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

Current · Source: Reserve Bank of India · RBI/2011-12/450 · issued 16 Mar 2012 · ~1 min read
Quick answerRBI mandates banks to update the UN Al-Qaida sanctions list, screen new and existing accounts, and freeze assets of designated individuals/entities under UAPA, 1967.
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

A KYC & compliance officer in Indore receives the updated Al-Qaida sanctions list from RBI. She first checks the name of a new customer applying for a gold loan against the list and finds no match, so she opens the account. Then she reviews her existing loan accounts and spots one linked to a listed entity; she immediately freezes that account's funds and assets, following the procedure from the September 2009 circular.

What changed

RBI received a March 14, 2012 UN Security Council 1267/1989 Committee update to the Al-Qaida Sanctions List. Banks must now incorporate these changes into their screening process.

What it means for you

Banks must ensure no new account is opened for listed individuals/entities and scan all existing accounts for matches. Freezing of funds and assets must follow the procedure in the September 17, 2009 circular.

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 Al-Qaida Sanctions Committee, forwarded by the Ministry of External Affairs.

What action is required for existing accounts?

Banks must scan all existing accounts to ensure none are held by or linked to listed individuals/entities, and freeze assets as per the September 17, 2009 circular.

Who must acknowledge receipt of this circular?

The Compliance Officer or Principal Officer of the bank must acknowledge receipt.

📜 Read the original circular — full text as issued by RBI
RBI/2011-12/450 DBOD. AML. No.13900 /14.06.001/2011-12 March 16, 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. 13747/14.06.001/2011-12 dated March 14, 2012 . We have since received from Government of India, Ministry of External Affairs, UNP Division copy of note dated March 14, 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/2011-12/450 · issued 16 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 51-A: Update Al-Qaida Sanctions List” is: “Update your internal sanctions list with the latest UN Al-Qaida Sanctions List changes.” (RBI issued this 16 Mar 2012).

  1. Circular: RBI/2011-12/450 -- UAPA Section 51-A: Update Al-Qaida Sanctions List
  2. Issued: 16 Mar 2012
  3. Action required: Update your internal sanctions list with the latest UN Al-Qaida Sanctions List changes.
  4. Action required: Screen all new account applicants against the updated list before onboarding.
  5. Action required: Review all existing accounts to identify and freeze any linked to listed entities.
  6. Action required: Ensure compliance with the UAPA Order of August 27, 2009 and related RBI circulars.
  7. Action required: Have your Compliance Officer acknowledge 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=7069&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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