India RBI Brief

Headline

RBI directs all regulated entities to implement UNSC amendments to two ISIL and Al-Qaida sanctions list entries

Executive Summary

The Reserve Bank of India issued a circular on September 7, 2026 transmitting UNSC press release SC/16446, dated September 4, 2026, which amends two entries on the ISIL (Da'esh) and Al-Qaida Sanctions List. The amendments update identifying information for Sanaullah Ghafari (QDi.431) and Abubakar Swalleh (QDi.436). All regulated entities must screen against the revised list immediately.

Bottom Line

All RBI-regulated financial institutions carry an immediate obligation to screen customer accounts and relationships against the revised ISIL (Da'esh) and Al-Qaida Sanctions List, incorporating the September 4, 2026 amendments to the Sanaullah Ghafari and Abubakar Swalleh entries. The Swalleh amendment materially expands the required screening surface by elevating Isaac Mupeta to a good-quality alias and adding a fraudulently acquired Zambian identification document. Any account or asset linked to either individual is subject to an assets freeze under Security Council resolution 2734 (2024). De-listing requests received by any bank must be routed electronically to the Joint Secretary (Counter Terrorism and Counter Radicalization) at the Ministry of Home Affairs.

Key Regulatory Signals

• Immediate Screening Obligation Across the Entire Regulated Population: The circular is addressed to commercial banks, small finance banks, payment banks, urban and rural co-operative banks, regional rural banks, local area banks, non-banking financial companies, asset reconstruction companies, and all-India financial institutions. Every institution in this population must verify that no account is held in the name of either amended individual under any alias listed.
• Sanaullah Ghafari Entry Updated (QDi.431): The UNSC amended the entry for Sanaullah Ghafari, designated leader of ISIL-Khorasan, on September 4, 2026. Regulated entities must screen against all eight good-quality aliases, including Dr. Shahab al Muhajir and its variants, and the Afghan passport number O1503093.
• Abubakar Swalleh Entry Updated (QDi.436): The amendment reclassifies the alias Isaac Mupeta from a low-quality to a good-quality alias and adds a fraudulently acquired Zambian national identification number (Z15105123, issued August 5, 2020). Regulated entities must update screening parameters to reflect the elevated alias classification and the additional document identifier.
• UAPA Compliance Procedure Remains Binding: The circular reaffirms that regulated entities must follow the procedure in the Unlawful Activities (Prevention) Act order dated February 2, 2021, as amended April 22, 2024. Any de-listing request received by a bank must be forwarded electronically to the Joint Secretary (Counter Terrorism and Counter Radicalization), Ministry of Home Affairs.
• Assets Freeze, Travel Ban, and Arms Embargo Apply: Both amended entries remain subject to the full suite of measures under Security Council resolution 2734 (2024), paragraph 1: assets freeze, travel ban, and arms embargo. Regulated entities holding any asset or account linked to either individual face an immediate freeze obligation.

Regulatory Delta

- The RBI has issued these UNSC sanctions-transmission circulars on a rolling basis throughout 2026-27, consistent with its standing obligation under the KYC Directions issued November 28, 2025. This circular reflects routine continuity of that transmission function, not a policy departure.

- The Abubakar Swalleh amendment carries a structurally significant change: it upgrades Isaac Mupeta from a low-quality to a good-quality alias and adds a fraudulently acquired Zambian identity document. Together, these changes expand the screening surface that regulated entities must maintain for an active ISIL facilitator operating across East and Southern Africa.

- The Ministry of External Affairs and Ministry of Home Affairs both appear in the transmission chain, reflecting the standard inter-ministerial coordination through which UNSC designations reach India's regulated financial sector.

Materiality Classification

HIGH — This action carries confirmed regulatory impact beyond its home jurisdiction.

Intelligence Outlook

Monitor the RBI and the UNSC 1267 Committee website for further amendments to the ISIL (Da'esh) and Al-Qaida Sanctions List, and monitor the Ministry of Home Affairs for any updated procedural guidance on de-listing request handling.