What changed
The UN Security Council split its consolidated sanctions list into two: the Al-Qaida Sanctions List (maintained by the 1267/1989 Committee) and the 1988 Sanctions List (for Taliban-associated entities). NBFCs must now refer to both lists separately for compliance with Section 51A of the UAPA, 1967.
What it means for you
NBFCs need to update their internal screening databases to include both new lists. Failure to check both lists could result in non-compliance with anti-terror financing regulations. This adds a step but aligns with global sanctions frameworks.
What you must do
- Update your customer screening systems to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.
- Before opening any new account, verify the proposed customer's name against both lists.
- Scan all existing accounts to ensure no account is linked to any individual or entity on either list.
- Circulate the updated lists within your organization as per RBI instructions.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)
What are the two new sanctions lists I need to check?
The Al-Qaida Sanctions List (maintained by the 1267/1989 Committee) and the 1988 Sanctions List (for Taliban-associated entities). Both are available on the UN website.
Do I 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 any listed individual or entity.
What law requires this action?
Section 51A of the Unlawful Activities (Prevention) Act, 1967, as per the Ministry of Home Affairs order dated 27 August 2009.