**Executive Summary**
This RBI circular, dated October 09, 2025, informs Regulated Entities (REs) about updates to the UNSC's 1267/1989 ISIL (Da'esh) & Al-Qaida Sanctions List, specifically regarding Amendment 02 Entries. It reiterates the obligation of REs to comply with Section 51A of the UAPA, 1967, and related KYC guidelines. REs must take appropriate action in terms of paragraph 51 of the Master Direction (MD) on KYC.
**Key Points / Main Content**
* **Regulatory Mandate:**
* REs must ensure they do not have any accounts in the name of individuals/entities appearing in the UNSC's lists of suspected terrorists, as per Section 51A of the UAPA Act, 1967.
* This is in accordance with paragraph 51 of the RBI Master Direction on Know Your Customer dated February 25, 2016, as amended August 14, 2025.
* **UNSC Updates:**
* The Ministry of External Affairs (MEA) has informed about UNSC press release SC / 16188 dated October 06, 2025.
* This concerns amendments to resolutions 1267 (1999), 1989 (2011), and 2253 (2015) regarding ISIL (Da'esh), Al-Qaida, and associated entities.
* Amendments are specified with strikethrough and/or underline in the entries on the ISIL (Da'esh) and Al-Qaida Sanctions List.
* The list of individuals includes ABD EL KADER and ARIS SUMARSONO
* **Sanction Measures:**
* The sanction measures and exemptions details are available on the UNSC website.
* **Delisting Requests:**
* Any de-listing request received by an RE must be forwarded electronically to the Joint Secretary (CTCR), MHA, for consideration.
* Individuals/entities seeking removal from the sanctions list can submit requests to the UN-appointed Ombudsperson.
* **Compliance:**
* REs are advised to take note of the UNSC communications and ensure meticulous compliance.
**Impact Analysis**
**Regulated Entities (REs):**
* **Impact:** REs are required to update their internal systems and processes to reflect the changes to the UNSC sanctions list. They must ensure compliance with UAPA Section 51A and KYC guidelines.
* **Action Required:**
* Review the updated UNSC sanctions list.
* Identify and freeze assets/accounts of listed individuals/entities.
* Report any identified accounts to the relevant authorities.
* Forward any delisting requests to the Joint Secretary (CTCR), MHA.
**Individuals/Entities Seeking Delisting:**
* **Impact:** The amendment will affect individuals or entities seeking to be removed from the ISIL (Da'esh) and Al-Qaida Sanctions List.
* **Action Required:** Submit a delisting request to the Ombudsperson appointed by the United Nations Secretary-General.
Key Entities Referenced
RBI Master Direction on Know Your Customer: A direction issued by the Reserve Bank of India (RBI) related to Know Your Customer (KYC) norms, referenced for compliance.
United Nations Security Council (UNSC): An organization responsible for approving and periodically circulating lists of individuals and entities with suspected terrorist links.
Unlawful Activities (Prevention) (UAPA) Act, 1967: An Indian act, specifically Section 51A, that mandates regulated entities to avoid accounts for listed individuals/entities.
ISIL (Da'esh) & Al-Qaida Sanctions List: A list managed by the UN Security Council, identifying individuals and entities subject to sanctions, requiring compliance from regulated entities.
Ministry of External Affairs (MEA): The ministry responsible for informing about the UNSC press releases.
RBI/2025-26/92
DOR.AML.REC.56/14.06.001/2025-26 October 09, 2025
The Chairpersons/ CEOs of all the Regulated Entities
Madam/Dear Sir,
Implementation of Section 51A of UAPA,1967: Updates to UNSC’s 1267/ 1989 ISIL
(Da'esh) & Al-Qaida Sanctions List: Amendment of 02 Entries
Please refer to paragraph 51 of the RBI Master Direction on Know Your Customer dated
February 25, 2016 as amended on August 14, 2025 (MD on KYC), in terms of which
“Regulated Entities (REs) shall ensure that in terms of Section 51A of the Unlawful
Activities (Prevention) (UAPA) Act, 1967 and amendments thereto, they do not have any
account in the name of individuals / entities appearing in the lists of individuals and
entities, suspected of having terrorist links, which are approved by and periodically
circulated by the United Nations Security Council (UNSC).”
2. In this connection, Ministry of External Affairs (MEA), Government of India has
informed about the UNSC press release SC / 16188 dated October 06, 2025 wherein
the Security Council Committee pursuant to resolutions 1267 (1999), 1989 (2011) and
2253 (2015) concerning ISIL (Da’esh), Al‑Qaida and associated individuals, groups,
undertakings and entities enacted the amendments specified with strikethrough and / or
underline in the entries below on its ISIL (Da’esh) and Al-Qaida Sanctions List of
individuals and entities subject to the assets freeze, travel ban and arms embargo set
out in paragraph 1of Security Council resolution 2734 (2024) and adopted under Chapter
VII of the Charter of the United Nations.
A. Individuals
QDi.065 Name: 1: ABD EL KADER 2: MAHMOUD 3: MOHAMED 4: ELSAYED
Name (original script) : ابحسعقلمي د ا د دو رد ا د
Title: na Designation: na DOB: 26 Dec. 1962 POB: Egypt Good quality a.k.a.: a) Es
Sayed, Kader b) Abdel Khader Mahmoud Mohamed el Sayed Low quality a.k.a.: na
विवियमि विभाग, केंद्रीय कायाालय, केंद्रीय कायाालय भिि, 12िी/ीं 13िी ींमींव़िल, शहीद भगत व ींह मागा, फोर्ा, म ींबई- 400001
र्ेलीफोि/ Tel No: 22661602, 22601000 फैक्स/ Fax No: 022-2270 5691
Department of Regulation, Central Office, Central Office Building, 12th/ 13th Floor, Shahid Bhagat Singh Marg, Fort, Mumbai - 400001
"Caution: RBI never sends mails, SMSs or makes calls asking for personal information like bank account details, passwords, etc. It never keeps or offers funds to anyone. Please
do not respond in any manner to such offers."2
Nationality: Egypt Passport no: na National identification no: na Address: na Listed
on: 24 Apr. 2002 (amended on 26 Nov. 2004, 7 Jun. 2007, 16 May 2011, 1 May 2019,
15 Nov. 2021, 6 Oct.2025) Other information: Italian Fiscal Code:
SSYBLK62T26Z336L.Sentenced to 8 years imprisonment in Italy on 2 February
2004.Considered a fugitive from justice by the Italian authorities. Reportedly killed in the
border region of Afghanistan and Pakistan in 2012. Review pursuant to Security Council
resolution 1822 (2008) was concluded on 22 Apr. 2010. Review pursuant to Security
Council resolution 2253 (2015) was concluded on 21 Feb. 2019. Review pursuant to
Security Council resolution 2368 (2017) was concluded on 15 November 2021.
INTERPOL-UN Security Council Special Notice web link:
https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals
QDi.187 Name: 1: ARIS 2: SUMARSONO 3: na 4: na
Title: na Designation: na DOB: 19 Apr. 1963 POB: Gebang village,Masaran, Sragen,
Central Java, Indonesia Good quality a.k.a.: a) Zulkarnan b) Zulkarnain c) Zulkarnin d)
Arif Sunarso e) Zulkarnaen f) ArisSunarso g) Ustad Daud Zulkarnaen Low quality
a.k.a.: a) Murshid b) Daud c) Pak Ud d) Mbah Zul e) Zainal Arifin f) Zul g)
AbdullahAbdurrahman h) Abdul i) Abdurrahman Nationality: Indonesia Passport no:
na National identification no: na Address: a) Desa Gebang, Kecamatan Masaran,
Kabupaten Sragen, Jawa Tengah, Indonesia b) DesaTaman Fajar, Kecamatan
Probolinggo, Kabupaten Lampung Timur, Lampung, Indonesia Listed on: 16 May 2005
(amended on 17 Apr. 2019,15 Nov. 2021, 27 May 2022, 6 Oct. 2025) Other information:
He was sentenced to 15 years in prison in Indonesia in January 2022. Review pursuant
to Security Council resolution 1822 (2008) was concluded on 8 Jun. 2010. Review
pursuant to Security Council resolution 2253 (2015) was concluded on 7 June 2018.
Review pursuant to Security Council resolution 2368 (2017) was concluded on 15
November 2021. INTERPOL-UN Security Council Special Notice web link:
https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals.
3. In accordance with paragraph 58 of resolution 2610 (2021), the Committee has made
accessible on its website the narrative summaries of reasons for listing of the above
entries at the following URL:
www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list/summaries.3
4. Press release dated October 06, 2025 regarding the above can be found at
https://press.un.org/en/2025/sc16188.doc.htm
Further, the UNSC press releases concerning amendments to the list are available at
URL: https://www.un.org/securitycouncil/sanctions/1267/press-releases
5. The details of the sanction measures and exemptions are available at the following
URL: https://www.un.org/securitycouncil/sanctions/1267#further_information
6. In view of the above, REs are advised to take appropriate action in terms of paragraph
51 of the MD on KYC and strictly follow the procedure as laid down in the UAPA Order
dated February 02, 2021 (amended on April 22, 2024) annexed to the MD on KYC.
7. Updated lists of individuals and entities linked to ISIL (Da'esh), Al-Qaida and Taliban
are available at:
www.un.org/securitycouncil/sanctions/1267/aq_sanctions_list
https://www.un.org/securitycouncil/sanctions/1988/materials
8. Further, as per the instructions from the Ministry of Home Affairs (MHA), any request
for de-listing received by any RE is to be forwarded electronically to Joint Secretary
(CTCR), MHA for consideration. Individuals, groups, undertakings or entities seeking to
be removed from the Security Council’s ISIL (Da'esh) and Al-Qaida Sanctions List can
submit their request for delisting to an independent and impartial Ombudsperson who
has been appointed by the United Nations Secretary-General. More details are available
at the following URL:
https://www.un.org/securitycouncil/ombudsperson/application
9. REs are advised to take note of the aforementioned UNSC communications and
ensure meticulous compliance.
Yours faithfully,
(Veena Srivastava)
Chief General Manager