UAPA Section 51-A: UN Al-Qaida Sanctions List Update
Current · Source: Reserve Bank of India · RBI/2011-12/336 · issued 03 Jan 2012 · ~1 min read
Quick answerRBI directs banks to update their records with the latest UN Al-Qaida sanctions list, screen new and existing accounts, and freeze assets of designated individuals/entities as per 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
Banks must update their list of bad people (sanctions list) with six new updates from the UN from October to December 2011.
Before opening a new account, check if the customer's name is on the updated list of bad people linked to Al-Qaida.
Check all existing accounts to see if any belong to or are linked to people or groups on the list.
If you find a matching account, freeze (lock) all money and assets in it, following the rules from the government's order of August 27, 2009.
The compliance officer (person in charge of following rules) must say they got this circular.
How it plays out — a real example
A KYC & compliance officer in Indore receives this RBI circular. She immediately updates her bank's computer system with the six new UN notes, then runs a check on all new loan applicants. She also scans old accounts and finds one linked to a listed entity, so she freezes that account and reports it as per the UAPA rules.
What changed
RBI has circulated six UN notes (dated Oct 5, Oct 17, Nov 30, Dec 13, Dec 28, and Dec 30, 2011) containing updates to the Al-Qaida Sanctions List. Banks must incorporate these changes into their customer screening databases immediately.
What it means for you
Banks must ensure no new account is opened for any listed individual/entity and that existing accounts are scanned for matches. Any identified accounts must be frozen and reported as per the UAPA Order of August 27, 2009. Non-compliance could lead to regulatory action.
What you must do
Update your internal sanctions list with the six new UN notes provided in the annexes.
Screen all new account applications against the updated Al-Qaida list before onboarding.
Conduct a retrospective scan of all existing accounts to identify any linked to listed entities.
Freeze funds and economic resources of matched accounts as per paragraph 6 of the September 17, 2009 circular.
Ensure the Compliance Officer acknowledges receipt of this circular.
Who it affects
All Scheduled Commercial Banks (excluding RRBs), Local Area Banks, All India Financial Institutions
❓ Common questions
What is the source of the updated sanctions list?
The list is from the UN Security Council's 1267/1989 Committee's Al-Qaida Sanctions List, forwarded by the Ministry of External Affairs.
What action is required for existing accounts that match the list?
Banks must freeze the funds, financial assets, or economic resources held in such accounts, following the procedure in paragraph 6 of the September 17, 2009 circular.
Where can I find the complete list of sanctioned individuals/entities?
The full list is available on the UN website at http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
📜 Read the original circular — full text as issued by RBI
RBI/2011-12/336
DBOD. AML. No. 9855 /14.06.001/2011-12
January 3, 2012
The Chairmen / CEOs of all Scheduled Commercial Banks (Excluding RRBs)/ Local Area Banks / All India Financial Institutions
Dear Sir,
Implementation of Section 51-A of UAPA, 1967
Updates of the UNSCR 1267(1999) and 1989( 2011) Committee's
Al Qaida Sanctions List
Please refer to our circular DBOD. AML. BC. No. 70 /14.06.001/2011-12 dated December 30, 2011 . We have since received from Government of India, Ministry of External Affairs, UNP Division copies of notes forwarded by the Chairman of UN Security Council's 1267/ 1989 Committee (copy enclosed) regarding changes made in the “Al-Qaida Sanctions List”, i.e. list of Individuals and entities linked to Al-Qaida, as detailed below:
Note dated October 5, 2011 ( Annex I )
Note dated October 17, 2011 ( Annex II )
Note dated November 30, 2011 ( Annex III )
Note dated December 13, 2011 ( Annex IV )
Note dated December 28, 2011 ( Annex V )
Note dated December 30, 2011 ( Annex VI )
2. Banks/All India Financial Institutions 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, banks 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. Banks are advised to strictly follow the procedure laid down in the UAPA Order dated August 27, 2009 enclosed to our circular DBOD.AML.BC. No. 44/14.01.001/2009-10 dated September 17, 2009 and ensure meticulous compliance to the Order issued by the Government.
4. 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 September 17, 2009, mentioned above.
5. The complete details of the said list are available on the UN website:
http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml
6. Compliance Officer/Principal Officer should acknowledge receipt of this circular.
Yours faithfully,
(S. K. Jha)
Deputy General Manager
Encl: as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/336 · issued 03 Jan 2012. The plain-English explanation above is BankPulse’s own independent summary.
Screen all new account applications against the updated Al-Qaida list before onboarding.
📜 Compliance
Update your internal sanctions list with the six new UN notes provided in the annexes.
Conduct a retrospective scan of all existing accounts to identify any linked to listed entities.
Freeze funds and economic resources of matched accounts as per paragraph 6 of the September 17, 2009 circular.
Ensure the Compliance Officer acknowledges receipt of this circular.
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 Scheduled Commercial Banks (excluding RRBs), Local Area Banks, All India Financial Institutions), your first concrete step on “UAPA Section 51-A: UN Al-Qaida Sanctions List Update” is: “Update your internal sanctions list with the six new UN notes provided in the annexes.” (RBI issued this 03 Jan 2012).
Circular: RBI/2011-12/336 -- UAPA Section 51-A: UN Al-Qaida Sanctions List Update
Issued: 03 Jan 2012
Action required: Update your internal sanctions list with the six new UN notes provided in the annexes.
Action required: Screen all new account applications against the updated Al-Qaida list before onboarding.
Action required: Conduct a retrospective scan of all existing accounts to identify any linked to listed entities.
Action required: Freeze funds and economic resources of matched accounts as per paragraph 6 of the September 17, 2009 circular.
Action required: Ensure the Compliance Officer acknowledges receipt of this circular.
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=6921&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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