What changed
The UNSC added one new individual, Hamidah Nabagala (Ugandan national, DOB 9 Mar 1996), to its ISIL (Da'esh) and Al-Qaida Sanctions List effective March 30, 2026. This triggers immediate compliance obligations under Section 51A of UAPA, 1967 and RBI's KYC Directions, 2025.
What it means for you
Banks and lenders must immediately screen all customer accounts and transactions against this updated list. Any account or transaction linked to Nabagala must be frozen, and a suspicious transaction report (STR) filed. Failure to comply can lead to regulatory action and reputational risk.
What you must do
- Update your UNSC sanctions screening systems with the new entry (Hamidah Nabagala, QDi.439) immediately.
- Run a backward-looking scan on all existing customer accounts and transactions for any matches.
- Freeze any identified accounts/assets and file STR with FIU-IND within the mandated timeline.
- Forward any de-listing requests received to Joint Secretary (CTCR), MHA as per MHA instructions.
- Ensure compliance with Chapter IX of RBI KYC Directions, 2025 and UAPA Order dated Feb 2, 2021 (amended Apr 22, 2024).
Who it affects
Commercial Banks, Small Finance Banks, Payment Banks, Urban Co-operative Banks, Rural Co-operative Banks, Regional Rural Banks, Local Area Banks, Non-Banking Financial Companies (NBFCs), Asset Reconstruction Companies (ARCs), All India Financial Institutions
What is the deadline for implementing this update?
The notification is effective from April 1, 2026. Immediate action is required—no grace period is specified. Banks should update screening systems and complete backward checks as soon as possible.
What if we find a match in our existing accounts?
You must freeze the account/assets immediately and file a Suspicious Transaction Report (STR) with FIU-IND. Also, ensure no further transactions are processed. Refer to Chapter IX of RBI KYC Directions, 2025 for detailed procedures.
How do we handle de-listing requests from customers?
Any de-listing request received must be forwarded electronically to Joint Secretary (CTCR), Ministry of Home Affairs. The UN also has an Ombudsperson process for individuals seeking removal from the sanctions list.