The UK's new Iran sanctions took effect on 29 September. The licence that pays UK staff at four Iranian banks ends on 22 October

The Iran (Sanctions) (Amendment) Regulations 2026 were laid before Parliament on 8 September and came into force on 29 September. The instrument, SI 2026/983, amends the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 and the Iran (Sanctions) Regulations 2023. Stephen Doughty, the Minister for the Middle East at the Foreign, Commonwealth and Development Office, described the package in a written statement on the day the regulations were laid.

Five new prohibitions, all inserted into the 2019 nuclear regulations, matter most to a financial firm:

The Department for Business and Trade's Notice to Exporters 2026/18 covers the trade side: nine new schedules, 1A to 1I, define controlled goods and technology. They run from energy equipment, gold and other precious metals, and graphite to natural gas, oil products, petrochemicals and sectoral software. The regulations also add a power to specify ships by IMO number.

A new trade general licence from the Office of Trade Sanctions Implementation and an amended OFSI general licence for the Shah Deniz gas field in Azerbaijan take effect the same day. The written statement says they keep operations there running, in line with EU and US policy.

The benchmark for a screening system is simple: give it a name, and it says whether that name is on a list. Regulation 17B fits that test only partly. It reaches an institution domiciled in Iran, its branches and subsidiaries wherever located, and an institution outside Iran that is owned or controlled by a person domiciled there. Domicile and ownership are facts about an institution, not strings in its name. Regulation 17A does not fit it at all. The borrower it protects against is defined by two things, a connection with Iran and an activity in oil, gas or a listed commodity code. Neither appears in a name.

A firm that reads "no match" on such a borrower has learned only that the borrower is not designated. That was never the test. The test is whether the loan is prohibited, and the answer lives in the customer file: where the business operates, who controls it, what it makes.

Ships are different, and a stricter check is available. When the Secretary of State specifies a vessel it will normally be by IMO number, which is an identifier and not a name; the regulation allows another means only where an IMO number is not practicable. A vessel check on IMO number is a real control. A check on the ship's name is not, since ships are renamed.

On 23 September, HM Treasury published licensing guidance for five Iranian banks: Bank Sepah, Melli Bank plc, Bank Saderat, Persia International Bank and Bank Tejarat. HM Treasury will presume such applications should be refused unless the applicant shows "clear and compelling" reasons.

The guidance says licences may be granted only where the law requires it, or in exceptional and urgent circumstances, "such as risk to life, limb or environmental safety". The Office of Financial Sanctions Implementation says it will publish a further FAQ on how it applies that test, and will look for clear written evidence.

It also lists conditions on any licence granted: UK operations only, no remittances back to Iran, no cash, auditable transactions only, and no transfers between the designated banks.

It tells a firm what to expect if it applies, and a firm that was planning a wind-down on the assumption that a licence would follow should now assume the opposite.

The same guidance says the Interim Necessities General Licence, INT/2025/7628424, will not be renewed. We read the licence itself. It took effect on 23 October 2025, and an update on 16 April 2026 moved its expiry from 22 April to 23:59 on 22 October 2026.

While it lasts, the licence lets designated persons named in Annex 1, and their UK subsidiaries, pay four things: pay, allowances and redundancy for UK employees taken on before designation and taxed through PAYE, and for UK directors, all of them resident and domiciled in the UK; their pensions; UK broadband, telephone, email, antivirus and cybersecurity, operating-system and regulatory reporting software; and UK accountancy fees. Payments must go to accounts at UK regulated institutions. Each month, within 14 days of month end, the UK branch must send HM Treasury a report giving the payer, purpose, amount, route, accounts and dates, and everyone involved must keep records for six years.

Annex 1 has five rows. They do not match the guidance's five banks:

Any firm working from one document should open the other.

From 23 October, the payments above are no longer authorised by that licence for any of the five. A UK office of one of these groups that still has staff on payroll needs a different authorisation, and the presumption of denial means it would be unwise to assume one.

1. Ask which of your customers are connected with Iran and what they do. Regulation 17A turns on that, so a list check will not answer it. Put the question in onboarding and in the periodic review.
2. Review every correspondent or account relationship with an institution domiciled in Iran. Regulation 17B applies to UK credit and financial institutions opening new ones, including with a branch or subsidiary of an Iranian institution located outside Iran, so a firm that does not bank Iranian names directly should check the parent.
3. Check insurance contracts by date. Regulation 17C spares agreements concluded before 8 September 2026 only if they were lawful when made.
4. Put 22 October in the calendar with an owner. Anyone paying UK staff, pensions, IT or accountants of the five groups under INT/2025/7628424 should have taken advice before it lapses.
5. Re-screen the whole customer base against the current UK list, not only the names in this post. The guidance calls the five banks designated already, and the ownership rule reaches entities that never appear on a list.
6. Store the reason, not only the result. Record which regulation a review considered and what it found.

A list match on the five banks and their subsidiaries is what our batch screening returns, against the UK list as published. The loan and insurance tests are not list matches, and we do not pretend they are.

This is a report of what four UK government documents and one statutory instrument say, read on 29 September 2026. It is not legal advice, and it takes no position on the policy.

We opened the regulations and read the provisions on loans, banks, insurance, bonds, ships and aircraft. The amending instrument has 31 regulations and nine schedules, and one regulation alone inserts dozens of new provisions into the 2019 regulations, so we did not read every one, so the table lists the rules a financial firm meets first and is not a complete inventory. The guidance's list of licence conditions and its promise of a further FAQ come from the guidance page; we could not open that FAQ and do not describe it. We did not check the UK Sanctions List entries for the five banks, so we make no claim about their listing dates or identifiers.