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

Current · Source: Reserve Bank of India · RBI/2011-12/498 · issued 13 Apr 2012 · ~1 min read
Quick answerRBI mandates banks to update and screen customers against the latest UN Al-Qaida sanctions list. New accounts must be checked, and existing accounts scanned for matches. Freeze assets of designated individuals/entities per earlier UAPA 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

A KYC & compliance officer in Indore receives this circular. She immediately updates her bank's sanctions list with the new UN Al-Qaida names. The next day, when a customer applies for a gold loan, she checks the name against the list before opening the account. She also runs a scan of all existing gold-loan accounts to ensure none are linked to the updated list.

What changed

RBI received updated UN Al-Qaida sanctions list from the Ministry of External Affairs via notes dated March 21 and April 2, 2012. Banks must now incorporate these changes into their customer screening processes.

What it means for you

Banks must immediately update their internal sanctions lists and screen all new and existing customers against the revised UN list. Non-compliance with UAPA orders could lead to regulatory action. This reinforces the need for robust AML/KYC systems.

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, forwarded by the Ministry of External Affairs. It is available on the UN website.

What action is required for existing accounts?

Banks must scan all existing accounts to ensure no account is 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 dated September 17, 2009, regarding UAPA implementation.

📜 Read the original circular — full text as issued by RBI
RBI/2011-12/498 DBOD. AML. No.15291 /14.06.001/2011-12 April 13, 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. 13900/14.06.001/2011-12 dated March 16, 2012 . We have since received from Government of India, Ministry of External Affairs, UNP Division copies of notes dated March 21, 2012 and April 2, 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/2011-12/498 · issued 13 Apr 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 opening accounts.
📜 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 updated list.
  • Freeze funds and assets of any matched individuals/entities as per the September 17, 2009 circular.
  • Ensure 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: UN Al-Qaida Sanctions List Update” is: “Update your internal sanctions list with the latest UN Al-Qaida list from the provided UN website.” (RBI issued this 13 Apr 2012).

  1. Circular: RBI/2011-12/498 -- UAPA Section 51-A: UN Al-Qaida Sanctions List Update
  2. Issued: 13 Apr 2012
  3. Action required: Update your internal sanctions list with the latest UN Al-Qaida list from the provided UN website.
  4. Action required: Screen all new account applications against the updated list before opening accounts.
  5. Action required: Scan all existing accounts to identify any matches with the updated list.
  6. Action required: Freeze funds and assets of any matched individuals/entities as per the September 17, 2009 circular.
  7. Action required: Ensure 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=7127&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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