HomeCirculars › RBI/2022-23/134

10 New UAPA Terrorist Designations: Immediate Compliance Required

Current · Source: Reserve Bank of India · RBI/2022-23/134 · issued 27 Oct 2022 · ~2 min read
Quick answerRBI mandates all regulated entities to immediately screen customers against 10 newly designated terrorists under UAPA Schedule IV, report matches to FIU-IND and MHA, and apply existing KYC Master Direction procedures to these additions.
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 KYC & compliance officer in Indore, Priya, is checking a new customer's application. She runs the customer's name through her bank's screening system, which she just updated with the 10 new terrorist names. The system shows a match, so Priya immediately reports the account to FIU-IND and MHA, following the bank's KYC rules, and blocks the loan until she gets further instructions.

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

Who it affects

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

❓ Common questions

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.

📜 Read the original circular — full text as issued by RBI
RBI/2022-23/134 DOR.AML.REC.80/14.06.001/2022-23 October 27, 2022 The Chairpersons/ CEOs of all the Regulated Entities Madam/Dear Sir, Designation of 10 individuals as ‘Terrorists’ under Section 35 (1) (a) of the Unlawful Activities (Prevention) Act (UAPA), 1967 and their listing in the Schedule IV of the Act- Reg. In terms of Section 53 of our Master Direction on Know Your Customer dated February 25, 2016 as amended on May 10, 2021, “The procedure laid down in the UAPA Order dated February 2, 2021 (Annex II of this Master Direction) shall be strictly followed and meticulous compliance with the Order issued by the Government shall be ensured.” Further, Section 52 of the aforementioned Master Direction states that, “Details of accounts resembling any of the individuals/entities in the lists shall be reported to FIU-IND apart from advising Ministry of Home Affairs as required under UAPA notification dated February 2, 2021 (Annex II of this Master Direction)”. In this regard, it is highlighted that the UAPA Order in Annex II of the MD on KYC, 2016 shall also apply to amendments carried out in Schedule IV of the UAPA, 1967 apart from the UNSC lists mentioned in the Order. 2. In this connection, please refer to the Gazette notifications dated October 4, 2022, of the MHA in respect of ten individuals who have been declared as ‘Terrorists’ and have been listed in the Schedule IV of the UAPA 1967, under Section 35 (1) (a) of UAPA 1967. The Gazette notifications can be downloaded from https://egazette.nic.in/ . The Gazette IDs are as follows: Gazette IDs
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2022-23/134 · issued 27 Oct 2022. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
Who does what — compliance checklist
⚙️ Operations
  • Download the full gazette notifications from egazette.nic.in using the provided IDs for accurate record-keeping.
💻 IT / Systems
  • Update your AML/KYC screening systems with the 10 newly designated individuals and their aliases from the gazette notifications.
📜 Compliance
  • 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.
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, Cooperative banks, Non-banking financial companies (NBFCs), Payment system operators, All other RBI-regulated entities), your first concrete step on “10 New UAPA Terrorist Designations: Immediate Compliance Required” is: “Update your AML/KYC screening systems with the 10 newly designated individuals and their aliases from the gazette notifications.” (RBI issued this 27 Oct 2022).

  1. Circular: RBI/2022-23/134 -- 10 New UAPA Terrorist Designations: Immediate Compliance Required
  2. Issued: 27 Oct 2022
  3. Action required: Update your AML/KYC screening systems with the 10 newly designated individuals and their aliases from the gazette notifications.
  4. Action required: Cross-check all existing customer accounts and transactions against these names and report any matches to FIU-IND and MHA.
  5. Action required: Ensure your compliance team is aware that future Schedule IV amendments also fall under the same UAPA Order procedures.
  6. Action required: Download the full gazette notifications from egazette.nic.in using the provided IDs for accurate record-keeping.
  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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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12406&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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