Description
BSE notifies market participants about amendments to one entry in the UN Security Council's ISIL and Al-Qaida Sanctions List affecting individuals subject to asset freeze, travel ban, and arms embargo.
Summary
BSE has issued a notification regarding the implementation of Section 51A of the Unlawful Activities (Prevention) Act (UAPA), 1967, informing market participants about amendments to the UN Security Council’s ISIL (Da’esh) and Al-Qaida Sanctions List. On 21 October 2025, the Security Council Committee amended one entry in its sanctions list of individuals and entities subject to asset freeze, travel ban, and arms embargo under Resolution 2734 (2024).
Key Points
- Amendment made to one individual entry (QDi.065) in the UNSC ISIL and Al-Qaida Sanctions List on 21 October 2025
- Individual: Abd El Kader Mahmoud Mohamed El Sayed, Egyptian national, DOB: 26 December 1962
- Subject to assets freeze, travel ban, and arms embargo under Chapter VII of the UN Charter
- Individual was sentenced to 8 years imprisonment in Italy on 2 February 2004 and is considered a fugitive
- Reportedly killed in Afghanistan-Pakistan border region in 2012
- Italian Fiscal Code: SSYBLK62T26Z336L
- Previous amendments made on multiple dates, latest being 6 October 2025 and 21 October 2025
- Entry includes INTERPOL-UN Security Council Special Notice
Regulatory Changes
This circular implements Section 51A of UAPA, 1967, which requires compliance with UN Security Council sanctions resolutions. The amendment updates the existing entry with revised information pursuant to Security Council resolutions 1267 (1999), 1989 (2011), 2253 (2015), and 2734 (2024). Market participants must ensure their systems and processes reflect these updated sanctions list entries.
Compliance Requirements
- All market participants, including brokers, financial institutions, and intermediaries must update their sanctions screening systems with the amended entry
- Conduct screening of existing and new clients against the updated ISIL and Al-Qaida Sanctions List
- Freeze any assets or accounts linked to the listed individual
- Report any matches or suspicious activities to appropriate authorities
- Maintain records of compliance with sanctions obligations
- Access the updated sanctions list at: https://main.un.org/securitycouncil/en/sanctions/1267/aq_sanctions_list
- Refer to the UN Security Council Consolidated List at: https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list
Important Dates
- 21 October 2025: Amendment to sanctions list entry enacted by UN Security Council Committee
- 28 October 2025: BSE circular issued notifying market participants
- Immediate: Compliance required with updated sanctions list
Impact Assessment
Market Impact: Limited direct market impact as this affects a single individual entry in the sanctions list. However, compliance is mandatory for all market participants.
Operational Impact: Market intermediaries must update their sanctions screening databases and AML/CFT systems to reflect the amended entry. This requires immediate action to ensure compliance with international sanctions obligations.
Regulatory Impact: High regulatory significance as non-compliance with UAPA and UN sanctions can result in severe penalties. Financial institutions must maintain robust sanctions screening processes to prevent dealings with designated individuals and entities.
Compliance Risk: Failure to implement updated sanctions lists may expose market participants to legal, regulatory, and reputational risks, including potential penalties under UAPA, 1967 and international sanctions regimes.
Impact Justification
High importance due to mandatory compliance with UN sanctions and UAPA requirements for all market participants. Medium market impact as it affects one specific individual entry with limited direct trading implications but critical for AML/CFT compliance.