What changed
The UN Security Council removed one entry (QDi.099 – Khalil Ben Ahmed Ben Mohamed Jarraya) from its 1267/1989 ISIL & Al-Qaida Sanctions List effective January 24, 2022. RBI has communicated this deletion to all regulated entities, referencing the Master Direction on KYC (Section 51A of UAPA).
What it means for you
Banks and other regulated entities must promptly update their internal sanctions screening systems to reflect this deletion. Any accounts or assets previously frozen solely due to this entry should be unfrozen, subject to independent verification. Continued freezing after deletion could expose the entity to legal or reputational risk.
What you must do
- Update your UNSC sanctions list database to remove the deleted entry (Khalil Jarraya) immediately.
- Review any frozen accounts or transactions linked to this individual and unfreeze them if no other legal hold applies.
- Ensure compliance with MHA’s delisting request procedure: forward any delisting requests from affected parties to Joint Secretary (CTCR), MHA.
- Document the update and unfreezing actions for audit and regulatory review.
Who it affects
All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, Other RBI-regulated entities
What is the significance of this deletion for my bank?
It means you must remove this individual from your internal sanctions watchlist and unfreeze any accounts or assets that were frozen solely because of this UNSC listing. Failure to update could lead to compliance gaps.
How do I verify the updated UNSC sanctions list?
The official updated list is available at www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list. Cross-check your internal database against this source.
What if the deleted individual contacts us for delisting?
Forward the request electronically to Joint Secretary (CTCR), Ministry of Home Affairs, as per MHA instructions. Also inform the individual about the UN Ombudsperson process for delisting.