UAPA Compliance: Update Al-Qaida Sanctions List for Urban Co-op Banks
Current · Source: Reserve Bank of India · RBI/2011-12/419 · issued 01 Mar 2012 · ~1 min read
Quick answerRBI directs all Primary Urban Co-operative Banks to update their UN Al-Qaida sanctions list with six new annexes from the UN Security Council, screen new and existing accounts against this list, and follow UAPA freezing procedures from earlier circulars.
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
Urban co-op banks must add six new UN lists (Annex I to VI from Oct 5 to Dec 30, 2011) to their Al-Qaida sanctions list.
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 or are linked to a person or group on the list.
If you find a matching account, freeze the money and assets following the steps in the November 16, 2009 circular (paragraph 7).
The Compliance Officer must say they received this circular.
How it plays out — a real example
Ravi, a co-operative bank branch officer in Indore, receives this RBI circular. He immediately updates his bank's sanctions list with the six new annexes. The next day, when a new customer applies for a gold loan, Ravi screens the name against the updated list and finds no match, so he proceeds. Later, he scans all existing loan accounts and finds one linked to a listed entity; he freezes that account as per the 2009 procedure.
What changed
RBI has forwarded six new UN notes (dated Oct 5, 2011 to Dec 30, 2011) that update the Al-Qaida Sanctions List of individuals and entities. Urban co-operative banks must now incorporate these changes into their customer screening process.
What it means for you
Banks must immediately update their internal sanctions lists and ensure no new account is opened for any listed individual/entity. Existing accounts must be scanned for matches, and if found, freezing of funds must follow the procedure outlined in the November 16, 2009 circular. Non-compliance could lead to regulatory action.
What you must do
Update your internal UNSCR 1267/1989 sanctions list with the six new annexes provided.
Screen all new account applications against the updated list before opening.
Scan all existing accounts to identify any linked to listed individuals/entities.
Freeze any matched accounts as per paragraph 7 of the November 16, 2009 circular.
Ensure the Compliance Officer acknowledges receipt of this circular.
Who it affects
Primary (Urban) Co-operative Banks, Compliance Officers / Principal Officers of these banks
❓ Common questions
What is the source of the updated list?
The updates come from six notes from the Chairman of the UN Security Council's 1267/1989 Committee, forwarded by the Ministry of External Affairs.
What should we do if we find a match in existing accounts?
Follow the freezing procedure detailed in paragraph 7 of the RBI circular dated November 16, 2009, which covers freezing of funds, financial assets, or economic resources.
Where can we find the full list?
The complete Al-Qaida Sanctions 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/2011-12/419
UBD.CO.BPD (PCB) Cir. No. 21/14.01.062/2011-12
March 1, 2012
The Chief Executive Officer of
All Primary (Urban) Co-operative Banks
Madam/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 UBD.CO.BPD (PCB) Cir. No.20/14.01.062/2011-12 dated March 1, 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. Primary (Urban) Co-operative Banks 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. Primary (Urban) Co-operative Banks are advised to strictly follow the procedure laid down in the UAPA Order dated August 27, 2009 enclosed to our circular UBD.CO.BPD. PCB.Cir. No. 21/12.05.001/2009-10 dated November 16, 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 7 of the circular dated November 16, 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,
(Scenta Joy)
Deputy General Manager
Encl: As above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/419 · issued 01 Mar 2012. The plain-English explanation above is BankPulse’s own independent summary.
Screen all new account applications against the updated list before opening.
📜 Compliance
Update your internal UNSCR 1267/1989 sanctions list with the six new annexes provided.
Scan all existing accounts to identify any linked to listed individuals/entities.
Freeze any matched accounts as per paragraph 7 of the November 16, 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 (Primary (Urban) Co-operative Banks, Compliance Officers / Principal Officers of these banks), your first concrete step on “UAPA Compliance: Update Al-Qaida Sanctions List for Urban Co-op Banks” is: “Update your internal UNSCR 1267/1989 sanctions list with the six new annexes provided.” (RBI issued this 01 Mar 2012).
Circular: RBI/2011-12/419 -- UAPA Compliance: Update Al-Qaida Sanctions List for Urban Co-op Banks
Issued: 01 Mar 2012
Action required: Update your internal UNSCR 1267/1989 sanctions list with the six new annexes provided.
Action required: Screen all new account applications against the updated list before opening.
Action required: Scan all existing accounts to identify any linked to listed individuals/entities.
Action required: Freeze any matched accounts as per paragraph 7 of the November 16, 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=7033&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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