What changed
RBI issued a circular on October 28, 2011, referencing UN Security Council updates from July 29, August 12, and August 22, 2011, to the consolidated list of terrorist individuals and entities. This supersedes the previous circular dated September 12, 2011, and requires NBFCs/RNBCs to incorporate these changes into their screening processes.
What it means for you
NBFCs and RNBCs must immediately update their internal KYC and AML systems with the revised UN list to avoid onboarding or servicing prohibited entities. Failure to screen new and existing accounts could lead to regulatory action and reputational risk. This reinforces the sector's role in combating terror financing.
What you must do
- Update your internal database with the latest UN 1267 Committee consolidated list from the UN website.
- Screen all new account applications against the updated list before account opening.
- Conduct a fresh scan of all existing customer accounts to identify any matches with the list.
- Report any matches to the relevant authorities as per existing AML/CFT guidelines.
Who it affects
All Non-Banking Financial Companies (NBFCs), All Residuary Non-Banking Companies (RNBCs)
Where can we access the latest consolidated list?
The complete consolidated list is available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
Do we need to check only new accounts or existing ones too?
Both. You must ensure new accounts are not linked to listed entities, and you must scan all existing accounts to identify any links.
What should we do if we find a match in an existing account?
Follow your existing AML/CFT reporting procedures and inform the appropriate authorities as per regulatory guidelines.