**Executive Summary**
This RBI circular, dated November 14, 2025, informs Regulated Entities (REs) about updates to the UNSC's 1267/1989 ISIL (Da'esh) & Al-Qaida Sanctions List, specifically regarding the delisting of two entries. REs must ensure compliance with Section 51A of the UAPA, 1967, and follow KYC procedures as outlined in the Master Direction. The circular references a UNSC press release dated November 6, 2025 (SC/16214) and reiterates the need for meticulous compliance with UNSC communications.
**Key Points / Main Content**
* **Delisting of Individuals:**
* Ahmed al-Sharaa, previously listed as Ahmad Hussain Al-Sharaa (QDi.317), is delisted.
* Anas Hasan Khattab (QDi.336) is delisted from the ISIL (Da'esh) and Al-Qaida Sanctions List.
* **Compliance with UAPA and KYC Norms:**
* REs must ensure that they do not have any accounts in the name of individuals/entities appearing in the lists of individuals and entities suspected of having terrorist links, as per Section 51A of the UAPA Act, 1967.
* REs should take appropriate action in terms of paragraph 51 of the Master Direction on KYC dated February 25, 2016, as amended on August 14, 2025, and follow the procedure laid down in the UAPA Order dated February 02, 2021 (amended on April 22, 2024).
* **Delisting Requests:**
* Any delisting requests received by REs are to be forwarded electronically to Joint Secretary (CTCR), MHA.
* Individuals/entities seeking removal from the Sanctions List can submit their request to the Ombudsperson appointed by the United Nations Secretary-General.
* **Information Sources:**
* The UNSC press release dated November 06, 2025, is available at https://press.un.org/en/2025/sc16214.doc.htm
* Details of sanction measures and exemptions are available at https://www.un.org/securitycouncil/sanctions/1267#further_information
* 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
* Details on the Ombudsperson application are available at https://www.un.org/securitycouncil/ombudsperson/application
**Impact Analysis**
**Regulated Entities (REs)**
**Impact**
REs must update their records to reflect the delisting of the specified individuals and ensure that they are not in violation of UAPA or KYC norms.
**Action Required**
REs must review their records, update their databases, and ensure compliance with the updated sanctions list. They must also adhere to the procedure for handling any delisting requests received.
Key Entities Referenced
RBI Master Direction on Know Your Customer dated February 25, 2016: A key regulatory document from the Reserve Bank of India (RBI) guiding KYC compliance for Regulated Entities, referenced for implementing the UAPA sanctions.
Section 51A of UAPA, 1967: A section of the Unlawful Activities (Prevention) Act mandating actions related to individuals/entities on terrorist lists.
UNSC's 1267/ 1989 ISIL (Da'esh) & Al-Qaida Sanctions List: The United Nations Security Council's list of sanctioned individuals and entities associated with ISIL (Da'esh) and Al-Qaida, serving as the primary basis for domestic implementation.
Ministry of External Affairs (MEA): The Government of India Ministry that provides information about UNSC press releases.
Regulated Entities (REs): Entities regulated by the RBI that are required to implement the sanctions.
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