**Executive Summary**
This RBI circular, dated October 24, 2025, addresses regulated entities (REs) regarding updates to the UNSC's ISIL (Da'esh) & Al-Qaida Sanctions List, specifically amendments to one entry. It mandates compliance with Section 51A of the UAPA, 1967, ensuring REs do not maintain accounts for individuals or entities on the sanctioned lists. The circular refers to the RBI Master Direction on Know Your Customer dated February 25, 2016, as amended on August 14, 2025.
**Key Points / Main Content**
* **Regulatory Compliance:**
* REs must comply with Section 51A of the UAPA, 1967, regarding sanctioned individuals and entities.
* REs must follow the UAPA Order dated February 02, 2021 (amended on April 22, 2024) annexed to the MD on KYC.
* REs are advised to take note of the aforementioned UNSC communications and ensure meticulous compliance.
* **UNSC Sanctions List Updates:**
* The Ministry of External Affairs (MEA) informed about UNSC press release SC/16197 dated October 21, 2025 concerning amendments to the ISIL (Da’esh) and Al-Qaida Sanctions List.
* Amendments specify strikethroughs and/or underlines on the ISIL (Da’esh) and Al-Qaida Sanctions List, affecting asset freezes, travel bans, and arms embargoes.
* Narrative summaries of reasons for listing are accessible on the UNSC website.
* Press release dated October 21, 2025 can be found on the UNSC website.
* The UNSC press releases concerning amendments to the list are available on the UNSC website.
* Details of sanction measures and exemptions are available on the UNSC website.
* Updated lists of individuals and entities linked to ISIL (Da'esh), Al-Qaida and Taliban are available on the UNSC website.
* **Individual Entry Amendment:**
* The circular highlights amendments for the individual named ABD EL KADER MAHMOUD MOHAMED EL SAYED (QDi.065).
* Details provided include aliases, nationality (Egypt), passport information, and other relevant data.
* **De-listing Requests:**
* Any de-listing request received by an RE is to be forwarded electronically to Joint Secretary (CTCR), MHA for consideration.
* Individuals/entities seeking removal from the Sanctions List can submit their request to an independent Ombudsperson.
**Impact Analysis**
**Regulated Entities (REs)**
* **Impact:**
* REs are directly responsible for implementing the changes to comply with Section 51A of the UAPA and UNSC sanctions. They are required to update their systems and processes to screen against the revised ISIL (Da'esh) and Al-Qaida Sanctions List.
* **Action Required:**
* Review and update customer due diligence processes based on the provided individual entry amendment.
* Ensure compliance with KYC guidelines related to sanctioned individuals and entities.
* Forward de-listing requests to Joint Secretary (CTCR), MHA electronically.
* Take note of the aforementioned UNSC communications and ensure meticulous compliance.
**Ministry of Home Affairs (MHA)**
* **Impact:**
* The MHA is involved in processing de-listing requests from sanctioned entities or individuals.
* **Action Required:**
* Consider de-listing requests forwarded by REs through the Joint Secretary (CTCR).
**Individuals/entities on the ISIL (Da’esh) & Al-Qaida Sanctions List**
* **Impact:**
* Individuals/entities are subject to asset freeze, travel ban, and arms embargo as set out in Security Council resolution 2734 (2024).
* **Action Required:**
* Submit their request for delisting to an independent and impartial Ombudsperson.
Key Entities Referenced
Section 51A of the Unlawful Activities (Prevention) (UAPA) Act, 1967: Indian law used for implementing sanctions against individuals and entities associated with terrorism.
RBI Master Direction on Know Your Customer: A direction by the Reserve Bank of India related to KYC compliance, relevant to regulated entities.
United Nations Security Council (UNSC): The UN body whose sanctions lists are being implemented.
ISIL (Da'esh) & Al-Qaida Sanctions List: The list of individuals and entities sanctioned by the UNSC for association with terrorism.
Regulated Entities (REs): Entities regulated by the RBI that are subject to the directive to ensure compliance.
RBI/2025-26/94
DOR. AML.REC. 58 /14.06.001/2025-26 October 24, 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: Amendments to 01 Entry
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 / 16197 dated October 21, 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 entry 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: EL SAYED
Name (original script): ديسلا دمحم دومحم رداقلا دبع
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 Nationality: Egypt Passport no: na National identification
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
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, 21 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.
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.
4. Press release dated October 21, 2025 regarding the above can be found at
https://main.un.org/securitycouncil/en/content/sc16197
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/materials3
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