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UAPA: 1 Individual & 2 Groups Added to Terror Lists

Current · Source: Reserve Bank of India · RBI/2022-23/183 · issued 28 Feb 2023 · ~2 min read
Quick answerRBI directs all regulated entities to immediately apply UAPA screening to one individual and two organisations newly listed in Schedule IV and I of the UAPA, 1967 via MHA gazette notifications dated February 17, 2023.
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

A KYC & compliance officer in Indore is reviewing a new loan application. She runs the customer's name through her bank's screening system and sees a match with 'Harwinder Singh Sandhu @ Rinda'. She immediately flags the account, reports it to FIU-IND and the Ministry of Home Affairs, and freezes the loan process until she gets further instructions, following the UAPA rules her compliance team trained her on.

What changed

The Ministry of Home Affairs issued three gazette notifications on February 17, 2023, designating one individual (Harwinder Singh Sandhu @ Rinda) and two organisations (Jammu and Kashmir Ghaznavi Force and Khalistan Tiger Force, including all their manifestations and front organisations) as 'Individual Terrorist' and 'Terrorist Organisations' under the UAPA, 1967. RBI has now communicated these additions to all regulated entities, reiterating that the existing KYC Master Direction's UAPA compliance framework applies to these new listings and any future amendments to Schedule I and IV.

What it means for you

Banks and other regulated entities must immediately update their screening systems to flag any accounts or transactions linked to these newly designated entities and individual. The existing obligation to report matches to FIU-IND and the Ministry of Home Affairs under the UAPA order of February 2, 2021, now extends to these additions. Failure to comply could lead to regulatory action, as the RBI has stressed meticulous adherence to the UAPA framework.

What you must do

Who it affects

All scheduled commercial banks, All non-banking financial companies (NBFCs), All payment system operators, All other regulated entities under RBI's purview

❓ Common questions

What exactly do I need to do with these new UAPA listings?

You must immediately add the three entries—Jammu and Kashmir Ghaznavi Force, Harwinder Singh Sandhu @ Rinda, and Khalistan Tiger Force (including all manifestations and front organisations)—to your AML screening systems. Then, run a retrospective check on your existing customer base and transactions. Any match must be reported to FIU-IND and the Ministry of Home Affairs as per the UAPA order of February 2, 2021.

Does this circular apply only to banks, or to all regulated entities?

It applies to all regulated entities (REs) under RBI's supervision, including banks, NBFCs, payment system operators, and others. The circular is addressed to 'The Chairpersons/ CEOs of all the Regulated Entities'.

Will RBI issue separate circulars for future UAPA amendments?

No. The circular explicitly states that REs 'shall also take note of any future amendments to Schedule I and IV of the UAPA, 1967, for immediate necessary compliance.' You are expected to monitor MHA gazette notifications independently and apply them without waiting for a separate RBI directive.

📜 Read the original circular — full text as issued by RBI
RBI/2022-23/183 DOR.AML.REC.105/14.06.001/2022-23 February 28, 2023 The Chairpersons/ CEOs of all the Regulated Entities Madam/Dear Sir, Designation of 1 individual and 2 organisations under Section 35(1) (a) and 2(1) (m) of the Unlawful Activities (Prevention) Act, 1967 and their listing in the Fourth and First Schedule 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 reiterated that the UAPA Order in Annex II of the MD on KYC, 2016 shall also apply to amendments carried out in Schedule IV and I of the UAPA, 1967 apart from the UNSC lists mentioned in the Order. 2. In this connection, please refer to the Gazette notifications dated February 17, 2023 of the MHA in respect of one individual and two organizations which have been declared as ‘Individual Terrorists’ and ‘Terrorist Organsiations’ and have been listed in the Schedule IV and I 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 as provided below: S.O. Numbers
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2022-23/183 · issued 28 Feb 2023. The plain-English explanation above is BankPulse’s own independent summary.
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Worked example & action-note template

Example: if you are a Compliance officer 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 purview), your first concrete step on “UAPA: 1 Individual & 2 Groups Added to Terror Lists” is: “Update your AML/KYC screening databases to include the three new entries: Jammu and Kashmir Ghaznavi Force, Harwinder Singh Sandhu @ Rinda, and Khalistan Tiger Force, along with all their manifestations and front organisations.” (RBI issued this 28 Feb 2023).

  1. Circular: RBI/2022-23/183 -- UAPA: 1 Individual & 2 Groups Added to Terror Lists
  2. Issued: 28 Feb 2023
  3. Action required: Update your AML/KYC screening databases to include the three new entries: Jammu and Kashmir Ghaznavi Force, Harwinder Singh Sandhu @ Rinda, and Khalistan Tiger Force, along with all their manifestations and front organisations.
  4. Action required: Cross-check existing customer accounts and transactions against these new listings and report any matches to FIU-IND and the Ministry of Home Affairs as per the UAPA order of February 2, 2021.
  5. Action required: Ensure your compliance team monitors future MHA gazette amendments to Schedule I and IV of the UAPA, 1967, and applies them immediately without waiting for a separate RBI circular.
  6. Action required: Reinforce staff training on the UAPA compliance procedures outlined in the Master Direction on KYC, particularly Sections 52 and 53.
  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=12459&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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