RBI Orders Fresh UAPA Sanctions Screening After UNSC Amends Two ISIL-Al-Qaida Entries

The Reserve Bank of India has directed banks, non-bank lenders and other regulated entities to act on fresh amendments to the United Nations Security Council's ISIL (Da'esh) and Al-Qaida sanctions list. RBI issued the compliance communication on September 7, 2026 as RBI/2026-27/253, DOR.AML.REC.219/14.06.001/2026-27, after the Ministry of External Affairs informed the central bank of amendments made by the UN Security Council on September 4, 2026.

Which regulated entities are covered

The RBI communication is addressed to a wide range of regulated institutions, including commercial banks, small finance banks, payments banks, urban co-operative banks, rural co-operative banks, regional rural banks, local area banks, non-banking financial companies, asset reconstruction companies and all-India financial institutions.

For these entities, the notification is an operational anti-money-laundering and sanctions-screening update rather than a general policy statement. RBI has asked regulated entities to take appropriate action under Chapter IX of the Reserve Bank of India Know Your Customer Directions, 2025 and to follow the procedure laid down in the UAPA Order dated February 2, 2021, as amended on April 22, 2024.

What changed in the UN sanctions list

RBI said the Ministry of External Affairs had informed it about UN Security Council press release SC/16446 dated September 4, 2026. Under the applicable Security Council resolutions, amendments were made to two individual entries on the ISIL (Da'esh) and Al-Qaida Sanctions List.

The first amended entry is Sanaullah Ghafari, also known by variants including Shahab al Muhajir. The RBI communication records that the entry was amended on September 4, 2026 and identifies him as the leader of Islamic State of Iraq and the Levant - Khorasan, or ISIL-K.

The second amended entry is Abubakar Swalleh. RBI's communication states that his sanctions-list entry was also amended on September 4, 2026 and describes him as having provided financial, material or technological support, or financial or other services, in support of ISIL, including financial and logistical support and recruitment activity in East and Southern Africa.

The compliance obligation for financial institutions

RBI's KYC Directions require regulated entities, in terms of Section 51A of the Unlawful Activities (Prevention) Act, 1967 and related amendments, to ensure that they do not maintain accounts in the names of individuals or entities appearing in relevant UN Security Council lists of persons and entities suspected of terrorist links.

The sanctions measures connected with the updated UN list include an assets freeze, travel ban and arms embargo under the relevant Security Council framework. For Indian regulated entities, the immediate practical task is to ensure that sanctions-screening databases, customer and beneficial-owner screening, transaction monitoring controls and escalation procedures reflect the latest list amendments.

What compliance, audit and finance teams should do

- Refresh sanctions data promptly: Institutions should confirm that internal and vendor screening engines have ingested the September 4 UN amendments reflected in RBI's September 7 communication.

- Re-screen relevant records: Depending on the institution's policy and system architecture, compliance teams should determine whether existing customers, beneficial owners, counterparties and related parties require re-screening against the updated aliases and identifiers.

- Check alias handling: The amended entries contain multiple name variants and identifying particulars. Screening controls should not rely solely on one spelling of a name.

- Follow UAPA escalation procedures: Any potential match should be handled under the prescribed statutory and regulatory process rather than through an informal account-level decision.

- Maintain an audit trail: Compliance officers, internal auditors and finance-control teams should retain evidence of list updates, screening runs, alert disposition and escalation where relevant.

Delisting requests and official reference points

RBI also reiterates that requests for delisting received by a bank are to be forwarded electronically to the Joint Secretary (CTCR), Ministry of Home Affairs for consideration. The central bank points regulated entities to the updated UN sanctions lists, the UN narrative summaries and the procedure for applications to the UN Ombudsperson.

Although the September 7 notification changes only two UN list entries, the compliance significance is broader: regulated financial institutions are expected to keep sanctions controls continuously aligned with official list updates. For CAs working in banks, NBFCs, ARCs, internal audit, risk or compliance functions, the key issue is not the number of amended entries but whether the institution can demonstrate timely list ingestion, effective matching, documented alert handling and adherence to the RBI KYC and UAPA procedures.

Official source: View the official source document

Key takeaway

RBI has told banks, NBFCs, ARCs and other regulated entities to act on September 4 amendments to two entries on the UN ISIL and Al-Qaida sanctions list.