Summary: The Reserve Bank of India, through RBI/2026-2027/270 dated September 24, 2026, has advised regulated entities to take note of the Ministry of Home Affairs notification dated September 16, 2026 declaring Shahzad Bhatti Network (SBN) as a “Terrorist Organisation” and listing it in the First Schedule to the Unlawful Activities (Prevention) Act, 1967. The communication applies 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. RBI reiterated that, under Chapter IX of the Reserve Bank of India – Know Your Customer, Directions, 2025, regulated entities must strictly follow the procedure prescribed in the UAPA Order dated February 2, 2021 and ensure meticulous compliance with Government orders. They are also required to report details of accounts resembling individuals or entities appearing in the relevant lists to FIU-IND, besides advising the Ministry of Home Affairs as required. RBI clarified that the UAPA Order contained in Annex I of the KYC Directions also applies to amendments to Schedules IV and I of the UAPA, 1967. MHA Statutory Order S.O. 5080(E) adds “46. Shahzad Bhatti Network (SBN)” to the First Schedule. Regulated entities have also been advised to take note of future amendments to Schedule I for immediate necessary compliance.
Reserve Bank of India
RBI/2026-2027/270
DOR.AML.REC.233/14.06.001/2026-27 | Dated: September 24, 2026
The Chairpersons/ CEOs of the Commercial Banks,
Small Finance Banks, Payment Banks, Urban Co-operative Banks,
Rural Co-operative Banks, Regional Rural Banks, Local Area Banks,
Non-Banking Financial Companies, Asset Reconstruction Companies,
All India Financial Institutions
Madam/Dear Sir,
Designation of terrorist organisation under clause (a) of sub-section (1) of section 35 of the Unlawful Activities (Prevention) Act, 1967 and listed in the First Schedule of the Act
In terms of Chapter IX on “Requirements/obligations under International Agreements – Communications from International Agencies” of the Reserve Bank of India – Know Your Customer, Directions, 2025 dated November 28, 2025 (amended as on September 18, 2026) (“Directions”), as applicable, regulated entities shall strictly follow the procedure laid down in the UAPA Order dated February 2, 2021 (Annex I of these Directions), and ensure the meticulous compliance with the Order issued by the Government. Further, regulated entities shall report the details of accounts resembling any of the individuals / entities in the lists to FIU-IND in addition to advising the Ministry of Home Affairs (MHA) as required under UAPA notification dated February 2, 2021. In this regard, it is reiterated that the UAPA Order in Annex I of the aforementioned Directions shall also apply to amendments carried out in Schedule IV and I of the UAPA, 1967 apart from the UNSC lists mentioned in the Order.
2. In this connection, please refer to the notifications dated September 16, 2026 of the MHA, as per which, following entity has been declared as “Terrorist Organisation” and has been listed in the First Schedule of UAPA, 1967, under clause (a) of sub-section (1) of section 35 of UAPA, 1967. The Statutory Order (S.O.) numbers and the respective entry is as provided below:
| S.O. Numbers | Entries |
|---|---|
| 5080(E) | “46. Shahzad Bhatti Network (SBN)” |
3. Regulated Entities (REs) are advised to take note of the aforementioned Gazette notification issued by MHA for necessary compliance. REs shall also take note of any future amendments to Schedule I of the UAPA, 1967, for immediate necessary compliance.
Yours faithfully,
(Veena Srivastava)
Chief General Manager
