What changed
The Ministry of Home Affairs gazetted 10 individuals as terrorists under Section 35(1)(a) of UAPA, 1967, adding them to Schedule IV. RBI now requires all regulated entities to treat these additions as per the existing UAPA Order in Annex II of the KYC Master Direction, including reporting obligations.
What it means for you
Banks and other regulated entities must update their screening databases with these 10 names immediately. Any account or transaction linked to these individuals must be reported to FIU-IND and the Ministry of Home Affairs. The existing compliance framework under the KYC Master Direction now explicitly covers all future Schedule IV amendments, not just UNSC lists.
What you must do
- Update your AML/KYC screening systems with the 10 newly designated individuals and their aliases from the gazette notifications.
- Cross-check all existing customer accounts and transactions against these names and report any matches to FIU-IND and MHA.
- Ensure your compliance team is aware that future Schedule IV amendments also fall under the same UAPA Order procedures.
- Download the full gazette notifications from egazette.nic.in using the provided IDs for accurate record-keeping.
Who it affects
All scheduled commercial banks, Cooperative banks, Non-banking financial companies (NBFCs), Payment system operators, All other RBI-regulated entities
What is the legal basis for this notification?
It stems from Section 35(1)(a) of the Unlawful Activities (Prevention) Act, 1967, and the RBI's Master Direction on KYC dated February 25, 2016 (as amended), which requires strict adherence to the UAPA Order of February 2, 2021.
Do we need to report only if we find a match?
Yes, Section 52 of the KYC Master Direction mandates reporting details of accounts resembling any listed individuals/entities to FIU-IND and advising MHA as per the UAPA notification.
Does this apply to future additions to Schedule IV?
Yes, the circular explicitly states that REs shall take note of any future amendments to Schedule IV for immediate necessary compliance.