The Reserve Bank has notified financial institutions of an update to the UNSC 1267/1989 ISIL & Al-Qaida sanctions list under Section 51A of the UAPA, 1967, requiring immediate compliance for freezing assets linked to designated individuals or entities.
UAPA Section 51A Implements UNSC Terror List Update
The Reserve Bank of India (RBI), in a communication dated September 29, 2026, has directed all regulated financial entities—including commercial banks, NBFCs, and co-operative banks—to implement amendments to the United Nations Security Council’s (UNSC) 1267/1989 ISIL (Da'esh) and Al-Qaida Sanctions List. The update is issued pursuant to Section 51A of the Unlawful Activities (Prevention) Act, 1967 (UAPA), which mandates domestic enforcement of UNSC terrorist designations and asset freezes.
Entities covered under the circular include all category-I authorised dealer banks, small finance banks, payment banks, urban and rural co-operative banks, regional rural banks, local area banks, non-banking financial companies, asset reconstruction companies, and all India financial institutions. The directive requires immediate identification, freezing, and prohibition of transactions related to the specified entry amended in the UNSC sanctions list, in line with India’s international obligations under counter-terrorism financing frameworks.
Practitioners must ensure that their institutions’ screening mechanisms are updated to reflect the revised list. Non-compliance may attract regulatory action under anti-money laundering (AML) and terror financing (TF) regulations. Legal teams in financial institutions should review internal compliance protocols and coordinate with compliance officers to implement the necessary alerts and reporting procedures.
Citations
- Unlawful Activities (Prevention) Act, 1967, Section 51A
