UN Sanctions Lists Split: NBFCs Must Update Screening
Current · Source: Reserve Bank of India · RBI/2011-12/447 · issued 15 Mar 2012 · ~1 min read
Quick answerRBI directs NBFCs to use two separate UN sanctions lists—Al-Qaida and Taliban—for customer screening under UAPA Section 51A. Both lists must be checked before opening new accounts and for existing accounts.
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
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.
How it plays out — a real example
An NBFC compliance officer in Indore, Mr. Kumar, ensures that all new customers are checked against both the Al-Qaida Sanctions List and the 1988 Sanctions List before opening a new account. He also scans all existing accounts to ensure that no account is linked to any individual or entity on either list, as per RBI instructions.
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)
❓ Common questions
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.
📜 Read the original circular — full text as issued by RBI
RBI/2011-12/447
DNBS(PD).CC. No 260 /03.10.42 /2011-12
March 15, 2012
All Non Banking Financial Companies /
Residuary Non Banking Companies
Dear Sir,
Implementation of Section 51-A of UAPA, 1967- Splitting of UNSC 1267
Committee's list of individuals and entities linked to Al-Qaida and Taliban
Please refer to the UN Security Council's 1267 Committee’s Consolidated List of individuals and entities linked to Al-Qaida and Taliban who are subject to the assets freeze, travel ban and arms embargo as set out in relevant Security Council Resolution 1822 (2008). Pursuant to being included in the 1267 Committee’s Consolidated List these individuals and entities are subject of action under Section 51A of the Unlawful Activities (Prevention) Act, 1967.
2. The UN Security Council has adopted Resolutions 1988 (2011) and 1989 (2011) which have resulted in splitting of the Consolidated List into two separate lists , namely:
(i) “Al-Qaida Sanctions List”, which is maintained by the 1267 / 1989 Committee. This List shall include only the names of those individuals, groups, undertakings and entities associated with Al-Qaida. General information on the work of the committee is available at http://www.un.org/sc/committees/1267/information.shtml . The Updated Al-Qaida Sanctions List is available at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml
(ii) “1988 Sanctions List”, which is maintained by the 1988 Committee. This list consists of names previously included in Sections A (“Individuals associated with the Taliban”) and B (“Entities and other groups and undertakings associated with the Taliban”) of the Consolidated List. The Updated 1988 Sanctions list is available at
http://www.un.org/sc/committees/1988/list.shtml
3. It may be noted that both “Al-Qaida Sanctions List” and “1988 Sanctions List” are to be taken into account for the purpose of implementation of Section 51A of the Unlawful Activities (Prevention) Act, 1967.
4. This information is being issued in pursuance of the instructions contained in the Ministry of Home Affairs (Internal Security-I Division), Government of India’s order F. No. 17015/10/2002-IS-IV, dated 27 August 2009, regarding the Procedure for implementation of Section 51A of the Unlawful Activities (Prevention) Act, 1967.
5. NBFCs are required to update the lists of individuals/entities as circulated by Reserve Bank and before opening any new account, it should be ensured that the name/s of the proposed customer does not appear in either list. Further, NBFCs 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 two lists.
Yours faithfully,
(Dr Tuli Roy)
Deputy General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/447 · issued 15 Mar 2012. The plain-English explanation above is BankPulse’s own independent summary.
Update your customer screening systems to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.
📜 Compliance
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.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template
Example: if you are an IT/Systems lead at a bank this circular applies to (All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)), your first concrete step on “UN Sanctions Lists Split: NBFCs Must Update Screening” is: “Update your customer screening systems to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.” (RBI issued this 15 Mar 2012).
Circular: RBI/2011-12/447 -- UN Sanctions Lists Split: NBFCs Must Update Screening
Issued: 15 Mar 2012
Action required: Update your customer screening systems to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.
Action required: Before opening any new account, verify the proposed customer's name against both lists.
Action required: Scan all existing accounts to ensure no account is linked to any individual or entity on either list.
Action required: Circulate the updated lists within your organization as per RBI instructions.
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=7064&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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