UAPA Compliance: Updated UN Al-Qaida Sanctions List for NBFCs
Current · Source: Reserve Bank of India · RBI/2012-13/482 · issued 02 May 2013 · ~1 min read
Quick answerRBI directs all NBFCs to update their records with the latest UN Al-Qaida sanctions list (as of April 2013) and screen new and existing accounts against it to comply with Section 51-A of UAPA, 1967.
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
NBFCs (companies that lend money but are not banks) must get the newest UN Al-Qaida sanctions list (a list of bad people and groups linked to Al-Qaida) and use it to check all customers.
Before opening any new account, NBFCs must make sure the customer's name is NOT on that list.
NBFCs must also check all existing accounts to see if any customer is on the updated list.
This rule follows Section 51-A of UAPA (a law to stop terrorism funding) and replaces an older list from December 2012.
How it plays out — a real example
An NBFC compliance officer in Indore updates her bank's computer system with the new UN Al-Qaida list from April 2013. She then runs a check on all existing loan accounts and finds that a customer who opened an account last month now matches a newly added name. She immediately freezes that account and reports it to her compliance head, following the RBI rule.
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)
❓ Common questions
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.
📜 Read the original circular — full text as issued by RBI
RBI/2012-13/482
DNBS (PD).CC. No 324/03.10.42/2012-13
May 2, 2013
All Non Banking Financial Companies /
Residuary Non Banking Companies
Dear Sir/Madam,
Implementation of Section 51-A of UAPA, 1967 -Updates of the UNSCR 1267 (1999) /1989 (2011) Committee's Al Qaida Sanctions List and Consolidated List
Please refer to DNBS (PD).CC.No 318/03.10.42/2012-13 dated December 28, 2012 . The Chairman of UN Security Council's 1267/ 1989 Committee has issued notes dated January 15, February 5, 11, 22, 25 and March 12, 14, 18, 19, 20 and 25, 2013, ( copies enclosed ) regarding changes made in the “Al-Qaida Sanctions List”, i.e. list of Individuals and entities linked to Al-Qaida. Further, Consolidated List of the Committee with respect to individuals, groups, undertakings and entities associated with Al-Qaida received with Note Verbale SCA/2/13(13) dated April 8, 2013 is also enclosed.
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/pressreleases.shtml
http://www.un.org/sc/committees/1267/pdf/AQList.pdf
Yours faithfully,
(Sindhu Pancholy)
Deputy General Manager
Encl: as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2012-13/482 · issued 02 May 2013. The plain-English explanation above is BankPulse’s own independent summary.
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.
📜 Compliance
Conduct a fresh scan of all existing accounts to identify any matches with the newly added names.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template
Example: if you are an IT/Systems lead at a bank this circular applies to (All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs)), your first concrete step on “UAPA Compliance: Updated UN Al-Qaida Sanctions List for NBFCs” is: “Update your internal sanctions screening system with the latest UN Al‑Qaida list from the enclosed notes and consolidated list.” (RBI issued this 02 May 2013).
Circular: RBI/2012-13/482 -- UAPA Compliance: Updated UN Al-Qaida Sanctions List for NBFCs
Issued: 02 May 2013
Action required: Update your internal sanctions screening system with the latest UN Al‑Qaida list from the enclosed notes and consolidated list.
Action required: Screen all new account applications against the updated list before onboarding any customer.
Action required: Conduct a fresh scan of all existing accounts to identify any matches with the newly added names.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
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.
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=7955&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.
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