What changed
The UN Security Council's 1988 Committee issued two notes (dated October 19 and 25, 2012) making changes to the '1988 Sanctions List' of individuals and entities linked to the Taliban. RBI has communicated these updates to all NBFCs and RNBCs, requiring them to incorporate the revised list into their compliance checks.
What it means for you
NBFCs must immediately update their internal sanctions screening systems with the latest UN list. Before onboarding any new customer, you must verify the proposed name against this updated list. Additionally, you are required to review all existing accounts to identify and flag any matches with the listed individuals or entities.
What you must do
- Update your internal sanctions list with the latest UNSCR 1988 Taliban list as of October 25, 2012.
- Screen all new account applications against the updated list before opening accounts.
- Conduct a one-time review of all existing accounts to check for matches with the updated list.
- Ensure compliance with Section 51-A of UAPA, 1967, and report any matches to the appropriate authorities.
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/1988/list.shtml.
Do I need to screen only new customers or also existing ones?
Both. You must screen new customers before opening accounts and also scan all existing accounts to ensure none are held by or linked to listed individuals or entities.
What is the legal basis for this requirement?
This directive is issued under Section 51-A of the Unlawful Activities (Prevention) Act, 1967 (UAPA), which empowers the government to prevent financing of terrorism.