The Reserve Bank of India has issued notifications regarding amendments to the UNSC's sanctions list under Section 51A of the UAPA, which affect commercial banks and financial institutions. The updates include important changes that practitioners must be aware of for compliance purposes.
Updates to UNSC Sanctions List under UAPA, 1967
On August 18, 2026, the Reserve Bank of India (RBI) issued a series of notifications related to the implementation of Section 51A of the Unlawful Activities (Prevention) Act (UAPA), 1967. These notifications pertain to updates concerning the United Nations Security Council's (UNSC) 1267/1989 sanctions list addressing ISIL (Da'esh) and Al-Qaida.
The RBI has revised four entries in the UNSC's list, which will directly impact how commercial banks and financial institutions conduct due diligence and compliance measures. All financial entities are urged to review these updates to ensure adherence to the revised provisions, specifically concerning the handling of accounts associated with the sanctioned entities.
These amendments mandate that all banks listed in the notification must implement specific compliance measures related to the designated individuals and entities on the sanctions list. This step aligns with the government's commitment to combating terrorism financing, as outlined by international standards set by the Financial Action Task Force (FATF).
Practitioners should closely monitor these developments as failure to comply with the revised sanctions list may lead to severe penalties for financial institutions. Additionally, legal advisors must guide their clients on the implications of these changes on operational protocols pertaining to affected transactions.
Citations
- RBI Notification (2026) RBI/2026-27/235

