NBFCs Must Update Al-Qaida Sanctions List for UAPA Compliance
Current · Source: Reserve Bank of India · RBI/2011-12/486 · issued 26 Mar 2011 · ~1 min read
Quick answerRBI directs all NBFCs to update their records with the latest UN Al-Qaida Sanctions List. Before opening new accounts, check customer names against this list. Also, review existing accounts to ensure no linked entities are present.
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 internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.
Screen all new account applicants against the updated list before account opening.
Review all existing accounts to identify and flag any matches with the list.
Maintain records of screening and actions taken for audit purposes.
How it plays out — a real example
Before opening a new gold loan account for a customer named 'Mohammed', Rohan, the NBFC compliance officer in Indore, checks Mohammed's name against the updated UN Al-Qaida Sanctions List. After verifying that Mohammed's name is not on the list, Rohan proceeds with the account opening process. He also reviews the existing accounts to ensure that no linked entities are present, maintaining records of the screening and actions taken for audit purposes.
What changed
The UN Security Council's 1267/1989 Committee issued notes on February 23, March 6, and March 12, 2012, updating the Al-Qaida Sanctions List. RBI now requires NBFCs to incorporate these changes into their screening processes.
What it means for you
NBFCs must proactively update their internal lists to match the UN's latest sanctions. This ensures compliance with Section 51-A of UAPA, 1967, and prevents inadvertent dealings with prohibited individuals or entities. Non-compliance could lead to regulatory action.
What you must do
Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.
Screen all new account applicants against the updated list before account opening.
Review all existing accounts to identify and flag any matches with the list.
Maintain records of screening and actions taken for audit purposes.
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 their website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
Do we need to check existing customers as well?
Yes, the circular explicitly requires NBFCs to scan all existing accounts to ensure no account is held by or linked to any entity or individual on the updated list.
📜 Read the original circular — full text as issued by RBI
RBI/2011-12/486
DNBS(PD).CC. No.269 /03.10.42 /2011-12
April 04 , 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) /1989( 2011) Committee's Al Qaida Sanctions List
Please refer to DNBS (PD).CC. No 267 /03.10.42 /2011-12 dated March 26, 2011 . The Chairman of UN Security Council's 1267/ 1989 Committee has issued notes dated February 23, 2012 , March 6, 2012 , and March 12, 2012 (copies 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/2011-12/486 · issued 26 Mar 2011. The plain-English explanation above is BankPulse’s own independent summary.
Screen all new account applicants against the updated list before account opening.
⚙️ Operations
Maintain records of screening and actions taken for audit purposes.
📜 Compliance
Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.
Review all existing accounts to identify and flag any matches with the list.
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: “Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.” (RBI issued this 26 Mar 2011).
Circular: RBI/2011-12/486 -- NBFCs Must Update Al-Qaida Sanctions List for UAPA Compliance
Issued: 26 Mar 2011
Action required: Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.
Action required: Screen all new account applicants against the updated list before account opening.
Action required: Review all existing accounts to identify and flag any matches with the list.
Action required: Maintain records of screening and actions taken for audit purposes.
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=7109&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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