What changed
RBI has circulated the latest updates to the UN Security Council's Al-Qaida Sanctions List, covering changes made between January and March 2013, along with the consolidated list as of April 8, 2013. This replaces the previous list sent in December 2012.
What it means for you
NBFCs must update their internal databases with the new list of sanctioned individuals and entities and screen both new and existing accounts against it, as required by the RBI circular.
What you must do
- Update your internal sanctions screening system with the latest UN Al‑Qaida list from the enclosed notes and consolidated list.
- Screen all new account applications against the updated list before onboarding any customer.
- Conduct a fresh scan of all existing accounts to identify any matches with the newly added names.
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 the URLs provided in the circular: http://www.un.org/sc/committees/1267/pressreleases.shtml and http://www.un.org/sc/committees/1267/pdf/AQList.pdf.
Do I need to screen only new accounts or also existing ones?
Both. You must screen all new accounts before opening them and also scan all existing accounts to ensure none are linked to any entity or individual on the updated list.
What happens if I find a match in an existing account?
You must immediately freeze the account and report the details to the RBI and the Financial Intelligence Unit (FIU) as per the procedures under Section 51-A of UAPA, 1967.