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RBI mandates action on 7 new UAPA terrorist designations

Current · Source: Reserve Bank of India · RBI/2022-23/75 · issued 23 Jun 2022 · ~2 min read
Quick answerRBI has directed all regulated entities to immediately update their records with 7 individuals newly designated as terrorists under UAPA, 1967, and ensure strict compliance with KYC Master Direction procedures for freezing assets and reporting.
The rule, in the simplest words
How it plays out — a real example

As a KYC & compliance officer in Indore, Rohan must immediately update the bank's records with the 7 newly designated terrorists. He then screens the customer database and freezes any accounts linked to these individuals, following the strict KYC Master Direction procedures. Rohan reports any matches to the Financial Intelligence Unit (FIU-IND) and other designated authorities as per UAPA guidelines to ensure compliance with the regulations.

What changed

RBI issued a circular on June 23, 2022, referencing a MHA Gazette notification that added 7 individuals to Schedule IV of UAPA, 1967. Regulated entities must now treat these individuals as designated terrorists and follow the KYC Master Direction's freezing and reporting obligations.

What it means for you

Banks and other regulated entities must immediately screen their customer databases against these 7 names and freeze any accounts or assets linked to them. Failure to comply with the UAPA order and KYC Master Direction could lead to regulatory action. This is a standard but critical update to the terrorist financing watchlist.

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 is the legal basis for this circular?

It is issued under Section 35(1)(a) of the Unlawful Activities (Prevention) Act, 1967, and references Section 53 of RBI's Master Direction on KYC dated February 25, 2016 (as amended).

How many individuals are added and what are their names?

Seven individuals are added: Hafiz Talha Saeed, Mohiuddin Aurangzeb Alamgir, Ali Kashif Jan, Mushtaq Ahmed Zargar, Ashiq Ahmed Nengroo, Sheikh Sajad, and Arjumand Gulzar Dar.

What should we do if we find a match?

Immediately freeze the account/asset, file a Suspicious Transaction Report (STR) with FIU-IND, and follow the procedure in Section 53 of the KYC Master Direction.

📜 Read the original circular — full text as issued by RBI
RBI/2022-23/75 DOR.AML.REC.50/14.06.001/2022-23 June 23, 2022 The Chairpersons/ CEOs of all the Regulated Entities Madam/Dear Sir, Designation of 7 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, please also refer to Section 52 of the aforementioned Master Direction on Know Your Customer . 2. In this connection, please refer to the Gazette notification of the MHA in respect of seven individuals who have been declared as ‘Terrorists’ and have been listed in the Schedule IV of the UAPA 1967, under Section 35 (1) (a) of UAPA 1967. The link to the aforementioned Gazette notification is provided below: https://mha.gov.in/sites/default/files/UAPAlistGazette_25042022.pdf 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/2022-23/75 · issued 23 Jun 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/KYC systems with the 7 new entries from the MHA Gazette notification (S.O. 1729(E) to 1876(E)).
  • Monitor future amendments to Schedule IV of UAPA and update your systems promptly.
📜 Compliance
  • Screen existing and new customers against this updated list and freeze any matching accounts or transactions.
  • Ensure strict adherence to the procedure laid down in Section 53 of the KYC Master Direction dated Feb 25, 2016 (as amended).
  • Report any matches to the Financial Intelligence Unit (FIU-IND) and other designated authorities as per UAPA guidelines.
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 purview), your first concrete step on “RBI mandates action on 7 new UAPA terrorist designations” is: “Update your AML/KYC systems with the 7 new entries from the MHA Gazette notification (S.O. 1729(E) to 1876(E)).” (RBI issued this 23 Jun 2022).

  1. Circular: RBI/2022-23/75 -- RBI mandates action on 7 new UAPA terrorist designations
  2. Issued: 23 Jun 2022
  3. Action required: Update your AML/KYC systems with the 7 new entries from the MHA Gazette notification (S.O. 1729(E) to 1876(E)).
  4. Action required: Screen existing and new customers against this updated list and freeze any matching accounts or transactions.
  5. Action required: Ensure strict adherence to the procedure laid down in Section 53 of the KYC Master Direction dated Feb 25, 2016 (as amended).
  6. Action required: Report any matches to the Financial Intelligence Unit (FIU-IND) and other designated authorities as per UAPA guidelines.
  7. Action required: Monitor future amendments to Schedule IV of UAPA and update your systems promptly.
  8. Owner: ____________ Target date: ____________
  9. Board/committee approval needed? Y / N
  10. 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=12343&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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