What changed
RBI issued a circular on July 22, 2011, referencing UN Security Council 1267 Committee notes from May 2011 that updated the consolidated list of terrorist individuals and organisations. All NBFCs and RNBCs are now required to ensure no new or existing accounts are linked to any entity on this list.
What it means for you
NBFCs and RNBCs must proactively screen all new account openings against the UN list and review existing accounts for matches. Non-compliance could lead to regulatory action, as this is a key anti-money laundering and counter-terrorism financing measure. Lenders need to integrate this screening into their KYC and ongoing due diligence processes.
What you must do
- Update your internal systems with the latest UNSC 1267/1822 consolidated list from the UN website.
- Screen all new customer applications against the list before opening accounts.
- Conduct a one-time scan of all existing accounts to identify any matches with listed individuals or entities.
- Report any matches to the appropriate authorities as per regulatory guidelines.
Who it affects
All Non-Banking Financial Companies (NBFCs), All Residuary Non-Banking Companies (RNBCs)
What is the UNSC 1267/1822 consolidated list?
It is a list maintained by the UN Security Council's 1267 Committee of individuals and entities associated with Al-Qaida and Taliban, updated periodically.
Do we need to check existing accounts or only new ones?
Both. The circular requires you to screen new accounts before opening and also scan all existing accounts to ensure no account is linked to any listed entity.
Where can we find the latest consolidated list?
The complete list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml.