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
- Update your AML/KYC screening systems with the three new entries from Gazette notifications S.O. 71(E), 104(E), and 105(E).
- 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.
Who it affects
All scheduled commercial banks, All non-banking financial companies (NBFCs), All other regulated entities under RBI's AML/KYC framework
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.