What changed
MHA gazette notifications dated January 4 and 5, 2023, added two individuals (Aijaz Ahmad Ahanger and Mohammed Amin Khubaiab) and one organisation (The Resistance Front and all its manifestations) to Schedules I and IV of UAPA, 1967. RBI circular directs all regulated entities to treat these additions as part of the existing UAPA Order (Annex II of KYC Master Direction) and comply accordingly.
What it means for you
Banks and other regulated entities must update their screening databases with these new entries and ensure no accounts or transactions are linked to these designated persons or entities. Failure to report matches to FIU-IND and MHA could lead to regulatory action. The circular also clarifies that any future amendments to UAPA Schedules I and IV will automatically trigger compliance obligations under the same framework.
What you must do
- Immediately update your AML/KYC screening systems with the three new entries from S.O. 29(E), 39(E), and 45(E).
- Cross-check all existing and new customer accounts for matches with these names and the organisation.
- Report any identified matches to FIU-IND and the Ministry of Home Affairs as per Section 52 of the KYC Master Direction.
- Ensure your compliance team is aware that future UAPA Schedule amendments also require immediate action under the same process.
Who it affects
All scheduled commercial banks, All non-banking financial companies (NBFCs), All payment system operators, All other regulated entities under RBI's AML/KYC framework
What is the legal basis for this circular?
It references Section 53 and Section 52 of the RBI Master Direction on KYC (February 25, 2016, as amended), which require strict compliance with the UAPA Order dated February 2, 2021, and reporting of matches to FIU-IND and MHA.
Do we need to report accounts that only partially match the names?
Yes, the circular says 'details of accounts resembling any of the individuals/entities in the lists' must be reported. Use your usual name screening logic for potential matches.
Are we required to monitor future UAPA amendments proactively?
Yes, the circular explicitly states that REs shall take note of any future amendments to Schedule I and IV for immediate necessary compliance.