The Reserve Bank of India (RBI) has issued a new circular regarding the implementation of Section 51A of the Unlawful Activities (Prevention) Act (UAPA), 1967. The RBI has informed banks, NBFCs and other regulated financial institutions about an update made by the United Nations Security Council (UNSC) to its Taliban Sanctions List.
One Entry in Taliban Sanctions List Amended
The UNSC committee working under Resolution 1988 (2011) has amended one entry in its list of individuals and entities linked to the Taliban. The amended entry relates to Abdul Salam Hanafi, an individual associated with the Taliban.
The UNSC has also amended two entries in its ISIL (Da’esh) and Al-Qaida Sanctions List. The two individuals are:
- Sanaullah Ghafari, also known as Dr. Shahab al Muhajir and other aliases.
- Abubakar Swalleh, also known by aliases including Abubaker Swaleh and Tom Kiyurige.
The RBI has directed financial institutions to check the updated sanctions list carefully. Under Section 51A of UAPA, banks and other regulated entities must ensure that they do not maintain accounts in the name of individuals or entities included in the relevant UNSC sanctions lists.
Banks and other financial institutions are required to follow the procedures prescribed under the UAPA when dealing with individuals or entities appearing on the sanctions list. The updated lists related to ISIL (Da’esh), Al-Qaida and the Taliban are available through the UNSC.
What banks need to do?
RBI wants banks and other regulated financial institutions to check their customer records against the updated UN Taliban sanctions list and ensure compliance with Section 51A of UAPA. RBI issued this instruction on September 7, 2026, after the UN amended one entry in its Taliban sanctions list.
In practical terms, banks have to:
- Update their sanctions list with the latest information issued by the UN.
- Check their existing customer/accounts to see whether any person or entity matches the updated sanctions list.
- Do not maintain accounts in the name of a person or entity appearing on the relevant sanctions list.
- If a customer is found to match a designated person/entity, the bank must take action under the UAPA procedure, including freezing the relevant financial assets where required. RBI’s UAPA procedure requires banks to act quickly when such a match is identified.
- Report the required details to the authorities as prescribed under the UAPA procedure.
