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NBFCs Must Update UNSCR 1267/1989 Al-Qaida Sanctions List for UAPA Section 51-A Compliance

Current · Source: Reserve Bank of India · RBI/2011-12/531 · issued 03 May 2012 · ~2 min read
Quick answerRBI directs all NBFCs to update their records with the latest UNSCR 1267/1989 Committee's Al-Qaida sanctions list as circulated by RBI. Before opening new accounts, check proposed customers against this list and scan existing accounts for any matches. 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

An NBFC compliance officer in Indore updates her computer with the latest UN sanctions list from the RBI. She then checks every new customer's name against that list before approving any loan, and also runs a scan of all her existing borrowers to make sure none are on the list.

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

Who it affects

All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs), Compliance and AML teams at NBFCs

❓ 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 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.

📜 Read the original circular — full text as issued by RBI
RBI/2011-12/531 DNBS(PD).CC. No 271 /03.10.42 /2011-12 May 3, 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 269 /03.10.42 /2011-12 dated April 4, 2012 . The Chairman of UN Security Council's 1267/ 1989 Committee has issued notes dated March 14, 2012 , March 21, 2012 , April 2, 2012 and April 13, 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/2011-12/531 · issued 03 May 2012. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
Most relevant forCompliance TeamKYC / AML AnalystBranch Operations (Accounts / FD / CASA)Branch Manager — PSU / Co-op / RRB (sanctioning powers)Branch Manager — Private Bank / SFBInternal Audit
🛠 Banker’s toolkit — checklists & reply templates →
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Who does what — compliance checklist
⚙️ Operations
  • Document all screening actions and maintain records for audit purposes.
💻 IT / Systems
  • Screen all new account applications against the updated list before onboarding.
📜 Compliance
  • Update your internal sanctions list with the latest UN Al-Qaida entries as circulated by RBI from the provided UN website.
  • Conduct a retrospective scan of all existing customer accounts to identify any matches.
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), Compliance and AML teams at NBFCs), your first concrete step on “NBFCs Must Update UNSCR 1267/1989 Al-Qaida Sanctions List for UAPA Section 51-A Compliance” is: “Update your internal sanctions list with the latest UN Al-Qaida entries as circulated by RBI from the provided UN website.” (RBI issued this 03 May 2012).

  1. Circular: RBI/2011-12/531 -- NBFCs Must Update UNSCR 1267/1989 Al-Qaida Sanctions List for UAPA Section 51-A Compliance
  2. Issued: 03 May 2012
  3. Action required: Update your internal sanctions list with the latest UN Al-Qaida entries as circulated by RBI from the provided UN website.
  4. Action required: Screen all new account applications against the updated list before onboarding.
  5. Action required: Conduct a retrospective scan of all existing customer accounts to identify any matches.
  6. Action required: Document all screening actions and maintain records for audit purposes.
  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.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=7175&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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