Implementation of Section 51A of UAPA,1967: Updates to UNSC’s 1267/ 1989 ISIL (Da'esh) & Al-Qaida Sanctions List: Removal of 01 Entry

## Report on RBI Communication Regarding UAPA and UNSC Sanctions List Update **1. Executive Summary:** This report analyzes a Reserve Bank of India (RBI) communication (RBI20252658 DOR.AML.REC.3314.06.001202526) dated June 16, 2025, regarding the implementation of Section 51A of the Unlawful Activities Prevention Act (UAPA), 1967, and updates to the United Nations Security Council (UNSC) ISIL (Da'esh) and Al-Qaida Sanctions List. The communication informs Regulated Entities (REs) about the removal of one entry (Hajjaj Bin Fahd Al Ajmi) from the UNSC Sanctions List, necessitating adjustments to their Know Your Customer (KYC) procedures and compliance with UAPA regulations. The core purpose of this communication is to ensure that REs align their operations with the updated UNSC sanctions list. The key finding is that REs must update their records to reflect the delisting and ensure that assets freeze, travel ban, and arms embargoes no longer apply to the delisted individual. **2. Introduction:** This report aims to provide a comprehensive overview of the RBI communication (RBI20252658 DOR.AML.REC.3314.06.001202526) concerning updates to the UNSC ISIL (Da'esh) and Al-Qaida Sanctions List, specifically focusing on the removal of one entry and its implications for Regulated Entities. The analysis is based solely on the information provided within the given RBI communication. **3. Policy Overview:** * This communication refers to and provides updates related to Paragraph 51 of the RBI Master Direction on Know Your Customer dated February 25, 2016, as amended on June 12, 2025 (MD on KYC). * **Core Objective(s):** Based on the text, the core objectives are: * To inform Regulated Entities (REs) about updates to the UNSC Sanctions List related to ISIL (Da'esh) and Al-Qaida. * To ensure REs comply with Section 51A of the UAPA, 1967, and amendments thereto. * To ensure REs update their KYC procedures in accordance with the updated UNSC Sanctions List. **4. Background and Rationale:** This communication represents an amendment to existing guidelines. The likely reason for this specific amendment is that the UNSC has updated its ISIL (Da'esh) and Al-Qaida Sanctions List by removing one entry (Hajjaj Bin Fahd Al Ajmi). To maintain compliance with international regulations and prevent the misuse of the financial system, the RBI is communicating this change to REs, instructing them to adjust their internal controls accordingly. The communication ensures that REs are not inadvertently applying sanctions to individuals no longer designated under UNSC resolutions. **5. Key Provisions / Changes:** This communication serves as an update to the existing MD on KYC and UAPA guidelines. The key change introduced is the removal of *Hajjaj Bin Fahd Al Ajmi* from the UNSC ISIL (Da'esh) and Al-Qaida Sanctions List. * **Specific Part of Original Policy Affected:** Paragraph 51 of the RBI Master Direction on Know Your Customer dated February 25, 2016, as amended on June 12, 2025 (MD on KYC). * **New Rule/Provision (effectively):** The assets freeze, travel ban, and arms embargo set out in paragraph 1 of Security Council resolution 2734 (2024) no longer apply to Hajjaj Bin Fahd Al Ajmi. * **Difference/Effect of Change:** REs are no longer required to treat Hajjaj Bin Fahd Al Ajmi as a sanctioned individual or entity under the UAPA and related KYC procedures. This means that accounts, transactions, and other financial dealings with this individual are no longer subject to restrictions imposed by the sanctions regime. **6. Target Audience and Stakeholders:** The primary target audience and stakeholders are Regulated Entities (REs) under the purview of the RBI. These include banks, financial institutions, and other entities that are subject to KYC and AML (Anti-Money Laundering) regulations. **7. Implementation Aspects (Inferred):** * **Responsible Agency/Bodies:** * Reserve Bank of India (RBI) - issuing the communication and overseeing compliance. * Ministry of External Affairs (MEA), Government of India - informing about UNSC press releases. * Ministry of Home Affairs (MHA) - handling requests for delisting. * United Nations Security Council (UNSC) - responsible for the sanctions list and updates. * **Timelines/Procedures:** REs are expected to take "appropriate action" in terms of Paragraph 51 of the MD on KYC and strictly follow the procedure laid down in the UAPA Order dated February 02, 2021 (amended on April 22, 2024). No specific timelines are provided, but the implication is that action should be taken promptly. * **Amendment-Specific Implementation:** REs need to immediately update their internal databases and screening systems to reflect the removal of Hajjaj Bin Fahd Al Ajmi from the sanctions list. They should also review any existing accounts or transactions involving this individual to ensure compliance with the updated regulations. **8. Expected Outcomes / Impact of Changes:** The intended outcome of this amendment is to ensure that REs: * Accurately reflect the updated UNSC Sanctions List in their KYC and AML procedures. * Avoid unnecessary restrictions on individuals or entities no longer subject to sanctions. * Maintain compliance with international regulations and the UAPA. * Facilitate legitimate financial transactions with individuals or entities that have been delisted by the UNSC. **9. Conclusion:** The RBI communication regarding the removal of Hajjaj Bin Fahd Al Ajmi from the UNSC ISIL (Da'esh) and Al-Qaida Sanctions List is a crucial update for Regulated Entities. It necessitates a prompt review and adjustment of KYC procedures to ensure compliance with the UAPA and international regulations. This update underscores the importance of regularly monitoring UNSC sanctions lists and implementing changes in a timely and accurate manner to avoid both compliance failures and unwarranted restrictions on legitimate financial activities.

Key Entities Referenced