UAPA Schedule I Updated: Hizb-Ut-Tahrir Listed as Terrorist Organisation
Current · Source: Reserve Bank of India · RBI/2024-25/84 · issued 19 Oct 2024 · ~2 min read
Quick answerRBI directs all regulated entities to immediately update their screening databases to include 'Hizb-Ut-Tahrir (HuT)' and its front organisations, as notified by MHA on October 10, 2024, under the UAPA. Existing KYC and AML procedures under the Master Direction on KYC must be strictly followed.
The rule, in the simplest words
Banks must add 'Hizb-Ut-Tahrir (HuT)' and its front groups to their watchlists (lists of people or groups to check for illegal activity).
If a bank finds a customer or transaction linked to HuT, they must tell FIU-IND (the financial crime watchdog) and the Ministry of Home Affairs (the government's security department).
Banks must check all their current customers and past transactions to see if any are connected to HuT.
Banks must follow the same rules for updating their lists whenever the government adds new terrorist groups.
How it plays out — a real example
A KYC & compliance officer in Indore runs a routine check on a new customer's name and finds it matches 'Hizb-Ut-Tahrir (HuT)' in the updated screening database. She immediately freezes the account and reports the match to FIU-IND and the Ministry of Home Affairs, following the bank's strict KYC (Know Your Customer) rules to stay compliant with the RBI's latest directive.
What changed
The Ministry of Home Affairs has added 'Hizb-Ut-Tahrir (HuT)' and all its manifestations and front organisations to Schedule I of the UAPA, 1967, via Gazette notification S.O. 4391(E) dated October 10, 2024. RBI has now communicated this to all regulated entities, reiterating that the UAPA Order in Annex II of the Master Direction on KYC applies to such amendments.
What it means for you
Banks and other regulated entities must immediately screen their customer base and transactions for any links to Hizb-Ut-Tahrir or its front organisations. Any matching accounts or transactions must be reported to FIU-IND and the Ministry of Home Affairs as per the existing UAPA compliance framework. Failure to comply could lead to regulatory action.
What you must do
Update your AML/KYC screening systems to include 'Hizb-Ut-Tahrir (HuT)' and all its manifestations and front organisations.
Conduct a retrospective review of existing customers and transactions to identify any matches with the newly listed entity.
Report any identified matches to FIU-IND and the Ministry of Home Affairs as per the procedure in Annex II of the Master Direction on KYC.
Ensure your compliance team is aware of future amendments to Schedule I of the UAPA for immediate action.
Who it affects
All scheduled commercial banks, Non-banking financial companies (NBFCs), Payment system operators, All other regulated entities under RBI's AML/KYC framework
❓ Common questions
What is the effective date for this new listing?
The MHA gazette notification is dated October 10, 2024, and RBI's circular was issued on October 19, 2024. Compliance should be ensured immediately from the date of the circular.
Do we need to report only accounts that exactly match 'Hizb-Ut-Tahrir'?
No. The notification covers 'all its manifestations and front organisations'. You must screen for any name or entity that could be a front or manifestation of Hizb-Ut-Tahrir, using your risk-based approach.
What if we find a match after the reporting deadline?
There is no specific deadline mentioned in this circular, but the Master Direction on KYC requires immediate reporting. Delays could attract supervisory action.
📜 Read the original circular — full text as issued by RBI
RBI/2024-25/84
DOR.AML.REC.48/14.06.001/2024-25
October 19, 2024
The Chairpersons/ CEOs of all the Regulated Entities
Madam/Dear Sir,
Designation of one organisation under Section 35(1) (a) and 2(1) (m) of the Unlawful Activities (Prevention) Act, 1967 and its listing in the First Schedule of the Act- Reg.
In terms of Section 51(c) 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 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 reiterated that the UAPA Order in Annex II of the MD on KYC, 2016 shall also apply to amendments carried out in Schedule IV and I of the UAPA, 1967 apart from the UNSC lists mentioned in the Order.
2. In this connection, please refer to the Gazette notification dated October 10, 2024 of the MHA in respect of one organization which has been declared as ‘Terrorist Organsiation’ and has been listed in the Schedule I of the UAPA 1967, under Section 35 (1) (a) and 2(1) (m) of UAPA 1967. The Statutory Order (S.O.) number and the respective entry are as provided below:
S.O. Number
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2024-25/84 · issued 19 Oct 2024. The plain-English explanation above is BankPulse’s own independent summary.
Update your AML/KYC screening systems to include 'Hizb-Ut-Tahrir (HuT)' and all its manifestations and front organisations.
📜 Compliance
Conduct a retrospective review of existing customers and transactions to identify any matches with the newly listed entity.
Report any identified matches to FIU-IND and the Ministry of Home Affairs as per the procedure in Annex II of the Master Direction on KYC.
Ensure your compliance team is aware of future amendments to Schedule I of the UAPA for immediate action.
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 regulated entities under RBI's AML/KYC framework), your first concrete step on “UAPA Schedule I Updated: Hizb-Ut-Tahrir Listed as Terrorist Organisation” is: “Update your AML/KYC screening systems to include 'Hizb-Ut-Tahrir (HuT)' and all its manifestations and front organisations.” (RBI issued this 19 Oct 2024).
Circular: RBI/2024-25/84 -- UAPA Schedule I Updated: Hizb-Ut-Tahrir Listed as Terrorist Organisation
Issued: 19 Oct 2024
Action required: Update your AML/KYC screening systems to include 'Hizb-Ut-Tahrir (HuT)' and all its manifestations and front organisations.
Action required: Conduct a retrospective review of existing customers and transactions to identify any matches with the newly listed entity.
Action required: Report any identified matches to FIU-IND and the Ministry of Home Affairs as per the procedure in Annex II of the Master Direction on KYC.
Action required: Ensure your compliance team is aware of future amendments to Schedule I of the UAPA for immediate action.
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=12743&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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