What changed
RBI has issued an update to the UN Security Council's 1267/1989 Committee's Al-Qaida Sanctions List, incorporating changes from notes dated March 14, 2012, March 21, 2012, April 2, 2012, and April 13, 2012. This follows a previous circular (DNBS (PD).CC. No 269 /03.10.42 /2011-12 dated April 4, 2012) and requires NBFCs to refresh their screening databases.
What it means for you
NBFCs must immediately update their customer due diligence systems with the revised sanctions list. Failure to screen new and existing accounts could lead to violations of the UAPA, 1967, exposing the institution to legal and reputational risks. This is a standard but critical compliance update for all NBFCs.
What you must do
- Update your internal sanctions list with the latest UN Al-Qaida entries as circulated by RBI from the provided UN website.
- Screen all new account applications against the updated list before onboarding.
- Conduct a retrospective scan of all existing customer accounts to identify any matches.
- Document all screening actions and maintain records for audit purposes.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs), Compliance and AML teams at NBFCs
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 official website. RBI has circulated the latest changes via this circular.
Do we need to screen only new customers or existing ones too?
Both. You must check all new accounts before opening and also scan all existing accounts to ensure no account is linked to any listed entity or individual.
What happens if we find a match in an existing account?
The circular requires that you ensure no account is held by or linked to any listed entity or individual. Further actions would be as per UAPA guidelines and standard regulatory protocols.