NBFCs Must Update Al-Qaida Sanctions List for UAPA Compliance
Current · Source: Reserve Bank of India · RBI/2012-13/126 · issued 11 Jul 2012 · ~1 min read
Quick answerRBI mandates all NBFCs to update their records with the latest UN Al-Qaida sanctions list. Before opening new accounts, check customer names against this list. Also, review existing accounts to ensure no linked entities are present.
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
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.
How it plays out — a real example
An NBFC compliance officer in Indore, Mr. Kumar, checks the updated UN Al-Qaida sanctions list before opening a new account for a customer named 'Mohammed Ali'. After verifying, he finds that Mohammed Ali's name matches with an individual on the list. Mr. Kumar immediately reports this to the RBI and relevant authorities, following the UAPA guidelines to prevent any potential financing of terrorism.
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)
❓ Common questions
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.
📜 Read the original circular — full text as issued by RBI
RBI/2012-13/126
DNBS (PD).CC. No 296/03.10.42/2012-13
July 11, 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 294/03.10.42/2012-13 dated July 5, 2012 . The Chairman of UN Security Council's 1267/ 1989 Committee has issued a note dated May 25, 2012 (copy 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,
(Chandana Dasgupta)
Deputy General Manager
Encl: as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2012-13/126 · issued 11 Jul 2012. The plain-English explanation above is BankPulse’s own independent summary.
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 list.
Report any matches to the RBI and relevant authorities as per UAPA 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 Al-Qaida Sanctions List for UAPA Compliance” is: “Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.” (RBI issued this 11 Jul 2012).
Circular: RBI/2012-13/126 -- NBFCs Must Update Al-Qaida Sanctions List for UAPA Compliance
Issued: 11 Jul 2012
Action required: Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.
Action required: Screen all new account applications against the updated list before onboarding.
Action required: Conduct a retrospective scan of all existing accounts to identify any matches with the list.
Action required: Report any matches to the RBI and relevant authorities as per UAPA guidelines.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
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.
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=7444&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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