NBFCs Must Screen Customers Against Updated UN Terror List
Current · Source: Reserve Bank of India · RBI/2010-11/496 · issued 02 May 2011 · ~1 min read
Quick answerRBI directs all NBFCs and RNBCs to update their records with the latest UNSCR 1267/1822 consolidated list of terrorist individuals/entities, screen new accounts before opening, 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.
The rule, in the simplest words
Update your internal records with the latest consolidated list from the UN website.
Screen all new account applications against the updated list before opening accounts.
Conduct a thorough review of all existing accounts to identify and flag any matches with the list.
Ensure your compliance team is aware of the updated list and any subsequent changes.
How it plays out — a real example
As an NBFC compliance officer in Indore, Rohan must ensure that the names of all new customers do not appear in the updated UN list. Before opening a new account, he checks the UN website and verifies the customer's name against the list. He also reviews existing accounts to ensure that no account is linked to any listed entities or individuals.
What changed
The UN Security Council's 1267 Committee issued a note on March 10, 2011, updating the consolidated list of individuals and entities linked to Al-Qaida and the Taliban. RBI now requires NBFCs and RNBCs to incorporate these changes into their customer screening processes.
What it means for you
NBFCs and RNBCs must proactively update their internal databases with the revised UN list to prevent any association with listed terrorists or entities. This reinforces the regulatory expectation for robust KYC and AML compliance, with potential penalties for non-compliance.
What you must do
Update your internal records with the latest consolidated list from the UN website (http://www.un.org/sc/committees/1267/consolist.shtml).
Screen all new account applications against the updated list before opening accounts.
Conduct a thorough review of all existing accounts to identify and flag any matches with the list.
Ensure your compliance team is aware of the March 10, 2011 note and any subsequent updates.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)
❓ Common questions
What is the source of the updated list?
The updated consolidated list is issued by the UN Security Council's 1267 Committee and is available on their official website.
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 no account is linked to any listed individual or entity.
📜 Read the original circular — full text as issued by RBI
RBI/2010-11/496
DNBS(PD).CC. No. 217 /03.10.42 /2010-11
May 02, 2011
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 March 10, 2011 regarding changes made in the consolidated List of Individuals and entities linked to Al-Qaida and Taliban ( copy enclosed ). All NBFCs and RNBCs are advised to update the *consolidated list of individuals/entities and also those consolidated list of individuals/entities, issued prior to above mentioned note. Before opening any new account, it should be ensured that the name/s of the proposed customer does not appear in the list. Further NBFCs and RNBCs 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 consolidated lists are available on the UN website: http://www.un.org/sc/committees/1267/consolist.shtml
Yours faithfully,
(Uma Subramaniam)
Chief General Manager-in-Charge
Encl:as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2010-11/496 · issued 02 May 2011. The plain-English explanation above is BankPulse’s own independent summary.
Screen all new account applications against the updated list before opening accounts.
📜 Compliance
Update your internal records with the latest consolidated list from the UN website (http://www.un.org/sc/committees/1267/consolist.shtml).
Conduct a thorough review of all existing accounts to identify and flag any matches with the list.
Ensure your compliance team is aware of the March 10, 2011 note and any subsequent updates.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template
Example: if you are a Compliance officer at a bank this circular applies to (All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)), your first concrete step on “NBFCs Must Screen Customers Against Updated UN Terror List” is: “Update your internal records with the latest consolidated list from the UN website (http://www.un.org/sc/committees/1267/consolist.shtml).” (RBI issued this 02 May 2011).
Circular: RBI/2010-11/496 -- NBFCs Must Screen Customers Against Updated UN Terror List
Issued: 02 May 2011
Action required: Update your internal records with the latest consolidated list from the UN website (http://www.un.org/sc/committees/1267/consolist.shtml).
Action required: Screen all new account applications against the updated list before opening accounts.
Action required: Conduct a thorough review of all existing accounts to identify and flag any matches with the list.
Action required: Ensure your compliance team is aware of the March 10, 2011 note and any subsequent updates.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.
💬 Banker Discussion
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=6368&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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