Description

NSE advises members to implement SEBI communication regarding two amendments to UNSC's 1267/1989 ISIL (Da'esh) & Al-Qaida Sanctions List under Section 51A of UAPA, 1967.

Summary

NSE has forwarded a SEBI communication directing all members to implement updates to the UNSC 1267/1989 ISIL (Da’esh) & Al-Qaida Sanctions List. Notes SC/16323 and SC/16324 dated March 26, 2026 each amend one entry in the sanctions list. Members must scan all existing and future accounts against the updated list and ensure compliance with Section 51A of the Unlawful Activities (Prevention) Act, 1967.

Key Points

  • UNSC issued press releases SC/16323 and SC/16324 on March 26, 2026, each amending one entry in the 1267 (1999) sanctions list (totalling 2 amended entries)
  • NSE Circular Ref No: NSE/ISC/73599 (Download Ref No: 17/2026), issued April 02, 2026
  • Members must follow the Central Government Order dated February 02, 2021 for implementing Section 51A of UAPA, 1967
  • Compliance is governed by Clause 54 of SEBI Master Circular on AML/CFT Standards dated June 06, 2024
  • The latest UNSC sanctions lists are available on the UN Security Council website for both ISIL/Al-Qaida (resolution 1267/1999) and Taliban (resolution 1988/2011)
  • SEBI also publishes updates under “Media and Notifications” → “UNSC Sanctions Committee List” on its website

Regulatory Changes

  • Two entries amended in UNSC 1267 (1999) ISIL (Da’esh) & Al-Qaida Sanctions List per SC/16323 and SC/16324 (March 26, 2026)
  • No new framework introduced; existing obligations under Section 51A of UAPA, 1967 and PMLA, 2002 continue to apply

Compliance Requirements

  • Account Screening: Scan all existing accounts to ensure no account is held by or linked to any individual or entity in the updated sanctions list; apply the same screening to future accounts
  • De-listing Requests: Forward any de-listing requests received to:
  • Ombudsperson: Inform individuals/entities seeking removal from the ISIL/Al-Qaida Sanctions List that they may apply to the UN-appointed Ombudsperson at https://www.un.org/securitycouncil/ombudsperson/application
  • Regular Monitoring: Visit SEBI website regularly for further updates to the UNSC Sanctions Committee List
  • Reference: Clause 54 of SEBI Master Circular on AML/CFT dated June 06, 2024

Important Dates

  • March 26, 2026: UNSC issued SC/16323 and SC/16324 amending entries in the 1267 sanctions list
  • April 02, 2026: NSE circular issued; members must act immediately
  • February 02, 2021: Central Government Order on Section 51A UAPA implementation (reference procedure)
  • June 06, 2024: SEBI Master Circular on AML/CFT Standards (governing compliance clause)

Impact Assessment

This is a mandatory compliance circular affecting all NSE members (brokers, intermediaries). The operational impact involves re-screening client databases against the updated UNSC sanctions list. While the number of amended entries is limited (2 entries), failure to comply carries significant legal risk under UAPA, 1967 and PMLA, 2002. No direct market or trading impact is expected. Members should update their KYC/AML systems promptly and establish processes for continuous monitoring of SEBI’s UNSC Sanctions Committee List updates.

Impact Justification

Mandatory compliance circular requiring all NSE members to scan accounts against updated UNSC sanctions list; non-compliance with AML/CFT obligations carries regulatory and legal risk under UAPA and PMLA.