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
- Update your internal sanctions list with the latest UN Al-Qaida Sanctions List entries from June-July 2012.
- Screen all new account applications against the updated list before onboarding.
- 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.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)
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.