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UAPA Terrorist Designation: 3 New Names Added

Current · Source: Reserve Bank of India · RBI/2022-23/170 · issued 24 Jan 2023 · ~2 min read
Quick answerRBI mandates all regulated entities to immediately screen customers against three newly designated terrorists under UAPA, 1967, and report matches to FIU-IND and MHA as per existing KYC Master Direction.
The rule, in the simplest words
How it plays out — a real example

Rahul, a risk manager at a scheduled commercial bank, ensures that the bank's AML/KYC screening system is updated with the three new entries from Gazette notifications. He then reviews existing customer accounts and transactions for any matches to these individuals and reports any identified matches to FIU-IND and the Ministry of Home Affairs as per Section 52 of the KYC Master Direction.

What changed

The Ministry of Home Affairs gazetted three individuals—Arbaz Ahmad Mir, Dr. Asif Maqbool Dar, and Arshdeep Singh Gill—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 part of the UAPA Order referenced in the KYC Master Direction, extending compliance obligations to any future Schedule I and IV amendments.

What it means for you

Banks and lenders must update their screening databases with these three names and ensure ongoing monitoring for any account links. Failure to report matches to FIU-IND and MHA could lead to regulatory action. This reinforces that the UAPA compliance framework is dynamic—any government amendment to the schedules triggers immediate obligations without a separate RBI circular.

What you must do

Who it affects

All scheduled commercial banks, All non-banking financial companies (NBFCs), All other regulated entities under RBI's AML/KYC framework

❓ Common questions

Do we need to wait for a separate RBI circular for each new UAPA addition?

No. The RBI circular clarifies that the UAPA Order in the KYC Master Direction applies to all amendments to Schedule I and IV, so any government gazette notification triggers immediate compliance.

What are the reporting requirements if we find a match?

You must report the details to FIU-IND and also advise the Ministry of Home Affairs as required under the UAPA notification dated February 2, 2021, referenced in the Master Direction.

📜 Read the original circular — full text as issued by RBI
RBI/2022-23/170 DOR.AML.REC.98/14.06.001/2022-23 January 24, 2023 The Chairpersons/CEOs of all the Regulated Entities Madam/Dear Sir, Designation of 3 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 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 06, 2023, January 07, 2023 and January 09, 2023, of the MHA in respect of three individuals who have been declared as ‘Terrorists’ and have been listed in the IV of the UAPA 1967, under Section 35 (1) (a) of UAPA 1967. The Statutory Order (S.O.) numbers and the respective entries are as provided below: S.O. Numbers
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2022-23/170 · issued 24 Jan 2023. The plain-English explanation above is BankPulse’s own independent summary.
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Who does what — compliance checklist
💻 IT / Systems
  • Update your AML/KYC screening systems with the three new entries from Gazette notifications S.O. 71(E), 104(E), and 105(E).
📜 Compliance
  • Review existing customer accounts and transactions for any matches to these individuals.
  • Report any identified matches to FIU-IND and the Ministry of Home Affairs as per Section 52 of the KYC Master Direction.
  • Establish a process to track future amendments to UAPA Schedule I and IV for immediate compliance.
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 other regulated entities under RBI's AML/KYC framework), your first concrete step on “UAPA Terrorist Designation: 3 New Names Added” is: “Update your AML/KYC screening systems with the three new entries from Gazette notifications S.O. 71(E), 104(E), and 105(E).” (RBI issued this 24 Jan 2023).

  1. Circular: RBI/2022-23/170 -- UAPA Terrorist Designation: 3 New Names Added
  2. Issued: 24 Jan 2023
  3. Action required: Update your AML/KYC screening systems with the three new entries from Gazette notifications S.O. 71(E), 104(E), and 105(E).
  4. Action required: Review existing customer accounts and transactions for any matches to these individuals.
  5. Action required: Report any identified matches to FIU-IND and the Ministry of Home Affairs as per Section 52 of the KYC Master Direction.
  6. Action required: Establish a process to track future amendments to UAPA Schedule I and IV for immediate compliance.
  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.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=12446&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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