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NBFCs must update UN terror list for account screening

Current · Source: Reserve Bank of India · RBI/2011-12/172 · issued 12 Sep 2011 · ~2 min read
Quick answerRBI directs all NBFCs and RNBCs to update the consolidated UN list of individuals/entities linked to Al-Qaida and Taliban. Before opening new accounts and while reviewing existing ones, firms must ensure no customer is on this list.
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

An NBFC compliance officer in Indore, Priya, is about to open a new account for a customer. She first checks the updated UN list on her computer, sees the customer's name is not there, and proceeds. Later, she runs a scan of all existing accounts and finds one name matching the list, so she flags it for her manager to review.

What changed

RBI issued a circular on September 12, 2011, updating the previous August 2, 2011 circular on the UNSCR 1267/1822 terrorist list. The UN Security Council's 1267 Committee provided notes dated June 23, 2011 and July 19, 2011 with changes to the consolidated list of individuals and entities linked to Al-Qaida and Taliban. NBFCs and RNBCs are now required to incorporate these latest changes into their screening processes.

What it means for you

NBFCs and RNBCs must immediately update their internal databases with the revised UN consolidated list. This ensures compliance with anti-money laundering and counter-terrorism financing norms. Failure to screen new and existing accounts against this list could expose firms to regulatory action and reputational risk.

What you must do

Who it affects

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

❓ Common questions

What is the source of the list I need to use?

The consolidated list is maintained by the UN Security Council's 1267 Committee and is available at http://www.un.org/sc/committees/1267/consolist.shtml.

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

Both. You must ensure no new account is opened for a listed individual/entity, and you must scan all existing accounts to identify any that are held by or linked to listed parties.

What should I do if I find a match in an existing account?

The circular does not specify actions, but standard practice is to freeze the account, report to the Financial Intelligence Unit (FIU) and RBI, and follow applicable anti-money laundering guidelines.

📜 Read the original circular — full text as issued by RBI
RBI/2011-12/172 DNBS(PD).CC. No 241/03.10.42/2011-12 September 12, 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 240 dated August 2, 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 23, 2011 and July 19, 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/2011-12/172 · issued 12 Sep 2011. The plain-English explanation above is BankPulse’s own independent summary.
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Who does what — compliance checklist
⚙️ Operations
  • Maintain records of screening checks and any actions taken for audit and regulatory review.
📜 Compliance
  • Update your internal customer database with the latest UN consolidated list of individuals/entities linked to Al-Qaida and Taliban from the UN website.
  • Before opening any new account, verify that the proposed customer's name does not appear in the updated list.
  • Scan all existing accounts to identify and flag any account held by or linked to entities or individuals on the list.
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), All Residuary Non-Banking Companies (RNBCs)), your first concrete step on “NBFCs must update UN terror list for account screening” is: “Update your internal customer database with the latest UN consolidated list of individuals/entities linked to Al-Qaida and Taliban from the UN website.” (RBI issued this 12 Sep 2011).

  1. Circular: RBI/2011-12/172 -- NBFCs must update UN terror list for account screening
  2. Issued: 12 Sep 2011
  3. Action required: Update your internal customer database with the latest UN consolidated list of individuals/entities linked to Al-Qaida and Taliban from the UN website.
  4. Action required: Before opening any new account, verify that the proposed customer's name does not appear in the updated list.
  5. Action required: Scan all existing accounts to identify and flag any account held by or linked to entities or individuals on the list.
  6. Action required: Maintain records of screening checks and any actions taken for audit and regulatory review.
  7. Owner: ____________ Target date: ____________
  8. Board/committee approval needed? Y / N
  9. 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.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=6704&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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