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UAPA Compliance: Update Al-Qaida Sanctions List for NBFCs

Current · Source: Reserve Bank of India · RBI/2012-13/196 · issued 07 Sep 2012 · ~1 min read
Quick answerRBI directs all NBFCs to update their records with the latest UN Al-Qaida sanctions list (as of June-July 2012) and screen new and existing accounts against it to comply with Section 51-A of UAPA, 1967.
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

An NBFC compliance officer in Indore receives the RBI circular on September 7, 2012. She immediately updates her office's internal blacklist with the new UN Al-Qaida names from June-July 2012. The next day, when a new customer applies for a gold loan, she screens his name against the list and finds no match, so she proceeds with the account opening. She also runs a check on all 500 existing accounts and finds none linked to the list, ensuring full compliance.

What changed

The UN Security Council's 1267/1989 Committee updated its Al-Qaida Sanctions List through notes dated June 21, June 28, and July 2, 2012. RBI has now communicated these changes to all NBFCs, requiring them to incorporate the revised list into their customer screening processes.

What it means for you

NBFCs must immediately update their internal blacklists with the latest UN-designated individuals and entities linked to Al-Qaida. This is a mandatory compliance step under UAPA; failure to screen new and existing customers against this list could lead to regulatory action. It reinforces the need for robust AML/KYC frameworks in the NBFC sector.

What you must do

Who it affects

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

❓ Common questions

What is the source of the updated sanctions list?

The list is maintained by the UN Security Council's 1267/1989 Committee and is available on their website. RBI has circulated the changes via this circular.

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 none are linked to listed individuals or entities.

What happens if I find a match in an existing account?

You must follow the procedures under Section 51-A of UAPA, 1967, which typically involves freezing the account and reporting to the relevant authorities.

📜 Read the original circular — full text as issued by RBI
RBI/2012-13/196 DNBS (PD).CC. No 302 /03.10.42 /2012-13 September 7, 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 296/03.10.42/2012-13 dated July 11, 2012 . The Chairman of UN Security Council's 1267/ 1989 Committee has issued notes dated June 21, 2012 , June 28, 2012 , and July 2, 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/2012-13/196 · issued 07 Sep 2012. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
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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 entries from June-July 2012.
  • Conduct a one-time review of all existing accounts to identify any matches with the updated list.
  • Report any matches to the 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 “UAPA Compliance: Update Al-Qaida Sanctions List for NBFCs” is: “Update your internal sanctions list with the latest UN Al-Qaida Sanctions List entries from June-July 2012.” (RBI issued this 07 Sep 2012).

  1. Circular: RBI/2012-13/196 -- UAPA Compliance: Update Al-Qaida Sanctions List for NBFCs
  2. Issued: 07 Sep 2012
  3. Action required: Update your internal sanctions list with the latest UN Al-Qaida Sanctions List entries from June-July 2012.
  4. Action required: Screen all new account applications against the updated list before onboarding.
  5. Action required: Conduct a one-time review 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 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.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=7553&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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