HomeCirculars › RBI/2010-11/540

NBFCs Must Screen Against UN Terror List

Current · Source: Reserve Bank of India · RBI/2010-11/540 · issued 28 Apr 2011 · ~1 min read
Quick answerRBI directs all NBFCs and RNBCs to update and screen customers against the UNSC 1267 Committee's consolidated list of Al-Qaida/Taliban-linked individuals and entities, both for new accounts and existing ones.
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
How it plays out — a real example

Rohit, a micro‑finance loan officer in Jaipur, downloads the latest UN 1267 list each month, runs it through the bank’s software for every new borrower, and also runs a quarterly scan of all current borrowers. When the system flags a name, Rohit immediately notifies the compliance team and records the action, ensuring his NBFC stays clear of any terrorist connections.

What changed

RBI issued a circular on May 20, 2011, referencing a UN Security Council note from April 28, 2011, that updated the consolidated list of terrorist individuals and entities. All NBFCs and RNBCs are now required to incorporate these changes into their screening processes.

What it means for you

NBFCs and RNBCs must proactively check all new and existing customers against the updated UN list to prevent any association with designated terrorists. Non-compliance could lead to regulatory action, and lenders need to strengthen their KYC and AML frameworks to avoid penalties.

What you must do

Who it affects

All Non-Banking Financial Companies (NBFCs), All Residuary Non-Banking Companies (RNBCs)

❓ Common questions

Where can I find the latest consolidated list of terrorist individuals and entities?

The complete consolidated list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml.

Do I need to screen only new accounts or also existing ones?

Both. You must screen new accounts before opening them and also scan all existing accounts to ensure none are linked to listed individuals or entities.

What should I do if I find a match in my existing accounts?

You should immediately report the match to the relevant authorities as per RBI and UN guidelines. The circular does not specify further steps, but standard AML protocols apply.

📜 Read the original circular — full text as issued by RBI
RBI/2010-11/540 DNBS(PD).CC. No220/03.10.42 /2010-11 May  20 , 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 April 28, 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. 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 list is available on the UN website: http://www.un.org/sc/committees/1267/consolist.shtml Yours faithfully, (Dr Tuli Roy) Deputy General Manager Encl : as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2010-11/540 · issued 28 Apr 2011. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
Who does what — compliance checklist
🏦 Branch Manager
  • Screen all new account applicants against the list before account opening.
⚙️ Operations
  • Maintain records of screening activities for audit and compliance purposes.
💻 IT / Systems
  • Update your internal systems with the latest UNSC 1267 consolidated list from the UN website.
📜 Compliance
  • Conduct a retrospective scan of all existing accounts to identify any matches.
  • Report any matches to the appropriate authorities as per regulatory guidelines.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template

Example: if you are an IT/Systems lead at a bank this circular applies to (All Non-Banking Financial Companies (NBFCs), All Residuary Non-Banking Companies (RNBCs)), your first concrete step on “NBFCs Must Screen Against UN Terror List” is: “Update your internal systems with the latest UNSC 1267 consolidated list from the UN website.” (RBI issued this 28 Apr 2011).

  1. Circular: RBI/2010-11/540 -- NBFCs Must Screen Against UN Terror List
  2. Issued: 28 Apr 2011
  3. Action required: Update your internal systems with the latest UNSC 1267 consolidated list from the UN website.
  4. Action required: Screen all new account applicants against the list before account opening.
  5. Action required: Conduct a retrospective scan of all existing accounts to identify any matches.
  6. Action required: Report any matches to the appropriate authorities as per regulatory guidelines.
  7. Action required: Maintain records of screening activities for audit and compliance purposes.
  8. Owner: ____________ Target date: ____________
  9. Board/committee approval needed? Y / N
  10. 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

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=6420&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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