NBFCs Must Update UN Terrorist List for KYC Compliance
Current · Source: Reserve Bank of India · RBI/2011-12/137 · issued 02 Aug 2011 · ~1 min read
Quick answerRBI directs all NBFCs and RNBCs to update their records with the latest UNSCR 1267/1822 terrorist list. Before opening new accounts, verify customer names against this list, and scan 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 database with the latest UN list (UNSCR 1267/1822) from the UN website.
Before opening a new account, check the customer’s name against this list; if it appears, do not open the account.
Do a one‑time scan of all existing accounts to see if any match the list; if a match is found, report it to the authorities.
These rules apply to all Non‑Banking Financial Companies (NBFCs) and Residuary Non‑Banking Companies (RNBCs).
How it plays out — a real example
A gold‑loan officer in Indore checks a new customer’s name against the updated UN list before approving the loan, and later reviews old accounts to ensure none match the list, reporting any findings to the regulator.
What changed
RBI issued a circular on August 2, 2011, referencing updates from the UN Security Council's 1267 Committee. The updates include changes from notes dated June 10, 15, and 16, 2011, to the consolidated list of individuals and entities linked to Al-Qaida and Taliban. NBFCs and RNBCs must incorporate these changes into their screening processes.
What it means for you
NBFCs and RNBCs must tighten their KYC and AML checks by using the updated UN list. Failure to screen new and existing accounts could lead to regulatory action. This reinforces the need for robust compliance systems to avoid facilitating terrorist financing.
What you must do
Update your internal database with the latest consolidated UNSCR 1267/1822 list from the UN website.
Screen all new account applications against the updated list before onboarding.
Conduct a one-time review of all existing accounts to identify any matches with the list.
Report any matches to the appropriate authorities as per regulatory guidelines.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)
❓ Common questions
Where can we find the latest consolidated list?
The complete list is available on the UN website at http://www.un.org/sc/committees/1267/consolist.shtml.
Do we need to check only new accounts or existing ones too?
Both. You must verify new accounts before opening and also scan all existing accounts to ensure no account is linked to listed entities or individuals.
📜 Read the original circular — full text as issued by RBI
RBI/2011-12/137
DNBS(PD).CC. No 240 /03.10.42 /2011-12
August 2, 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
Please refer to Company Circular No 239 dated July 22, 2011 on List of Terrorist Individuals / Organisations under UNSCR 1267 (1999)and 1822(2008) on Taliban /AL-Qaida Organisation.
2. The Chairman of UN Security Council's 1267 Committee has forwarded copies of notes dated June 10, 2011 , June 15, 2011 and June 16, 2011 regarding changes made in the consolidated List of Individuals and entities linked to Al-Qaida and Taliban (copies 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.
3.The complete details of the consolidated list is available on the UN website:
http://www.un.org/sc/committees/1267/consolist.shtml
Yours faithfully,
(A. Mangalagiri)
General Manager
Encl:as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/137 · issued 02 Aug 2011. The plain-English explanation above is BankPulse’s own independent summary.
Screen all new account applications against the updated list before onboarding.
📜 Compliance
Update your internal database with the latest consolidated UNSCR 1267/1822 list from the UN website.
Conduct a one-time review of all existing accounts to identify any matches with the list.
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 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 Update UN Terrorist List for KYC Compliance” is: “Update your internal database with the latest consolidated UNSCR 1267/1822 list from the UN website.” (RBI issued this 02 Aug 2011).
Circular: RBI/2011-12/137 -- NBFCs Must Update UN Terrorist List for KYC Compliance
Issued: 02 Aug 2011
Action required: Update your internal database with the latest consolidated UNSCR 1267/1822 list from the UN website.
Action required: Screen all new account applications against the updated list before onboarding.
Action required: Conduct a one-time review of all existing accounts to identify any matches with the list.
Action required: Report any matches to the appropriate authorities as per regulatory guidelines.
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=6649&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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