Government of India: 7 sanctions entries removed, 6 replaced

The Government of India has removed seven individual entries and replaced six others in the schedule to its order implementing United Nations Security Council terrorism resolutions, according to a Ministry of External Affairs notification published on 19 October 2026. The amendment took effect that day, although the ministry’s order, S.O. 5703(E), is dated 15 October 2026.^[1]

The Prevention and Suppression of Terrorism (Implementation of Security Council Resolutions) Fifth Amendment Order, 2026 changes the lists attached to the 2007 order. The government issued it under Section 2 of the United Nations (Security Council) Act, 1947, the statutory power cited for making the amendment.^[1]

The distinction between removal and replacement is important. The notification deletes seven entries from Annexure 1, but substitutes revised text for another entry there and five entries in Annexure 2. Those six substitutions retain the individuals in the schedule with replacement particulars; they are not deletions.^[1]

Which entries change

Under the heading “A. Individuals” in Annexure 1, the ministry directs the omission of entries QDi.054, QDi.056, QDi.306, QDi.307, QDi.312, QDi.352 and QDi.433. These are the list identifiers used in the notification to specify the records being removed.^[1]

The same annexure replaces entry QDi.439 for Hamidah Nabaggala. Her replacement record gives an original listing date of 30 March 2026 and an amendment date of 8 July 2026. Those dates describe the history recorded in the listing, rather than the commencement of this Indian amendment, which is tied to Gazette publication on 19 October.^[1]

In Annexure 2, the notification substitutes the entries for Hamdullah Nomani, Abdul-Haq Wasiq, Noor Mohammad Saqib, Sirajuddin Jalaluddin Haqqani and Gul Agha Ishakzai. The corresponding identifiers are TAi.044, TAi.082, TAi.110, TAi.144 and TAi.147.^[1]

The replacement records contain names, aliases, historical designations and listing histories. For example, the notification describes Nomani as having been higher education minister and mayor of Kabul under the Taliban regime during 1996-2001, and Saqib as having been chief justice of its Supreme Court during that period. These are historical descriptions in the schedule, not announcements of new appointments.^[1]

The ministry’s notification amends the schedule rather than rewriting the substantive sanctions provisions. Its closing note records that the original order was notified through S.O. 460(E) on 28 March 2007 and was last amended through S.O. 4039(E) on 21 July 2026.^[1]

The restrictions behind the schedule

The schedule matters because it identifies the people and organisations covered by the order’s sanctions framework. A government amendment dated 8 June 2021, reproduced by the Securities and Exchange Board of India, explained that the underlying Security Council resolutions required measures involving assets, travel and arms supplies. It also described the UN committees’ practice of adding, deleting and modifying sanctions-list entries.^[2]

That 2021 amendment replaced paragraph 4 of the Indian order with provisions setting out three types of measure. An arms embargo restricts the direct or indirect supply, sale or transfer of weapons and related material to designated individuals and entities. The provision covered supplies from Indian territory, supplies by Indian nationals abroad and supplies using Indian-flagged vessels or Indian aircraft, as well as specified military assistance and training.^[2]

A travel ban restricts a designated person’s entry into, or transit through, India. The 2021 text included qualifications: it did not oblige India to refuse its own nationals entry or departure, and it provided exceptions for travel justified by the committee or required for a judicial process.^[2]

An asset freeze restricts access to funds, financial assets and economic resources. The provision introduced in 2021 extended to property owned or controlled indirectly and to persons acting on behalf of, or at the direction of, designated individuals and entities. It also addressed making funds or economic resources available for their benefit.^[2]

The same text provided exceptions for specified basic expenses, including food, housing, medical treatment and certain legal costs, subject to notification to the relevant committee. Extraordinary expenses required notification by the government and committee approval. These provisions show that the framework distinguished between blocking resources and permitting particular categories of expenditure through a formal process.^[2]

How list changes reach financial institutions

The government’s 2021 amendment also inserted a communication requirement into paragraph 5. It directed financial regulators, including the Reserve Bank of India and SEBI, and supervisors of designated businesses and professions to check the relevant UN sanctions lists daily for additions, deletions and other changes.^[2]

Under that provision, a modification by the Security Council or an order of the Ministry of External Affairs was to be communicated without delay to regulated institutions. The recipients included banks, stock exchanges, depositories, intermediaries and insurance companies.^[2]

A SEBI communication dated 2 March 2026 illustrates that regulatory channel. In circulating a separate UN list removal, SEBI cited Clause 54 of its master circular dated 6 June 2024, which required stock exchanges and registered intermediaries to ensure that they did not hold accounts in the names of individuals or entities appearing on the relevant Security Council lists, in terms of Section 51A of the Unlawful Activities (Prevention) Act, 1967.^[3]

That March communication also addressed delisting, meaning removal from a sanctions list. It said requests received by regulated entities were to be forwarded electronically to the Ministry of Home Affairs for consideration, with a copy that could be marked to the Ministry of External Affairs. Individuals and entities seeking removal from the Security Council’s ISIL and Al-Qaida list could also apply to the UN-appointed independent Ombudsperson.^[3]

For the October amendment, the operative instruction is the change to the Indian schedule itself: seven specified records are omitted and six are replaced. Clause 1(2) makes those changes effective on Gazette publication, without setting a later commencement date.^[1]

References

^[1] Ministry of External Affairs, Prevention and Suppression of Terrorism (Implementation of Security Council Resolutions) Fifth Amendment Order, 2026, S.O. 5703(E), dated 15 October 2026; Gazette publication dated 19 October 2026. Publisher: egazette.gov.in

^[2] Government of India, amendment to the Prevention and Suppression of Terrorism (Implementation of Security Council Resolutions) Order, 2007, S.O. 2174(E), dated 8 June 2021. Reproduced by the Securities and Exchange Board of India. Publisher: sebi.gov.in

^[3] Securities and Exchange Board of India, “Implementation of Section 51A of UAPA, 1967: Security Council ISIL (Da’esh) and Al-Qaida Sanctions Committee removes one entry from its sanctions list”, 2 March 2026. Publisher: sebi.gov.in