Home › Circulars › RBI/2012-13/115

NBFCs must update UN Al-Qaida sanctions list for KYC compliance

Current · Source: Reserve Bank of India · RBI/2012-13/115 · issued 05 Jul 2012 · ~1 min read
Quick answerRBI directs all NBFCs to update their records with the latest UN Al-Qaida sanctions list. Before opening new accounts, verify customer names against this list. Also, scan existing accounts to ensure no account is linked to listed individuals or entities.
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

Mr. Kumar checks the UN website for the latest list and updates his internal sanctions screening database. He then verifies Mr. Ali's name against the list and finds no match. However, during the retrospective scan, he discovers that an existing account holder, Mr. Khan, is linked to a listed entity. Mr. Kumar reports this to the relevant authorities as per UAPA, 1967 guidelines. A KYC & compliance officer in Indore, Mr. Kumar, verifies the name of a new customer, Mr. Ali, against the updated UN Al-Qaida sanctions list before opening a new account. He also scans the existing accounts to ensure no account is linked to listed individuals or entities.

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

Who it affects

All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)

❓ Common questions

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.

📜 Read the original circular — full text as issued by RBI
RBI/2012-13/115 DNBS(PD).CC.No 294/03.10.42/2012-13 July 05, 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 271/03.10.42/2011-12 dated May 3, 2012 . The Chairman of UN Security Council's 1267/ 1989 Committee has issued notes dated April 30, 2012 , May 3, 2012 , May 7, 2012 , May 9, 2012 , May 10, 2012 , May 18, 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) General Manager Encl: as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2012-13/115 · issued 05 Jul 2012. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
Most relevant forKYC / AML AnalystCompliance TeamBranch Operations (Accounts / FD / CASA)Video-KYC OfficerTeller / Cashier / Customer Service OfficerPersonal Banker / Branch RM (Portfolio)
🛠 Banker’s toolkit — checklists & reply templates →
Related circulars · NBFC Regulation
NBFCs: PMLA Compliance & Transaction Monitoring UpdateAnnual NBS-7 Return Mandate for NBFC-ND-SIMaster Circular: Exemptions from RBI Act, 1934 for NBFCsMaster Circular: NBFC/RNBC Liquid Asset Returns & MaintenanceNBFC Auditor Report Directions 1998: Master Circular
Browse all departments →
Who does what — compliance checklist
💻 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 sanctions list from the UN website.
  • 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.
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 UN Al-Qaida sanctions list for KYC compliance” is: “Update your internal sanctions list with the latest UN Al-Qaida sanctions list from the UN website.” (RBI issued this 05 Jul 2012).

  1. Circular: RBI/2012-13/115 -- NBFCs must update UN Al-Qaida sanctions list for KYC compliance
  2. Issued: 05 Jul 2012
  3. Action required: Update your internal sanctions list with the latest UN Al-Qaida sanctions list from the 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 accounts to identify any matches with the updated list.
  6. Action required: Report any matches to the relevant authorities as per UAPA, 1967 guidelines.
  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.

💬 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.

Loading comments…
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=7427&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.
Public beta — plain-English informational summaries. Always verify against the official RBI source (circular number cited on every page) before making compliance, credit, treasury, audit, or operational decisions. · Join our WhatsApp channel ↗
—