UAPA Compliance: UN Splits Al-Qaida & Taliban Sanctions Lists
Current · Source: Reserve Bank of India · RBI/2011-12/338 · issued 04 Jan 2012 · ~2 min read
Quick answerUN Security Council split the consolidated sanctions list into separate Al-Qaida and Taliban lists. Co-operative banks must screen new and existing accounts against both updated lists under Section 51A 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
Co-operative banks must check against two UN sanctions lists: Al-Qaida Sanctions List and 1988 Sanctions List.
Update internal screening systems to include both lists.
Verify new customers' names against both lists before opening accounts.
Scan existing accounts to freeze any linked to individuals or entities on either list.
How it plays out — a real example
Rahul, a co-operative bank branch officer in Indore, is opening a new account for a customer. He checks the customer's name against both the Al-Qaida Sanctions List and the 1988 Sanctions List to ensure compliance with Section 51A of UAPA, 1967. Rahul verifies the customer's name against both lists and finds no match, so he proceeds with opening the account.
What changed
The UN Security Council adopted Resolutions 1988 and 1989, splitting the earlier consolidated list of individuals and entities linked to Al-Qaida and Taliban into two separate lists: the 'Al-Qaida Sanctions List' and the '1988 Sanctions List'. Both lists are now relevant for implementing Section 51A of UAPA, 1967.
What it means for you
Co-operative banks must now check against two distinct UN sanctions lists instead of one consolidated list. This increases the compliance burden slightly but ensures alignment with updated international sanctions. Banks must update their internal screening databases and ensure no accounts are linked to any entity on either list.
What you must do
Update your internal sanctions screening systems to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.
Before opening any new account, verify the proposed customer's name against both lists.
Scan all existing accounts to identify and freeze any accounts linked to individuals or entities on either list.
Follow the procedure laid down in the UAPA Order dated August 27, 2009, and our earlier circular of October 29, 2009.
Acknowledge receipt of this circular to your respective RBI Regional Office through the Compliance Officer/Principal Officer.
Who it affects
State Co-operative Banks, Central Co-operative Banks, Compliance Officers / Principal Officers of co-operative banks
Built from our lineage records — each fact carries its provenance; missing history simply is not shown (never guessed).
What are the two new sanctions lists I need to check?
The Al-Qaida Sanctions List (maintained by the 1267/1989 Committee) and the 1988 Sanctions List (maintained by the 1988 Committee). Both are available on the UN website.
Do I need to check only new accounts or existing ones too?
Both. You must screen all new accounts before opening and also scan all existing accounts to ensure no account is held by or linked to any entity on either list.
What action should I take if I find a match?
Follow the freezing procedure detailed in paragraph 6 of our circular dated October 29, 2009, and the UAPA Order of August 27, 2009.
📜 This document’s life story (1 recorded event, each backed by RBI’s own words)
RBI’s words: “Please refer to our circular RPCD.CO.RCB.AML.BC.No.52/07.02.12/2011-12 dated January 4, 2012”
📜 Read the original circular — full text as issued by RBI
RBI/2011-12/338
RPCD.CO.RCB.AML.BC.No 52/07.02.12/2011-12
January 4, 2012
The Chairmen / CEOs of all State and Central Co-operative Banks
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. State and Central Co-operative Banks 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, 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 two lists.
6. Banks are advised to strictly follow the procedure laid down in the UAPA Order dated August 27, 2009 enclosed to our circular RPCD.CO.RF.AML. BC. No. 34/07.40.00/ 2009-10 dated October 29, 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 October 29, 2009, mentioned above.
8. Compliance Officer/Principal Officer should acknowledge receipt of this circular to our concerned Regional Office.
Yours faithfully,
(C.D.Srinivasan)
Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/338 · issued 04 Jan 2012. The plain-English explanation above is BankPulse’s own independent summary.
Update your internal sanctions screening systems to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.
📜 Compliance
Before opening any new account, verify the proposed customer's name against both lists.
Scan all existing accounts to identify and freeze any accounts linked to individuals or entities on either list.
Follow the procedure laid down in the UAPA Order dated August 27, 2009, and our earlier circular of October 29, 2009.
Acknowledge receipt of this circular to your respective RBI Regional Office through the Compliance Officer/Principal Officer.
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 (State Co-operative Banks, Central Co-operative Banks, Compliance Officers / Principal Officers of co-operative banks), your first concrete step on “UAPA Compliance: UN Splits Al-Qaida & Taliban Sanctions Lists” is: “Update your internal sanctions screening systems to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.” (RBI issued this 04 Jan 2012).
Action required: Update your internal sanctions screening systems to include both the Al-Qaida Sanctions List and the 1988 Sanctions List.
Action required: Before opening any new account, verify the proposed customer's name against both lists.
Action required: Scan all existing accounts to identify and freeze any accounts linked to individuals or entities on either list.
Action required: Follow the procedure laid down in the UAPA Order dated August 27, 2009, and our earlier circular of October 29, 2009.
Action required: Acknowledge receipt of this circular to your respective RBI Regional Office through the Compliance Officer/Principal Officer.
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=6923&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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