UAPA: Two New Terrorist Designations Added – Immediate Compliance Required
Current · Source: Reserve Bank of India · RBI/2023-24/106 · issued 02 Jan 2024 · ~2 min read
Quick answerRBI directs all regulated entities to immediately screen accounts against two newly designated terrorists under UAPA, 1967, and report matches to FIU-IND and MHA as per existing KYC Master Direction procedures.
The rule, in the simplest words
Banks must add two new people named Lakhbir Singh @ Landa and Satwinder Singh @ Goldy Brar to their watchlists (lists of bad guys to block).
If a bank finds any customer account that matches these names, they must tell FIU-IND (the financial crime watchdog) and MHA (the Home Ministry) right away.
Banks must also check all old customer accounts to see if any match these two new names.
Banks must set up a system to automatically add any future bad-guy names from government lists to their screening (checking) process.
How it plays out — a real example
A KYC & compliance officer in Indore, Priya, updates her bank's screening system with the two new names from the RBI circular. She then runs a backward check on all existing gold-loan customers and finds no matches, so she breathes a sigh of relief and notes the new procedure in her compliance log to ensure future updates are automatic.
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
❓ Common questions
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.
📜 Read the original circular — full text as issued by RBI
RBI/2023-24/106
DOR.AML.REC.65/14.06.001/2023-24
January 02, 2024
The Chairpersons/ CEOs of all the Regulated Entities
Madam/Dear Sir,
Designation of 2 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 51 read with Section 53A of our Master Direction on Know Your Customer dated February 25, 2016 as amended on October 17, 2023, “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 51(b) 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 highlighted that the UAPA Order in Annex II of the MD on KYC, 2016 shall also apply to amendments carried out in Schedule I and IV of the UAPA, 1967 apart from the UNSC lists mentioned in the Order.
2. In this connection, please refer to the Gazette notifications dated December 29, 2023 and January 01, 2024, of the MHA in respect of two 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 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/2023-24/106 · issued 02 Jan 2024. The plain-English explanation above is BankPulse’s own independent summary.
Brief compliance and operations teams on the updated UAPA compliance procedures.
📜 Compliance
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.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template
Example: if you are a Compliance officer at a bank this circular applies to (All scheduled commercial banks, Cooperative banks, Non-banking financial companies (NBFCs), Payment system operators, All other regulated entities under RBI's AML/CFT framework), your first concrete step on “UAPA: Two New Terrorist Designations Added – Immediate Compliance Required” is: “Update your AML/KYC screening databases with the two new entries from Gazette notifications S.O. 5491(E) and 2(E).” (RBI issued this 02 Jan 2024).
Circular: RBI/2023-24/106 -- UAPA: Two New Terrorist Designations Added – Immediate Compliance Required
Issued: 02 Jan 2024
Action required: Update your AML/KYC screening databases with the two new entries from Gazette notifications S.O. 5491(E) and 2(E).
Action required: Run a one-time backward check on existing customer accounts for matches with Lakhbir Singh @ Landa and Satwinder Singh @ Goldy Brar.
Action required: Report any identified matches to FIU-IND and MHA as per Section 51(b) of the KYC Master Direction.
Action required: Set up a process to automatically incorporate future UAPA Schedule I and IV amendments into your screening workflow.
Action required: Brief compliance and operations teams on the updated UAPA compliance procedures.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
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.
💬 Banker Discussion
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
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=12591&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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