UAPA Terrorist Designations: New Entities Added to Schedules I & IV
Current · Source: Reserve Bank of India · RBI/2022-23/166 · issued 17 Jan 2023 · ~2 min read
Quick answerRBI mandates all regulated entities to immediately screen accounts against two newly designated terrorists and one terrorist organisation under UAPA, 1967, and report matches to FIU-IND and MHA as per existing KYC Master Direction.
The rule, in the simplest words
All regulated entities must update their AML/KYC screening systems with new terrorist designations.
Cross-check all customer accounts for matches with the new designations and report any matches to FIU-IND and MHA.
Future amendments to UAPA Schedules I and IV will automatically trigger compliance obligations under the same framework.
How it plays out — a real example
Amla, a compliance officer at a scheduled commercial bank in Mumbai, ensures that the bank's AML/KYC screening system is updated with the new terrorist designations. She then cross-checks all customer accounts for matches and reports any identified matches to FIU-IND and MHA as per the RBI circular. Amla's diligence helps prevent potential terrorist financing and maintains the bank's compliance with regulatory requirements.
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
❓ Common questions
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.
📜 Read the original circular — full text as issued by RBI
RBI/2022-23/166
DOR. AML.REC.96/14.06.001/2022-23
January 17, 2023
The Chairpersons/ CEOs of all the Regulated Entities
Madam/Dear Sir,
Designation of two individuals and one organisation under Section 35(1) (a) and 2(1) (m) of the Unlawful Activities (Prevention) Act,1967 and their listing in the First and Fourth Schedule of the Act.
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 I and 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 January 04, 2023 and January 05, 2023, of the MHA in respect of two individuals and one organization which have been declared as ‘Terrorists’ and ‘Terrorist Organsiation’ and have been listed in the Schedule I and IV of the UAPA 1967, under Section 35 (1) (a) and 2(1) (m) of UAPA 1967. The Statutory Order (S.O.) numbers and the respective entries are in the table below:
S.O. Numbers
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2022-23/166 · issued 17 Jan 2023. The plain-English explanation above is BankPulse’s own independent summary.
Immediately update your AML/KYC screening systems with the three new entries from S.O. 29(E), 39(E), and 45(E).
📜 Compliance
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.
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, All non-banking financial companies (NBFCs), All payment system operators, All other regulated entities under RBI's AML/KYC framework), your first concrete step on “UAPA Terrorist Designations: New Entities Added to Schedules I & IV” is: “Immediately update your AML/KYC screening systems with the three new entries from S.O. 29(E), 39(E), and 45(E).” (RBI issued this 17 Jan 2023).
Circular: RBI/2022-23/166 -- UAPA Terrorist Designations: New Entities Added to Schedules I & IV
Issued: 17 Jan 2023
Action required: Immediately update your AML/KYC screening systems with the three new entries from S.O. 29(E), 39(E), and 45(E).
Action required: Cross-check all existing and new customer accounts for matches with these names and the organisation.
Action required: Report any identified matches to FIU-IND and the Ministry of Home Affairs as per Section 52 of the KYC Master Direction.
Action required: Ensure your compliance team is aware that future UAPA Schedule amendments also require immediate action under the same process.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
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
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
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=12441&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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