What changed
RBI issued a circular on July 11, 2012, referencing a UN Security Council note from May 25, 2012, that updated the Al-Qaida Sanctions List. This circular refers to the previous circular dated July 5, 2012, and requires NBFCs to incorporate the latest changes into their compliance checks.
What it means for you
NBFCs must now use the updated UN list to screen both new and existing customers for links to Al-Qaida. Failure to comply could lead to regulatory action under UAPA. This reinforces the need for robust KYC and AML processes 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 list.
- Report any matches to the RBI and relevant authorities as per UAPA guidelines.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)
Where can I find the updated Al-Qaida Sanctions List?
The complete list is available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
Do I need to check only new customers or existing ones too?
Both. You must screen new customers before opening accounts and also scan all existing accounts to ensure no account is held by or linked to listed individuals or entities.