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

Current · Source: Reserve Bank of India · RBI/2012-13/477 · issued 17 Apr 2013 · ~1 min read
Quick answerRBI mandates banks to update and screen against the latest UN Al-Qaida sanctions list, including eleven updates from Jan-Mar 2013 and a consolidated list. All new and existing accounts must be checked for designated individuals/entities.
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 branch operations officer in Indore receives this RBI circular. She immediately updates her bank's computer system with the new UN Al-Qaida sanctions list. Then, she checks all new gold-loan applications against the list, and also scans all existing loan accounts to see if any customer's name matches. She finds one match and freezes that account, following the RBI's freezing steps, to keep the bank safe and follow the law.

What changed

RBI has circulated eleven update notes from the UN Security Council's 1267/1989 Committee, dated between January 15 and March 25, 2013, along with a consolidated list as of April 8, 2013. Banks must update their internal lists and ensure compliance with the UAPA Order of August 27, 2009.

What it means for you

Banks must immediately update their customer screening databases with the latest UN sanctions list to avoid onboarding or maintaining accounts for designated terrorists or entities. Non-compliance could lead to regulatory action and reputational risk. The circular reinforces the need for rigorous AML/KYC checks.

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 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.

What action is required for existing accounts?

Banks must scan all existing accounts to ensure no account is held by or linked to any entity or individual on the updated list.

Where can I find the complete list?

The complete list is available on the UN website at the URLs provided in the circular.

📜 Read the original circular — full text as issued by RBI
RBI/2012-13/477 DBOD.AML.No.14982/14.06.001/2012-13 April 17, 2013 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 and Consolidated List Please refer to our circular DBOD. AML No. 8432/14.06.001/2012-13 dated December 12, 2012 on the captioned subject. We have since received from Government of India, Ministry of External Affairs, UNP Division, copies of eleven update notes dated January 15, February 5, 11, 22, 25 and March 12, 14, 18, 19, 20 and 25, 2013, ( 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. Further, Consolidated List of the Committee with respect to individuals, groups, undertakings and entities associated with Al-Qaida received with Note Verbale SCA/2/13(13) dated April 8, 2013 is also enclosed. 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/pressreleases.shtml http://www.un.org/sc/committees/1267/pdf/AQList.pdf 6. Compliance Officer/Principal Officer should acknowledge receipt of this circular. Yours faithfully, (Prakash Chandra Sahoo) Chief General Manager Encl: As above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2012-13/477 · issued 17 Apr 2013. 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 eleven update notes and consolidated list provided by RBI.
  • Scan all existing accounts to identify and freeze any linked to listed individuals or entities.
  • Follow the freezing procedures outlined in paragraph 6 of the September 17, 2009 circular.
  • Ensure the 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 Updates” is: “Update your internal sanctions list with the eleven update notes and consolidated list provided by RBI.” (RBI issued this 17 Apr 2013).

  1. Circular: RBI/2012-13/477 -- UAPA Section 51-A: UN Al-Qaida Sanctions List Updates
  2. Issued: 17 Apr 2013
  3. Action required: Update your internal sanctions list with the eleven update notes and consolidated list provided by RBI.
  4. Action required: Screen all new account applications against the updated list before opening accounts.
  5. Action required: Scan all existing accounts to identify and freeze any linked to listed individuals or entities.
  6. Action required: Follow the freezing procedures outlined in paragraph 6 of the September 17, 2009 circular.
  7. Action required: Ensure the 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.

💬 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.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=7945&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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