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No longer current — replaced by Revised regulatory framework for NBFCs – Directions, 2013 (updated circular replacing earlier NBFC instruction
Source: Reserve Bank of India · RBI/2009-10/427 · issued 23 Apr 2010 · ~1 min read
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.
Sanctions-list safety note. This circular refers to a specific UN Security Council / UAPA designated-entities list update as it stood on the date above — sanctions lists change often, and a newer update almost certainly exists today. Never use this page, or any single dated circular, as your current screening list. Always screen against the live, current list at the official UAPA proscribed-organisations list and the UN Consolidated List, and confirm the obligations for your bank on the official rbi.org.in source below.
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.
Historical instruction — do not use for current compliance. This is what was required at the time; it no longer reflects current RBI requirements. If no replacement rule is linked above, that only means none is recorded on our register yet — it does not prove no later applicable rule exists. Confirm on the official RBI source below.
What banks were required to do at the time
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
❓ Common questions
Regulatory timeline
Decoded by BankPulse2026-06-19 06:32 IST
Superseded by — Revised regulatory framework for NBFCs – Directions, 2013 (updated circular replacing earlier NBFC instruction
Status change: superseded03 Aug 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.
📜 This document’s life story (1 recorded event, each backed by RBI’s own words)
📜 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.
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
BankPulse Compliance Evidence Pack — generated 03 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). 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 reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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