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NBFCs Must Screen Accounts Against UNSCR 1929 Sanctions List

Current · Source: Reserve Bank of India · RBI/2011-12/442 · issued 04 Nov 2011 · ~1 min read
Quick answerRBI directs NBFCs/RNBCs to cross-check all new and existing accounts against the UNSCR 1929 sanctions list published in the Gazette of India on November 4, 2011, and report matches to RBI and FIU-IND.
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

A compliance officer at a Non-Banking Financial Company in Mumbai will use this rule every day by carefully checking all new account applications and existing transactions against the sanctions list, and immediately reporting any matches to the RBI and FIU-IND to prevent any potential illegal activities. This helps keep the financial system safe and secure. The officer will also update the company's internal systems to include this sanctions list for ongoing screening.

What changed

RBI issued a circular on March 14, 2012, enclosing the Ministry of External Affairs order of November 4, 2011, which implements UN Security Council Resolution 1929 (2010) on non-proliferation. NBFCs/RNBCs are now required to verify account applications and existing transactions against the listed individuals/entities and report any matches.

What it means for you

NBFCs and RNBCs must strengthen their KYC and transaction monitoring processes to screen against the updated sanctions list. Failure to identify and report matches could lead to regulatory action. This aligns India with global non-proliferation efforts and enhances financial system integrity.

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 sanctions list I need to check against?

The list is from the Ministry of External Affairs order dated November 4, 2011, published in the Gazette of India, implementing UN Security Council Resolution 1929 (2010) on non-proliferation.

What should I do if I find a match with the sanctions list?

You must report the account or transaction to both the Reserve Bank of India and the Financial Intelligence Unit-India (FIU-IND) immediately.

Does this apply only to new accounts or also to existing ones?

It applies to both: all new account opening applications and all transactions carried out in existing accounts must be cross-checked against the list.

📜 Read the original circular — full text as issued by RBI
RBI/2011-12/442 DNBS(PD).CC. No 258/03.10.42/2011-12 March 14 , 2012 All Non Banking Financial Companies / Residuary Non Banking Companies Dear Sir, Implementation of UNSCR 1929 (2010) on Non-proliferation –Government of India Order of November 04, 2011 Please find enclosed a copy of Ministry of External Affairs Order dated November 4, 2011 published in the Gazette of India on implementation of United Nations Security Council Resolution 1929 (2010). 2. Utmost care should be taken by NBFCs/RNBCs to ensure to cross check all account opening applications and transactions carried out in the existing accounts with the list of individuals / entities enlisted in the Gazette and report those accounts to Reserve Bank of India and Financial Intelligence Unit-India which bear resemblance with the individuals / entities listed therein. Yours faithfully, (Dr Tuli Roy) Deputy General Manager Encl: as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/442 · issued 04 Nov 2011. The plain-English explanation above is BankPulse’s own independent summary.
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Related circulars · NBFC Regulation
NBFCs: PMLA Compliance & Transaction Monitoring UpdateAnnual NBS-7 Return Mandate for NBFC-ND-SIMaster Circular: Exemptions from RBI Act, 1934 for NBFCsMaster Circular: NBFC/RNBC Liquid Asset Returns & MaintenanceNBFC Auditor Report Directions 1998: Master Circular
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Who does what — compliance checklist
🏦 Branch Manager
  • Cross-check all new account opening applications and existing account transactions against this list.
💻 IT / Systems
  • Update internal AML/KYC systems to include this sanctions list for ongoing screening.
📜 Compliance
  • Obtain the Gazette of India order dated November 4, 2011, and the list of sanctioned individuals/entities.
  • Report any accounts or transactions that match the listed individuals/entities to RBI and FIU-IND immediately.
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 Screen Accounts Against UNSCR 1929 Sanctions List” is: “Obtain the Gazette of India order dated November 4, 2011, and the list of sanctioned individuals/entities.” (RBI issued this 04 Nov 2011).

  1. Circular: RBI/2011-12/442 -- NBFCs Must Screen Accounts Against UNSCR 1929 Sanctions List
  2. Issued: 04 Nov 2011
  3. Action required: Obtain the Gazette of India order dated November 4, 2011, and the list of sanctioned individuals/entities.
  4. Action required: Cross-check all new account opening applications and existing account transactions against this list.
  5. Action required: Report any accounts or transactions that match the listed individuals/entities to RBI and FIU-IND immediately.
  6. Action required: Update internal AML/KYC systems to include this sanctions list for ongoing screening.
  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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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=7060&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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