UAPA Section 51-A: Update Al-Qaida Sanctions List for Account Screening
Current · Source: Reserve Bank of India · RBI/2012-13/262 · issued 25 Oct 2012 · ~2 min read
Quick answerRBI mandates banks to update their UNSCR 1267 Al-Qaida sanctions list with changes notified by the Government of India. Before opening new accounts and when reviewing existing ones, banks must ensure no customer is on this list 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
Update your internal sanctions list with the new UN Al-Qaida entries.
Screen all new account applications against the updated list before account opening.
Run a fresh scan of all existing accounts to identify any matches with the updated list.
Follow the freezing procedures outlined in paragraph 6 of the September 17, 2009 circular for any matches found.
How it plays out — a real example
A KYC & compliance officer in Indore, Mr. Kumar, must update the internal sanctions list with the new UN Al-Qaida entries before opening a new account for a customer. He screens the customer's name against the updated list and finds a match. Following the freezing procedures, Mr. Kumar freezes the customer's account and informs the Compliance Officer about the action taken.
What changed
RBI has forwarded five new UN Security Council notes (dated September 5, 27, October 4, 5, and 18, 2012) that update the Al-Qaida Sanctions List. Banks must incorporate these changes into their screening lists immediately.
What it means for you
Banks must update their internal sanctions databases with the latest UN Al-Qaida designations to avoid onboarding or servicing prohibited entities. Non-compliance could lead to regulatory action and reputational risk. The circular reinforces the existing UAPA framework for freezing assets of listed individuals/entities.
What you must do
Update your internal sanctions list with the new UN Al-Qaida entries from the five MEA notes received.
Screen all new account applications against the updated list before account opening.
Run a fresh scan of all existing accounts to identify any matches with the updated list.
Follow the freezing procedures outlined in paragraph 6 of the September 17, 2009 circular for any matches found.
Ensure your Compliance Officer acknowledges receipt of this circular to RBI.
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 list?
The updates come from the UN Security Council's 1267/1989 Committee's Al-Qaida Sanctions List, forwarded by the Ministry of External Affairs via five notes dated between September 5 and October 18, 2012.
Do I need to freeze accounts immediately if a match is found?
Yes. For any designated individual or entity found in your accounts, you must take action as detailed in paragraph 6 of RBI's circular dated September 17, 2009, which covers freezing of funds, financial assets, or economic resources.
Where can I 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/2012-13/262
DBOD. AML.No. 6278/14.06.001/2012-13
October 25, 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. 3396/14.06.001/2012-13 dated August 30, 2012 on the captioned subject. We have since received from Government of India, Ministry of External Affairs, UNP Division, copy of notes dated September 5, 2012 , September 27, 2012 , October 4, 2012 and October 5, 2012 and October 18, 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. 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)
General Manager
Encl: as above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2012-13/262 · issued 25 Oct 2012. The plain-English explanation above is BankPulse’s own independent summary.
Screen all new account applications against the updated list before account opening.
📜 Compliance
Update your internal sanctions list with the new UN Al-Qaida entries from the five MEA notes received.
Run a fresh scan of all existing accounts to identify any matches with the updated list.
Follow the freezing procedures outlined in paragraph 6 of the September 17, 2009 circular for any matches found.
Ensure your Compliance Officer acknowledges receipt of this circular to RBI.
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 for Account Screening” is: “Update your internal sanctions list with the new UN Al-Qaida entries from the five MEA notes received.” (RBI issued this 25 Oct 2012).
Circular: RBI/2012-13/262 -- UAPA Section 51-A: Update Al-Qaida Sanctions List for Account Screening
Issued: 25 Oct 2012
Action required: Update your internal sanctions list with the new UN Al-Qaida entries from the five MEA notes received.
Action required: Screen all new account applications against the updated list before account opening.
Action required: Run a fresh scan of all existing accounts to identify any matches with the updated list.
Action required: Follow the freezing procedures outlined in paragraph 6 of the September 17, 2009 circular for any matches found.
Action required: Ensure your Compliance Officer acknowledges receipt of this circular to RBI.
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=7641&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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