How OFSI will assess licence applications involving designated Iranian banks

OFSI has published a new FAQ explaining how it will assess licence applications involving the five designated Iranian banks covered by HM Treasury’s new licensing guidance.

The FAQ confirms that applications will continue to be assessed on a case-by-case basis, but licences will generally only be granted where required by law or in exceptional and urgent circumstances, such as risks to life, environmental safety, essential regulatory payments, asset preservation, or the wind-down of operations.

Here’s the Frequently Asked Question:

204. What criteria will OFSI be using in assessing future applications? / how will OFSI apply the test?

OFSI will assess applications on a case-by-case basis, against the relevant licensing grounds, alongside the criteria set out in this guidance and FAQs. The guidance is intended to give industry greater clarity on the narrower circumstances in which licences may be granted and the factors OFSI will take into account. 

Under this guidance, licences for the banks covered by the guidance will only be granted where required by law, or in exceptional and urgent circumstances, such as where there is a risk to life, limb or environmental safety. 

As such, activities that may be considered may include: 

• risks to life or limb; 
• environmental safety; 
• essential insurance premiums and property management fees; 
• remuneration, allowances or pensions for existing employees; 
• tax, rent, mortgage and utility payments; 
• essential payments required by regulators; 
• essential steps to preserve assets; and 
• steps towards the wind-down of operations, including insolvency.

Added on: 24 Sep 2026