Current · Source: Reserve Bank of India · RBI/2011-12/334 · issued 02 Jan 2012 · ~1 min read
Quick answerRBI directs RRBs to use two separate UN sanctions lists (Al-Qaida and Taliban) for UAPA Section 51A compliance. All new and existing accounts must be screened against both lists.
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
RRBs (Regional Rural Banks) must now check TWO separate UN lists (Al-Qaida list and Taliban list) instead of one when screening customers.
Before opening any new account, the bank must make sure the customer's name is NOT on either the Al-Qaida Sanctions List or the 1988 Sanctions List.
All existing accounts must be scanned once to see if any customer's name matches either list.
If a customer's name is on either list, the bank must follow the rules from the UAPA (Unlawful Activities Prevention Act) order of August 27, 2009.
The Compliance Officer must tell the RBI (Reserve Bank of India) that they received and understood this rule.
How it plays out — a real example
A payments & clearing officer in Indore is opening a new account for a customer. She pulls up the bank's system and checks the customer's name against both the Al-Qaida Sanctions List and the 1988 Sanctions List. She finds no match, so she proceeds with the account opening, knowing she has followed the new rule.
What changed
The UN Security Council split its consolidated sanctions list into two: the Al-Qaida Sanctions List (maintained by the 1267/1989 Committee) and the 1988 Sanctions List (for Taliban-associated entities). RRBs must now check both lists separately when implementing Section 51A of UAPA, 1967.
What it means for you
RRBs face increased screening burden as they must cross-check customers against two distinct lists instead of one. Non-compliance risks penalties under UAPA. The circular reinforces existing obligations from the 2009 UAPA order, with no new procedural changes beyond the list split.
What you must do
Update your internal sanctions database to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.
Screen all new account applicants against both lists before account opening.
Conduct a one-time scan of all existing accounts to identify any matches with either list.
Ensure compliance with the UAPA Order dated August 27, 2009, as per earlier RBI circular.
Have Compliance Officer/Principal Officer acknowledge receipt of this circular to the concerned RBI Regional Office.
Who it affects
All Regional Rural Banks (RRBs), Compliance Officers/Principal Officers of RRBs, Branch staff handling account opening and KYC
❓ Common questions
Why did the UN split the sanctions list?
The UN Security Council adopted Resolutions 1988 (2011) and 1989 (2011) to separate Taliban-related sanctions from Al-Qaida-related sanctions for clearer targeting.
Do we need to check only new accounts?
No, you must screen both new accounts before opening and all existing accounts to ensure no account is linked to any entity on either list.
What action is required if we find a match?
Follow the freezing procedure detailed in paragraph 6 of RBI circular RPCD.CO.RRB.No.39/03.05.33(E)/2009-10 dated November 5, 2009, as per the UAPA Order.
📜 Read the original circular — full text as issued by RBI
RBI/2011-12/334
RPCD.CO RRB.AML.BC.No.51 /03.05.33(E)/2011-12
January 2,2012
The Chairmen
All Regional Rural Banks (RRBs)
Dear Sir,
Implementation of Section 51-A of UAPA, 1967-
Splitting of UNSC 1267 Committee's list of individuals and entities
linked to Al-Qaida and Taliban
Please refer to the UN Security Council's 1267 Committee’s Consolidated List of individuals and entities linked to Al-Qaida and Taliban who are subject to the assets freeze, travel ban and arms embargo as set out in relevant Security Council Resolution 1822 (2008). Pursuant to being included in the 1267 Committee’s Consolidated List these individuals and entities are subject of action under Section 51A of the Unlawful Activities (Prevention) Act, 1967.
2. The UN Security Council has adopted Resolutions 1988 (2011) and 1989 (2011) which have resulted in splitting of the Consolidated List into two separate lists , namely:
(i) “Al-Qaida Sanctions List”, which is maintained by the 1267 / 1989 Committee. This List shall include only the names of those individuals, groups, undertakings and entities associated with Al-Qaida. General information on the work of the committee is available at http://www.un.org/sc/committees/1267/information.shtml . The Updated Al-Qaida Sanctions List is available at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml .
(ii) “1988 Sanctions List”, which is maintained by the 1988 Committee. This list consists of names previously included in Sections A (“Individuals associated with the Taliban”) and B (“Entities and other groups and undertakings associated with the Taliban”) of the Consolidated List. The Updated 1988 Sanctions list is available at http://www.un.org/sc/committees/ 1988/list.shtml .
3. It may be noted that both “Al-Qaida Sanctions List” and “1988 Sanctions List” are to be taken into account for the purpose of implementation of Section 51A of the Unlawful Activities (Prevention) Act, 1967.
4. This information is being issued in pursuance of the instructions contained in the Ministry of Home Affairs (Internal Security-I Division), Government of India’s order F. No. 17015/10/2002-IS-IV, dated 27 August 2009, regarding the Procedure for implementation of Section 51A of the Unlawful Activities(Prevention) Act, 1967.
5. RRBs are required to update the lists 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 either list. Further, RRBs 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 two lists.
6. RRBs are advised to strictly follow the procedure laid down in the UAPA Order dated August 27, 2009 enclosed to our circular RPCD . CO. RRB. No. 39 / 03.05.33(E) /2009-10 dated November 05, 2009 and ensure meticulous compliance to the Order issued by the Government.
7. As far as freezing of funds, financial assets or economic resources or related services held in the form of bank accounts of the designated individuals/entities are concerned, action should be taken as detailed in paragraph 6 of the circular dated November 05, 2009, mentioned above.
8. Compliance Officer/Principal Officer should acknowledge receipt of this letter to our Regional Office concerned.
Yours faithfully
(C.D.Srinivasan)
Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/334 · issued 02 Jan 2012. The plain-English explanation above is BankPulse’s own independent summary.
Screen all new account applicants against both lists before account opening.
📜 Compliance
Update your internal sanctions database to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.
Conduct a one-time scan of all existing accounts to identify any matches with either list.
Ensure compliance with the UAPA Order dated August 27, 2009, as per earlier RBI circular.
Have Compliance Officer/Principal Officer acknowledge receipt of this circular to the concerned RBI Regional Office.
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 Regional Rural Banks (RRBs), Compliance Officers/Principal Officers of RRBs, Branch staff handling account opening and KYC), your first concrete step on “RRBs: UN Sanctions List Split for UAPA Compliance” is: “Update your internal sanctions database to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.” (RBI issued this 02 Jan 2012).
Circular: RBI/2011-12/334 -- RRBs: UN Sanctions List Split for UAPA Compliance
Issued: 02 Jan 2012
Action required: Update your internal sanctions database to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.
Action required: Screen all new account applicants against both lists before account opening.
Action required: Conduct a one-time scan of all existing accounts to identify any matches with either list.
Action required: Ensure compliance with the UAPA Order dated August 27, 2009, as per earlier RBI circular.
Action required: Have Compliance Officer/Principal Officer acknowledge receipt of this circular to the concerned RBI Regional Office.
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=6915&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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