What changed
RBI issued a circular on March 26, 2012, referencing updates to the UN Security Council's 1267/1989 Committee's Al-Qaida Sanctions List as of January 26, 2012. NBFCs must now incorporate these changes into their customer screening processes.
What it means for you
NBFCs must proactively update their internal blacklists with the latest UN sanctions list to prevent any dealings with listed individuals or entities. This enhances compliance with UAPA and strengthens anti-terror financing measures. Failure to screen accounts could expose banks to legal and reputational risks.
What you must do
- Download the updated Al-Qaida Sanctions List from the UN website and cross-verify with RBI's circulated list.
- Screen all new account applications against the updated list before onboarding customers.
- Review all existing accounts to identify and flag any matches with the sanctions list.
- Report any matches to the appropriate regulatory and law enforcement authorities immediately.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)
What is the source of the updated sanctions list?
The list is maintained by the UN Security Council's 1267/1989 Committee and 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 screen new accounts before opening and also scan all existing accounts to ensure none are linked to listed individuals or entities.
What happens if we find a match in an existing account?
You should immediately report the match to the relevant authorities as per UAPA guidelines and take necessary action, including freezing the account.