What changed
The UN Security Council's 1267/1989 Committee updated its Al-Qaida Sanctions List through notes dated November 23, 26, 27, and December 5, 2012. RBI has directed all NBFCs to incorporate these changes into their internal screening lists.
What it means for you
NBFCs must immediately update their customer due diligence systems to include the latest UN sanctions list entries. Failure to screen new and existing accounts against this list could lead to regulatory action and compliance breaches under UAPA, 1967.
What you must do
- Update your internal sanctions list with the latest UN Al-Qaida entries from November-December 2012.
- Screen all new account applications against the updated list before onboarding.
- Review all existing customer accounts to identify and report any matches with the list.
- Maintain records of screening checks for audit and regulatory review.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)
Where can we 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 we do if we find a match in an existing account?
The circular does not specify further action, but standard practice under UAPA requires freezing the account and reporting to the relevant authorities immediately.
Does this apply only to new accounts?
No, it applies to both new accounts (pre-opening check) and existing accounts (retrospective scanning).