HomeCirculars › RBI/2020-21/36

UAPA Section 51A: UNSC Sanctions List Updated – 11 Entries Amended

Current · Source: Reserve Bank of India · RBI/2020-21/36 · issued 11 Sep 2020 · ~1 min read
Quick answerRBI mandates all regulated entities to update their screening systems with the latest UNSC ISIL & Al-Qaida sanctions list amendments affecting 10 individuals and 1 entity, ensuring no accounts or services are provided to listed terrorists.
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, Priya, logs into her bank's screening system after receiving the RBI circular. She sees the updated list includes 'WAFA HUMANITARIAN ORGANIZATION' as a banned entity. She immediately runs a check on all existing customer accounts and finds a small charity account under that name. She freezes the account and reports it to her compliance team, ensuring her bank follows the law and avoids penalties.

What changed

The UNSC updated its 1267/1989 ISIL & Al-Qaida Sanctions List, amending 11 entries (10 individuals and 1 entity/group). RBI has directed all regulated entities to incorporate these changes into their compliance checks under Section 51A of UAPA, 1967.

What it means for you

Banks and other regulated entities must immediately update their customer screening databases to reflect the amended UNSC list. Failure to identify and freeze assets of these newly updated entries could lead to regulatory action. The circular also reiterates the delisting process via MHA and the UN Ombudsperson.

What you must do

Who it affects

All scheduled commercial banks, All non-banking financial companies (NBFCs), All payment system operators, All other regulated entities under RBI's purview

❓ Common questions

What is the source of the updated list?

The UNSC Committee issued press release SC/14299 dated 10 September 2020, amending 11 entries in the ISIL & Al-Qaida Sanctions List. RBI has forwarded this to all regulated entities.

What should we do if a customer requests delisting?

Forward the request electronically to Joint Secretary (CTCR), Ministry of Home Affairs. The customer can also approach the UN Ombudsperson directly for delisting.

Does this circular replace earlier KYC master directions?

No, it supplements the existing KYC Master Direction of February 25, 2016 (as amended April 20, 2020), specifically Section 51A on UAPA compliance.

📜 Read the original circular — full text as issued by RBI
RBI/2020-21/36 DOR.AML.BC.No.14/14.06.001/2020-21 September 11, 2020 The Chairpersons/CEOs of all the Regulated Entities Madam/Dear Sir, Implementation of Section 51A of UAPA, 1967 - Updates to UNSC’s 1267/1989 ISIL (Da'esh) & Al-Qaida Sanctions List - Amendment to 11 entries (10 Individuals and one entry in Entities and Groups) Please refer to Section 51 of our Master Direction on Know Your Customer dated February 25, 2016 as amended on April 20, 2020, in terms of which “Regulated Entities (REs) shall ensure that in terms of Section 51A of the Unlawful Activities (Prevention) (UAPA) Act, 1967, they do not have any account in the name of individuals/entities appearing in the lists of individuals and entities, suspected of having terrorist links, which are approved by and periodically circulated by the United Nations Security Council (UNSC).” 2. In this regard, Ministry of External Affairs (MEA) has now forwarded the following Press Release issued by the United Nations Security Council (UNSC) Committee established pursuant to Resolutions 1267 (1999), 1989 (2011) and 2253 (2015) concerning ISIL (Da’esh), Al-Qaida, and associated individuals, groups, undertakings and entities regarding changes in the List of individuals and entities subject to the assets freeze, travel ban and arms embargo set out in paragraph 1 of UNSC resolution 2368 (2017), and adopted under Chapter VII of the Charter of the United Nations. Note SC/14299 dated 10 September 2020 amending available information relating to 11 entries (10 individuals and one entity/group) in UNSC’s 1267/1989 ISIL (Da'esh) & Al-Qaida Sanctions List viz. A. Individuals 1. QDi.096 Name: 1: MOUSSA 2: BEN OMAR 3: BEN ALI 4: ESSAADI 2. QDi.099 Name: 1: KHALIL 2: BEN AHMED 3: BEN MOHAMED 4: JARRAYA 3. QDi.138 Name: 1: SAID 2: BEN ABDELHAKIM 3: BEN OMAR 4: AL-CHERIF 4. QDi.139 Name: 1: IMED 2: BEN MEKKI 3: ZARKAOUI 4: na 5. QDi.140 Name: 1: KAMAL 2: BEN MAOELDI 3: BEN HASSAN 4: AL-HAMRAOUI 6. QDi.143 Name: 1: HAMADI 2: BEN ABDUL AZIZ 3: BEN ALI 4: BOUYEHIA 7. QDi.149 Name: 1: NOUREDDINE 2: BEN ALI 3: BEN BELKASSEM 4: AL-DRISSI 8. QDi.330 Name: 1: AZZAM 2: ABDULLAH 3: ZUREIK 4: AL-MAULID AL-SUBHI 9. QDi.332 Name: 1: IBRAHIM 2: SULEIMAN 3: HAMAD 4: AL-HABLAIN 10. QDi.370 Name: 1: TARAD 2: MOHAMMAD 3: ALJABRA ALNORI ALFARES 4: na ALJARBA B. Entities and other groups QDe.015 Name: WAFA HUMANITARIAN ORGANIZATION The UNSC press release concerning amendments to the list is available at URL: https://www.un.org/press/en/2020/sc14299.doc.htm 3. Updated lists of individuals and entities linked to ISIL (Da'esh), Al-Qaida and Taliban are available at: https://www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list https://www.un.org/securitycouncil/sanctions/1988/materials 4. The details of the sanctions measures and exemptions are available at the following URL: https://www.un.org/securitycouncil/sanctions/1267#further_information 5. As per the instructions from the Ministry of Home Affairs (MHA), any request for delisting received by any Regulated Entity (RE) is to be forwarded electronically to Joint Secretary (CTCR), MHA for consideration. Individuals, groups, undertakings or entities seeking to be removed from the Security Council’s ISIL (Da'esh) and Al-Qaida Sanctions List can submit their request for delisting to an independent and impartial Ombudsperson who has been appointed by the United Nations Secretary-General. More details are available at the following URL: https://www.un.org/securitycouncil/ombudsperson/application 6. In view of the above, REs are advised to take note of the aforementioned UNSC communication and ensure meticulous compliance. Yours faithfully, (Dr. S. K. Kar) Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2020-21/36 · issued 11 Sep 2020. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
Who does what — compliance checklist
💻 IT / Systems
  • Update your AML/KYC screening systems with the amended UNSC list entries (10 individuals and 1 entity).
📜 Compliance
  • Cross-check all existing customer accounts and transactions against the updated list and freeze any matches.
  • Ensure your compliance team is aware of the delisting request procedure through MHA and the UN Ombudsperson.
  • Document the steps taken for audit and regulatory review.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template

Example: if you are an IT/Systems lead at a bank this circular applies to (All scheduled commercial banks, All non-banking financial companies (NBFCs), All payment system operators, All other regulated entities under RBI's purview), your first concrete step on “UAPA Section 51A: UNSC Sanctions List Updated – 11 Entries Amended” is: “Update your AML/KYC screening systems with the amended UNSC list entries (10 individuals and 1 entity).” (RBI issued this 11 Sep 2020).

  1. Circular: RBI/2020-21/36 -- UAPA Section 51A: UNSC Sanctions List Updated – 11 Entries Amended
  2. Issued: 11 Sep 2020
  3. Action required: Update your AML/KYC screening systems with the amended UNSC list entries (10 individuals and 1 entity).
  4. Action required: Cross-check all existing customer accounts and transactions against the updated list and freeze any matches.
  5. Action required: Ensure your compliance team is aware of the delisting request procedure through MHA and the UN Ombudsperson.
  6. Action required: Document the steps taken for audit and regulatory review.
  7. Owner: ____________ Target date: ____________
  8. Board/committee approval needed? Y / N
  9. 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=11963&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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