UAPA Section 51A: 3 Names Removed from UN Sanctions List Oct 2026

What Happened?

On October 27, 2026, the Reserve Bank of India (RBI) circulated a critical directive to all commercial banks, payment banks, cooperative banks, and non-banking financial companies (NBFCs) regarding the removal of three individuals from the United Nations Security Council's consolidated sanctions list for ISIL (Da'esh) and Al-Qaida. This delisting was approved by the UN Security Council Committee on October 26, 2026, following formal delisting requests by the designating states in accordance with international protocols. The three individuals delisted are:

• Shafi Sultan Mohammed Sultan Al-Ajmi (QDi.338) — Kuwaiti national, previously listed as a fundraiser for Al-Nusrah Front, released from Kuwait prison in November 2023 under Special Amiri Decree Pardon.
• Bassam Ahmad Al-Hasri (QDi.399) — Syrian national, previously listed as a leader of Al-Nusrah Front for southern Syrian Arab Republic.
• Iyad Nazmi Salih Khalil (QDi.400) — Jordanian national, previously listed as a leader of Al-Nusrah Front for coastal areas of Syrian Arab Republic.

This delisting action means the asset freeze, travel bans, and arms embargoes previously imposed under United Nations Security Council Resolution 2734 (2024) no longer apply to these individuals.

Background & Legal Context

Section 51A of the Unlawful Activities (Prevention) Act, 1967 is the principal domestic legal framework that implements international sanctions obligations in India. This section mandates that all regulated financial entities must maintain strict compliance with the consolidated sanctions lists periodically circulated by the United Nations Security Council.

The RBI's directive specifically references Chapter IX of the RBI's Know Your Customer (KYC) Directions, 2025 (amended from time to time), which establishes mandatory requirements for regulated entities to:

• Maintain updated lists of individuals and entities suspected of terrorist links as approved by the UNSC.
• Ensure no accounts are opened in the names of individuals appearing in such lists.
• Freeze assets of individuals who appear on active sanctions lists.
• Screen all customers against the consolidated sanctions list during account opening and on an ongoing basis.
• Report any suspected matches to appropriate authorities.

The Income Tax Act, 2025 does not directly address terrorist financing or sanctions compliance, but the Finance Act's Money Laundering provisions under the Prevention of Money Laundering Act (PMLA) and anti-money laundering norms under the Income Tax Act link to these compliance requirements. Additionally, any transactions involving sanctioned individuals would constitute violations of multiple statutory provisions.

Under the UAPA Order dated February 2, 2021 (amended April 22, 2024), detailed procedures are mandated for compliance with asset freeze requirements, which are annexed to the RBI KYC Directions. The delisting of these three individuals effectively reverses their compliance status from October 26, 2026 onwards.

What Does This Mean for You?

For Financial Institutions and Banks:

• Immediate KYC Updates Required: All banks, NBFCs, payment banks, and asset reconstruction companies must immediately remove these three individuals from their active sanctions monitoring lists. Any ongoing asset freeze on accounts belonging to these individuals must be lifted, and account operations should be normalized.
• Customer Communication: If any of these three individuals hold accounts with your institution, you must promptly notify them that the asset freeze has been lifted and operations can resume. Documentation of this action should be maintained for audit purposes.
• Compliance Documentation: Institutions must maintain records demonstrating that the delisting was acted upon within a reasonable timeframe. This documentation may be reviewed during RBI inspections, income tax audits, or compliance audits.
• System Updates: Core banking systems, customer screening databases, and automated transaction monitoring systems must be updated to reflect that these individuals are no longer subject to sanctions.

For Individuals and Businesses:

• Account Reopening or Activation: If you were unable to open or maintain a bank account due to sanctions, you may now do so by reapplying to your preferred financial institution with updated Know Your Customer documentation.
• Transaction Processing: Any legitimate transactions that were previously blocked due to sanctions screening can now be processed through the regular banking system.
• No Automatic Implications for Income Tax: The delisting does not create any automatic tax liability or compliance requirement under the Income Tax Act, 2025 for these individuals. However, normal income tax compliance obligations continue to apply based on their residency status and source of income.
• Record Retention: If you were previously unable to conduct banking operations, you should maintain documentation of this period for explanations if required during income tax assessments.

For Assessment Year (AY) 2026-27: Financial institutions should ensure that any accounts of these delisted individuals are properly normalized in their books before finalizing financial statements for AY 2025-26. Any provisions made for asset freeze compliance during FY 2025-26 should be reviewed and adjusted if necessary.

What Should You Do Now?

Action Items for Banks and Financial Institutions:

• Step 1: Immediately access the official United Nations Security Council's consolidated sanctions list to confirm the delisting and obtain the delisting date (October 26, 2026).
• Step 2: Remove these three individuals from your active sanctions monitoring system and update your KYC compliance records to reflect delisted status.
• Step 3: Conduct a reverse screening of your customer database to identify any accounts held by these individuals and mark them as "sanctions lifted."
• Step 4: Lift any asset freezes and restore operational capabilities on accounts of these individuals. Document the date and time of lifting the freeze.
• Step 5: Send written notification to account holders (if applicable) confirming that sanctions have been lifted and banking operations can resume normally.
• Step 6: Brief your compliance team and ensure all staff understand this delisting. Update your internal sanction screening procedures accordingly.
• Step 7: Maintain complete audit trails and documentation for 5-7 years to demonstrate compliance with this RBI directive during inspections.

Action Items for Affected Individuals:

• If you hold accounts with any bank that was subject to asset freeze, contact your relationship manager to confirm that the freeze has been lifted.
• Request written confirmation from the bank that your account is no longer subject to sanctions monitoring (at least for the purposes of these specific UNSC sanctions).
• Ensure all normal KYC and income tax compliance requirements continue to be met as per standard banking norms and Income Tax Act, 2025.

Key Takeaways

• Delisting is Effective Immediately: As of October 26, 2026, the three individuals (Shafi Sultan Mohammed Sultan Al-Ajmi, Bassam Ahmad Al-Hasri, and Iyad Nazmi Salih Khalil) are no longer subject to UNSC sanctions under Resolutions 1267, 1989, and 2253. All asset freezes and travel bans are lifted.
• Financial Institutions Must Act Urgently: Banks and NBFCs have a legal obligation under Section 51A UAPA and the RBI KYC Directions to immediately update their systems and remove these individuals from sanctions monitoring lists. Non-compliance could attract RBI penalties and regulatory action.
• No Automatic Tax Impact: Delisting does not create any new income tax liability or compliance requirement under the Income Tax Act, 2025. Normal tax filing obligations based on residency and income source continue to apply as before.
• Documentation is Critical: All financial institutions must maintain comprehensive audit trails proving timely implementation of this delisting directive. This documentation will be reviewed during compliance inspections and income tax audits.
• Ongoing UN List Monitoring Required: Regulated entities must continue to monitor updated UN sanctions lists regularly. The RBI has advised that institutions can access the consolidated ISIL and Al-Qaida Sanctions List along with Taliban-related lists through official UN portals. Any new additions or future delistings must be implemented with similar urgency.

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