**Executive Summary**
This RBI circular, dated November 14, 2025, informs Regulated Entities (REs) about updates to the UNSC's ISIL (Da'esh) & Al-Qaida Sanctions List, specifically the delisting of two entries. It requires REs to comply with Section 51A of the UAPA, 1967, and paragraph 51 of the RBI Master Direction on Know Your Customer (KYC). The circular references UNSC press release SC/16214 dated November 06, 2025.
**Key Points / Main Content**
* **Delisting of Individuals:**
* Ahmed al-Sharaa (Ahmad Hussain Al-Sharaa (QDi.317))
* Anas Hasan Khattab (QDi.336)
* **Compliance Requirements for REs:**
* REs must ensure no accounts are held for individuals/entities on terrorist lists.
* REs must take appropriate action as per paragraph 51 of the MD on KYC.
* REs must strictly follow the procedure in the UAPA Order dated February 02, 2021 (amended on April 22, 2024), annexed to the MD on KYC.
* REs are advised to note UNSC communications and ensure meticulous compliance.
* **De-listing Requests:**
* Any de-listing requests received by REs must be forwarded electronically to Joint Secretary (CTCR), MHA.
* Individuals/entities seeking de-listing can submit requests to the Ombudsperson.
* **Reference Documents & Information:**
* UNSC press release: https://press.un.org/en/2025/sc16214.doc.htm
* Sanction details and exemptions: https://www.un.org/securitycouncil/sanctions/1267#further_information
* Updated lists: [www.un.org/securitycouncil/sanctions/1267/aq\_sanctions](http://www.un.org/securitycouncil/sanctions/1267/aq_sanctions) list
and [https://www.un.org/securitycouncil/sanctions/1988/materials](https://www.un.org/securitycouncil/sanctions/1988/materials)
* Ombudsperson application details: https://www.un.org/securitycouncil/ombudsperson/application
**Impact Analysis**
**Regulated Entities (REs)**
* **Impact:** REs must update their records to reflect the delisting of the mentioned individuals, ensuring compliance with regulatory requirements related to KYC and anti-terrorism financing.
* **Action Required:** Review and update internal lists and systems, conduct necessary due diligence, and report any relevant information to the appropriate authorities.
**Ministry of Home Affairs (MHA)**
* **Impact:** The MHA will receive de-listing requests forwarded by REs for consideration.
* **Action Required:** Process de-listing requests received from REs.
**Individuals/entities seeking de-listing**
* **Impact:** They can submit de-listing requests to an independent and impartial Ombudsperson.
* **Action Required:** Submit their request for delisting to the Ombudsperson.
Key Entities Referenced
UNSC's 1267/ 1989 ISIL (Da'esh) & Al-Qaida Sanctions List: A list maintained by the United Nations Security Council identifying individuals and entities subject to sanctions due to their association with ISIL (Da'esh) and Al-Qaida.
RBI Master Direction on Know Your Customer: A set of guidelines issued by the Reserve Bank of India regarding Know Your Customer (KYC) norms for regulated entities.
Section 51A of UAPA, 1967: A section of the Unlawful Activities (Prevention) Act, 1967 related to financial sanctions and asset freezing of individuals and entities linked to terrorism.
Regulated Entities: Entities that are regulated by the Reserve Bank of India, who are instructed to take action based on the sanctions list.
Ministry of External Affairs: The Government of India's ministry responsible for foreign affairs, that informed about the delisting of individuals from the ISIL/Al-Qaida sanctions list.
RBI/2025-26/97
DOR. AML.REC. 61 /14.06.001/2025-26 November 14, 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: Delisting 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/16214 dated November 06, 2025 wherein
the Security Council Committee has decided to remove two individuals from its Islamic
State in Iraq and the Levant (ISIL/Da’esh) and Al-Qaida sanctions list.
2.1 The Committee recalling its previous resolutions on the Syrian Arab Republic and
those relating to the ISIL (Da’esh) and Al-Qaida sanctions regime, including 1267 (1999),
1989 (2011), 2178 (2014), 2253 (2015), 2368 (2017), 2396 (2017), 2462 (2019), 2664
(2022), 2734 (2024), and 2761 (2024), as well as the main principles and objectives
embodied in its resolution 2254 (2015), adopted Resolution 2799 (2025) under Chapter
VII of the Charter of the United Nations:
Deciding that Ahmed al-Sharaa, included on the ISIL (Da’esh) and Al-Qaida
Sanctions List as Ahmad Hussain Al-Sharaa (QDi.317), and Anas Hasan
Khattab (QDi.336) are delisted from the ISIL (Da’esh) and Al-Qaida
Sanctions List.
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
3. Press release dated November 06, 2025 regarding the above can be found at
https://press.un.org/en/2025/sc16214.doc.htm
The details of the sanction measures and exemptions are available at the following
URL: https://www.un.org/securitycouncil/sanctions/1267#further_information
4. 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.
5. 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
6. 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
7. REs are advised to take note of the aforementioned UNSC communications and
ensure meticulous compliance.
Yours faithfully,
(Veena Srivastava)
Chief General Manager