RBI advisory on UNSC sanctions list update for ISIL (Da’esh) & Al-Qaida: Compliance under Section 51A of UAPA

The Reserve Bank of India (RBI), through Notification RBI/2026-27/271 dated September 29, 2026, has alerted regulated entities to a modification in one entry on the United Nations Security Council’s ISIL (Da’esh) & Al-Qaida Sanctions List. This intimation is issued in the context of obligations arising from Section 51A of the Unlawful Activities (Prevention) Act, 1967 (UAPA) and the anti-money laundering/terrorism-financing framework embedded in the Reserve Bank of India – Know Your Customer, Directions, 2025.

The communication primarily aims to ensure that all banks and financial sector entities regulated by RBI promptly align their screening mechanisms and customer due diligence processes with the latest UNSC update related to Khatiba Jamaat Al-Tawhid Wal-Jihad (KTJ).

Regulatory background

Linkage with KYC framework and international commitments

Chapter IX of the Reserve Bank of India – Know Your Customer, Directions, 2025 (as updated up to September 18, 2026) sets out the “Requirements/obligations under International Agreements – Communications from International Agencies”. Under these Directions, each regulated entity is required to:

  • Integrate lists circulated by the United Nations Security Council (UNSC) concerning individuals and entities suspected of terrorist links into their KYC/AML systems
  • Ensure strict adherence to Section 51A of the Unlawful Activities (Prevention) Act, 1967 and its amendments
  • Verify that no account relationship exists or is established in the name of any individual or entity appearing in the relevant UNSC sanctions lists

In functional terms, this means that regulated entities must have robust, regularly updated name-screening tools and escalation procedures to ensure that they do not maintain accounts for individuals or entities covered by the UNSC sanctions regimes relating to ISIL (Da’esh), Al‑Qaida and associated entities.

Statutory basis: Section 51A of UAPA

Section 51A of the Unlawful Activities (Prevention) Act, 1967 provides the domestic legislative foundation for implementing UN Security Council decisions relating to prevention and suppression of terrorist acts and financing of terrorism. Under this section (and the rules/orders issued thereunder), financial institutions and other specified persons are obligated to:

  • Freeze, without delay, funds and other assets held by identified individuals / entities
  • Prohibit the provision of financial services or other economic resources to persons appearing in the relevant UN lists
  • Comply with the procedures specified in the UAPA Orders issued by the Central Government, including the UAPA Order dated February 02, 2021 (as amended on April 22, 2024)

UNSC communication notified by MEA

Reference to UNSC press release

The RBI notification notes that the Ministry of External Affairs (MEA), Government of India, has shared details of UNSC press release SC/16465 dated September 28, 2026. The press release relates to the Security Council’s actions under resolutions:

  • 1267 (1999)
  • 1989 (2011)
  • 2253 (2015)

These resolutions govern the sanctions regime applicable to ISIL (Da’esh), Al‑Qaida and associated individuals, groups, undertakings and entities.

Pursuant to these resolutions and acting under Chapter VII of the Charter of the United Nations, the Security Council has carried out amendments (shown with strikethroughs and underlining in the official UN text) to one entry on its ISIL (Da’esh) and Al‑Qaida Sanctions List. The measures linked to this listing include:

  • Assets freeze
  • Travel ban
  • Arms embargo

as contained in paragraph 1 of Security Council resolution 2734 (2024).

Specific entity: Khatiba Jamaat Al-Tawhid Wal-Jihad (KTJ)

The RBI communication reproduces the updated sanctions list entry concerning the following entity:

**B.