HomeCirculars › RBI/2026-27/01

UAPA Sanctions Update: New ISIL/Al-Qaida Listing

Current · Source: Reserve Bank of India · RBI/2026-27/01 · issued 01 Apr 2026 · ~2 min read
Quick answerRBI mandates immediate freeze on accounts linked to newly listed Ugandan national Hamidah Nabagala under UNSC sanctions. All regulated entities must check existing accounts and block any transactions involving this individual.
Sanctions-list safety note. This circular refers to a specific UN Security Council / UAPA designated-entities list update as it stood on the date above — sanctions lists change often, and a newer update almost certainly exists today. Never use this page, or any single dated circular, as your current screening list. Always screen against the live, current list at the official UAPA proscribed-organisations list and the UN Consolidated List, and confirm the obligations for your bank on the official rbi.org.in source below.
The rule, in the simplest words
How it plays out — a real example

A KYC & compliance officer in Indore, Priya, is reviewing her bank's customer list after the new UNSC sanctions update. She runs a backward scan and finds that a customer named Hamidah Nabagala has a small savings account opened last year. Priya immediately freezes the account, files a suspicious transaction report with FIU-IND, and updates her screening system to block any future transactions linked to this individual.

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

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

❓ 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 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.

📜 Read the original circular — full text as issued by RBI
RBI/2026-27/01 DOR.AML.REC.1/14.06.001/2026-27 April 01, 2026 The Chairpersons/ CEOs of the 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, Asset Reconstruction Companies, All India Financial Institutions Madam/Dear Sir, Implementation of Section 51A of UAPA, 1967: Updates to UNSC’s 1267/ 1989 ISIL (Da'esh) & Al-Qaida Sanctions List: Listing of 01 Entry Please refer to Chapter IX on “ Requirements/obligations under International Agreements - Communications from International Agencies ” of the Reserve Bank of India - Know Your Customer, Directions, 2025 dated November 28, 2025 as amended on December 29, 2025 (“Directions”), in terms of which, regulated entity shall ensure that in terms of Section 51A of the Unlawful Activities (Prevention) (UAPA) Act, 1967 and amendments thereto, it does not have any account in the name of individuals / entities appearing in the lists of individuals and entities, suspected of having terrorist links, which are approved by and periodically circulated by the United Nations Security Council (UNSC). 2. In this connection, Ministry of External Affairs (MEA), Government of India has informed about the UNSC press release SC/16325, dated March 30, 2026, wherein the Security Council Committee pursuant to resolutions 1267 (1999), 1989 (2011) and 2253 (2015) concerning ISIL (Da’esh), Al‑Qaida and associated individuals, groups, undertakings and entities, approved the addition of the entry specified below to its ISIL (Da’esh) and Al-Qaida Sanctions List of individuals and entities subject to assets freeze, travel ban and arms embargo set out in paragraph 1 of Security Council resolution 2734 (2024), and adopted under Chapter VII of the Charter of the United Nations. A. Individuals QDi.439 Name : 1: HAMIDAH 2: NABAGALA 3: na 4:na Name (original script ): حمیدة ناباجالا Title: na Designation: na DOB: 9 Mar. 1996 POB: Uganda Good quality a.k.a.: na Low quality a.k.a.: a) NABAGGALA (b) NABAGGAKA (c) HAMIDA d) HAMIDAH Nationality: Uganda Passport no : Uganda number A00044599 (expiry on 19 Mar. 2029) National identification no : na Address : Democratic Republic of the Congo Listed on: 30 Mar. 2026 Other information : Works as a mediator in financing channels for ISIL in Central Africa, has been charged with financing a bombing that occurred in the Ugandan capital, Kampala, in 2021, attempted to coerce her three children in Uganda to send them to ISIL camps in the Democratic Republic of the Congo. Gender: Female. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals 3. Press releases dated March 30, 2026 regarding the above can be found at https://press.un.org/en/2026/sc16325.doc.htm Further, the UNSC press releases concerning amendments to the list are available at URL: https://www.un.org/securitycouncil/sanctions/1267/press-releases 4. The details of the sanction measures and exemptions are available at the following URL: https://www.un.org/securitycouncil/sanctions/1267#further_information 5. In view of the above, regulated entities are advised to take appropriate action in terms of Chapter IX of the aforementioned Directions and strictly follow the procedure as laid down in the UAPA Order dated February 02, 2021 (amended on April 22, 2024) annexed to the Directions. 6. Updated lists of individuals and entities linked to ISIL (Da'esh), Al-Qaida and Taliban are available at: www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list https://www.un.org/securitycouncil/sanctions/1988/materials 7. Further, as per the instructions from the Ministry of Home Affairs (MHA), any request for de-listing received by any regulated entity is to be forwarded electronically to Joint Secretary (CTCR), MHA for consideration. Individuals, groups, undertakings or entities seeking to be removed from the Security Council’s ISIL (Da'esh) and Al-Qaida Sanctions List can submit their request for delisting to an independent and impartial Ombudsperson who has been appointed by the United Nations Secretary-General. More details are available at the following URL: https://www.un.org/securitycouncil/ombudsperson/application 8. Regulated entities are advised to take note of the aforementioned UNSC communications and ensure meticulous compliance. Yours faithfully, (Veena Srivastava) Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2026-27/01 · issued 01 Apr 2026. The plain-English explanation above is BankPulse’s own independent summary.
🧰 Tools — save, print, templates & related
Who does what — compliance checklist
💻 IT / Systems
  • Update your UNSC sanctions screening systems with the new entry (Hamidah Nabagala, QDi.439) immediately.
📜 Compliance
  • 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).
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 (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), your first concrete step on “UAPA Sanctions Update: New ISIL/Al-Qaida Listing” is: “Update your UNSC sanctions screening systems with the new entry (Hamidah Nabagala, QDi.439) immediately.” (RBI issued this 01 Apr 2026).

  1. Circular: RBI/2026-27/01 -- UAPA Sanctions Update: New ISIL/Al-Qaida Listing
  2. Issued: 01 Apr 2026
  3. Action required: Update your UNSC sanctions screening systems with the new entry (Hamidah Nabagala, QDi.439) immediately.
  4. Action required: Run a backward-looking scan on all existing customer accounts and transactions for any matches.
  5. Action required: Freeze any identified accounts/assets and file STR with FIU-IND within the mandated timeline.
  6. Action required: Forward any de-listing requests received to Joint Secretary (CTCR), MHA as per MHA instructions.
  7. Action required: Ensure compliance with Chapter IX of RBI KYC Directions, 2025 and UAPA Order dated Feb 2, 2021 (amended Apr 22, 2024).
  8. Owner: ____________ Target date: ____________
  9. Board/committee approval needed? Y / N
  10. 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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BankPulse Compliance Evidence Pack — generated 02 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=13357&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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