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)
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.