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
- Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.
- Screen all new account applications against the updated list before opening accounts.
- 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.
- Maintain records of screening and compliance actions for audit purposes.
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 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.