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UAPA Section 51A: UNSC Sanctions List Updated with 3 New Entries

Current · Source: Reserve Bank of India · RBI/2021-22/145 · issued 03 Jan 2022 · ~2 min read
Quick answerRBI directs all regulated entities to immediately screen accounts against three new UNSC sanctions list entries: ASHRAF AL-QIZANI, JUND AL-KHILAFAH IN TUNISIA, and SANAULLAH GHAFARI. Freeze assets, deny services, and report as per UAPA Section 51A obligations.
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 payments & clearing officer in Indore, Priya, receives the RBI circular about the three new UNSC entries. She immediately updates her bank's screening system with the names ASHRAF AL-QIZANI, JUND AL-KHILAFAH IN TUNISIA, and SANAULLAH GHAFARI. Then she runs a check on all existing gold-loan customers and finds a match for one of the names, so she freezes that customer's account and reports it to the FIU-IND and MHA as required.

What changed

The UNSC 1267/1989 ISIL & Al-Qaida Sanctions Committee added two entries on December 29, 2021 (ASHRAF AL-QIZANI and JUND AL-KHILAFAH IN TUNISIA) and one entry on December 21, 2021 (SANAULLAH GHAFARI). RBI has now communicated these additions to all regulated entities for compliance under Section 51A of UAPA, 1967.

What it means for you

Banks and lenders must immediately update their sanctions screening systems with these three new names and freeze any linked accounts or transactions. Failure to comply could lead to regulatory action and reputational risk. The circular also reiterates the delisting process through MHA or the UN Ombudsperson.

What you must do

Who it affects

All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, Cooperative banks, All other RBI-regulated entities

❓ Common questions

What is the legal basis for this circular?

It is issued under Section 51A of the Unlawful Activities (Prevention) Act, 1967, read with RBI's Master Direction on KYC dated February 25, 2016 (as amended). Regulated entities must not maintain accounts for individuals or entities on the UNSC sanctions list.

How should we handle a customer who claims to be wrongly listed?

Per MHA instructions, forward any delisting request electronically to Joint Secretary (CTCR), MHA. Alternatively, the individual/entity can approach the UN Ombudsperson directly via the UN website. Do not unfreeze assets without official clearance.

Are these additions effective immediately?

Yes. The circular is dated January 3, 2022, and requires immediate compliance. The UNSC press releases for the additions were issued on December 21 and December 29, 2021, so entities should have already updated their lists.

📜 Read the original circular — full text as issued by RBI
RBI/2021-22/145 DOR.AML.REC.75/14.06.001/2021-22 January 03, 2022 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: Addition of entries Please refer to Section 51 of our Master Direction on Know Your Customer dated February 25, 2016 as amended on May 10 , 2021, 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 dated December 29, 2021 , 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. Reference SCA/2/21(19) dated 29 December 2021 regarding addition of 2 entries [QDi.432 Name: 1: ASHRAF 2: AL-QIZANI 3: na 4: na and QDe.167 Name: JUND AL-KHILAFAH IN TUNISIA] in UNSC’s 1267/ 1989 ISIL (Da'esh) & Al-Qaida Sanctions List. The UNSC press release concerning amendments to the list is available at URL: https://www.un.org/securitycouncil/sanctions/1267/press-releases 3. Updated lists of individuals and entities linked to ISIL (Da'esh), Al-Qaida and Taliban are available at: 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. 7. Attention of REs is also invited to the following Press Release dated December 21, 2021 , 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/14748 dated 21 December 2021 regarding addition of 1 entry [QDi.431 Name: 1: SANAULLAH 2: GHAFARI 3: na 4: na ] in UNSC’s 1267/ 1989 ISIL (Da'esh) & Al-Qaida Sanctions List. The UNSC press release concerning amendments to the list is available at URL: https://www.un.org/securitycouncil/sanctions/1267/press-releases Instructions in the above-mentioned points 3 to 6 are similarly applicable to the December 21, 2021 UNSC communication. Yours faithfully, (Vivek Srivastava) General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2021-22/145 · issued 03 Jan 2022. The plain-English explanation above is BankPulse’s own independent summary.
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Worked example & action-note template

Example: if you are a Compliance officer at a bank this circular applies to (All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, Cooperative banks, All other RBI-regulated entities), your first concrete step on “UAPA Section 51A: UNSC Sanctions List Updated with 3 New Entries” is: “Update your AML/KYC screening databases with the three new UNSC entries: ASHRAF AL-QIZANI, JUND AL-KHILAFAH IN TUNISIA, and SANAULLAH GHAFARI.” (RBI issued this 03 Jan 2022).

  1. Circular: RBI/2021-22/145 -- UAPA Section 51A: UNSC Sanctions List Updated with 3 New Entries
  2. Issued: 03 Jan 2022
  3. Action required: Update your AML/KYC screening databases with the three new UNSC entries: ASHRAF AL-QIZANI, JUND AL-KHILAFAH IN TUNISIA, and SANAULLAH GHAFARI.
  4. Action required: Conduct a retrospective check on existing customers and transactions for any matches with these names.
  5. Action required: Freeze assets and report any matches to the Financial Intelligence Unit (FIU-IND) and the Joint Secretary (CTCR), MHA immediately.
  6. Action required: Ensure your compliance team is aware of the delisting request process via MHA or the UN Ombudsperson.
  7. Action required: Document all screening actions and maintain audit trails for regulatory inspection.
  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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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=12214&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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