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UAPA Section 51A: Update Al-Qaida Sanctions List Now

Current · Source: Reserve Bank of India · RBI/2011-12/436 · issued 09 Mar 2012 · ~2 min read
Quick answerRBI mandates banks to update the UN Al-Qaida sanctions list immediately. Before opening new accounts, verify proposed customers aren't on this list. Also, scan all existing accounts to identify and freeze any linked to listed individuals or entities, following the UAPA Order of August 27, 2009.
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
How it plays out — a real example

Ravi, a compliance officer at a bank in Mumbai, gets the new Al-Qaida sanctions list from RBI. He first updates the bank's computer system with the list, then checks every new customer's name before opening accounts. He also runs a scan of all existing accounts and finds one linked to a listed person – he immediately freezes that account, following the UAPA rules.

What changed

RBI has circulated an updated Al-Qaida Sanctions List from the UN Security Council's 1267/1989 Committee, received via the Ministry of External Affairs on March 6, 2012. Banks must now use this latest list for customer screening and account freezing actions.

What it means for you

Banks must immediately update their internal sanctions lists and ensure no new accounts are opened for any individual or entity on the updated Al-Qaida list. Existing accounts must be reviewed to identify and freeze any linked assets, as per the UAPA Order of August 27, 2009. Non-compliance could lead to regulatory action.

What you must do

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 on March 6, 2012.

What actions are 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, and freeze any such accounts as per the UAPA Order.

Where can I find the complete list?

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/2011-12/436 DBOD. AML.No.13481/14.06.001/2011-12 March 9, 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. 12757/14.06.001/2011-12 dated February 24, 2012 . We have since received from Government of India, Ministry of External Affairs, UNP Division copy of note dated March 6, 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/2011-12/436 · issued 09 Mar 2012. The plain-English explanation above is BankPulse’s own independent summary.
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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: Update Al-Qaida Sanctions List Now” is: “Update your internal sanctions database with the latest UN Al-Qaida Sanctions List from the UN website.” (RBI issued this 09 Mar 2012).

  1. Circular: RBI/2011-12/436 -- UAPA Section 51A: Update Al-Qaida Sanctions List Now
  2. Issued: 09 Mar 2012
  3. Action required: Update your internal sanctions database with the latest UN Al-Qaida Sanctions List from the UN website.
  4. Action required: Before opening any new account, verify the proposed customer's name against the updated list.
  5. Action required: Scan all existing accounts to identify any linked to listed individuals or entities.
  6. Action required: Freeze funds, financial assets, or economic resources of designated entities as per paragraph 6 of the September 17, 2009 circular.
  7. Action required: Ensure Compliance Officer/Principal Officer acknowledges receipt of this circular.
  8. Owner: ____________ Target date: ____________
  9. Board/committee approval needed? Y / N
  10. 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.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=7053&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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