I asked Claude to explain:

General Licence INT/2025/7628424 — Plain English Summary

What is this, and why does it exist?

This is a UK financial sanctions licence issued by OFSI (the Office of Financial Sanctions Implementation, part of HM Treasury). It was granted under Regulation 40 of the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 — the UK’s domestic legal framework for Iran-related nuclear sanctions.

Under those sanctions, certain Iranian banks and their UK subsidiaries are “Designated Persons” (DPs) — meaning their assets are frozen and financial transactions involving them are normally prohibited. But a total freeze creates a practical problem: these entities still have UK staff, UK office costs, and UK legal obligations. This licence is the solution. It carves out a narrow, carefully controlled set of payments that are permitted despite the freeze.

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Who are the “Designated Persons” covered?

The licence names five entities in Annex 1: Bank Melli (including Melli Bank PLC), Bank Saderat Iran, Bank Tejarat, Persia International Bank Plc, and Iran Insurance Company. These are the Iranian-linked financial institutions with a UK presence that the licence applies to.

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What does the licence actually allow?

The DPs, or persons acting on their behalf, may make payments for:

• Staff pay: remuneration, allowances, and contractual or statutory redundancy payments to UK employees and UK directors;
• Pensions of UK employees and UK directors;
• IT services: fees and costs for UK providers of broadband, telephone, email, anti-virus/cybersecurity software, operating system software, and regulatory reporting software; and
• Accountancy services: fees for UK chartered or certified accountants for the DPs’ UK operations.

In short: the frozen entities can still pay their UK-based staff, keep their IT running, and meet their accountancy obligations — but nothing more.

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Key safeguards and conditions

All payments may only be made to accounts held at a regulated UK financial institution (a “Relevant Institution”).

Payments must not be made, directly or indirectly, to any Designated Person. So the money can flow to ordinary UK employees and suppliers, but not back into frozen accounts.

Within 14 days of the end of each calendar month, the UK branch of the DP must send a report to HM Treasury detailing every payment made that month — including who sent and received the money, the purpose, the amount, the payment route, and the date.

All parties must keep accurate records for a minimum of six years.

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Duration and today’s update

The licence took effect on 23 October 2025 and, as updated today (16 April 2026), expires at 23:59 on 22 October 2026 — the update today appears to have extended the expiry date by six months, from 22 April 2026 to 22 October 2026. This is consistent with the typical OFSI practice of rolling such licences forward in six-month blocks.

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🔍 Transparency: What is and isn’t supported by my sources

Claim	Source support
Licence issued under Iran Nuclear Regulations	✅ Directly from the licence text
Five named DPs in Annex 1	✅ Directly from the licence text
Four categories of permitted payments	✅ Directly from the licence text
Reporting and record-keeping requirements	✅ Directly from the licence text
Extension today to 22 October 2026	✅ The fetched PDF (updated 16 April 2026) shows this date, replacing the earlier 22 April 2026 expiry
The reason for today’s update (i.e., why it was extended, not just that it was)	⚠️ Not stated in the licence text or any source I found. OFSI does not typically explain renewals. This is an inference based on the changed expiry date.
Previous amendment history (Oct/Dec 2025)	✅ Confirmed by both the licence text and Mayer Brown’s sanctions update

If you need to act on this licence — for example, if you are one of the named banks or are providing services to them — you should consult the official GOV.UK page and consider seeking specialist sanctions law advice, as I am not a lawyer and the licence text itself notes that full details govern over any summary.

These sort of explanations almost makes sanctions compliance easy… almost.