What changed
The Ministry of Home Affairs gazetted two individuals—Lakhbir Singh @ Landa and Satwinder Singh @ Goldy Brar—as terrorists under Section 35(1)(a) of UAPA, 1967, adding them to Schedule IV. RBI now mandates that all regulated entities treat these additions as per the UAPA Order (Annex II of the KYC Master Direction) and apply the same compliance process to any future amendments to Schedules I and IV.
What it means for you
Banks and other regulated entities must immediately update their screening systems to include these two names and ensure no accounts or transactions are linked to them. Any matching accounts must be reported to FIU-IND and MHA without delay. This reinforces the ongoing obligation to monitor and act on all UAPA designations, not just UNSC lists.
What you must do
- Update your AML/KYC screening databases with the two new entries from Gazette notifications S.O. 5491(E) and 2(E).
- Run a one-time backward check on existing customer accounts for matches with Lakhbir Singh @ Landa and Satwinder Singh @ Goldy Brar.
- Report any identified matches to FIU-IND and MHA as per Section 51(b) of the KYC Master Direction.
- Set up a process to automatically incorporate future UAPA Schedule I and IV amendments into your screening workflow.
- Brief compliance and operations teams on the updated UAPA compliance procedures.
Who it affects
All scheduled commercial banks, Cooperative banks, Non-banking financial companies (NBFCs), Payment system operators, All other regulated entities under RBI's AML/CFT framework
What is the legal basis for this notification?
RBI issued this under Section 35(1)(a) of UAPA, 1967, referencing the KYC Master Direction (February 25, 2016, as amended) which requires strict adherence to the UAPA Order dated February 2, 2021.
Do we need to report only if we find an exact name match?
No. Section 51(b) of the Master Direction says 'accounts resembling any of the individuals/entities' must be reported. Use your usual fuzzy matching and due diligence process.
Does this apply to future UAPA amendments as well?
Yes. The circular explicitly states that the UAPA Order applies to any future amendments to Schedule I and IV, so you must monitor and act on all such updates.