UAPA Sanctions: Co-op Banks Must Update Al-Qaida Lists
Current · Source: Reserve Bank of India · RBI/2011-12/343 · issued 06 Jan 2012 · ~2 min read
Quick answerRBI directs all state and central co-operative banks to update their UNSCR 1267/1989 Al-Qaida sanctions list with six new UN notes from Oct-Dec 2011. Banks must screen new and existing accounts against this list and follow UAPA freezing procedures.
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 update their Al-Qaida sanctions list with six new UN notes from Oct-Dec 2011.
Banks must screen new and existing accounts against the updated list to identify any links to designated individuals or entities.
Banks must follow UAPA freezing procedures for any matches and verify all new customers against the list.
How it plays out — a real example
Rahul, a co-operative bank branch officer in Indore, ensures that all new customers are screened against the updated Al-Qaida sanctions list before onboarding. He also scans existing accounts to identify any links to newly added individuals or entities, and follows the freezing procedures outlined in the UAPA Order of August 27, 2009, to maintain compliance with the RBI circular.
What changed
RBI has forwarded six new UN Security Council notes (dated Oct 5, Oct 17, Nov 30, Dec 13, Dec 28, and Dec 30, 2011) that update the Al-Qaida Sanctions List of individuals and entities. Co-operative banks must now incorporate these changes into their consolidated list and ensure compliance with the UAPA Order of August 27, 2009.
What it means for you
Co-operative banks must immediately update their internal sanctions screening systems with the latest UN list entries. Failure to identify and freeze accounts linked to designated individuals or entities could lead to regulatory action. The circular reinforces that banks must verify all new customers against the list and periodically scan existing accounts.
What you must do
Update your consolidated sanctions list with the six UN notes (Annex I-VI) provided in the circular.
Screen all new account openings against the updated list before onboarding.
Scan all existing accounts to identify any links to newly added individuals or entities.
Follow the freezing procedures outlined in paragraph 6 of RBI circular dated October 29, 2009 for any matches.
Acknowledge receipt of this circular to your respective RBI Regional Office through your Compliance/Principal Officer.
Who it affects
State Co-operative Banks, Central Co-operative Banks, Compliance Officers and 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 is the source of the updated sanctions list?
The updates come from six notes issued by the Chairman of the UN Security Council's 1267/1989 Committee between October and December 2011, forwarded by the Ministry of External Affairs.
Do we need to check only new accounts or existing ones too?
Both. You must ensure no new account is opened for a listed entity or individual, and you must scan all existing accounts to confirm none are held by or linked to any listed party.
What action is required if we find a match?
Follow the freezing of funds, financial assets, or economic resources as detailed in paragraph 6 of RBI circular dated October 29, 2009, which implements the UAPA Order.
📜 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.No.6764/07.02.12/2011-12 dated January 06, 2012”
📜 Read the original circular — full text as issued by RBI
RBI/2011-12/343
RPCD.CO.RCB.AML.No.6764/07.02.12/2011-12
January 06, 2012
The Chairmen / CEOs of all State and Central Co-operative Banks
Dear Sir,
Implementation of Section 51-A of UAPA, 1967-
Updates of UNSCR 1267 (1999) and 1989 (2011) Committee's Al-Qaida
Sanctions List
Please refer to our circular RPCD.CO.RCB.AML.BC.No.52/07.02.12/2011-12 dated January 4, 2012 . 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. State and Central Co-operative Banks are required to update the consolidated 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 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.
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 October 29, 2009, mentioned above.
5. The complete details of the said consolidated 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 letter to our concerned Regional Office.
Yours faithfully,
(I.S.Negi)
General Manager
Encl: As above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/343 · issued 06 Jan 2012. The plain-English explanation above is BankPulse’s own independent summary.
Screen all new account openings against the updated list before onboarding.
📜 Compliance
Update your consolidated sanctions list with the six UN notes (Annex I-VI) provided in the circular.
Scan all existing accounts to identify any links to newly added individuals or entities.
Follow the freezing procedures outlined in paragraph 6 of RBI circular dated October 29, 2009 for any matches.
Acknowledge receipt of this circular to your respective RBI Regional Office through your Compliance/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 a Compliance officer at a bank this circular applies to (State Co-operative Banks, Central Co-operative Banks, Compliance Officers and Principal Officers of co-operative banks), your first concrete step on “UAPA Sanctions: Co-op Banks Must Update Al-Qaida Lists” is: “Update your consolidated sanctions list with the six UN notes (Annex I-VI) provided in the circular.” (RBI issued this 06 Jan 2012).
Action required: Update your consolidated sanctions list with the six UN notes (Annex I-VI) provided in the circular.
Action required: Screen all new account openings against the updated list before onboarding.
Action required: Scan all existing accounts to identify any links to newly added individuals or entities.
Action required: Follow the freezing procedures outlined in paragraph 6 of RBI circular dated October 29, 2009 for any matches.
Action required: Acknowledge receipt of this circular to your respective RBI Regional Office through your Compliance/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=6928&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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