Overview
India is a UN member state and implements UNSC sanctions. India enacted the United Nations (Security Council) Act 1947 (UNSCA) by which the Central Government may implement sanctions, not involving the use of armed force, when called upon by the UNSC. Sanctions and export controls are imposed under different domestic legislation including:
- Foreign Trade (Development and Regulation) Act 1992 (FTDR Act) and the Foreign Trade Policy 2023 (FTP).
- Unlawful Activities (Prevention) Act 1967 (UAPA).
- Prevention of Money Laundering Act 2002 (PMLA).
- Weapons of Mass Destruction and their Delivery Systems (Prohibition of Unlawful Activities) Act 2005 (WMD Act).
National Competent Authorities
Sanctions and export controls are implemented and enforced through various ministries and regulators including:
Ministry of External Affairs (MEA): coordinates and enforces UNSC sanctions.
Ministry of Home Affairs (MHA): imposes sanctions primarily through security-related measures. These actions are enforced through the declaration of an association as unlawful, or the addition of an organization or individual to the relevant schedule identifying it as a terrorist organization under the UAPA. It may also impose restrictions such as asset freezes and travel bans.
Directorate General of Foreign Trade (DGFT): an office within the Ministry of Commerce and Industry responsible for advising the Central Government on import and export policy, export licensing, and trade controls through the FTDR Act and the FTP. Through the DGFT, India also imposes controls on the export of special chemicals, organisms, materials, equipment, and technologies including dual-use and military items, software, and technology (the SCOMET list).
Financial Intelligence Unit – India (FIU): is the central agency for financial intelligence which implements sanctions in India by enforcing anti–money laundering (AML) and counter‑terrorist financing (CFT) laws such as the PMLA, and monitoring, flagging, and penalizing financial activity involving designated individuals, entities, or countries. It also acts as the central reception point for receiving Cash Transaction Reports (CTRs), Non-Profit Organization Transaction Report (NTRs), Cross Border Wire Transfer (CBWT) Reports, Reports on Purchase or Sale of Immovable Property (IPRs), and Suspicious Transaction Reports (STRs) from various reporting entities.
Reserve Bank of India (RBI): India’s central bank, which monitors and enforces prohibitions on transactions with sanctioned individuals.
Central Board of Indirect Taxes (CBIC): regulates cross-border trade and customs. Enforces trade-related sanctions through its customs offices.
Securities and Exchange Board of India (SEBI): is the securities market regulator.
These ministries and regulators usually implement sanctions in India by publishing orders in India’s Official Gazette. Examples of such sanctions orders are:
- The DGFT’s Notification 06/2025-26, banning all imports or transit of goods originating in, or being exported from, Pakistan.
Legislation
United Nations (Security Council) Act 1947
India implements UN sanctions under the UNSCA. Section 2 of the UNSCA says the Central Government may:
- Give effect to UNSC sanctions, not involving the use of armed force, by publishing an order in the Official Gazette.
- Make any necessary provisions to enable the implementation of UNSC sanctions.
- Make provisions for the punishment of persons breaching such orders.
The MEA is responsible for implementing UNSC sanctions resolutions. These are implemented through orders under the UNSCA, which are published and searchable in India’s Official Gazette.
There is no mechanism for an individual/entity to be delisted except through the relevant UN delisting mechanism. However, persons/individuals or entities designated under certain UNSC resolutions, such as Resolutions 2231 (2015) and 1718 (2006) (i.e., sanctions on Iran and the Democratic People’s Republic of Korea (DPRK/North Korea), respectively), may apply to the Director of the FIU to ask India to submit a request for delisting to the relevant UN sanctions committee.
Foreign Trade (Development and Regulation) Act 1992 & the Foreign Trade Policy 2023
UNSC arms/trade embargoes are implemented through the FTDR Act read in line with the FTP. Chapter II of the FTDR Act says the Central Government may:
- Prohibit, restrict, or otherwise regulate trade by publishing notices in the Official Gazette.
- Formulate and amend India’s Foreign Trade Policy.
Countries, organizations, and individuals subject to trade controls are added to Chapter 2 of the FTP, which prohibits certain exports and imports to and from those countries. The DGFT oversees the formulation of and implements the FTP.
In May 2025, the DGFT issued Notification 06/2025-26, banning all imports of goods originating in, or being exported from, Pakistan. This was added as Paragraph 2.20A of the FTP.
As of December 2025, the following countries and groups are subject to trade controls under Chapter 2 of the FTP:
- Iraq: arms and related material.
- ISIL, Al Nusrah Front, Al Qaida: trade in oil and refined oil products, modular refineries and related materials, besides items of cultural (including antiquities), scientific and religious importance.
- North Korea: direct or indirect export and import of items as detailed in Appendix I of the FTP’s Chapter 2.
- Iran: direct or indirect export to Iran or import from Iran of any item, material, equipment, goods, and technology as listed in UNSC or International Atomic Energy Agency (IAEA) documents.
- Somalia: direct or indirect import of charcoal.
- Pakistan: direct or indirect import or transit of all goods originating in, or being exported from, Pakistan.
Under the UAPA, the Central Government may declare an association unlawful or add an organization to the relevant schedule identifying it as a terrorist organization. Section 2(1)(p) of the UAPA defines unlawful associations as groups or associations which have unlawful activity; promotion of enmity or imputations prejudicial to national integrity as their object; or if the group’s members engage in such activity.
India imposes criminal penalties on those who support or belong to unlawful associations. The MHA designates unlawful associations under Section 3 of the UAPA. Such designation is valid for 5 years. Associations may challenge their listing by making an application to the Unlawful Activities (Prevention) Tribunal. The UAPA or the Central Government may delist entities on its own account.
Groups and individuals can also be designated as terrorist organizations under the UAPA. Section 51A of the UAPA gives the Central Government the power to:
- Freeze the assets of designated individuals and entities.
- Prohibit financial support to any designated entity.
- Impose entry/travel bans on designated individuals.
A terrorist organization may be designated by the MHA under the UAPA if it meets the criteria set out in Section 35 of the UAPA. Such designation is subject to parliamentary approval. The list of banned terrorist organizations is maintained by the MHA. Such list is set out in Schedule I of the UAPA and the list of banned individuals is set out in Schedule IV of the UAPA. Applications for delisting may be made in accordance with the procedure set out in Section 36 of the UAPA.
UAPA sanctions are implemented by UAPA nodal officers. They identify and report assets, financial transactions, and movements of individuals/entities listed under the UAPA.
Prevention of Money Laundering Act, 2002
The PMLA inter alia gives effect to UNSC resolutions on terrorism and terrorist financing, including Resolutions 1267 (1999) and 1373 (2001), by enabling the freezing, seizure, or attachment of funds and assets of designated persons and entities. The FIU’s analysis of STRs and related data helps identify dealings with designated terrorists, sanctioned organizations, or high-risk jurisdictions. Such intelligence is forwarded to enforcement and security agencies like the Directorate of Enforcement (ED), the National Investigation Agency (NIA), police, and other regulators for asset freezing and prosecution.
The WMD Act prohibits unlawful activities related to the manufacture, transport, or transfer of nuclear, chemical, or biological weapons and their delivery systems. Its primary objective is to safeguard national security by preventing such weapons from being accessed or used by non-state actors or terrorist groups. It includes provisions to curb the financing of prohibited activities by enabling the freezing of related assets.
Other relevant legislation
Guidance
MEA
Guidance on implementation of UNSC DPRK sanctions
Guidance on implementation of UNSC counterterrorism sanctions
MHA
Procedure for implementation of Section 51A UAPA 1967
Corrigendum to the procedure for implementation of Section 51A UAPA 1967
FIU
Updates for implementation of Section 51A UAPA 1967
Export control
Licensing
The DGFT is responsible for granting licenses for the import of restricted goods, and for the export of restricted goods and for items in the SCOMET list. The DGFT website has a dedicated portal for license and authorization applications.
There is no dedicated portal for applications for the humanitarian exemption in India.
Enforcement
Criminal enforcement
Dealing with funds of an unlawful association despite a prohibitory order under the UAPA is punishable with imprisonment of up to 3 years or with a fine or both. Being a member of/providing support to an unlawful association is punishable with imprisonment of up to 2 years and a fine. A person who is, or continues to be, a member of an unlawful association, or voluntarily does an act aiding or promoting the objects of such association, and in either case is in possession of weapons or substances capable of causing mass destruction and commits an act resulting in grievous injury or significant damage to property, shall be punishable with imprisonment of not less than 5 years, which may extend to imprisonment for life as well as a fine. If such act results in the loss of human life, it shall be punishable with death or imprisonment for life.
Exports in contravention of Section 13(4) of the WMD Act are punishable with a fine and by imprisonment of up to 5 years.
Reporting
Indian sanctions legislation does not impose general reporting obligations on sanctioned persons or those who hold the assets of such sanctioned persons. Entities regulated by the RBI must report potential matches between persons designated by the UNSC or the (Indian) Central Government and clients. The details of these obligations are at Chapter IX and Annex II of the Know Your Customer (KYC) Directions 2016:
- Regulated entities must report potential matches between customers and sanctions lists to a designated officer for the UAPA (see Annex II for details)
- Regulated entities must also report the details of matching accounts to the FIU.
Export controls
The DGFT is the competent authority for most export controls in India. India imposes controls inter alia on the export of dual-use and military items, software, and technology specified in the SCOMET list. Every item on the SCOMET list is regulated and requires permission/notification to be exported.
India is a member of multilateral export regimes, including the following:
- Missile Technology Control Regime (MCTR)
- Wassenaar Arrangement
- Australia Group on Biological and Chemical items.
The SCOMET list is harmonized with these regimes.
The SCOMET list was last updated in September 2025. The list is maintained in Schedule 2 Appendix 3 of the Import, Export and SCOMET Policy. There are 9 categories on the list, with different government departments responsible for licensing applications. Export of dual-use items on the SCOMET list is either prohibited, restricted, or exempted.
Applying for a license
SCOMET license applications falling under categories 1-5 & 8 are assessed by the Inter Ministerial Working Group (IMWG) within the DGFT. Applications may be made online and are assessed against 6 criteria:
- The end-user’s credentials, the credibility of the declaration of end-use, and the potential of the item or technology to threaten India’s national security and foreign policy goals.
- Risk that the exported items will be fall into the hands of terrorists, terrorist groups, and non-State actors and be used for the purpose of terrorism.
- Export control measures instituted by the recipient state.
- The recipient state’s weapons program.
- Assessment of end-uses.
- Applicability of bilateral or multilateral agreements and arrangements to which India is a party or adherent.
A successful license application will result in an individual export authorization or a general authorization. A general authorization is a one-time bulk authorization granted to an exporter for export of SCOMET list items under a specific category to the pre-approved list of countries without any quantitative restrictions. Certain general authorizations may require post-reporting submissions of exports. Depending on the category of the export, general authorizations may last between 1 and 5 years.
There are separate procedures in place to apply for nuclear material and munitions list export licenses, which are administered by the Department of Atomic Energy (DAE) and the Department of Defense Production (DDP), respectively.
Catch-all controls
Export of items not in the SCOMET list may also be regulated under provisions of the WMD Act.
Breach of export controls
Under Section 11 of the FTDR Act, any person who exports or attempts to export in contravention of the FTDR Act, the FTP, or any rules or orders made under them, shall be liable to a penalty not less than INR 10,000 and not more than five times the value of the goods that are exported or being attempted to be exported, whichever is more.
The DGFT encourages voluntary self-disclosure of failure to comply with export control provisions.
Breaches of the WMD Act are punishable by imprisonment according to the terms of the Act.
