RBI Issues Compliance Guidelines on UNSC’s Updated ISIL & Al-Qaida Sanctions List

On August 25, 2025, the Reserve Bank of India (RBI) issued a circular to all regulated entities (REs) regarding updates to the United Nations Security Council’s (UNSC) ISIL (Da’esh) and Al-Qaida Sanctions List. This communication highlights amendments to five entries on the sanctions list and provides detailed compliance instructions under Section 51A of the Unlawful Activities (Prevention) Act (UAPA), 1967. The circular emphasizes the importance of ensuring that REs do not maintain accounts for individuals or entities listed by the UNSC for suspected terrorist links.

Background

The UNSC sanctions list is a critical tool in combating terrorism globally. It includes individuals, groups, undertakings, and entities associated with ISIL (Da’esh), Al-Qaida, and other terrorist organizations. Sanctions measures include asset freezes, travel bans, and arms embargoes, as outlined in paragraph 1 of Security Council resolution 2734 (2024). The RBI’s circular aligns with its Master Direction on Know Your Customer (KYC), ensuring compliance with international obligations.

Key Updates to the Sanctions List

The Ministry of External Affairs (MEA), Government of India, informed the RBI about amendments to five entries on the UNSC sanctions list. These updates were published in the UNSC press release SC/16155 dated August 22, 2025. Below are the key details of the amended entries:

Ibrahim Ali Abu Bakr Tantoush (QDi.057)
- DOB: February 2, 1966
- Nationality: Libya
- Associated with Afghan Support Committee (ASC), Revival of Islamic Heritage Society (RIHS), and Libyan Islamic Fighting Group (LIFG).
- Listed since January 11, 2002, with multiple amendments, including the latest on August 22, 2025.
Al-Azhar Ben Khalifa Ben Ahmed Rouine (QDi.150)
- DOB: November 20, 1975
- Nationality: Tunisia
- Sentenced for terrorism-related crimes in Italy and Tunisia.
- Listed since November 12, 2003, with the latest amendment on August 22, 2025.
Sulaiman Jassem Sulaiman Ali Abo Ghaith (QDi.154)
- DOB: December 14, 1965
- Nationality: Kuwait
- Currently incarcerated in the United States.
- Listed since January 16, 2004, with the latest amendment on August 22, 2025.
Shafi Sultan Mohammed Al-Ajmi (QDi.338)
- DOB: January 1, 1973
- Nationality: Kuwait
- Fundraiser for Al-Nusrah Front for the People of the Levant.
- Listed since September 23, 2014, with the latest amendment on August 22, 2025.
Gulmurod Khalimov (QDi.372)
- DOB: May 14, 1975
- Nationality: Tajikistan
- Syria-based military expert and recruiter for ISIL.
- Listed since February 29, 2016, with the latest amendment on August 22, 2025.

Compliance Guidelines for Regulated Entities

The RBI has outlined specific actions for REs to ensure compliance with the updated sanctions list:

Account Restrictions REs must ensure that no accounts are maintained for individuals or entities listed by the UNSC. This is mandated under Section 51A of the UAPA Act, 1967.
Access to Updated Lists REs should regularly refer to the updated sanctions lists available at:
- UNSC ISIL (Da’esh) & Al-Qaida Sanctions List
- UNSC Taliban Sanctions List
Procedure for De-Listing Requests Any request for de-listing received by REs must be forwarded electronically to the Joint Secretary (CTCR), Ministry of Home Affairs (MHA). Individuals or entities seeking removal from the sanctions list can also approach the UNSC Ombudsperson. More details are available at:
- UNSC Ombudsperson Application
Sanction Measures and Exemptions REs should familiarize themselves with the details of sanction measures and exemptions provided at:
- UNSC Sanctions Information
Strict Adherence to UAPA Order REs must follow the procedure outlined in the UAPA Order dated February 2, 2021 (amended on April 22, 2024), annexed to the RBI’s Master Direction on KYC.

Additional Resources For further information, REs can access the following:

UNSC Press Releases
Narrative Summaries of Reasons for Listing

Conclusion

The RBI’s circular underscores the importance of meticulous compliance with international sanctions to combat terrorism financing. Regulated entities must stay updated on amendments to the UNSC sanctions list and ensure strict adherence to the guidelines under the UAPA Act. By doing so, they contribute to global efforts in maintaining financial integrity and security.

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Source: RBI

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