your company to acknowledge receipt of this circular letter to the concerned Regional Office of DNBS in whose jurisdiction NBFC/ RNBC is functioning.

 Yours faithfully,

 (A.S.Rao)

 CGM-in-Charge

 Encl: As above

Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2009-10/427 · issued 23 Apr 2010. The plain-English explanation above is BankPulse’s own independent summary.

Test yourself

Quick self-check built only from the facts already on this page — tap a question to reveal the answer.

Q1. In one line, what does this circular do?

RBI directs all NBFCs and RNBCs to update their records with the UN's consolidated list of individuals/entities linked to Al-Qaida and Taliban, screen new accounts against it, and review existing accounts for matches.

Q2. Who does this circular apply to?

All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs), Compliance Officers and Principal Officers of NBFCs/RNBCs

Q3. What is the first thing you should do about it?

Update your internal systems with the latest UN consolidated list from the provided URL.

Related circulars · NBFC Regulation

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Who does what — compliance checklist

💻 IT / Systems

Update your internal systems with the latest UN consolidated list from the provided URL.
Screen all new account applications against the updated list before opening accounts.

📜 Compliance

Conduct a retrospective review of all existing accounts to identify any matches with the list.
Ensure the Compliance Officer acknowledges receipt of this circular to the relevant DNBS Regional Office.

Grouped from the action items above — a single circular may involve more than one team.

Worked example & action-note template

Example: if you are an IT/Systems lead at a bank this circular applies to (All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs), Compliance Officers and Principal Officers of NBFCs/RNBCs), your first concrete step on “NBFCs Must Screen Customers Against UN Terror List” is: “Update your internal systems with the latest UN consolidated list from the provided URL.” (RBI issued this 23 Apr 2010).

Circular: RBI/2009-10/427 -- NBFCs Must Screen Customers Against UN Terror List
Issued: 23 Apr 2010
Action required: Update your internal systems with the latest UN consolidated list from the provided URL.
Action required: Screen all new account applications against the updated list before opening accounts.
Action required: Conduct a retrospective review of all existing accounts to identify any matches with the list.
Action required: Ensure the Compliance Officer acknowledges receipt of this circular to the relevant DNBS Regional Office.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
Evidence filed in compliance register on: ____________

Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.

AI-drafted · 1-model AI consensus fact-check · under the editorial review of our expert review panel · decoded & published by BankPulse · 20 Jun 2026, 15:46 IST

Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=5625&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert review panel. Independent platform, not affiliated with the Reserve Bank of India; never reproduces RBI text verbatim.