NBFCs Must Update UN Terrorist List for KYC Compliance
Current · Source: Reserve Bank of India · RBI/2011-12/235 · issued 28 Oct 2011 · ~1 min read
Quick answerRBI directs all NBFCs and RNBCs to update their records with the latest UN 1267 Committee consolidated list of Al-Qaida/Taliban-linked individuals and entities, screen new accounts against it, 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
NBFCs and RNBCs must update their internal databases with the latest UN 1267 consolidated list of terrorist individuals and entities (the list can be found on the UN website).
Before opening any new account, they must screen the proposed customer’s name against this list to ensure it is not present.
They must also scan all existing customer accounts to check for any matches with the list.
If a match is found, they must report it to the relevant authorities following AML/CFT guidelines.
Failure to comply can lead to regulatory action and damage the company’s reputation.
How it plays out — a real example
A loan officer named Rohan at a NBFC in Pune checks the new applicant’s name against the UN list before approving the loan. He finds a match, stops the account, and reports it to the compliance team, ensuring the company stays compliant and protects its reputation.
What changed
RBI issued a circular on October 28, 2011, referencing UN Security Council updates from July 29, August 12, and August 22, 2011, to the consolidated list of terrorist individuals and entities. This supersedes the previous circular dated September 12, 2011, and requires NBFCs/RNBCs to incorporate these changes into their screening processes.
What it means for you
NBFCs and RNBCs must immediately update their internal KYC and AML systems with the revised UN list to avoid onboarding or servicing prohibited entities. Failure to screen new and existing accounts could lead to regulatory action and reputational risk. This reinforces the sector's role in combating terror financing.
What you must do
Update your internal database with the latest UN 1267 Committee consolidated list from the UN website.
Screen all new account applications against the updated list before account opening.
Conduct a fresh scan of all existing customer accounts to identify any matches with the list.
Report any matches to the relevant authorities as per existing AML/CFT guidelines.
Who it affects
All Non-Banking Financial Companies (NBFCs), All Residuary Non-Banking Companies (RNBCs)
❓ Common questions
Where can we access the latest consolidated list?
The complete consolidated list is available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
Do we need to check only new accounts or existing ones too?
Both. You must ensure new accounts are not linked to listed entities, and you must scan all existing accounts to identify any links.
What should we do if we find a match in an existing account?
Follow your existing AML/CFT reporting procedures and inform the appropriate authorities as per regulatory guidelines.
📜 Read the original circular — full text as issued by RBI
RBI/2011-12/235
DNBS(PD).CC. No 246/03.10.42/2011-12
October 28, 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 241 dated September 12, 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 July 29, 2011 , August 12, 2011 and August 22, 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/aq_sanctions_list.shtml
Yours faithfully,
(A. Mangalagiri)
General Manager
Encl:as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/235 · issued 28 Oct 2011. The plain-English explanation above is BankPulse’s own independent summary.
Screen all new account applications against the updated list before account opening.
📜 Compliance
Update your internal database with the latest UN 1267 Committee consolidated list from the UN website.
Conduct a fresh scan of all existing customer accounts to identify any matches with the list.
Report any matches to the relevant authorities as per existing AML/CFT 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), All 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 UN 1267 Committee consolidated list from the UN website.” (RBI issued this 28 Oct 2011).
Circular: RBI/2011-12/235 -- NBFCs Must Update UN Terrorist List for KYC Compliance
Issued: 28 Oct 2011
Action required: Update your internal database with the latest UN 1267 Committee consolidated list from the UN website.
Action required: Screen all new account applications against the updated list before account opening.
Action required: Conduct a fresh scan of all existing customer accounts to identify any matches with the list.
Action required: Report any matches to the relevant authorities as per existing AML/CFT 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=6782&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.
Help us keep this accurate
Found an inaccuracy or have an improvement? Tell us. Every report is reviewed by our team before any change is made — nothing goes live unverified.
Public beta — plain-English informational summaries. Always verify against the official RBI source (circular number cited on every page) before making compliance, credit, treasury, audit, or operational decisions. · Join our WhatsApp channel ↗
BANKPULSE · FREE DAILY BRIEF
Get RBI updates for your role
Every important RBI update, decoded in plain English — for your career, exams & financial awareness.
We collect only your email, name and role, used solely to send your brief — never sold or shared. Withdraw anytime via the unsubscribe link in any email. Independent platform, not affiliated with the RBI. Information, not legal advice.
REPORT AN ERROR · BETA
Spotted an error? Earn 500 BankPulse Credits
Help us stay accurate. If your correction is verified true and approved by our founder, you earn 500 BankPulse Credits — redeemable when the platform monetises.
Reviewed by a human before any credit is awarded. We never change the site from crowd input without verification.
WANT A NEW FEATURE · BETA
What would make BankPulse more useful for you?
Tell us what to build next — a tool, a data view, a role page, anything. We read every suggestion.
Thank you — your ideas directly shape what we build.