**Executive Summary**
This RBI notification, dated November 14, 2025, informs regulated entities about updates to the UNSC's ISIL (Da'esh) & Al-Qaida Sanctions List, specifically the delisting of two entries. It references paragraph 51 of the RBI Master Direction on Know Your Customer dated February 25, 2016, and advises regulated entities to take appropriate action. The delisting decision was made by the Security Council Committee, as per the press release dated November 06, 2025.
**Key Points / Main Content**
* **Delisting of Individuals:**
* Ahmed al-Sharaa (Ahmad Hussain Al-Sharaa (QDi.317)) and Anas Hasan Khattab (QDi.336) have been delisted from the ISIL (Da'esh) and Al-Qaida Sanctions List.
* **Compliance Requirements for Regulated Entities (REs):**
* REs must adhere to Section 51A of the UAPA Act, 1967, ensuring they do not have accounts for individuals/entities on the UNSC's lists of those with suspected terrorist links.
* REs are advised to take appropriate action in terms of paragraph 51 of the Master Direction on KYC and strictly follow the UAPA Order dated February 02, 2021.
* REs must take note of the aforementioned UNSC communications and ensure meticulous compliance.
* **Information and Resources:**
* The UNSC press release dated November 06, 2025 regarding the delisting 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
* **Procedure for Delisting Requests:**
* Any delisting requests received by REs must be forwarded electronically to the Joint Secretary (CTCR), MHA for consideration, as per MHA instructions.
* Individuals/entities seeking removal from the ISIL (Da'esh) and Al-Qaida Sanctions List can submit their request to the Ombudsperson appointed by the United Nations Secretary-General.
* Details on submitting a delisting request to the Ombudsperson are available at: https://www.un.org/securitycouncil/ombudsperson/application.
**Impact Analysis**
**Regulated Entities (REs)**
*Impact*
Regulated Entities are impacted by the changes to the sanctions list. They must update their records and screening processes to reflect the delisting of Ahmed al-Sharaa and Anas Hasan Khattab. Failure to comply could lead to regulatory action.
*Action Required*
1. Update internal lists and screening mechanisms to reflect the delisting.
2. Ensure compliance with Section 51A of UAPA, 1967 and relevant KYC directives.
3. Follow established procedures for forwarding any delisting requests received.
Key Entities Referenced
RBI Master Direction on Know Your Customer dated February 25, 2016: A key regulatory document that outlines the procedures and guidelines for regulated entities regarding KYC compliance, referenced for specific instructions in this context.
Section 51A of UAPA,1967: The primary legal basis for the directive, requiring regulated entities to adhere to sanctions related to terrorism.
UNSC's 1267/1989 ISIL (Da'esh) & Al-Qaida Sanctions List: The core subject of the directive, concerning updates to the list of sanctioned individuals and entities linked to ISIL (Da'esh) and Al-Qaida.
United Nations Security Council (UNSC): The international body responsible for maintaining peace and security, which issues the sanctions lists that this directive enforces.
Ministry of Home Affairs (MHA): Indian Government ministry involved in forwarding delisting requests related to the 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