HomeCirculars › RBI/2023-24/133

UAPA Terrorist Listing Update: Mohammad Qasim Gujjar Added

Current · Source: Reserve Bank of India · RBI/2023-24/133 · issued 08 Mar 2024 · ~2 min read
Quick answerRBI mandates immediate compliance with MHA's March 7, 2024 notification adding Mohammad Qasim Gujjar to UAPA Schedule IV. All regulated entities must freeze accounts, report to FIU-IND and MHA, and apply existing KYC Master Direction procedures to this and future Schedule I/IV amendments.
The rule, in the simplest words
How it plays out — a real example

A KYC & compliance officer in Indore, Priya, logs into her bank's system on March 8, 2024, and sees a new alert from RBI. She immediately runs a search for 'Mohammad Qasim Gujjar' across all customer accounts. Finding none, she still updates her screening software and notes the date in her compliance log, knowing she must repeat this check every time the government updates its terrorist lists.

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

Who it affects

All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, All other RBI-regulated entities

❓ Common questions

Regulatory timeline

Built from our lineage records — each fact carries its provenance; missing history simply is not shown (never guessed).

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.

📜 This document’s life story (1 recorded event, each backed by RBI’s own words)
Amends RRBs: Updated UN Terror List Compliance Mandate
📜 Read the original circular — full text as issued by RBI
RBI/2023-24/133 DOR.AML.REC.82/14.06.001/2023-24 March 08, 2024 The Chairpersons / CEOs of all the Regulated Entities Madam / Dear Sir, Designation of an individual under clause (a) of Sub-section (1) and Sub-section (2) of Section 35 of the Unlawful Activities (Prevention) Act (UAPA), 1967 and listing in the Fourth Schedule 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 January 04, 2024, "The procedure laid down in the UAPA Order dated February 02, 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 02, 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 notification dated March 07, 2024 of the MHA in respect of an individual who has been declared as 'Terrorist' and has been listed in the Schedule IV of the UAPA 1967, under clause (a) of Sub-section (1) and Sub-section (2) of Section 35 of UAPA 1967. The Statutory Order (S.O.) number and the respective entry is as provided below: S.O. Numbers
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2023-24/133 · issued 08 Mar 2024. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
Who does what — compliance checklist
💻 IT / Systems
  • Immediately update your AML/KYC screening systems to include Mohammad Qasim Gujjar (entry 57 in S.O. 1120(E)).
📜 Compliance
  • 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.
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, Non-banking financial companies (NBFCs), Payment system operators, All other RBI-regulated entities), your first concrete step on “UAPA Terrorist Listing Update: Mohammad Qasim Gujjar Added” is: “Immediately update your AML/KYC screening systems to include Mohammad Qasim Gujjar (entry 57 in S.O. 1120(E)).” (RBI issued this 08 Mar 2024).

  1. Circular: RBI/2023-24/133 -- UAPA Terrorist Listing Update: Mohammad Qasim Gujjar Added
  2. Issued: 08 Mar 2024
  3. Action required: Immediately update your AML/KYC screening systems to include Mohammad Qasim Gujjar (entry 57 in S.O. 1120(E)).
  4. Action required: 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).
  5. Action required: Ensure your compliance team monitors future MHA gazette notifications for any amendments to UAPA Schedules I and IV for immediate action.
  6. Action required: 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.
  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=12621&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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