Home › Circulars › RBI/2012-13/321

NBFCs Must Update UN Al-Qaida Sanctions List for UAPA Compliance

Current · Source: Reserve Bank of India · RBI/2012-13/321 · issued 10 Dec 2012 · ~2 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 against this list, and scan existing accounts to ensure no linked entities or individuals are present.
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

A KYC & compliance officer in Indore updates her system with the latest UN Al-Qaida sanctions list from the UN website. Before approving a new gold loan account, she checks the customer's name against the list and finds no match, so she proceeds safely. She also runs a scan of all existing accounts and finds one linked to a listed entity, so she reports it to the authorities as required.

What changed

RBI has issued a circular forwarding updates from the UN Security Council's 1267/1989 Committee's Al-Qaida Sanctions List, incorporating changes from notes dated September 5, 27, October 4, 5, 18, and November 15, 2012. All NBFCs must now use this updated list for customer due diligence.

What it means for you

NBFCs must immediately update their internal sanctions screening systems with the revised list to avoid onboarding or maintaining accounts for prohibited individuals/entities. Failure to comply could lead to regulatory action under UAPA, 1967. This is a critical compliance requirement for all NBFCs.

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 official website. RBI has circulated the changes via this circular.

Do we need to check only new customers or existing ones too?

Both. You must screen all new customers before account opening and also scan all existing accounts to ensure no account is linked to any listed entity or individual.

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

You must immediately report the match to the relevant authorities as per the provisions of Section 51-A of UAPA, 1967, and take necessary action as directed.

📜 Read the original circular — full text as issued by RBI
RBI/2012-13/321 DNBS(PD).CC. No 313/03.10.42 /2012-13 December 10, 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 306/03.10.42/2012-13 dated October 3, 2012 . The Chairman of UN Security Council's 1267/ 1989 Committee has issued notes dated September 5, 2012 , September 27, 2012 , October 4, 2012 , October 5, 2012 , October 18, 2012 and November 15, 2012 (copies 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/2012-13/321 · issued 10 Dec 2012. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
Most relevant forCompliance TeamKYC / AML AnalystBranch Operations (Accounts / FD / CASA)Branch Manager — PSU / Co-op / RRB (sanctioning powers)Branch Manager — Private Bank / SFBInternal Audit
🛠 Banker’s toolkit — checklists & reply templates →
Related circulars · NBFC Regulation
NBFCs: PMLA Compliance & Transaction Monitoring UpdateAnnual NBS-7 Return Mandate for NBFC-ND-SIMaster Circular: Exemptions from RBI Act, 1934 for NBFCsMaster Circular: NBFC/RNBC Liquid Asset Returns & MaintenanceNBFC Auditor Report Directions 1998: Master Circular
Browse all departments →
Who does what — compliance checklist
⚙️ Operations
  • Maintain records of screening and compliance actions for audit purposes.
💻 IT / Systems
  • Screen all new account applications against the updated list before opening accounts.
📜 Compliance
  • Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.
  • Conduct a retrospective scan of all existing accounts to identify any matches with the 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 “NBFCs Must Update UN Al-Qaida Sanctions List for UAPA Compliance” is: “Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.” (RBI issued this 10 Dec 2012).

  1. Circular: RBI/2012-13/321 -- NBFCs Must Update UN Al-Qaida Sanctions List for UAPA Compliance
  2. Issued: 10 Dec 2012
  3. Action required: Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.
  4. Action required: Screen all new account applications against the updated list before opening accounts.
  5. Action required: Conduct a retrospective scan of all existing accounts to identify any matches with the list.
  6. Action required: Report any matches to the relevant authorities as per UAPA guidelines.
  7. Action required: Maintain records of screening and compliance actions for audit purposes.
  8. Owner: ____________ Target date: ____________
  9. Board/committee approval needed? Y / N
  10. 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.

Loading comments…
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=7739&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.
Public beta — plain-English informational summaries. Always verify against the official RBI source (circular number cited on every page) before making compliance, credit, treasury, audit, or operational decisions. · Join our WhatsApp channel ↗
—