In an important update, OFSI published new guidance highlighting that, with immediate effect, HM Treasury will apply a presumption of denial to license applications made by the five designated Iranian banks listed below. OFSI clarifies that license applications involving these banks will generally be refused unless there are clear and compelling reasons to justify an exception. Bank Sepah Melli Bank plc Bank Saderat Persia International Bank Bank Tejarat OFSI issued a subsequent FAQ on 24 September in this regard, and notes that applications will continue to be assessed on a case-by-case basis, but licenses 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. In addition, OFSI has clarified that it will not renew the Iran Interim Basic Necessities General Licence INT/2025/7628424, which 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.