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
- Obtain the Gazette of India order dated November 4, 2011, and the list of sanctioned individuals/entities.
- Cross-check all new account opening applications and existing account transactions against this list.
- Report any accounts or transactions that match the listed individuals/entities to RBI and FIU-IND immediately.
- Update internal AML/KYC systems to include this sanctions list for ongoing screening.
Who it affects
All Non-Banking Financial Companies (NBFCs), All Residuary Non-Banking Companies (RNBCs)
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.