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UAPA Section 51A: UNSC Sanctions List Updated for Two Entries

Current · Source: Reserve Bank of India · RBI/2022-23/18 · issued 04 Apr 2022 · ~2 min read
Quick answerRBI mandates all regulated entities to update their screening systems with the latest UNSC 1267/1989 sanctions list amendments for two entries: individual Emraan Ali and entity ISIL-Khorasan, as per UNSC press release SC/14850 dated April 1, 2022, communicated via RBI circular dated April 4, 2022.
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

As a branch operations officer in Indore, Rohan must ensure that the bank's screening system is updated with the latest UNSC sanctions list amendments. He cross-checks existing customer accounts and transactions against the updated information and freezes any accounts linked to Emraan Ali or ISIL-Khorasan, reporting the action to FIU-IND to maintain compliance with Section 51A of UAPA, 1967.

What changed

The UNSC amended two entries on its 1267/1989 ISIL & Al-Qaida sanctions list: individual QDi.430 (Emraan Ali) with details including aliases, passport numbers, and addresses, and entity QDe.161 (ISIL-Khorasan) with additional aliases. These changes were communicated via MEA press release SC/14850 dated April 1, 2022, as per RBI circular dated April 4, 2022.

What it means for you

Banks and other regulated entities must immediately update their KYC and AML screening databases to reflect these amendments. Failure to identify and freeze accounts linked to these updated entries could lead to regulatory action under UAPA, 1967. The inclusion of ISIL-Khorasan with multiple aliases requires enhanced due diligence for transactions involving South Asian regions.

What you must do

Who it affects

All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, Other regulated entities under RBI's AML/KYC framework

❓ Common questions

What is the significance of the UNSC press release SC/14850 for Indian banks?

It provides specific amendments to two sanctions list entries—an individual and an entity—which banks must incorporate into their screening processes to avoid violating UAPA, 1967.

How should banks handle the multiple aliases for ISIL-Khorasan?

Banks should ensure their screening systems can match all listed aliases (e.g., ISIS-K, IS-Khorasan) to prevent false negatives during transaction monitoring and customer due diligence.

What are the consequences of non-compliance with this update?

Non-compliance could result in regulatory penalties, including fines or restrictions, as per RBI's AML/KYC directives and the UAPA, 1967.

📜 Read the original circular — full text as issued by RBI
RBI/2022-23/18 DOR.AML.REC.11/14.06.001/2022-23 April 04, 2022 The Chairpersons/ CEOs of all the Regulated Entities Madam/Dear Sir, Implementation of Section 51A of UAPA, 1967: Updates to UNSC’s 1267/ 1989 ISIL (Da'esh) & Al-Qaida Sanctions List: Amendment in two entries Please refer to Section 51 of our Master Direction on Know Your Customer dated February 25, 2016 as amended on May 10 , 2021, in terms of which “Regulated Entities (REs) shall ensure that in terms of Section 51A of the Unlawful Activities (Prevention) (UAPA) Act, 1967, they do not have any account in the name of individuals/entities appearing in the lists of individuals and entities, suspected of having terrorist links, which are approved by and periodically circulated by the United Nations Security Council (UNSC).” 2. In this connection, Ministry of External Affairs (MEA) has informed about UNSC press release (SC/14850 dated April 01, 2022) regarding amendments which have been specified with underline and strikethrough in the following two entries. A. Individuals QDi.430 Name: 1: EMRAAN 2: ALI 3: 4: na Title: na Designation: na DOB: 4 Jul. 1967 POB: Rio Claro, Trinidad and Tobago Good quality a.k.a.: na Low quality a.k.a.: Abu Jihad TNT Nationality: a) Trinidad and Tobago b) United States of America Passport no: a) Trinidad and Tobago number TB162181 (issued on 27 January 2015, expired 26 January 2020) b) United States of America number 420985453 (expired 6 February 2017) National identification no: Trinidad and Tobago 19670704052 Address: a) United States of America (in detention, Federal Detention Center – Miami, Register Number: 10423-509) b) # 12 Rio Claro Mayaro Road, Rio Claro, Trinidad and Tobago (previous location 2008-March 2015) c) #7 GUAYAGUAYARE Road, Rio Claro, Trinidad and Tobago (previous location circa 2003) d) United States of America (previous location- January 1991-2008) Listed on: 23 Nov. 2021 ( Amended on 1 Apr. 2022). Other information: Senior member of Islamic State in Iraq and the Levant (ISIL), listed as Al-Qaida in Iraq (QDe.115). Recruited for ISIL and instructed individuals to perpetrate terrorist acts via online video . Physical description: height 176 cm, weight 73 kg, medium built, colour of eyes- brown, colour of hair- black/bald, complexion- brown. Speaks English. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals . B. Entities and other groups QDe.161 Name: ISLAMIC STATE IN IRAQ AND THE LEVANT - KHORASAN (ISIL- K) A.k.a.: a) ISIL KHORASAN b) ISLAMIC STATE’S KHORASAN PROVINCE c) ISIS WILAYAT KHORASAN d) ISIL’S SOUTH ASIA BRANCH e) SOUTH ASIAN CHAPTER OF ISIL f) The Islamic State of Iraq and ash-Sham—Khorasan Province g) The Islamic State of Iraq and Syria—Khorasan h) Islamic State of Iraq and Levant in Khorasan Province i) Islamic State Khurasan j) ISIS-K k) ISISK l) IS-Khorasan F.k.a.: na Address: na Listed on: 14 May 2019 ( Amended on 1 Apr. 2022). Other information: Islamic State of Iraq and the Levant - Khorasan (ISIL - K) was formed on January 10, 2015 by a former Tehrik-e Taliban Pakistan (TTP) (QDe.132) commander and was established by former Taliban faction commanders who swore an oath of allegiance to the Islamic State of Iraq and the Levant (listed as Al-Qaida in Iraq (QDe.115)). ISIL – K has claimed responsibility for numerous attacks in both Afghanistan and Pakistan. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Entities . The UNSC press release concerning amendments to the list is available at URL: https://www.un.org/securitycouncil/sanctions/1267/press-releases 3. Updated lists of individuals and entities linked to ISIL (Da'esh), Al-Qaida and Taliban are available at: http://www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list; https://www.un.org/securitycouncil/sanctions/1988/materials; 4. The details of the sanction measures and exemptions are available at the following URL: https://www.un.org/securitycouncil/sanctions/1267#further_information 5. As per the instructions from the Ministry of Home Affairs (MHA), any request for delisting received by any Regulated Entity (RE) is to be forwarded electronically to Joint Secretary (CTCR), MHA for consideration. Individuals, groups, undertakings or entities seeking to be removed from the Security Council’s ISIL (Da'esh) and Al-Qaida Sanctions List can submit their request for delisting to an independent and impartial Ombudsperson who has been appointed by the United Nations Secretary-General. More details are available at the following URL: https://www.un.org/securitycouncil/ombudsperson/application 6. In view of the above, REs are advised to take note of the aforementioned UNSC communication and ensure meticulous compliance Yours faithfully, (Santosh Kumar Panigrahy) Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2022-23/18 · issued 04 Apr 2022. 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 screening systems with the amended UNSC sanctions list entries for Emraan Ali (QDi.430) and ISIL-Khorasan (QDe.161) as per the UNSC press release dated April 1, 2022, and RBI circular dated April 4, 2022.
📜 Compliance
  • Cross-check existing customer accounts and transactions against the updated aliases, passport numbers, and addresses provided in the notification.
  • Ensure compliance with Section 51A of UAPA, 1967 by freezing any accounts or assets linked to these individuals/entities and reporting to FIU-IND.
  • Take note of the UNSC communication and ensure meticulous compliance as advised by RBI.
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, Non-banking financial companies (NBFCs), Payment system operators, Other regulated entities under RBI's AML/KYC framework), your first concrete step on “UAPA Section 51A: UNSC Sanctions List Updated for Two Entries” is: “Update your AML screening systems with the amended UNSC sanctions list entries for Emraan Ali (QDi.430) and ISIL-Khorasan (QDe.161) as per the UNSC press release dated April 1, 2022, and RBI circular dated April 4, 2022.” (RBI issued this 04 Apr 2022).

  1. Circular: RBI/2022-23/18 -- UAPA Section 51A: UNSC Sanctions List Updated for Two Entries
  2. Issued: 04 Apr 2022
  3. Action required: Update your AML screening systems with the amended UNSC sanctions list entries for Emraan Ali (QDi.430) and ISIL-Khorasan (QDe.161) as per the UNSC press release dated April 1, 2022, and RBI circular dated April 4, 2022.
  4. Action required: Cross-check existing customer accounts and transactions against the updated aliases, passport numbers, and addresses provided in the notification.
  5. Action required: Ensure compliance with Section 51A of UAPA, 1967 by freezing any accounts or assets linked to these individuals/entities and reporting to FIU-IND.
  6. Action required: Take note of the UNSC communication and ensure meticulous compliance as advised by RBI.
  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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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=12284&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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