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NBFCs Must Update Al-Qaida Sanctions List for UAPA Compliance

Current · Source: Reserve Bank of India · RBI/2011-12/471 · issued 26 Mar 2012 · ~1 min read
Quick answerRBI directs all NBFCs to update the UN Al-Qaida sanctions list, screen new and existing accounts against it, and ensure no prohibited individuals or entities are linked. Non-compliance risks regulatory action.
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 large NBFC in Mumbai will download the updated Al-Qaida sanctions list from the UN website and cross-verify it with the RBI's circulated list. She will then screen all new account applications and review existing accounts to identify and flag any matches, reporting them to the regulatory authorities immediately to ensure her company's compliance with UAPA [Unlawful Activities Prevention Act] regulations.

What changed

RBI issued a circular on March 26, 2012, referencing updates to the UN Security Council's 1267/1989 Committee's Al-Qaida Sanctions List as of January 26, 2012. NBFCs must now incorporate these changes into their customer screening processes.

What it means for you

NBFCs must proactively update their internal blacklists with the latest UN sanctions list to prevent any dealings with listed individuals or entities. This enhances compliance with UAPA and strengthens anti-terror financing measures. Failure to screen accounts could expose banks to legal and reputational risks.

What you must do

Who it affects

All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)

❓ Common questions

What is the source of the updated sanctions list?

The list is maintained by the UN Security Council's 1267/1989 Committee and 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 screen new accounts before opening and also scan all existing accounts to ensure none are linked to listed individuals or entities.

What happens if we find a match in an existing account?

You should immediately report the match to the relevant authorities as per UAPA guidelines and take necessary action, including freezing the account.

📜 Read the original circular — full text as issued by RBI
RBI/2011-12/471 DNBS(PD).CC. No 267/03.10.42/2011-12 March 26, 2012 All Non Banking Financial Companies / Residuary Non Banking Companies Dear Sir, Implementation of Section 51-A of UAPA, 1967-Updates of the UNSCR 1267 (1999) /2989 (2011) Committee's Al Qaida Sanctions List Please refer to DNBS (PD).CC. No 261/03.10.42 /2011-12 dated March 20, 2012 . The Chairman of UN Security Council's 1267/ 1989 Committee has issued note on January 26, 2012 ( copy enclosed ) regarding changes made in the “Al-Qaida Sanctions List”, i.e. list of Individuals and entities linked to Al-Qaida. 2. All NBFCs are required to update the list 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 the 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 list. 3. The complete details of the said list are available on the UN website : http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml Yours faithfully, (Dr Tuli Roy) Deputy General Manager Encl: as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/471 · issued 26 Mar 2012. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
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Who does what — compliance checklist
💻 IT / Systems
  • Screen all new account applications against the updated list before onboarding customers.
📜 Compliance
  • Download the updated Al-Qaida Sanctions List from the UN website and cross-verify with RBI's circulated list.
  • Review all existing accounts to identify and flag any matches with the sanctions list.
  • Report any matches to the appropriate regulatory and law enforcement authorities 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), Residuary Non-Banking Companies (RNBCs)), your first concrete step on “NBFCs Must Update Al-Qaida Sanctions List for UAPA Compliance” is: “Download the updated Al-Qaida Sanctions List from the UN website and cross-verify with RBI's circulated list.” (RBI issued this 26 Mar 2012).

  1. Circular: RBI/2011-12/471 -- NBFCs Must Update Al-Qaida Sanctions List for UAPA Compliance
  2. Issued: 26 Mar 2012
  3. Action required: Download the updated Al-Qaida Sanctions List from the UN website and cross-verify with RBI's circulated list.
  4. Action required: Screen all new account applications against the updated list before onboarding customers.
  5. Action required: Review all existing accounts to identify and flag any matches with the sanctions list.
  6. Action required: Report any matches to the appropriate regulatory and law enforcement authorities immediately.
  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.

💬 Banker Discussion

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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=7090&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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