NBFCs Must Update Al-Qaida Sanctions List for UAPA Compliance
Current · Source: Reserve Bank of India · RBI/2012-13/232 · issued 03 Oct 2012 · ~1 min read
Quick answerRBI directs all NBFCs to update their records with the latest UN Al-Qaida sanctions list. Before opening new accounts, verify proposed customers are not on the list, and scan existing accounts for any matches.
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
NBFCs (companies that give loans but are not banks) must get the newest UN Al-Qaida sanctions list (a list of bad people/groups linked to Al-Qaida) from the UN website.
Before opening a new account, check that the customer's name is NOT on that list.
Also check all existing accounts to see if any match the list, and report any matches.
This is a legal rule under Section 51-A of UAPA (a law against terrorism), and not following it can get the NBFC in trouble.
How it plays out — a real example
An NBFC compliance officer in Indore updates her NBFC's internal system with the latest UN Al-Qaida list from July and August 2012. Before approving a new gold loan for a customer, she runs the name through the updated list and finds no match, so she proceeds. She also checks all existing loan accounts and finds none linked to the list, keeping her branch compliant.
What changed
The UN Security Council's 1267/1989 Committee issued notes on July 5, 20, 27, and August 29, 2012, updating the Al-Qaida Sanctions List. RBI now requires NBFCs to incorporate these changes into their customer screening processes.
What it means for you
NBFCs must proactively update their internal databases with the revised UN sanctions list to prevent any dealings with listed individuals or entities. This is a legal obligation under Section 51-A of UAPA, 1967, and non-compliance could lead to regulatory action.
What you must do
Update your internal sanctions list with the latest UN Al-Qaida list from the UN website.
Screen all new account applications against the updated list before onboarding.
Review all existing accounts to identify and report any matches with the list.
Ensure compliance teams are aware of the July and August 2012 UN notes.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)
❓ Common questions
Where can I find the complete updated sanctions list?
The full list is available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
What should I do if I find an existing account matching the list?
You must immediately report and freeze the account as per UAPA guidelines, and inform the RBI and other relevant authorities.
📜 Read the original circular — full text as issued by RBI
RBI/2012-13/232
DNBS(PD).CC. No 306/03.10.42/2012-13
October 3, 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 302/03.10.42/2012-13 dated September 7, 2012 . The Chairman of UN Security Council's 1267/ 1989 Committee has issued notes dated July 5, 2012 , July 20, 2012 and July 27, 2012 and August 29, 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/2012-13/232 · issued 03 Oct 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 list from the UN website.
Review all existing accounts to identify and report any matches with the list.
Ensure compliance teams are aware of the July and August 2012 UN notes.
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 list from the UN website.” (RBI issued this 03 Oct 2012).
Circular: RBI/2012-13/232 -- NBFCs Must Update Al-Qaida Sanctions List for UAPA Compliance
Issued: 03 Oct 2012
Action required: Update your internal sanctions list with the latest UN Al-Qaida list from the UN website.
Action required: Screen all new account applications against the updated list before onboarding.
Action required: Review all existing accounts to identify and report any matches with the list.
Action required: Ensure compliance teams are aware of the July and August 2012 UN notes.
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=7603&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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