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

Current · Source: Reserve Bank of India · RBI/2011-12/441 · issued 14 Mar 2012 · ~1 min read
Quick answerRBI mandates banks to update the UN Al-Qaida sanctions list, screen new and existing accounts against it, and freeze assets of designated individuals/entities as per UAPA 1967 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
How it plays out — a real example

Ravi, a compliance officer at a bank in Mumbai, receives the new Al-Qaida sanctions list from RBI. He updates the bank's system with the names, then screens all new account applications that day, catching one applicant whose name matches the list. He immediately freezes that account and reports it, following the procedure from the 2009 government order.

What changed

RBI has circulated the latest changes to the UN Security Council's Al-Qaida Sanctions List, as notified by the Ministry of External Affairs. Banks must update their records with this revised list and ensure compliance with the UAPA Order of August 27, 2009.

What it means for you

Banks must immediately update their internal databases with the new list of sanctioned individuals and entities linked to Al-Qaida. All new account openings must be screened against this list, and existing accounts must be reviewed to identify any matches. For any matches, banks must freeze funds and assets as per the September 2009 circular's paragraph 6.

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 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 individual or entity on the updated list.

What should we do if we find a match?

Follow the freezing procedures detailed in paragraph 6 of RBI circular DBOD.AML.BC. No. 44/14.01.001/2009-10 dated September 17, 2009.

📜 Read the original circular — full text as issued by RBI
RBI/2011-12/441 DBOD. AML. No. 13747/14.06.001/2011-12 March 14, 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.13481/14.06.001/2011-12 dated March 9, 2012 . We have since received from Government of India, Ministry of External Affairs, UNP Division copy of note dated March 12, 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/2011-12/441 · issued 14 Mar 2012. The plain-English explanation above is BankPulse’s own independent summary.
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Who does what — compliance checklist
💻 IT / Systems
  • Screen all new account applications against the updated list before onboarding.
📜 Compliance
  • Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.
  • Scan all existing accounts to identify any linked to listed individuals or entities.
  • Freeze funds and assets of any matched accounts following the procedure in the September 17, 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 (All Scheduled Commercial Banks (excluding RRBs), Local Area Banks, All India Financial Institutions), your first concrete step on “UAPA Section 51-A: Update Al-Qaida Sanctions List” is: “Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.” (RBI issued this 14 Mar 2012).

  1. Circular: RBI/2011-12/441 -- UAPA Section 51-A: Update Al-Qaida Sanctions List
  2. Issued: 14 Mar 2012
  3. Action required: Update your internal sanctions list with the latest UN Al-Qaida Sanctions List from the UN website.
  4. Action required: Screen all new account applications against the updated list before onboarding.
  5. Action required: Scan all existing accounts to identify any linked to listed individuals or entities.
  6. Action required: Freeze funds and assets of any matched accounts following the procedure in the September 17, 2009 circular.
  7. Action required: Ensure the Compliance 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=7058&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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