Guidance

Presumption of Denial of Licence Applications for Designated Iranian banks

Published 23 September 2026

1. Context

Iran’s nuclear programme continues to pose a serious threat to international peace and security. Following Iran’s non-compliance with the Joint Comprehensive Plan of Action, the UK implemented the snapback of UN Iran sanctions on 1 October 2025.

The UK Government has been and will continue to apply economic pressure on Iran, alongside the US and other partners, to enable diplomacy that delivers a lasting and sustainable settlement. On 8 September 2026, the Foreign, Commonwealth and Development Office laid legislation tightening sanctions against Iran, including financial measures intended to reduce the Government of Iran’s access to the UK financial system and its ability to raise funds in support of its nuclear programme.

On 16 June 2026, the Financial Action Task Force reminded jurisdictions of their obligations to address terrorist and proliferation financing risks emanating from Iran. The Government is determined to prevent the Iranian regime from exploiting the global economy and the UK financial system to advance its nuclear programme and wider destabilising activities.

With immediate effect, OFSI will apply a presumption of denial to licence applications made by the designated Iranian banks listed below. Each application will continue to be considered on its individual facts.

2. Banks in scope

This policy applies to licence applications made by the following designated banks operating in the UK:

• Bank Sepah
• Melli Bank plc
• Bank Saderat
• Persia International Bank
• Bank Tejarat

These banks are designated under the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019.

3. Licensing approach

HM Treasury may issue licences permitting activity otherwise prohibited by sanctions where an applicable licensing purpose exists and its criteria are met. It retains a discretion to refuse a request where licensing would be inappropriate, which includes where this would undermine the integrity or objectives of the sanctions regime.

Applications from the banks listed above will therefore be presumed for denial unless the applicant demonstrates clear and compelling reasons for licensing the proposed activity, as outlined in paragraph 4 below. .

Additionally, the current General Licence INT/2025/7628424 will not be renewed when it expires on 22 October 2026. Following its expiry, transactions previously authorised under that General Licence will no longer be authorised unless permitted by another applicable general licence or by a specific licence issued by HM Treasury.

4. Activities that may be considered

Under this policy, licences will only be granted to the above banks as required by law or in exceptional and urgent circumstances, such as risk to life, limb or environmental safety. OFSI will publish a further FAQ clarifying how it will apply this test.

5. Conditions and limitations

Applicants will need to demonstrate that one or more of the criteria in paragraph 4 above are met. Even where a licence is issued, this will only be granted to cover requirements at the most basic level.

In addition, the strong presumption in considering such applications is that transactions may only take place within the UK. No licences will be issued for funds held by entities operating in the UK to be remitted back to Iran (directly or indirectly).

Licences will only be issued to permit recordable and auditable transactions. No licences will be issued to permit payments in cash, nor will transfers be allowed from one designated bank to another. 

6. Case-by-case assessment

OFSI will continue to review each application on a case-by-case basis, but, unless the strict criteria above are met any application from these banks will ordinarily fall to be denied.  Should applicants consider that one of the criteria above are met, they should provide clear written evidence of their assertion when any licence application is made.