UAPA Compliance: Update Al-Qaida Sanctions List for RRBs and Co-op Banks
Current · Source: Reserve Bank of India · RBI/2012-13/188 · issued 31 Aug 2012 · ~1 min read
Quick answerRBI directs RRBs and co-op banks to update their UN Al-Qaida sanctions list using new government inputs, screen new and existing accounts against it, and follow UAPA freezing procedures strictly.
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
Banks must update their list of bad people linked to Al-Qaida using new government notes from July and August 2012.
Before opening any new account, check the customer's name against the updated list to make sure they are not on it.
Check all existing accounts to see if any are linked to people or groups on the updated list.
If you find a match, freeze their money and assets following rules from earlier RBI circulars (from 2009).
Your Compliance Officer must tell the RBI regional office that they got this circular.
How it plays out — a real example
A compliance officer at a co-operative bank in Lucknow receives this circular. She immediately updates the bank's sanctions list with the new names from the government notes. Then, she screens all new account applications that day and reviews existing accounts, finding one match. She freezes that account's assets as per the 2009 RBI rules and reports it to the RBI regional office.
What changed
RBI has forwarded four new UN notes (dated July 5, 20, 27, and August 29, 2012) from the 1267/1989 Committee that update the Al-Qaida Sanctions List. Banks must now incorporate these changes into their screening processes.
What it means for you
Banks must immediately update their internal sanctions lists to include the newly designated individuals/entities. Failure to screen new accounts or review existing ones against this list could lead to regulatory action. The circular reinforces the strict compliance framework under UAPA, 1967, including freezing of assets linked to listed entities.
What you must do
Update your internal sanctions list with the latest UN Al-Qaida Sanctions List changes from the enclosed government notes.
Screen all new account applications against the updated list before opening accounts.
Review all existing accounts to identify any matches with the updated list and report findings.
Follow the freezing procedures outlined in earlier RBI circulars (dated Nov 5, 2009 and Oct 29, 2009) for any matched accounts.
Ensure your Compliance Officer/Principal Officer acknowledges receipt of this circular to the concerned RBI Regional Office.
Who it affects
All Regional Rural Banks (RRBs), All State and Central Co-operative Banks
❓ Common questions
What is the source of the updated sanctions list?
The updates come from the UN Security Council's 1267/1989 Committee, communicated via four notes from the Ministry of External Affairs dated July 5, 20, 27, and August 29, 2012.
Do we need to freeze accounts immediately if a match is found?
Yes, you must follow the freezing procedures detailed in paragraph 6 of the earlier circulars (RPCD.CO.RRB.No.39/03.05.33(E)/2009-10 dated Nov 5, 2009 and RPCD.CO.RF.AML.BC.No.34/07.40.00/2009-10 dated Oct 29, 2009).
Where can we access the full sanctions list?
The complete 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/2012-13/188
RPCD.CO.RRB.RCB.AML.No.2090/07.02.12/2012-13
August 31, 2012
The Chairmen / CEOs of all Regional Rural Banks/
State and Central Co-operative Banks
Dear Sir,
I mplementation 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 RPCD.CO.RRB.RCB.AML.No.358/07.02.12/2012-13 dated July 12, 2012 . We have since received from Government of India, Ministry of External Affairs, UNP Division copy of notes dated July 5,2012 , July 20, 2012 , July 27, 2012 and August 29, 2012 (copies enclosed) forwarded by the Chairman of UN Security Council's 1267/1989 Committee regarding changes made in the “Al-Qaida Sanctions List”, i.e. list of Individuals and entities linked to Al-Qaida.
2. All Regional Rural Banks / State and Central 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 . Banks are advised to strictly follow the procedure laid down in the UAPA Order dated August 27, 2009 enclosed to our circular RPCD.CO.RRB.No.39/03.05.33 (E)/2009-10 dated November 05, 2009 and RPCD.CO.RF.AML. BC. No. 34/07.40.00/ 2009-10 dated October 29, 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 circulars mentioned in paragraph 3 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 letter to our concerned Regional Office.
Yours faithfully,
(I.S.Negi)
General Manager
Encl: As above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2012-13/188 · issued 31 Aug 2012. The plain-English explanation above is BankPulse’s own independent summary.
Screen all new account applications against the updated list before opening accounts.
📜 Compliance
Update your internal sanctions list with the latest UN Al-Qaida Sanctions List changes from the enclosed government notes.
Review all existing accounts to identify any matches with the updated list and report findings.
Follow the freezing procedures outlined in earlier RBI circulars (dated Nov 5, 2009 and Oct 29, 2009) for any matched accounts.
Ensure your Compliance Officer/Principal Officer acknowledges receipt of this circular to the concerned RBI Regional Office.
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 Regional Rural Banks (RRBs), All State and Central Co-operative Banks), your first concrete step on “UAPA Compliance: Update Al-Qaida Sanctions List for RRBs and Co-op Banks” is: “Update your internal sanctions list with the latest UN Al-Qaida Sanctions List changes from the enclosed government notes.” (RBI issued this 31 Aug 2012).
Circular: RBI/2012-13/188 -- UAPA Compliance: Update Al-Qaida Sanctions List for RRBs and Co-op Banks
Issued: 31 Aug 2012
Action required: Update your internal sanctions list with the latest UN Al-Qaida Sanctions List changes from the enclosed government notes.
Action required: Screen all new account applications against the updated list before opening accounts.
Action required: Review all existing accounts to identify any matches with the updated list and report findings.
Action required: Follow the freezing procedures outlined in earlier RBI circulars (dated Nov 5, 2009 and Oct 29, 2009) for any matched accounts.
Action required: Ensure your Compliance Officer/Principal Officer acknowledges receipt of this circular to the concerned RBI Regional Office.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
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
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
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=7540&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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