What changed
RBI issued a circular on August 2, 2011, referencing updates from the UN Security Council's 1267 Committee. The updates include changes from notes dated June 10, 15, and 16, 2011, to the consolidated list of individuals and entities linked to Al-Qaida and Taliban. NBFCs and RNBCs must incorporate these changes into their screening processes.
What it means for you
NBFCs and RNBCs must tighten their KYC and AML checks by using the updated UN list. Failure to screen new and existing accounts could lead to regulatory action. This reinforces the need for robust compliance systems to avoid facilitating terrorist financing.
What you must do
- Update your internal database with the latest consolidated UNSCR 1267/1822 list from the UN website.
- Screen all new account applications against the updated list before onboarding.
- Conduct a one-time review of all existing accounts to identify any matches with the list.
- Report any matches to the appropriate authorities as per regulatory guidelines.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)
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.
Do we need to check only new accounts or existing ones too?
Both. You must verify new accounts before opening and also scan all existing accounts to ensure no account is linked to listed entities or individuals.