What changed
The UN Security Council's 1988 Committee issued multiple notes (March 2, March 19, May 18, June 1, and June 11, 2012) updating the sanctions list of individuals and entities linked to the Taliban. RBI now requires NBFCs to incorporate these updates into their compliance checks.
What it means for you
NBFCs must immediately update their internal sanctions screening databases with the latest UN list revisions. Failure to screen new and existing customers against this list could lead to regulatory action under UAPA, 1967. This reinforces the need for robust AML/KYC frameworks.
What you must do
- Update your internal sanctions list with the latest UNSCR 1988 changes from the notes dated March 2, March 19, May 18, June 1, and June 11, 2012.
- Before opening any new account, verify the proposed customer's name against the updated sanctions list.
- Conduct a retrospective scan of all existing accounts to identify any matches with the updated list.
- Ensure compliance teams have access to the UN website (http://www.un.org/sc/committees/1988/list.shtml) for the complete list.
- Document all screening actions and maintain records for regulatory inspection.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs), Compliance and AML/KYC teams at NBFCs
What is the UNSCR 1988 sanctions list?
It is a list maintained by the UN Security Council's 1988 Committee of individuals and entities associated with the Taliban, subject to asset freezes and other sanctions.
Do we need to check only new accounts or existing ones too?
Both. The circular explicitly requires NBFCs to screen new accounts before opening and to scan all existing accounts for any links to the updated list.
Where can we find the complete sanctions list?
The full list is available on the UN website at http://www.un.org/sc/committees/1988/list.shtml, as referenced in the RBI circular.