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)
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.