What changed
RBI issued a circular on July 5, 2012, updating the UNSCR 1267/1989 Al-Qaida sanctions list based on multiple notes from the UN Security Council Committee dated April 30 to May 18, 2012. This supersedes the previous circular of May 3, 2012, and requires NBFCs to incorporate these changes into their compliance checks.
What it means for you
NBFCs must immediately update their internal sanctions screening databases with the revised UN list. Failure to comply could lead to regulatory action. This reinforces the importance of robust KYC and AML frameworks to prevent financing of terrorism.
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 applications against the updated list before onboarding.
- Conduct a retrospective scan of all existing accounts to identify any matches with the updated list.
- Report any matches to the relevant authorities as per UAPA, 1967 guidelines.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)
Where can I find the complete updated sanctions list?
The full list is available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
What should I do if I find a match in an existing account?
You must immediately freeze the account and report the details to the RBI and other designated authorities under the UAPA, 1967.
Does this circular apply to all NBFCs?
Yes, it applies to all Non-Banking Financial Companies and Residuary Non-Banking Companies regulated by RBI.