HomeCirculars › RBI/2011-12/584

UAPA Compliance: Update Al-Qaida Sanctions List for Urban Co-op Banks

Current · Source: Reserve Bank of India · RBI/2011-12/584 · issued 30 May 2012 · ~1 min read
Quick answerRBI mandates Primary (Urban) Co-operative Banks to update their records with the latest UN Al-Qaida sanctions list, screen new and existing accounts, and follow UAPA freezing 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

Riya, a compliance officer at a primary urban co‑operative bank in Mumbai, receives the RBI circular. She updates the bank’s sanctions database with the seven new UN notes, screens a new applicant named Ahmed and finds no match, but later discovers that an existing customer, Mr. Khan, is on the list. Riya freezes Mr. Khan’s account following the freezing steps in paragraph 7 of the 2009 circular and sends a confirmation to the Regional Office through the Compliance Officer. The bank stays compliant and avoids penalties.

What changed

RBI forwarded seven UN notes from February to April 2012 updating the Al-Qaida sanctions list. Urban co-operative 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 verify that no new or existing customer matches the updated UN designations. Failure to comply could lead to regulatory action and reputational risk.

What you must do

Who it affects

Primary (Urban) Co-operative Banks, Compliance Officers, Principal Officers

❓ Common questions

What is the source of the updated sanctions list?

The list comes from the UN Security Council's 1267/1989 Committee, forwarded by the Ministry of External Affairs via seven notes dated between February 23 and April 13, 2012.

What action is 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 Al-Qaida sanctions list.

Where can I find the complete sanctions 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
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No.37/14.01.062/2011-12 May 30, 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 – Primary (Urban) Co-operative Banks Please refer to our circular UBD.CO.BPD (PCB) Cir. No. 30/14.01.062/2011-12 dated April 19, 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 (copies enclosed) regarding changes made in the “Al-Qaida Sanctions List”, i.e. list of Individuals and entities linked to Al-Qaida as detailed below: 1 Note dated February 23, 2012 ( Annex I ) 2 Note dated March 06, 2012 ( Annex II ) 3 Note dated March 12, 2012 ( Annex III ) 4 Note dated March 14, 2012 ( Annex IV ) 5 Note dated March 21, 2012 ( Annex V ) 6 Note dated April 02, 2012 ( Annex VI ) 7 Note dated April 13, 2012 ( Annex VII ) 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. The Compliance Officer/Principal Officer should acknowledge receipt of this circular to the Regional Office concerned. Yours faithfully, (M. 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Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/584 · issued 30 May 2012. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
Who does what — compliance checklist
💻 IT / Systems
  • Screen all new account applications against the updated Al-Qaida list before opening accounts.
📜 Compliance
  • Update your internal sanctions database with the seven UN notes (Annex I to VII) from February-April 2012.
  • Review all existing accounts to identify and freeze any linked to listed individuals or entities.
  • Follow the freezing procedures outlined in paragraph 7 of the November 16, 2009 circular.
  • Acknowledge receipt of this circular to your Regional Office through the Compliance Officer.
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), your first concrete step on “UAPA Compliance: Update Al-Qaida Sanctions List for Urban Co-op Banks” is: “Update your internal sanctions database with the seven UN notes (Annex I to VII) from February-April 2012.” (RBI issued this 30 May 2012).

  1. Circular: RBI/2011-12/584 -- UAPA Compliance: Update Al-Qaida Sanctions List for Urban Co-op Banks
  2. Issued: 30 May 2012
  3. Action required: Update your internal sanctions database with the seven UN notes (Annex I to VII) from February-April 2012.
  4. Action required: Screen all new account applications against the updated Al-Qaida list before opening accounts.
  5. Action required: Review all existing accounts to identify and freeze any linked to listed individuals or entities.
  6. Action required: Follow the freezing procedures outlined in paragraph 7 of the November 16, 2009 circular.
  7. Action required: Acknowledge receipt of this circular to your Regional Office through the Compliance Officer.
  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.

💬 Banker Discussion

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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=7248&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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