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)
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.