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NBFCs Must Update UN Sanctions List for UAPA Compliance

Current · Source: Reserve Bank of India · RBI/2013-14/311 · issued 03 Oct 2013 · ~1 min read
Quick answerRBI mandates NBFCs to update their records with the latest UN Al-Qaida sanctions list from August 2013, screen new and existing accounts against it, and ensure no linked accounts exist.
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

Before opening a new account for a customer, Rohan, the NBFC compliance officer in Indore, checks the updated UN Al-Qaida sanctions list to ensure Rohan's name doesn't appear on it. He also scans the existing accounts to identify any matches with the updated list. If he finds any matches, Rohan reports them to the RBI and relevant authorities as per UAPA guidelines to maintain compliance.

What changed

RBI circular DNBS(PD).CC. No 358/03.10.42/2013-14 updates the earlier May 2013 directive with the UN Security Council's 1267/1989 Committee's August 6, 2013 changes to the Al-Qaida Sanctions List. NBFCs must now use this updated list for customer screening.

What it means for you

NBFCs must immediately incorporate the revised UN sanctions list into their account opening and monitoring processes. Failure to screen against this list could lead to regulatory action under UAPA, 1967. This reinforces the need for robust AML/KYC frameworks.

What you must do

Who it affects

All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs), Compliance and AML/KYC teams at NBFCs

❓ Common questions

What is the source of the updated sanctions list?

The list is from the UN Security Council's 1267/1989 Committee, updated as of August 6, 2013, and available on the UN website at the URLs given in the circular.

Do we need to screen only new accounts or existing ones too?

Both. The circular requires NBFCs to check new accounts before opening and also scan all existing accounts to ensure no account is linked to listed individuals or entities.

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

You must follow the procedures under Section 51-A of UAPA, 1967, which typically involves freezing the account and reporting to the RBI and other authorities.

📜 Read the original circular — full text as issued by RBI
RBI/2013-14/311 DNBS(PD).CC. No 358/03.10.42/2013-14 October 3, 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 324/03.10.42/2012-13 dated May 2, 2013 . The Chairman of UN Security Council's 1267/ 1989 Committee has issued a note dated August 6, 2013, ( copy enclosed ) regarding changes made in the “Al-Qaida Sanctions List”, i.e. list of Individuals and entities linked to Al-Qaida. The copy of the update is available on UN website at the following url; http://www.un.org/News/Press/docs/2013/sc11089.doc.htm 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/aq_sanctions_list.shtml Yours faithfully, (A .Mangalagiri) General Manager Encl: as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2013-14/311 · issued 03 Oct 2013. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
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Who does what — compliance checklist
💻 IT / Systems
  • Screen all new account applications against the updated list before opening accounts.
  • Update internal compliance systems and train staff on the latest sanctions list.
📜 Compliance
  • Download the updated Al-Qaida Sanctions List from the UN website URLs provided in the circular.
  • Review all existing customer accounts to identify any matches with the updated list.
  • Report any matches to the RBI and 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), Compliance and AML/KYC teams at NBFCs), your first concrete step on “NBFCs Must Update UN Sanctions List for UAPA Compliance” is: “Download the updated Al-Qaida Sanctions List from the UN website URLs provided in the circular.” (RBI issued this 03 Oct 2013).

  1. Circular: RBI/2013-14/311 -- NBFCs Must Update UN Sanctions List for UAPA Compliance
  2. Issued: 03 Oct 2013
  3. Action required: Download the updated Al-Qaida Sanctions List from the UN website URLs provided in the circular.
  4. Action required: Screen all new account applications against the updated list before opening accounts.
  5. Action required: Review all existing customer accounts to identify any matches with the updated list.
  6. Action required: Report any matches to the RBI and relevant authorities as per UAPA guidelines.
  7. Action required: Update internal compliance systems and train staff on the latest sanctions list.
  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.

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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=8489&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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