What changed
The Ministry of Home Affairs gazette notification dated March 7, 2024 (S.O. 1120(E)) has designated Mohammad Qasim Gujjar as a terrorist under UAPA Section 35, adding him to Schedule IV. RBI clarifies that the UAPA Order in Annex II of the KYC Master Direction applies to all amendments to Schedule I and IV, not just UNSC lists.
What it means for you
Banks and other regulated entities must immediately screen their customer base against this new entry and freeze any linked accounts or transactions. The circular reinforces that compliance obligations under the KYC Master Direction extend to all government-issued UAPA Schedule updates, requiring proactive monitoring and reporting to FIU-IND and MHA.
What you must do
- Immediately update your AML/KYC screening systems to include Mohammad Qasim Gujjar (entry 57 in S.O. 1120(E)).
- Freeze all accounts and transactions linked to this individual and report to FIU-IND and Ministry of Home Affairs as per KYC Master Direction Section 51(b).
- Ensure your compliance team monitors future MHA gazette notifications for any amendments to UAPA Schedules I and IV for immediate action.
- Review and reinforce internal procedures to apply the UAPA Order (Annex II of KYC MD) to all Schedule I and IV updates, not just UNSC lists.
Who it affects
All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, All other RBI-regulated entities
What is the specific action required for this new UAPA listing?
You must immediately identify any accounts or transactions involving Mohammad Qasim Gujjar, freeze them, and report to FIU-IND and MHA as per Section 51(b) of the KYC Master Direction.
Does this circular apply only to UNSC sanctions lists?
No. RBI explicitly states that the UAPA Order in Annex II applies to all amendments to Schedule I and IV of UAPA, 1967, not just UNSC lists. This includes domestic designations like this one.
How should we handle future UAPA Schedule amendments?
You must take immediate note of any future MHA gazette notifications amending Schedule I or IV and ensure compliance without delay, following the same procedures as for this listing.