RBI guidelines on implementation of Section 51A of UAPA, 1967 after UNSC sanctions list amendments
The Reserve Bank of India has issued Circular No. RBI/2026-27/296 dated October 19, 2026, addressing changes made by the United Nations Security Council (UNSC) to the ISIL (Da’esh) and Al‑Qaida Sanctions List. The circular reiterates obligations of banks and other regulated entities under Section 51A of the Unlawful Activities (Prevention) Act, 1967 and under Chapter IX of the Reserve Bank of India – Know Your Customer, Directions, 2025.
This write-up explains the revised sanctions details and sets out the compliance expectations that commercial banks, cooperative banks, small finance banks, payment banks, NBFCs, Asset Reconstruction Companies and other regulated entities must follow.
1. Background: Link between UNSC sanctions and Section 51A UAPA
1.1 Statutory framework
Section 51A of the Unlawful Activities (Prevention) Act, 1967 empowers the Central Government to give effect to binding UNSC resolutions relating to terrorism and terrorist financing. In the financial sector, these obligations flow to regulated entities through:
- The Unlawful Activities (Prevention) (Procedure for Seizure of Property) Order, 2021 dated February 02, 2021 (as amended on April 22, 2024) issued under UAPA; and
- Chapter IX of the Reserve Bank of India – Know Your Customer, Directions, 2025 (as amended from time to time).
Under these directions, every regulated entity is required to:
- Screen its customer base and transactions against the lists of individuals and entities approved and circulated by the UNSC;
- Ensure that it does not maintain any account or business relationship in the name of persons or entities appearing on such lists; and
- Take action as prescribed in the UAPA Order whenever a match is found.
1.2 Relevant UNSC sanctions regimes
The October 2026 circular pertains to updates under the UNSC sanctions regimes concerning:
- ISIL (Da’esh) and Al‑Qaida pursuant to resolutions
1267 (1999),1989 (2011)and2253 (2015); and - Measures under Security Council resolution
2734 (2024)which provide for:- Asset freeze,
- Travel ban, and
- Arms embargo
against individuals, groups, undertakings and entities included in the relevant sanctions lists.
2. UNSC amendments communicated via MEA
2.1 MEA communication to RBI
The Ministry of External Affairs (MEA), Government of India, has intimated RBI about UNSC press release SC/16480 dated October 15, 2026. Through this press release, the Security Council, acting under Chapter VII of the Charter of the United Nations, has made specific amendments – highlighted by strikethrough and underline in the official UN documentation – to three entries in its ISIL (Da’esh) and Al‑Qaida Sanctions List.
These amendments do not remove the listed persons/entities from the sanctions list; rather, they refine or update the factual details associated with the entries. The asset freeze, travel ban and arms embargo continue to apply in full.
2.2 Scope of amended entries
The UNSC communication updates the following entries:
- Individual:
QDi.082– Mounir El Motassadeq - Individual:
QDi.427– Noor Wali Mehsud - Entity:
QDe.132– Tehrik-e Taliban Pakistan (TTP)
RBI’s circular reproduces the amended UN list particulars. Regulated entities are expected to align their internal screening and database records with these updated identifiers.
3. Updated UN sanctions particulars
The details below are part of the official UNSC sanctions list and must be reproduced exactly for compliance purposes. They are not to be altered in any way in internal systems other than formatting for data ingestion.