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

Current · Source: Reserve Bank of India · RBI/2013-14/399 · issued 04 Dec 2013 · ~1 min read
Quick answerRBI mandates banks to update and screen customers against the latest UN Al Qaida sanctions list under UAPA, 1967. New accounts must be checked, existing accounts scanned, and funds frozen per earlier 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

Rohit Sharma, a senior relationship manager at a Mumbai branch of State Bank of India, receives the RBI circular, updates the bank’s sanctions database with updates 24‑30, screens a new loan applicant’s name against the list, runs a system‑wide scan of all current customers, and when the system flags a match, he promptly freezes that account as per the September 17, 2009 procedure and informs his compliance officer, who acknowledges the circular.

What changed

RBI has circulated press releases from the Ministry of External Affairs covering updates 24 to 30 of the UNSCR 1267/1989 Al Qaida sanctions list. Banks must now incorporate these latest updates into their customer screening processes.

What it means for you

Banks must immediately update their internal sanctions lists with the new entries from updates 24-30. Failure to screen new and existing accounts against this list could lead to regulatory action and compliance breaches under UAPA.

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 updates are from the UN Security Council's 1267/1989 Committee's Al Qaida Sanctions List, communicated via press releases from the Ministry of External Affairs.

Do I need to check existing accounts as well?

Yes, the circular explicitly requires banks to scan all existing accounts to ensure no account is held by or linked to any entity or individual on the updated list.

What action should be taken if a match is found?

Follow the procedure laid down in the UAPA Order dated August 27, 2009, and detailed in paragraph 6 of RBI's circular dated September 17, 2009, which includes freezing of funds and assets.

📜 Read the original circular — full text as issued by RBI
RBI/2013-14/399 DBOD.AML.No.10917/14.06.001/2013-14 December 4, 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 Please refer to our circular DBOD. AML No. 8677/14.06.001/2013-14 dated November 7, 2013 on the captioned subject releasing update note dated October 30, 2013 and a PDF containing a hard copy of the compilation of all amendments made to the List in the third quarter of 2013, forwarded by the Chairman of UN Security Council's 1267/1989. 2. Press releases of updates from 24th update to 30th update have since been received from Ministry of External Affairs (MEA), UNP Division. 3. 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. 4. 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. 5. 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. 6. A link of press releases in which the relevant changes to the list are announced are posted on the Committee’s website at the following URL: http://www.un.org/sc/committees/1267/pressreleases.shtml . 7. Compliance Officer/Principal Officer should acknowledge receipt of this circular. Yours faithfully, (Thomas Mathew) General Manager Encl: As above
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2013-14/399 · issued 04 Dec 2013. The plain-English explanation above is BankPulse’s own independent summary.
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Who does what — compliance checklist
🏦 Branch Manager
  • Screen all new account applications against the updated list before account opening.
📜 Compliance
  • Update your internal sanctions database with the latest UN Al Qaida list updates (24th to 30th press releases).
  • Conduct a fresh scan of all existing customer accounts to identify any matches with the updated list.
  • Freeze funds and assets of any matched individuals/entities as per the procedure in the September 17, 2009 circular.
  • Ensure your 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: Update UN Al Qaida Sanctions List” is: “Update your internal sanctions database with the latest UN Al Qaida list updates (24th to 30th press releases).” (RBI issued this 04 Dec 2013).

  1. Circular: RBI/2013-14/399 -- UAPA Section 51-A: Update UN Al Qaida Sanctions List
  2. Issued: 04 Dec 2013
  3. Action required: Update your internal sanctions database with the latest UN Al Qaida list updates (24th to 30th press releases).
  4. Action required: Screen all new account applications against the updated list before account opening.
  5. Action required: Conduct a fresh scan of all existing customer accounts to identify any matches with the updated list.
  6. Action required: Freeze funds and assets of any matched individuals/entities as per the procedure in the September 17, 2009 circular.
  7. Action required: Ensure your 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=8618&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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