Current · Source: Reserve Bank of India · RBI/2011-12/409 · issued 24 Feb 2012 · ~1 min read
Quick answerRBI mandates banks to update and screen accounts against the UN's revised Al-Qaida sanctions list under UAPA, 1967. Freeze assets of newly designated individuals/entities and ensure no new accounts are opened for listed parties.
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 internal list of bad guys (sanctions list) with the new Al-Qaida names from the UN.
Before opening any new account, check the customer's name against this updated list; if it matches, do not open the account.
Check all existing accounts to see if any belong to people or groups on the new list.
If you find a match, freeze (lock) their money and assets right away, following the rules from the September 2009 circular.
Your Compliance Officer (the 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 sanctions list with the new Al-Qaida names from the UN website. The next day, while reviewing existing loan accounts, she spots a name that matches the updated list. She freezes that account's funds and reports it to her Compliance Officer, following the bank's procedures exactly.
What changed
RBI received a February 23, 2012 note from the UN Security Council's 1267/1989 Committee with changes to the Al-Qaida Sanctions List. Banks must now update their internal lists and screen all existing and new accounts against this revised list.
What it means for you
Banks must immediately incorporate the updated UN sanctions list into their KYC/AML checks. Failure to identify and freeze accounts of newly listed individuals or entities could lead to regulatory action. This reinforces the government's commitment to counter-terrorism financing under UAPA.
What you must do
Update your internal sanctions list with the latest UN Al-Qaida list from the provided UN website.
Screen all new account applications against the updated list before onboarding.
Scan all existing accounts to identify any matches with the revised list.
Freeze funds and assets of any matched accounts as per the September 17, 2009 circular's paragraph 6.
Ensure your 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 list?
The list is from the UN Security Council's 1267/1989 Committee's Al-Qaida Sanctions List, available on the UN website.
What action is required for existing accounts?
Banks must scan all existing accounts to ensure none are held by or linked to any entity or individual on the updated list.
What should we do if we find a match?
Follow the freezing procedure detailed in paragraph 6 of RBI's circular dated September 17, 2009, which covers funds, financial assets, or economic resources.
📜 Read the original circular — full text as issued by RBI
RBI/2011-12/409
DBOD. AML. No.12757/14.06.001/2011-12
February 24, 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) / 1989(2011) Committee's
Al Qaida Sanctions List
Please refer to our circular DBOD. AML. No. 11330/14.06.001/2011-12 dated January 31, 2012 . We have since received from Government of India, Ministry of External Affairs, UNP Division copy of note dated February 23, 2012 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.
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/2011-12/409 · issued 24 Feb 2012. The plain-English explanation above is BankPulse’s own independent summary.
Screen all new account applications against the updated list before onboarding.
📜 Compliance
Update your internal sanctions list with the latest UN Al-Qaida list from the provided UN website.
Scan all existing accounts to identify any matches with the revised list.
Freeze funds and assets of any matched accounts as per the September 17, 2009 circular's paragraph 6.
Ensure your 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 51A: Updated Al-Qaida Sanctions List” is: “Update your internal sanctions list with the latest UN Al-Qaida list from the provided UN website.” (RBI issued this 24 Feb 2012).
Circular: RBI/2011-12/409 -- UAPA Section 51A: Updated Al-Qaida Sanctions List
Issued: 24 Feb 2012
Action required: Update your internal sanctions list with the latest UN Al-Qaida list from the provided UN website.
Action required: Screen all new account applications against the updated list before onboarding.
Action required: Scan all existing accounts to identify any matches with the revised list.
Action required: Freeze funds and assets of any matched accounts as per the September 17, 2009 circular's paragraph 6.
Action required: Ensure your 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=7022&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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